Bat Scoping Report and Preliminary Ecological Appraisal

Unit 4, Langham Stables, Langham Lane, Lodsworth, Petworth, West Sussex GU28 9BU

Tel: 01798 861 800 - E-Mail: [email protected] - Web: www.ecologyco-op.co.uk

Mill House, Mill Lane, Cocking

Author: Paul Whitby BSc, MCIEEM, CEcol Reviewed by: Dr Ryan Walker MCIEEM, CEnv

22th April 2021

Project No: 4146

The Ecology Co-operation Ltd Registered Office: Greens Court, West Street, Midhurst, West Sussex, GU29 9NQ Company number: 8905527

Mill House – BAT SCOPING REPORT AND PEA

Document Control Issue No Author Reviewer Issue Date Additions/alterations Notes Original PW RW 22/04/21 Small changes to text

This report has been prepared by The Ecology Co-operation Ltd, with all reasonable skill, care and diligence within the terms of the Contract with the client. This report only becomes the property of the client once payment for it has been received in full.

We disclaim responsibility to the client and others in respect of any matters outside the scope of the above.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

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Report Summary

1. The Ecology Co-op was commissioned by Mr and Mrs Dixon to undertake a Bat Scoping Assessment and Preliminary Ecological Appraisal at Mill House, Mill Lane, Cocking. The purpose of this report is to present the findings of the appraisal and identify potential ecological constraints and opportunities in relation to a proposal to add an extension to the rear of the property, and to demolish the existing garage, which will be re-built in a new location.

2. An assessment of the site was undertaken by Paul Whitby BSc, MCIEEM, CEcol and Natural England Level 2 bat survey class licence holder on the 10th March 2021. This included a ground-based external inspection of the buildings, an internal inspection of potential roost features, such as enclosed loft spaces (subject to access), and an appraisal of the surrounding habitats, to evaluate the site for its potential to support bats. All bat species are European Protected Species (Annex IV, ‘Habitats Directive’).

3. This site is situated in the rural village of Cocking, West Sussex. It comprises a large residential building and a small garage on a tarmac driveway with a small managed garden. Within a wider context, it is surrounded by agricultural fields, small patches of woodland, and there is the presence of Costers brook to the east of the site.

4. The area of the property that will be impacted by the proposals for a new extension was found to support a solitary bat, visibly roosting behind a hanging tile, whilst at the norther end of the property where new French doors are proposed, the hanging tile in this location were deemed to have ‘moderate’ roosting suitability. The garage building to be demolished has a negligible suitability for roosting bats. Habitats within the zone of influence of the proposals was considered to be of value to bats for foraging, commuting, and wider dispersal purposes.

5. Therefore, in accordance with current guidelines, two emergence/re-entry surveys are recommended to complete a roost characterisation assessment of the property, focussing on the two zones of impact. These must be spaced approximately three weeks apart, between May and September (although September is considered a sub-optimal survey month and surveys cannot be undertaken in September for low potential buildings).

6. A chalk stream called Costers Brook is present adjacent to the garage and supports high biodiversity value. It is important that strict measures are in place to ensure that impact risks to this feature are minimised. The production of a Construction Environment Management Plan will help to ensure that impact risks to this watercourse are minimised.

7. A European Protected Species (EPS) licence will be required for works which will destroy the identified bat roost. The EPS licence would detail full mitigation measures during the development likely to include careful timing of the works to avoid adverse impacts on bats, the precautionary sensitive removal of roost features, supervised by a bat license holder, and provision of permanent bat roosting features.

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CONTENTS PAGE

1 INTRODUCTION ...... 5

1.1 Purpose of the Report ...... 5 1.2 Background ...... 5 1.3 Policy and Legislation ...... 7 2 METHODOLOGY ...... 7

2.1 Desk Study ...... 7 2.2 Field Survey ...... 7 2.2.1 Roosting Potential ...... 7 2.2.2 Hibernation Potential ...... 8 2.2.3 Foraging and Commuting Potential ...... 9 2.3 Other Protected and/or Notable Species ...... 9 3 RESULTS/OBSERVATIONS ...... 9

