Secretary of State (SoS) for Ministry of Housing Communities and Local Government (MHCLG) PARKSIDE INQUIRY PROOF OF EVIDENCE – ECOLOGY MR P BLACK, MR P ASTLES, DR P RICHARDSON

PARKSIDE ACTION GROUP

PARKSIDE LINK ROAD (PLR) Planning Inspectorate References St Helens BC: APP/H4315/V/20/3253230 Warrington BC: APP/MO655/V/20/3253232 St Helens BC (SHBC) Planning Application Reference: P/2018/2049/FUL Warrington BC (WBC) Planning Application Reference: 2018/32514 & 2019/34719

PARKSIDE REGENERATION LLP (PHASE 1) Planning Inspectorate Reference: APP/H4315/V20/ 3253194 St Helens BC (SHBC)Planning Application Reference: P/2018/0048/OUP

PAG Proof of Evidence Ecology

Document History

Date Version Status/Purpose Author 8-Dec-2020 Rev 1.0 Final Dave Tyas

Contents

1 A million species facing extinction ...... 2 2 Biodiversity - Background and Policy ...... 4 3 How important is Parkside for Biodiversity? ...... 5 4 What about the wider context? ...... 6 5 The Last Great Wild Space - biodiversity and people ...... 9 6 Biodiversity Net Gain and mitigation ...... 10 7 Other issues ...... 13 8 Cumulative effects ...... 14 9 Conclusion ...... 14 10 Appendix A – Leigh Ecology Report ...... 16 11 Appendix B – GMLRC record ...... 16 12 Appendix C – Evidence of badgers in the Parkside area ...... 25 13 Appendix D – letter from Leigh Ornithological Society...... 26 14 Appendix E – Letter from Local Ornithologists ...... 28

Definitions

AQMA Air Quality Management Area BNG Biodiversity Net Gain EIA Environmental Impact Assessment ES Environmental Statement GHG Greenhouse Gases GMLRC Greater Manchester Local records centre LOS Leigh Ornithology Society NPPF National Planning Policy Framework PLR Parkside Link Road Phase 1 Phase 1 Planning Application SHC St Helens Council SRFI Strategic Rail Freight Interchange TA Traffic Assessment

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1 A million species facing extinction

1.1 In May 2019, the UN reported1 that human activity is causing an unprecedented decline in biodiversity, with more than a million species across the planet threatened with extinction. Scientists report that species extinction is 100 times the ‘normal rate’. England is already one of the most impoverished countries in the world for biodiversity as we progressively destroy our wild places.

1.2 ‘Biodiversity2‘refers to the variety of life on earth, including the different species of animals, plants, and micro-organisms that coexist globally. It covers the variety of ecosystems and their component habitats, including more human designed locations, like agricultural and urban landscapes.

1.3 This proof covers the importance of Parkside Phase 1 (Phase 1) and Parkside Link Road (PLR) sites for biodiversity and the community, and how the appellant has underestimated: • the importance of the site itself and reduced its wildlife value • its regional biodiversity value, • its future potential. • why wildlife and biodiversity of this ‘Last Great Wilderness’ are important to the people of St Helens, Warrington, and Wigan, including how Covid-19 has revealed exactly how nature enhances physical health and mental well-being. 1.4 It discusses the now universally accepted requirement for Biodiversity Net Gain (BNG) and how the proposals fail to measure up. We also discuss biodiversity in relation to climate change, air quality and aquatic habitats.

1.5 We commissioned an independent consultant review of the appellants’ case and include the evidence knowledge from residents with over 40 years of experience in studying nature in the area.

1 UN Global Assessment Report on Biodiversity and Ecosystem Services, 2019 2 UN Convention on Biological Diversity www.cbd.int/

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Qualifications and Professional Expertise 1.6 Peter Black is a chartered town planner, with more than 25 years’ experience in planning, habitat and tree surveys, habitat management, environmental impact assessment, and strategic environmental assessment who has worked in the public, private and voluntary sectors. He is familiar with the area and the site. He holds a Masters in Civic Design from Liverpool University and a BA (Hons) in Natural Science (Botany) from the University of Oxford. He is an Associate member of the Arboricultural Association.

1.7 Peter Black is separately representing Croft Parish Council and Culcheth and Glazebury Parish Council but here is representing the views of Parkside Action Group He is also providing evidence on Cumulative Effects, and climate change.

1.8 Peter Astles, Associate Chartered Management Accountant (ACMA), Associate Chartered Secretaries and Administrators (ACIS), an accountant by profession now retired and above membership lapsed. He has held senior financial positions in the Brewing, Banking, Insurance and Pharmaceutical sectors analysing complex commercial situations throughout his working life, both UK and overseas. He represented Newton-Le-Willows at the St Helens MBC core strategy in 2012. Brought up in rural Cheshire, his father instilled in him as a toddler a lifelong love and appreciation of the natural world. He is a local resident, amateur wildlife photographer, who has lived in Newton-Le-Willows for 50 years and studied and observed the natural world both directly on Parkside and the surrounding area for over 40 years.