3.1 Desk Study and Granted EPS Licences ...... 9 3.2 Site Context and Surrounding Habitats ...... 12 3.3 Inspection for Bats ...... 13 3.3.1 Roost Potential ...... 13 3.3.2 Hibernation Potential ...... 14 3.4 Foraging and Commuting Potential ...... 15 3.5 Other Protected and/or Notable Species ...... 15 3.6 Survey Limitations ...... 15 3.7 Photographs ...... 16 4 ECOLOGICAL CONSTRAINTS AND OPPORTUNITIES ...... 20

4.1 Designated Sites ...... 20 4.2 Bats ...... 20 4.2.1 Roost Potential ...... 20 4.2.2 Hibernation Potential ...... 21 4.2.3 Foraging and Commuting Suitability ...... 21 4.3 Other Protected and/or Notable Species ...... 21 4.4 Biodiversity Enhancement Opportunities ...... 22 APPENDIX 1 – Wildlife Legislation and National Planning Policy ...... 23 APPENDIX 2 – Reducing Impacts of Artificial Light ...... 25

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1 INTRODUCTION

1.1 Purpose of the Report

The Ecology Co-op has been commissioned to undertake a bat scoping assessment and Preliminary Ecological Appraisal of Mill House by Mr and Mrs Dixon. This report presents the findings of a walkover survey and building/tree inspection for occupation by bats, undertaken by Paul Whitby BSc, MCIEEM, CEcol and Natural England Level 2 bat survey class licence holder on the 10th March 2021. Whilst this report has maintained a focus on assessing potential impacts upon roosting bats and bat activity within the proposal’s zone of influence, it has also considered the potential for any other protected/notable species and/or habitats to be adversely affected. The proposal for the site comprises rear extensions to the ground and first floor of the property and the demolition of the existing garage with a relocated new garage that will include new accommodation. Recommendations for further surveys that are likely to be required to inform a planning application and Ecological Impact Assessment are provided, if necessary. Where appropriate, measures to avoid, mitigate and/or compensate for significant adverse effects are outlined.

This report is intended to inform the client and the appropriate planning authority of the potential impacts that this development proposal may have upon roosting bats as well as identifying potential impacts to commuting routes and foraging habitat of value. Where bat roosting potential, or physical evidence of bats has been identified, further survey effort will be required in order to complete an impact assessment to inform a planning application.

1.2 Background

The site is located at Mill House, Mill Lane, Cocking, GU29 0HJ. The central grid reference for the site is SU88001763.

The site comprises a large residential building and a small garage on a tarmac driveway with a small managed garden. The site is in a semi-rural location with low-density housing to the north, south, and west. In a wider context, it is surrounded by agricultural fields, small patches of woodland, and there is the presence of a brook to the east of the site.

The location of the study buildings is based on a site plan provided by WCEC Architecture and is illustrated in Figure 1.

The proposed development/project includes a rear extension to the ground and first floor of the residential building (see Figure 2). It also includes the demolition of the existing garage and the relocation of a new garage with a first floor comprising a residential/holiday accommodation (Figure 2).

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Figure 1. Aerial image showing the location of Mill House where the proposed building works will be carried out (outlined in red). Site plan. Image produced courtesy of Google maps (map data ©2021 Google).

Figure 2. Proposed floor plan for the site. Drawings by WCEC Architecture, 2020.

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1.3 Policy and Legislation

Legal protection applying to all bat species in the UK and any other species relevant to this appraisal, is outlined in Appendix 1 of this report.

The results of this survey will be used to determine the need for further surveys, impact avoidance measures and/or an appropriate mitigation/compensation strategy to ensure compliance with UK wildlife legislation, policy and best practice.

2 METHODOLOGY

The methodologies used for this survey are in accordance with the bat survey guidelines produced by the Bat Conservation Trust1. Where there has been any deviation from the guidelines due to any site- specific constraints or other circumstances, reasoning and justification has been provided. This survey has also considered the Guidelines for Preliminary Ecological Appraisal produced by CIEEM2, where the potential for impacts to species other than bats has been identified.

2.1 Desk Study

A search of on-line mapping resources has been undertaken to characterise the local context of the site with respect to semi-natural habitats and linear features of value to foraging and commuting bats.

The MAGIC website resource (www.magic.gov.uk) has been used to identify the location of designated sites for nature conservation within 2km and European Protected Species (EPS) licences granted within a 1km radius of the survey site. Priority habitats and ancient woodland, upon the site and within the proposal’s zone of influence, have also been identified due to their ecological value and potential to act as important foraging resources for bats.

Priority habitats and ancient woodland are classified as habitats of principal importance. Habitats of principal importance are listed in Section 41 of the Natural Environment and Rural Communities (NERC) Act, 20063, which places a duty on Local Planning Authorities to have due regard to biodiversity.

2.2 Field Survey

2.2.1 Roosting Potential Bats can use a wide range of features for roosting purposes including loft spaces, cavity walls, loose tiles, mortice joints and cracks/gaps in a variety of built structures. They can also be found in trees with holes, splits, cracks, cavities, ivy and loose bark.

1 Collins, J.(ed.) (2016) Bat Surveys for Professional Ecologists: Good Practice Guidelines (3rd edn). The Bat Conservation Trust, London. 2 CIEEM (2017) Guidelines for Preliminary Ecological Appraisal, 2nd edition. Chartered Institute of Ecology and Environmental Management, Winchester. 3 HM Government (2006). Natural Environment and Rural Communities Act 2006. Available online at: https://www.legislation.gov.uk/ukpga/2006/16/section/41.

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A detailed building inspection was carried out, looking for potential access points and Potential Roosting Features (PRFs) that bats could use and any evidence indicating the presence of bats using the building, such as rub marks, feeding remains, staining or droppings. This included a ground-based external inspection around both buildings and internal inspection of PRFs associated with the garage (no roof voids will be impacted at the property). A high-powered torch was used for the internal and external assessment.

The suitability of each feature, or group of features, to support roosting bats has been assessed as either negligible, low, moderate, or high, in accordance with best practice guidance1 (see Table 1) Any evidence confirming the presence of bats was clearly recorded including photos and samples taken (e.g. droppings), where appropriate. Further surveys have been recommended in accordance with best practice guidance and the surveyors professional judgement, where evidence of a bat roost or PRFs have been identified that would be adversely impacted by the proposal and where precautionary mitigation alone cannot ensure that bats would not be potentially disturbed or harmed.

Table 1. Guidelines for assessing suitability of structures (buildings and trees etc) to support bat roosts Suitability Description of roosting habitats

Negligible A structure that does not support any features that could be used by roosting bats.

A structure that has one or more potential roosting features that could support individual Low roosting bats opportunistically. These features however lack the space, shelter or appropriate conditions, to support larger numbers of bats (such as a maternity roost). A structure with one or more potential roost sites that could be used by bats due to their size, Moderate shelter and suitable conditions for roosting, but are unlikely to support a roost of high conservation significance. A structure with one or more potential roost sites that are obviously suitable for use by larger High numbers of bats on a more regular basis and potential for longer periods of time due to their size, shelter, protection and conditions.

2.2.2 Hibernation Potential The structure and its associated features were assessed for their suitability to be used by hibernating bats. The assessment was carried out in accordance with guidelines produced by BatAbility4 and the bat survey guidelines produced by the Bat Conservation Trust1. To determine the potential for features to support hibernating bats the following aspects were considered: • The suitability of features to support roosting bats or to allow access for roosting bats; • The temperature and humidity conditions likely to be present within the feature during the winter period and the suitability in this respect for it to be used by bats for hibernating; • The surrounding habitat, in terms of its potential for use by bats outside of the hibernation period for commuting and/or foraging purposes; and • The presence of known roosts within the structure, or adjacent structures, or surrounding area during the active season.

The potential for use by hibernating bats for each feature, or group of features was assessed as either negligible, low, moderate, or high, in accordance with best practice. Further surveys are recommended

4 Middleton. N. (2019). Assessing Sites for Hibernation Potential. A Practical Approach, including a Proposed Method & Supporting Notes. Version’ Draft/V2.2019. BatAbility.

8 Mill House – BAT SCOPING REPORT AND PEA where appropriate, considering the feasibility of a hibernation survey for certain PRFs.