1.9 Dr Paul Richardson will provide support at the biodiversity round table discussion. He is a retired GP who practised for 30 years in Leigh, 5 miles NE of the proposed development. For the past 10 years he has been involved with Leigh Ornithological Society, and participating in bird species surveys and recording in the area, including the Barrow Lane arable land which would be affected by the access/relief road proposal. He has been involved with development and management policy discussions about local green spaces on the Wigan Greenheart Forum, and the Bickershaw (Country Park) Steering Group, as well as speaking on behalf of LOS at planning meetings and inquiries.

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Roy Leigh3 ACIEEM is an experienced ecologist with over 20 years working as a consultant. He holds numerous survey licences and has worked on a wide range of EIA projects from large infrastructure schemes and windfarms to house extensions. He has also undertaken many novel specific studies using intrusive methods for example pit tagging and radio tracking as part of research and conservation projects. He has led on owls, raptors, and mammal species in Cheshire. He is chair of the Cheshire and Wirral Raptor Study Group.

2 Biodiversity - Background and Policy

2.1 There is a Biodiversity Crisis. The World Wildlife Fund (WWF) Living Planet Report Sept 2020 reported an average 68% decline in global species population sizes tracked over 46 years (1970-2016). For the UK, the 2019 state of nature report declared around 41% of UK species have declined over a similar timeframe. one in 7 species in the UK are in danger of extinction and 58% of species are in decline. This serious situation is replicated in St Helens and threatens our environment, health and wellbeing, economy, and quality of life.

2.2 The Environment Bill due to receive Royal Assent in early 2020 will put the environment at the centre of policy making. It will make sure that we have a cleaner, greener, and more resilient country for the next generation. In September 2020, the Prime Minister committed to 30% nature recovery by 2030.

2.3 Protection and enhancement of biodiversity is entrenched in policy. NPPF 175a requires Biodiversity Net Gain. National Planning Practice Guidance Natural Environment (10 – 35) highlights protected and priority species and habitats; assessment on biodiversity impacts at all stages of development; local ecology networks and nature recovery networks; mitigation hierarchy, net gain metrics, and promotion of woodlands,

2.4 Local planning policies for St Helens and Warrington also theoretically emphasise the need to protect and enhance biodiversity.

3 Leigh Ecology: http://www.leighecology.co.uk/

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3 How important is Parkside for Biodiversity?

3.1 Leigh Ecology was commissioned to review ecology documents submitted for Phase 1 and PLR. (Appendix A). We have also used the expertise of Leigh Ornithological Society (LOS), a group founded in 1971 which conserves wildlife, collects, and publishes biological data and liaises with local, regional, and national bodies. It was awarded the Queen’s Award for Voluntary Service in 2020. This is the highest award a voluntary group can receive in the UK. Their objection letter is attached as appendix D

3.2 The applicant has painted Phase 1 as a derelict colliery with little wildlife in both public presentations and to commercial interests. However, apart from a small area of hard standing the site has a range of maturing secondary habitats. The NPPF definition of previously developed land (PDL) specifically excludes land ‘that was previously developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape’. Almost the whole of the colliery footprint apart from the hard standings has blended into the landscape and is therefore not PDL.

3.3 Findings from the Roy Leigh Report (Appendix A) included: • Outdated ecology surveys - some over 5 years old • Bat surveys using incorrect methodology • Non-conformance with some regulations • Incorrect methodology for Water Vole surveys - providing discrepancies between results • Structural issues with mitigation report • Further amphibian surveys required • Lack of recognition of ecology fluidity • Concerns with aspects of Landscape plan 3.4 We think this means that the applicants have significantly underestimated biodiversity at Parkside. Even given this, the ecological studies describe a site that is rich in biodiversity. The records of Greater Manchester Local Record Centre (GMLRC) are included as an appendix.

Tree Felling

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3.5 Substantial areas of secondary woodland grew up on the site but in 2017 the owner/appellant clear-felled a substantial area of trees over 8cm dbh and more than 5 cubic metres of timber without a Felling License. This was witnessed by local people and work stopped following inspection by the forestry commission. It is not obvious if the owner was intending to clear the whole site of woodland.

Figure 1 Parkside site after 2017 tree felling 3.6 This felling was before some of the surveys and therefore these may not have captured the full ecological range and potential of the site.

3.7 It is unfortunately common for developers to attempt to clear their sites of wildlife habitat that they think may inhibit a grant of planning consent. This shows that the developer has no appreciation of the value of habitat to either biodiversity or local people. Either way they should not profit from this vandalism.

Badgers 3.8 The applicant’s reports state that there is no evidence of badgers in the area, and it is possible site surveys might not have found any. Badgers are common in the rural Warrington borough areas and roadkill has been found within yards of the site (Appendix C).

4 What about the wider context?

4.1 The countryside between Newton-le-Willows, Winwick and Lowton is large and complex habitat with a mosaic of interconnected habitats. Wildlife exists in

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interconnecting ecosystems both in the green belt buffer between Newton, Winwick, and Lowton and beyond, making it regionally important.

4.2 The approach by the developers is to divide the planned overall development into four elements - Phase 1, 2, 3 and PLR (which is essential infrastructure) which inevitably results in incremental environmental assessment – a process that fails to assess the environment properly and is discouraged by case law.

4.3 Phase 1 and the nearby Highfield Moss SSSI and SBI are highly interdependent in wildlife terms with both holding reasonably undisturbed wetland, a mosaic of grasslands, and scrub. In effect Parkside East (Highfield Moss) is the public viewing area, Parkside West the holding, roosting, and breeding areas.

4.4 One anomaly is that County bird records (appendix B) are submitted mainly from publicly accessible areas such as Highfield Moss and less in the more inaccessible Phase 1 area. Given the limited recording area, the range of species (including red status) is extraordinary and what would be expected in undisturbed countryside

4.5 This is one of the few habitats in the local region that supports species such as barn owl, short eared owl, and other birds of prey. Prey species such as voles thrive in mature grassland and this habitat allied with marshland, wetland and scrub is declining, almost extinct in the local area.

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Figure 2 All five species of British Owls use Parkside 4.6 The site is well known in the northwest for ornithology. All five species of British Owl are present. Short Eared Owl overwinter in Phase 1 as they require a high density of voles and small mammals in specific habitats.

4.7 The area is important for the following red listed birds, under current status of the British Trust for Ornithology (BTO), evidence in the records of Greater Manchester Local Records Centre (GMLRC). The appendix lists letters from local naturalists also supporting evidence. • Skylark • Grey partridge • Yellow Wagtail • Corn Bunting • Lapwing • Woodcock • Cuckoo • Merlin • Willow Tit • Grasshopper Warbler • Starling • Fieldfare • Song Thrush • Mistle Thrush • Spotted Flycatcher • Winchat • Tree Sparrow

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• Lesser spotted woodpecker • Tree Pipit • Ring Ouzel • Spotted Flycatcher • Linnet 4.8 It also holds several brown hares, a declining species. Tree sparrows and yellowhammers also feed in the fields. Vagrant birds such as quail and the black- headed wagtail have also been found.

4.9 There has been no attempt by the developer to involve local ecology groups who have knowledge of the species and habitats in the area either to identify what species are present, or to design mitigation measures.

5 The Last Great Wild Space - biodiversity and people

Figure 3 - Parkside Phase 1 - pristine wilderness 5.1 In an area of dense urbanisation and intensive agriculture, Parkside is known by local people as Newton Park, the last ‘Great Wild Space’ between St Helens, Wigan, and Warrington. It is also shown as Newton Park on OS maps and in medieval times was a deer hunting park. The earliest documentary reference to Newton Park occurs in 1322, when Roger Dun and Adam le Wylde were accused of stealing 8s. from Meurick de Wygan in Newton Park. It is also referred to as a wildlife area from Dr Kearden’s visit through Newton Park in 1685. While theoretically private land in practice the public have walked on the

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land for decades and access is easy. During the Covid-19 lockdowns it has played a vital role in the physical and mental well-being of residents across a wide area.

5.2 This is the local countryside for tens of thousands of local people. It is rich in wildlife and plays a critical role in recreation, relaxation, and education. This is not an optional extra it is part of the experience of life. For most people, a stroll in the fresh air, dog walking, wildlife watching, are an intrinsic part of their existence. In an age where mental health and the stresses of life are high, the loss of such a facility on this scale will have impacts on wellbeing for a large section of the local population. Any future walkways or historical trails will be through an industrial area that will have no value or meaning.

5.3 People travel from other areas of the North West and beyond to visit this area for its wildlife including: • All five British species of owl • Peregrine, Merlin, Red kite, and other birds of prey. • Fields around Barrow Lane have the rare Corn Bunting. • Yellow Wagtail, Whinchat, Stonechat, Wheatear are also common. • Skylark (nationally declining) is abundant, particularly in spring. • One of the few local places with Brown Hare 5.4 Abundant local biodiversity and countryside attracts talent and wealth creators. This delivers benefits to the local economy both from the spending power from new residents and the jobs they create. 5.5 In contrast, an area dominated by ‘Shedscapes’ will not attract people who will create wealth in the future, but will attract low-value and unskilled industries.

6 Biodiversity Net Gain and mitigation

6.1 The concept is already a key part of NPPF 170 ‘Planning policies and decisions should contribute to and enhance the natural and local environment by: d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures’. The Environment Bill just enshrines BNG formally in law.

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6.2 In the government's view, the hidden environmental costs of development are not being considered systematically and there are no mechanisms to compensate for resulting harm to the local area. The benefits of creating greener development are not currently properly understood or measured. It is the clear intention of Government policy that BNG should be a material consideration now,

6.3 The promoters accept that Phase 1 means a ‘significant reduction in semi- natural habitat’ and describe it as ‘moderate adverse’. For PLR habitat loss includes broadleaved woodland, hedgerows, marshy grassland, and poor semi- improved grassland described as ‘significant at the local level.’

6.4 We think that these assessments greatly understate the damage to both individual species and habitats, and the overall biodiversity of the area.

6.5 They have made no attempt to use the DEFRA metric where existing habitats are assessed against four criteria – distinctiveness, condition, strategic significance, and connectivity – to act as multipliers in a formula used to calculate a site’s ‘baseline’ biodiversity value which can then be compared to the proposals. The final score must be 10 per cent greater than the baseline score to meet the policy test.

6.6 On site mitigation is hopelessly inadequate. Site landscaping is not the same as ecological mitigation. As is common with development proposals, mitigation is tucked away on a separate agricultural field to the south an afterthought.