2.2.3 Foraging and Commuting Potential The habitats surrounding the site and wider landscape were broadly assessed for their potential to support foraging and commuting bats, and were categorised as negligible, low, moderate or high potential suitability in line with published guidance1.

2.3 Other Protected and/or Notable Species

Any birds identified, or evidence of nesting birds discovered during the site visit, were recorded. Special attention was paid to notable species such as red-listed Birds of Conservation Concern5 and those species afforded special protection on Schedule 1 of the Wildlife and Countryside Act (1981), such as barn owl Tyto alba and swallow Hirundo rustica.

Whilst this survey has focussed on bats and no specific searches were made with respect to other protected/notable species, any evidence of such species that was encountered during the site visit was also recorded.

3 RESULTS/OBSERVATIONS

3.1 Desk Study and Granted EPS Licences

Four statutory designated sites are present within a 2km radius of Mill House (See Figure 3). Full details of the designated sites are provided in Table 2 below. Two of these sites, Singleton and Cocking Tunnels SSSI and SAC include bats as a designated feature.

Table 2. Designated sites within 2km of Mill House. Site name Designation Features listed on citation Proximity to the site Singleton Site of Singleton and Cocking Tunnels constitute the most important sites 840m and Special for hibernating bats in south-east England and are the fifth most southwest Cocking Scientific important in Britain. During the winter months they support large Tunnels Interest numbers of hibernating bats, and are the only known location in (SSSI) Britain for the Mouse-eared bat Myotis myotis. Eight species of bats have been found in this SSSI, including Natterer’s Myotis nattereri, Daubenton’s Myotis daubentoni, Brown long-eared Plecotus auritus, and Brandt’s Myotis brandti/Whiskered Myotis mystacinus. Other species regularly occur in small numbers. Singleton Special Area Annex II species which present as a qualifying feature for site 840m and of selection include bat species Barbastelle Barbastella barbastellus southwest Cocking Conservation and Bechstein’s Myotis bechsteinii. Tunnels (SAC)

5 Eaton et al. (2015). Birds of Conservation Concern 4: the population status of birds in the UK, Channel Islands and Isle of Man.

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Treyford to Site of Representative examples of unimproved grassland and yew 1460m Bepton Special woodland which are rare nationally. Species-rich unimproved chalk west Down Scientific grassland is dominated by sheep’s fescue Festuca ovina and Interest upright brome Bromus erectus. Hawthorn Crataegus monogyna (SSSI) scrub is now invading much of the ungrazed grassland, while a more diverse mixed scrub community with hazel Corylus avellana and guelder rose Viburnum opulus is established in other areas. Mature mixed woodland with yew Taxus baccata, beech Fagus sylvatica and ash Fraxinus excelsior clothes the lower slopes and Stead Combe. In all but the most shaded areas there is a dense ground cover of dog’s mercury Mercurialis perennis and false brome Brachypodium sylvaticum. Bird’s-nest orchid Neottia nidus- avis is also present. Several particularly rare and uncommon mollusc species (snails) are present. Heyshott Site of An example of unimproved chalk grassland, a nationally rare 1250m Down Special habitat. It is rich in plant species, consisting of a short turf west Scientific dominated by sheep’s fescue Festuca ovina and upright brome Interest Bromus erectus with taller patches of tor grass Brachypodium (SSSI) pinnatum and cock’s foot Dactylis glomerata. The site has an assemblage of bryophytes (mosses and liverworts) which is not known from any other site on chalk in southern England. Several subalpine species that are more usually restricted to north and northwest Britain are present, including Hylocomium brevirostre, Rhytidiadelphus loreus and of particular interest Antitrichia curtipendula, Rhacomitrium lanuginosum and Jungermannia atrovirens, a species known from only one other site in southeast England. It is also nationally important for two groups of Arachnid (spiders) and harvestmen; Tapinocyboides pygmaea has been recorded in Britain from here and on Scottish site, while Pelecopsis radicicola is known at only one other West Sussex site. The calcareous grassland and woodland also support rich communities of woodlice (Isopoda) and bugs (Hemiptera). The site is also a locality of the rufous grasshopper Gomphocerippus rufus which is uncommon in the county.