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Figure 4 Phase 1 mitigation proposals 6.7 Planning policy makes clear mitigation is a last resort. Also, BNG requires that mitigation and improvements be maintained for at least 30 years, for instance through a ‘conservation covenant’, legally binding even if land changes hands.

6.8 The appellants made vague off-site mitigation proposals for Phase 1 in 2019 after prompting by Merseyside Environmental Advisory Service (MEAS), but the objectives are too generalised and should be tailored to the application and the land it covers. The area of land set aside for ecology is hopelessly inadequate and isolated from other habitats on the site. Even the previous SRFI applications in 2006 (Pro Logis/Astral) provided more detail for a smaller development. While this is an outline report and would be subject to planning condition, the applications do not so far demonstrate that mitigation for the biodiversity loss caused by the development can be effectively mitigated.

6.9 All applications and planning decisions (including at appeal) already seek BNG. It is standard, accepted practice. A methodology exists and should be applied at this PI. The applicant has failed to reach this standard.

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6.10 Section 40 the Natural Environment and Rural Communities Act 2006 requires local authorities to preserve biodiversity. The mitigation plan does not currently achieve those objectives.

7 Other issues

Climate change 7.1 Climate change is covered in a separate paper. The 2008 Climate Change act commits the UK to net zero emissions by 2050. St Helens, Wigan, and Warrington Councils have all declared a Climate Change Emergency. Development would release continuing large amounts of carbon.

7.2 Through natural regeneration, the Parkside area has already sequestered a large amount of climate change gases since the colliery closed, and this has the potential to be long-term or even permanent particularly where wetlands accumulating peat.

7.3 Rates of sequestration in wildlife habitats can be high. Woodland can sequester 2T CO2 per ha per year and even agricultural soil 900kg (0.9t) CO2/ha/year4.

7.4 Parkside is the ideal site in the area to be managed as a huge carbon sink – ironic but perhaps poetic justice given that part of the site was a coal mine and part of the fossil fuel industry that has largely created the climate change crisis..

Air Quality 7.5 Substantial parts of St Helens and Warrington are designated as Air Quality Management Areas. Green spaces and the habitats they contain disperse and absorb local air pollutants. The Air Quality Expert Group reported in 2018 that ‘an estimated 1.4 billion kg of air pollutants were removed by natural vegetation in 2015 – saving a potential £1 billion in avoided health costs’.

7.6 The Green Belt serves not only conventional functions but is also a buffer that improves air quality between Newton-Le-Willows, Lowton and Winwick.

4 farmcarbontoolkit.org.uk/resources/articles/growing-food-absorbing-carbon (Accessed 3/12/20)

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Aquatic Habitats 7.7 The Mersey basin clean-up campaign was one of the major projects undertaken in British history. In 1999 the restoration won the inaugural World Thiess River prize for the best river clean up anywhere in the world.

7.8 Today Salmon and Sea Trout run the Mersey and tributaries and coarse fish are found throughout. Dolphins and other Cetaceans are common in the river mouth. 7.9 St Oswald’s Brook (a tributary of the Mersey) runs partly underground after burial when the colliery was started in 1957. Near the A49 St Oswald’s brook runs into Newton Brook, a small river with coarse fish, some game fish, Kingfisher and other aquatic birds. If pollution from the Parkside complex enters Oswald’s Brook, there is a danger of pollution spreading into the Mersey system.

8 Cumulative effects

8.1 For Phase 1 the appellants claim ‘There are not however considered to be any impacts either at construction or operational of the Phase 1 Development on statutory designated sites such as SSSI/SAC/SPA and as such there are no cumulative impacts with the Phase 2 Development or PLR developments.’ It also claims in 9.44 that ‘The Phase 2 Development will be designed to ensure that habitat loss is mitigated for and will maintain the connective linkages from the Phase 1 Development’.

8.2 The logic of this is hard to follow. Just because there is no direct damage to statutory sites does not mean there is no cumulative effects. This is dealt with in more detail in a separate proof.

9 Conclusion

9.1 NPPF 175a) states: ‘if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused’.

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9.2 The developments underestimate the importance of the site itself, its regional biodiversity value, and its future potential. The wildlife and biodiversity of this ‘Last Great Wilderness’ are critical to the economy and physical health and mental well-being people of St Helens, Warrington, and Wigan.

9.3 For the reasons set out above, and given the high priority given by Government to biodiversity, it is recommended that the proposals are refused.

Declaration I have read and assessed in detail the proof of evidence statement and the background evidence papers submitted by Parkside Action Group for the Parkside Public Inquiry submission by 8th December. In my professional opinion this is a true and fair view

Roy S Leigh 5th December 2020

Roy S Leigh ACIEEM – Principal Ecologist Leigh Ecology Ltd

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10 Appendix A – Leigh Ecology Report

10.1 This report is provided as a separate document, Appendix A – Leigh Ecology Report P1 and Link Road.pdf.

11 Appendix B – GMLRC record

Scientific Name Common Name Eriophyes laevis Eriophyes laevis Bufo bufo Common Toad Rana temporaria Common Frog Acanthis cabaret Lesser Redpoll Accipiter nisus Sparrowhawk Acrocephalus schoenobaenus Sedge Warbler Actitis hypoleucos Common Sandpiper Aegithalos caudatus Long-tailed Tit Alauda arvensis Skylark Alcedo atthis Kingfisher Alectoris rufa Red-legged Partridge Anas crecca Teal Anas platyrhynchos Mallard Anser anser Greylag Goose Anser brachyrhynchus Pink-footed Goose Anthus pratensis Meadow Pipit Anthus spinoletta Water Pipit Anthus trivialis Tree Pipit Apus apus Swift Ardea cinerea Grey Heron Asio flammeus Short-eared Owl Asio otus Long-eared Owl Athene noctua Little Owl Bombycilla garrulus Waxwing Branta canadensis Canada Goose Branta leucopsis Barnacle Goose Buteo buteo Buzzard Caprimulgus europaeus Nightjar Carduelis carduelis Goldfinch Certhia familiaris Treecreeper Chloris chloris Greenfinch Chroicocephalus ridibundus Black-headed Gull Columba oenas Stock Dove Columba palumbus Woodpigeon Corvus corax Raven

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Corvus corone Carrion Crow Corvus frugilegus Rook Corvus monedula Jackdaw Cuculus canorus Cuckoo Cyanistes caeruleus Blue Tit Cygnus olor Mute Swan Delichon urbicum House Martin Dendrocopos major Great Spotted Woodpecker Dendrocopos minor Lesser Spotted Woodpecker Egretta garzetta Little Egret Emberiza calandra Corn Bunting Emberiza citrinella Yellowhammer Emberiza schoeniclus Reed Bunting Erithacus rubecula Robin Falco biarmicus Lanner Falco columbarius Merlin Falco peregrinus Peregrine Falco subbuteo Hobby Falco tinnunculus Kestrel Fringilla coelebs Chaffinch Fringilla montifringilla Brambling Gallinago gallinago Snipe Gallinula chloropus Moorhen Garrulus glandarius Jay Haematopus ostralegus Oystercatcher Hirundo rustica Swallow Larus argentatus Herring Gull Larus canus Common Gull Larus fuscus Lesser Black-backed Gull Linaria cannabina Linnet Locustella naevia Grasshopper Warbler Loxia curvirostra Common Crossbill Lymnocryptes minimus Jack Snipe Mergus merganser Goosander Milvus milvus Red Kite Motacilla alba White/Pied Wagtail Motacilla alba subsp. yarrellii Pied Wagtail Motacilla flava Yellow Wagtail Muscicapa striata Spotted Flycatcher Numenius arquata Curlew Oenanthe oenanthe Wheatear Parus major Great Tit Passer domesticus House Sparrow Perdix perdix Grey Partridge Periparus ater Coal Tit Phalacrocorax carbo Cormorant

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Phasianus colchicus Pheasant Phylloscopus collybita Chiffchaff Phylloscopus trochilus Willow Warbler Pica pica Magpie Picus viridis Green Woodpecker Pluvialis apricaria Golden Plover Pluvialis squatarola Grey Plover Poecile montanus Willow Tit Prunella modularis Dunnock Pyrrhula pyrrhula Bullfinch Rallus aquaticus Water Rail Regulus regulus Goldcrest Riparia riparia Sand Martin Saxicola rubetra Whinchat Saxicola rubicola Stonechat Scolopax rusticola Woodcock Sitta europaea Nuthatch Spinus spinus Siskin Sterna hirundo Common Tern Streptopelia decaocto Collared Dove Sturnus vulgaris Starling Sylvia atricapilla Blackcap Sylvia borin Garden Warbler Sylvia communis Whitethroat Sylvia curruca Lesser Whitethroat Tachybaptus ruficollis Little Grebe Tadorna tadorna Shelduck Tringa ochropus Green Sandpiper Tringa totanus Redshank Troglodytes troglodytes Wren Turdus iliacus Redwing Turdus merula Blackbird Turdus philomelos Song Thrush Turdus pilaris Fieldfare Turdus torquatus Ring Ouzel Tyto alba Barn Owl Vanellus vanellus Lapwing Dryopteris dilatata Broad Buckler-fern Pteridium aquilinum Bracken Aethusa cynapium Fool's Parsley Agrostis capillaris Common Bent Alnus glutinosa Alder Angelica sylvestris Wild Angelica Anthemis arvensis Corn Chamomile Atriplex prostrata agg. Atriplex prostrata agg. Avena fatua Wild-oat