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Figure 3. Designated sites within a radius of 2km of the application site. Images produced courtesy of Magic maps (http://www.magic.gov.uk/, contains public sector information licensed under the Open Government Licence v3.0)

Ancient and semi-natural woodland is present at its closest point approximately 40m from the site, and areas of ancient and semi-natural woodland are present in all directions from the site. Ancient replanted woodland is present in all directions from the site, the closest area is approximately 500m from the site. Deciduous woodland (Priority Habitat) is also present in all directions around the site, and at its closest point is approximately 30m from the site (see Figure 4).

Figure 4. Ancient and semi-natural woodland/ancient replanted woodland relative to Mill House (outlined in red).

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Image produced courtesy of Magic maps (http://www.magic.gov.uk/, contains public sector information licensed under the Open Government Licence v3.0)

There is one EPS licence granted for mitigation projects concerning bats within 1km of the site shown on the Magic Maps website (see Figure 5). The licence (2014-4264-EPS-MIT) concerns the destruction of a common pipistrelle Pipistrellus pipistrellus resting place and is dated 2014-2019. It is centered on a location in Cocking approximately 350m from the site. There are no EPS licences granted for mitigation projects regarding any other protected species within 2km from the site.

Figure 5. European Protected Species Licence within a radius of 1km of the application site (purple indicates EPS licence for bats). Images produced courtesy of Magic maps (http://www.magic.gov.uk/, contains public sector information licensed under the Open Government Licence v3.0)

3.2 Site Context and Surrounding Habitats

This site is located in a rural location in Cocking. A treeline leading to ancient and semi-natural woodland is present, leading from the west of the site to the woodland north of the site. Mixed farmland, hedges, a brook, and low-density housing surround the site. The close surrounding habitats are considered to be of high value for a range of bat species, whilst within the wider landscape there are high value habitats present, including ancient woodland, Costers Brook and Singleton and Cocking Tunnels SSSI and SAC, which combine to provide a variety of habitats that are likely to support a wide variety of bat species.

The site supports two buildings; one main residential building and one garage outbuilding. The building sits within a garden space comprising mown lawn areas, occasional shrubs and a tarmac driveway.

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3.3 Inspection for Bats

3.3.1 Roost Potential The Mill House Property This is a period building, with brick and sandstone walls, with a clay tiled half-hipped roof that has dormer extensions on the northwestern side of the roof and a single story gable roof extension on the northeastern face. As the development proposals would only impact the central northeastern face of the main roof of the property and a northeastern facing gable end wall on the single storey extension, the survey and descriptions of the property have focused on these features.

The proposed extension on the northwestern face will sandwich between two existing dormer extensions on a large roof pitch that falls just below ground floor ceiling height. `The roof is clad with handmade clay roof tiles and an inspection around the eaves revealed the presence of a bitumen roof lining that is likely to extend up underneath the tiles across this roof face. The tiles in this location are quite heavily shaded by a tall embankment and the adjacent dormer extensions. This has led to some significant mossy growth across much of this roof section, which smothers the tiles in places and reduces the number of potential accessible crevices that would otherwise be present.

The dormer extension on the southern side of this location is clad with handmade clay hanging tiles that include a small number of gaps that could be exploited by smaller bat species and an investigation with a high-powered torch revealed the presence of a pipistrelle bat behind a hanging tile near the join with the sloping roof. A visible dark band across the face of this bat indicated that it was likely a common pipistrelle Pipistrellus pipistrellus (see Photograph 4).

The northern of the two dormer extensions is clad with timber weatherboarding and this is largely tight- fitting across all faces, with no clear visible gaps present between boards. A single board has however fallen down on the southern side where the new extension is proposed, creating an access opportunity for bat roosting (see Photograph 5).

At the northeastern face of the property the wall where the French doors are proposed were clad with handmade clay hanging tiles. These tiles are in a tired condition, with some appearing to have slipped or lifted and there are numerous potentially accessible crevices that could be exploited by bats, although a close inspection with a high-powered torch did not find any evidence of bat droppings and only evidence of bird roosting was seen. A bitumen lining was visible behind the tiles and these are hung on timber battens.