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Avena sativa Oat Ballota nigra Black Horehound Betula x aurata Hybrid Birch Betula pubescens Downy Birch Calluna vulgaris Heather Carex nigra Common Sedge Centaurea nigra sens. Lat Common Knapweed Chamerion angustifolium Rosebay Willowherb Cirsium palustre Marsh Thistle Cirsium vulgare Spear Thistle Crepis biennis Rough Hawk's-beard Dactylis glomerata Cock's-foot Dactylorhiza x wintoni Marsh-Orchid Danthonia decumbens Heath-grass Deschampsia flexuosa Wavy Hair-grass Digitalis purpurea Foxglove Drosera rotundifolia Round-leaved Sundew Epilobium hirsutum Great Willowherb Epilobium montanum Broad-leaved Willowherb Erica cinerea Bell Heather Erica tetralix Cross-leaved Heath Eriophorum angustifolium Common Cottongrass Eriophorum vaginatum Hare's-tail Cottongrass Euphorbia helioscopia Sun Spurge Festuca ovina Sheep's-fescue Festuca rubra Red Fescue Fumaria muralis Common Ramping-fumitory Fumaria officinalis Common Fumitory Galeopsis tetrahit Common Hemp-nettle Galium aparine Cleavers Galium saxatile Heath Bedstraw Genista anglica Petty Whin Gentiana pneumonanthe Marsh Gentian Gnaphalium sylvaticum Heath Cudweed Hedera helix Ivy Heracleum sphondylium Hogweed Hieracium sect. Sabauda Hawkweed Holcus lanatus Yorkshire-fog Holcus mollis Creeping Soft-grass Hydrocotyle vulgaris Marsh Pennywort Hypochaeris radicata Cat's-ear Juncus acutiflorus Sharp-flowered Rush Juncus articulatus Jointed Rush Juncus conglomeratus Compact Rush Juncus effusus Soft-rush Juncus effusus Soft-rush

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Juncus squarrosus Heath Rush Lamium album White Dead-nettle Lamium purpureum Red Dead-nettle Luzula campestris Field Wood-rush Molinia caerulea Purple Moor-grass Nardus stricta Mat-grass Pedicularis sylvatica Lousewort Pentaglottis sempervirens Green Alkanet Phalaris arundinacea Reed Canary-grass Plantago major Greater Plantain Poa annua Annual Meadow-grass Poa trivialis Rough Meadow-grass Potentilla erecta Tormentil Potentilla reptans Creeping Cinquefoil Quercus Acorn Quercus petraea Sessile Oak Quercus robur Pedunculate Oak Ranunculus repens Creeping Buttercup Rosa canina agg. Dog Rose Rubus fruticosus agg. Bramble Rumex acetosa Common Sorrel Rumex acetosella Sheep's Sorrel Salix cinerea Common Sallow Sambucus nigra Elder Scorzoneroides autumnalis Autumn Hawkbit Senecio jacobaea Common Ragwort Senecio sylvaticus Heath Groundsel Silene dioica Red Campion Silene latifolia White Campion Silene x hampeana Hybrid Campion Solidago virgaurea Goldenrod Stachys palustris Marsh Woundwort Succisa pratensis Devil's-bit Scabious Teucrium scorodonia Wood Sage Trichophorum caespitosum Deergrass Trifolium repens White Clover Ulex europaeus Gorse Ulex gallii Western Gorse Urtica dioica Common Nettle Vaccinium myrtillus Bilberry Vaccinium oxycoccos Cranberry Veronica chamaedrys Germander Speedwell Veronica persica Common Field-speedwell Vicia cracca Tufted Vetch Viola arvensis Field Pansy Viola tricolor Wild Pansy

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Amanita rubescens Blusher Epichloe typhina Choke Erysiphe alphitoides Oak Mildew Gomphidius glutinosus Slimy Spike Hebeloma crustuliniforme Poisonpie Hygrocybe miniata Vermilion Waxcap Hypholoma elongatum Sphagnum Brownie Hypomyces chrysospermus Bolete Mould Lactarius quietus Oakbug Milkcap Lactarius subdulcis Mild Milkcap Lactarius tabidus Birch Milkcap Leccinum scabrum Brown Birch Bolete Mycena pura Lilac Bonnet Paxillus involutus Brown Roll Rim Puccinia arenariae Puccinia arenariae Russula betularum Birch Brittlegill Russula claroflava Yellow Swamp Brittlegill Russula ochroleuca Ochre Brittlegill Scleroderma citrinum Earth Ball Scutellinia scutellata Common Eyelash Sphagnurus paluster Sphagnum Greyling Stereum hirsutum Hairy Curtain Crust Stropharia semiglobata Dung Roundhead Trametes versicolor Turkeytail Agelastica alni Alder Leaf Beetle Athous haemorrhoidalis Athous haemorrhoidalis Chrysolina fastuosa Dead-Nettle Leaf Beetle Cicindela campestris Green Tiger Beetle Cionus scrophulariae Figwort Weevil Coccinella septempunctata 7-spot Ladybird Ctenicera cuprea Ctenicera cuprea Exapion ulicis Gorse Weevil Harmonia axyridis Harlequin Ladybird Luperus longicornis Luperus longicornis Phyllobius pyri Common Leaf Weevil Rhagonycha fulva Common Red Soldier Beetle Aglais io Peacock Aglais urticae Small Tortoiseshell Coenonympha pamphilus Small Heath Gonepteryx rhamni Brimstone Lycaena phlaeas Small Copper Maniola jurtina Meadow Brown Ochlodes sylvanus Large Skipper Pararge aegeria Speckled Wood Pieris brassicae Large White Pieris napi Green-veined White

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Pieris rapae Small White Pyronia tithonus Hedge Brown Pyronia tithonus Hedge Brown Thymelicus sylvestris Small Skipper Aeshna cyanea Southern Hawker Aeshna grandis Brown Hawker Aeshna juncea Common Hawker Anax imperator Emperor Dragonfly Calopteryx splendens Banded Demoiselle Enallagma cyathigerum Common Blue Damselfly Enallagma cyathigerum Common Blue Damselfly Ischnura elegans Blue-tailed Damselfly Lestes sponsa Emerald Damselfly Libellula quadrimaculata Four-spotted Chaser Orthetrum cancellatum Black-tailed Skimmer Sympetrum danae Black Darter Sympetrum striolatum Common Darter Andrena cineraria Ashy Mining Bee Andrena fulva Tawny Mining Bee Andricus curvator Andricus curvator Andricus curvator f. sexual Curved-leaf Gall Causer Andricus foecundatrix f. agamic Artichoke Gall Causer Andricus kollari f. agamic Marble Gall Causer Andricus lignicolus f. agamic Cola-nut Causer Apis mellifera Western Honey Bee Biorhiza pallida Oak Apple Gall Causer Biorhiza pallida f. sexual Oak-apple Causer Bombus lapidarius Large Red Tailed Bumble Bee Bombus lucorum White-Tailed Bumble Bee Bombus muscorum Moss Carder-bee Bombus pascuorum Common Carder Bee Bombus pascuorum Common Carder Bee Bombus pratorum Early Bumble Bee Bombus terrestris Buff-Tailed Bumble Bee Lasius flavus Yellow Meadow Ant Neuroterus numismalis f. agamic Silk-button Gall Causer Neuroterus quercusbaccarum f. agamic Common Spangle Gall Causer Vespula vulgaris Common Wasp Deltote uncula Silver Hook Nemophora degeerella Yellow-barred Long-horn Nomophila noctuella Rush Veneer Pterophoridae Pterophoridae Rivula sericealis Straw Dot Scotopteryx chenopodiata Shaded Broad-bar Tyria jacobaeae Cinnabar

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Chorthippus brunneus Field Grasshopper Chorthippus parallelus Meadow Grasshopper Conocephalus fuscus Long-winged Cone-head Omocestus viridulus Common Green Grasshopper Mecoptera Mecoptera Panorpa Panorpa Cicadella viridis Cicadella viridis Liocoris tripustulatus Liocoris tripustulatus Pentatoma rufipes Red-legged Shieldbug Philaenus spumarius Cuckoo-Spit Insect Phytocoris (Ktenocoris) varipes Phytocoris (Ktenocoris) varipes Chirosia grossicauda Chirosia grossicauda Dasineura pteridis Dasineura pteridis Episyrphus balteatus Marmalade Hoverfly Eristalis pertinax Eristalis pertinax Helophilus pendulus Helophilus pendulus Scathophaga stercoraria Scathophaga stercoraria Syrphus ribesii Syrphus ribesii Lecanora chlarotera Lecanora chlarotera Lecidella elaeochroma f. Lecidella elaeochroma f. elaeochroma elaeochroma Melanelixia subaurifera Melanelixia subaurifera Melanelixia subaurifera Melanelixia subaurifera Parmelia sulcata Netted Shield Lichen Parmelia sulcata Netted Shield Lichen Peltigera hymenina Peltigera hymenina Physcia tenella Physcia tenella Punctelia subrudecta s. lat. Punctelia subrudecta s. lat. Ramalina farinacea Ramalina farinacea Ramalina farinacea Ramalina farinacea Xanthoria parietina Common Orange Lichen Calypogeia fissa Common Pouchwort Cephalozia bicuspidata Two-horned Pincerwort Cephalozia bicuspidata Two-horned Pincerwort Lophocolea bidentata Bifid Crestwort Metzgeria furcata Forked Veilwort Metzgeria violacea Blueish Veilwort Atrichum undulatum Common Smoothcap Aulacomnium palustre Bog Groove-moss Aulacomnium palustre Bog Groove-moss Brachythecium albicans Whitish Feather-moss Brachythecium albicans Whitish Feather-moss Brachythecium rutabulum Rough-stalked Feather-moss Bryum argenteum Silver-moss Calliergonella cuspidata Pointed Spear-moss Campylopus introflexus Heath Star Moss

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Campylopus pyriformis Dwarf Swan-neck Moss Campylopus pyriformis Campylopus pyriformis Ceratodon purpureus Redshank Dicranoweisia cirrata Common Pincushion Dicranum scoparium Broom Fork-moss Didymodon rigidulus Rigid Beard-moss Funaria hygrometrica Common Cord-moss Grimmia pulvinata Grey-cushioned Grimmia Hypnum cupressiforme Cypress-leaved Plait-moss Hypnum cupressiforme Cypress-leaved Plait-moss Hypnum jutlandicum Heath Plait-moss Kindbergia praelonga Common Feather-moss Orthotrichum affine Wood Bristle-moss Orthotrichum pulchellum Elegant Bristle-moss Plagiothecium undulatum Waved Silk-moss Plagiothecium undulatum Waved Silk-moss Polytrichum commune Common Haircap Polytrichum juniperinum Juniper Haircap Polytrichum piliferum Bristly Haircap Pseudoscleropodium purum Neat Feather-moss Rhytidiadelphus squarrosus Springy Turf-moss Sphagnum capillifolium subsp. rubellum Red Bog-moss Sphagnum cuspidatum Feathery Bog-moss Sphagnum fallax Flat-topped Bog-moss Sphagnum fimbriatum Fringed Bog-moss Sphagnum palustre Blunt-leaved Bog-moss Sphagnum papillosum Papillose Bog-moss Sphagnum subnitens Sphagnum subnitens Sphagnum subnitens Sphagnum subnitens Thuidium tamariscinum Common Tamarisk-moss Ulota bruchii Bruch's Pincushion Ulota crispa Crisped Pincushion Ulota phyllantha Frizzled Pincushion Zootoca vivipara Common Lizard Arvicola amphibius European Water Vole Erinaceus europaeus West European Hedgehog Lepus europaeus Brown Hare Myotis nattereri Natterer's Bat Nyctalus noctula Noctule Bat Oryctolagus cuniculus European Rabbit Pipistrellus Pipistrelle Bat species Pipistrellus pipistrellus Pipistrelle Pipistrellus pygmaeus Soprano Pipistrelle Sciurus carolinensis Eastern Grey Squirrel