The double garage on the eastern side of the property that is to be demolished has a bitumen lined flat roof that is tightly fitted to timber soffits. These soffits fit flush to the walls of the garage and there are no gaps that bats might use to access the roof structure. Internally, the garage is open to reveal the timber roof and it is lit via windows on the northern wall. A search of the interior aspects of the garage did not reveal any evidence of use by bats.

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Table 3. Assessment of Potential Roosting Features (PRFs). Building section Description of features Assessment of suitability (Collins 2016) Roof tiles in Several gaps were identified, though many were smothered with moss, Moderate bat location of which is an indication of a cold roof zone. A bitumen lining was visible roost suitability proposed and the gaps between the roof tiles and this lining would likely form a extension suitable roost feature. Hanging tiles on Suitable tile crevices are present across this dormer, though only a Confirmed roost dormer extension small number of these would be directly impacted. The shaded location means this area of tiles is not likely suitable as a maternity roost location, but could support several solitary roosting bats or a social roost. A solitary roosting common pipistrelle bat was identified at the time of the survey Weatherboarding The dislodged weatherboard provides potential access to a crevice Moderate bat on dormer behind the weatherboarding, though this was the only clear feature in roost suitability extension the zone of construction that would be directly affected. Northwestern The handmade clay hanging tiles feature numerous gaps that could be Low/moderate facing dormer wall accessed by bats, though only evidence of bird roosting was visible at bat roost the time of the assessment suitability Double garage The flat-roofed garage lacked any suitable features for roosting bats, Negligible with the facia around the sides of the roof appearing tight-fitting and an suitability. absence of any evidence of use by bats internally.

Overall, the bat roost suitability of the property in the locations where the new extension and French doors are proposed is considered moderate/high and a solitary roosting common pipistrelle bat was identified at the time of the assessment. The presence of the watercourse and tree-lines approaching the building may increase the potential for roosts to be present and for foraging and commuting bats to use these features.

There were no trees contained within the boundary of the site and tree roosting bats would therefore not be a constraint to development.

3.3.2 Hibernation Potential Each structure/feature was assessed for its hibernation potential. The potential for each structure/feature is described in Table 4 below and illustrated in the following photographs section.

Table 4. Assessment of hibernation roost potential Building section Description of features Assessment of hibernation potential1 & 3 Roof tiles, hanging There were a number of crevices present that could be used by Moderate tiles and weather- hibernating bats, particularly given the more sheltered location where potential boarding features the new extension is proposed. It is not however possible to search such features during the winter months as to do so would result in the significant disturbance or destruction of roosting features. Double garage No potential roost features were identified as described in table 4 Negligible potential

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3.4 Foraging and Commuting Potential

The site is situated in a rural location with close proximity to large arable fields divided by hedgerows and fields of pasture. The South Downs is within 1km and includes large woodland parcels and pasture that is likely to have a high floristic interest and therefore support higher numbers and diversity of invertebrate prey.

3.5 Other Protected and/or Notable Species

There was some evidence of birds roosting behind some hanging tiles and it is possible that small birds such as blue tits may be able to nest behind hanging tiles or the dropped weatherboard on the northern dormer extension. The footprint of the extension proposal and the proposed replacement garage comprises solely of hardstanding and improved mown lawn space, which has a negligible value for reptiles, amphibians, hedgehogs and other species of conservation interest. The proposals will have a very low biodiversity impact over all given the value of the habitats present within the construction zone.

Of significance is the risk of the proposals to impact Costers Brook, which has the potential to support aquatic species of interest such as bullhead Cottus gobio. The banks of this watercourse around the location of the garage are reinforced and not therefore suitable for water vole Arvicola amphibious, whilst the combination of the size of this watercourse and disturbance from the properties that it runs through in this location means the potential for otters to be present is very low.

3.6 Survey Limitations

An initial site assessment such as this is only able to act like a ‘snapshot’ to record any flora or fauna that is present at the time of the survey. It is therefore possible that some species may not have been present during the survey, but may be evident at other times of the year. Bats will commonly roost in small inaccessible crevices, such as spaces underneath ridge tiles that are impossible to inspect during a scoping assessment. For this reason, habitats and features are assessed for their potential to support bats, even where no direct evidence (such as droppings) has been identified.