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12 Appendix C – Evidence of badgers in the Parkside area

Figure 5 Dead Badger, June 2015 at side of Winwick Lane,part of the proposed Parkside Link Road (photo Peter Astles) This was also evidenced by Jonathan Platt another local person Jonathan has confirmed this via email with further evidence of badgers on another occasion. Badgers are common in nearby North Cheshire and there are thought to be badger sets in nearby croft and Culcheth areas. For obvious reasons these are secret locations. Badgers are rapidly expanding their local range in the local area.

Figure 6 Dead Badger near site (Photo Jonathan Platt)

Figure 7 Confirmation both incidents were reported to Cheshire Badger Group

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13 Appendix D – letter from Leigh Ornithological Society

Leigh Ornithological Society has this year been awarded the Queen’s Award for Voluntary Service and is a volunteer organisation with concern for much more than just bird life, but for the biodiversity of the countryside as a whole. As such, we are concerned for the conservation of green spaces around the South Lancashire and North Cheshire areas, and our members have been recording bird species and other wildlife and plants in the area affected by these proposals for 50 years. We would oppose the creation of this large development for the following reasons: 1. Loss of biodiversity and habitat. The landscape affected by these proposals is one where man and nature co-exist successfully at the present time. The open, arable landscape around Barrow Lane is host to three iconic bird species, ALL of which are on the RSPB/British Trust for Ornithology RED list of Birds of Conservation Concern. Skylark, the migrant Yellow Wagtail and the rapidly disappearing Corn Bunting are all found in this area. This arable habitat is relatively rare around Greater Manchester and Merseyside, with much of the countryside being given to poor quality grazing land. Green space is rapidly disappearing from the conurbations of this area, and we believe that the assumption that all unbuilt land is “fair game” for development has to be challenged, and the sacrifice of more green space must be reversed.

We take note of and appreciate the mitigation proposals for planting of areas of native woodland, hedgerow, semi-improved grassland, etc. This is better than making no attempt to compensate for loss of habitat, but in its extent it is little short of derisory. The areas within the proposed development total 12.5 Hectares, and will be split into small corridors on the periphery of the site (p8 of the mitigation plan) and small areas within the landscaping of the site. Thus they will be disjointed and small in scale. An additional 4.7 hectares of offsite semi-improved grassland is the size of a small field, and while welcome, again fails to compensate for losses, and will not result in a net gain for biodiversity.

2. Loss of connectivity of habitat. With the disappearance of green spaces between our developed areas, the ability of wildlife and plants to move freely and spread around the landscape is severely curtailed. As long ago as 2011, DEFRA was publishing its paper, “Biodiversity 2020” with the commitment:

“We will enhance ecological connections between, or join up, existing areas of priority habitat, increasing opportunity for wildlife to move around the landscape by making use of ‘stepping stones’, ‘corridors’ and other features. To achieve this, we will take and encourage a more spatially-based approach, focussed on places, and landscape-scale action.”

We believe that an area which supports red listed species and is in itself increasingly rare locally, should be regarded as “priority habitat” as referred to above. Green space preservation and landscape stepping-stones and corridors are not a new idea, and it is time that planning regulations and their implementation caught up with this policy.

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PARKSIDE WEST is at present an area of mature grassland, scrub, woodland and wetland. It is closely geographically linked with the arable landscape at Barrow Lane, and with the rare lowland raised bog habitat at Highfield Moss SSSI. The value of these three different types of habitat is greater because of their proximity to one another than the value of each on its own. This contributes additional significance to the biodiversity of the whole area. The loss of Parkside West for the warehouse scheme and Barrow Lane arable for the road scheme will have a significant impact for wildlife movement into and out of Highfield Moss area.

3. Public concern for green space and about biodiversity loss. In the 2019 report from Natural England, “Monitor of Engagement with the Natural Environment”, the increasing concern of the public at large for our environment is both documented and measured. 90% of adults in the UK agreed with the statement, “I am concerned about damage to the natural environment.” In NW England, 49% of people STRONGLY agreed with this statement. 62% of adults are both aware of and concerned about loss of biodiversity. (MENE Headline Report, pp. 22,23.) With more and more people valuing green space for both mental and physical wellbeing, we believe the sacrifice of the land involved in this development would be an action in direct contradiction to the thinking and mood of the majority of people who live in the surrounding towns and cities.

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14 Appendix E – Letter from Local Ornithologists

NICK ISHERWOOD

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JOHNATHAN PLATT

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