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3.7 Photographs

Photograph 1. The front elevation of bungalow and courtyard area. The former stable building and garage are to the left of the image.

Photograph 2. The western elevation of the stable. Note skylight visible in western loft space and gable end in distance and dense vegetation covering walls.

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Photograph 3. The eastern elevation of the former stables and garage annex to bungalow. Note peg tile roof covering in good general condition with few dislodged or missing tiles.

Photograph 4. A common pipistrelle bat visible behind a hanging tiles on a dormer extension.

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Photograph 5. The weatherboarding cladding the northern of the dormer extensions, with a weatherboard visible that has dropped.

Photographs 6 & 7. The hanging tiles on the northeast facing gable wall that will be disturbed to insert a set of French doors. There are numerous gaps present between tiles.

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Photograph 8. The existing double garage, which is situated directly adjacent to a watercourse called Costers Brook.

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4 ECOLOGICAL CONSTRAINTS AND OPPORTUNITIES

4.1 Designated Sites

The scale of the proposals are very small and potential, impacts from such proposals such as noise, localised air pollution, dust and ground contamination risk do not tend to extend more than 50 metres to a significant level. As the closest designated site (Cocking railway tunnel) lies approximately 840 metres away, there are no perceived impact mechanisms that might affect the integrity of this site.

4.2 Bats

4.2.1 Roost Potential In accordance with the Bat Conservation Trust guidelines, the overall suitability of the Mill House property to support bats is rated as ‘’medium/high’ in the location of the proposed extension and new French doors, whilst the garage to be demolished has a negligible suitability for bats. In accordance with the Bat Conservation Trust guidelines, the Mill House property has been confirmed as a bat roost, with the overall potential for the buildings to support further roosting bats rated as high. The works to build the new extension on the northwestern face of the property will cause the destruction of at least a solitary common pipistrelle bat roost, with a possibility of affecting further bat roosts, not yet identified.

Therefore, in accordance with the guidelines three bat emergence/re-entry survey are required to determine the importance of this building to bats as without further surveys the level of impact upon bats cannot be fully assessed. The northeast facing gable wall will only require two bat emergence surveys based on the moderate suitability this part of the property supports. To ensure adequate coverage of all potential roost features, it is estimated that two observers and one infra-red camera set ups will be required for each survey visit.

These surveys can be undertaken between May and mid-September (although September is considered to be a sub-optimal survey month and surveys cannot be undertaken in September for low potential buildings). These surveys will be completed at dusk or at dawn, during suitable weather conditions for bat activity to observe any bats emerging or re-entering roosts. Surveyors will use ultrasonic recording equipment to try and establish the species of bat present. If bats are discovered, further surveys to classify the nature of the roost (day/maternity/social) may be required.

The identification of a bat roost also means that careful timing of the development will be required in order to avoid impacts on bats, with a precautionary ‘soft strip’ of tiles supervised by a licensed and suitably qualified bat ecologist and provision of permanent bat roosting features into the development will also be required, the nature of which will be dependent on the outcome of the surveys.

An EPS licence will be required for any actions that would directly disturb, modify or destroy a bat roost and detailed mitigation measures appropriate for this development will be specified within the license, subject to the findings of the surveys and a subsequent roost characterisation.

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4.2.2 Hibernation Potential The dwelling is assessed as having moderate hibernation potential for bats with the potential to support small numbers of bats. Further surveys are not possible at the property due to the inability to search for signs of bats without either disturbing or destroying roost features. For this reason, it is best practice to ensure that any work that would result in the disturbance or destruction of the potential roost features identified must avoid the hibernation period, which broadly runs from the 1st November to the 1st of March.

4.2.3 Foraging and Commuting Suitability As the site and zone of influence may be used by foraging and commuting bats, it is important that the potential for disturbance from artificial lights is considered. The proposed development should include an ‘ecologically sensitive lighting scheme’ in accordance with guidance produced by the Bat Conservation Trust (summarised in Appendix 2).

4.3 Other Protected and/or Notable Species

Potential bird nesting features are present on the property, where some large crevices behind hanging tiles and weatherboarding could be utilised by smaller nesting birds such as blue tits. Any work should therefore be mindful of the bird nesting season (1st March to 31st August) and work should either avoid the nesting season, or proceed only after a hand search for bird nests has confirmed their absence. If an active nest is identified, the nest location must remain undisturbed until all chicks have fledged.

Costers Brook, which is situated immediately on the east side of the garage to be demolished has a high biodiversity value and is a chalk-fed stream that is likely to support an interesting assemblage of aquatic fauna. The proposals will not directly impact this watercourse, though there are clearly risks that the demolition process will have to proceed extremely sensitively to ensure that debris and other contaminants do not enter the waterbody. The proposed replacement garage and ancillary accommodation will be situated slightly further from the watercourse than the existing garage, which may represent a long-term benefit, however similarly, the construction process will need strict construction measures in place to ensure there are no adverse impacts to the watercourse.

Considering the potential impact risks to the watercourse, it is considered essential that the demolition of the existing garage and construction of the replacement building proceeds strictly according to a Construction Environment Management Plan (CEMP), which should be produced as a condition of planning permission. The CEMP must include the following commitments:

1. A demolition plan that details the machinery that will be used and how debris, dust and other contaminants will be prevented from entering the watercourse. 2. Safe fuel and material storage practices and a strict policy for re-fuelling on solid impermeable surfaces more than 10m from the watercourse. 3. Heras fencing to act as a barrier along the watercourse and prevent materials etc from being placed near to it. 4. Dust suppression measures and measures to eliminate ground contamination risk.

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4.4 Biodiversity Enhancement Opportunities

The proposed development represents an opportunity for habitat enhancement to benefit insects, birds, and bats. Any planting scheme should include native shrub species and flowering species known to encourage insect diversity. Such enhancement measures are in line with the recommendations of the NPPF and as such would be considered favourably when determining the planning application.

For example, it is recommended that two native trees are planted as part of the landscaping, which will create greater habitat for a variety of birds and invertebrates. Only specimens sourced only from UK stock should be planted. The following species are recommended in this location: wild cherry Prunus avium, wayfaring tree Viburnum lantana, hawthorn Crataegus monogyna, or damson Prunus domestica. Given the arrival of ash dieback, it is not recommended that any ash saplings are planted anywhere on the site.

The developer is also encouraged to consider including integral bat roosting opportunities into the fabric of the proposed extension and replacement garage, such as bat tiles and internal voids/access points for bats. For example, three Schwegler 2FR bat tubes could be built into the south, west and east facing elevations and 3no. purpose designed bat tiles onto the south-facing pitched roof. Specific details should be made within the subsequent bat survey report once the species of bats active in the area and roosting at the property are known, so they can be best tailored to suit the locality.

If any bats or other protected species are found during the development, work should be stopped immediately, and an ecologist must be contacted for advice.

Should you need any further advice on the information provided above, please do not hesitate to contact The Ecology Co-op.

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APPENDIX 1 – Wildlife Legislation and National Planning Policy

The following text is intended for general guidance only and does not constitute comprehensive professional legal advice. It provides a summary of the current legal protection afforded to bats.

All bat species in the UK are included in Schedule II of the Habitats Regulations 2017, which transpose Annex II of the Council Directive 92/43/EEC 1992 on the Conservation of Natural Habitats and of Wild Fauna and Flora (“The EC Habitats Directive”). As such all bat species in the UK are defined as ‘European Protected Species (EPS).

Four species of bat (Bechstein’s bat Myotis bechsteinii, Barbastelle bat Barbastella barbastellus, greater and lesser horseshoe bats, Rhinolophus ferrumequinum and R. hipposideros) are also listed on Annex IV of the EC Habitats Directive. This requires the designation of a series of sites which contain important populations of these species as Special Areas of Conservation (SACs).

All species of British bat are also fully protected under the Wildlife and Countryside Act (1981), as amended, through inclusion in Schedule V.

All species of bat are listed on Section 41 of the Natural Environment and Rural Communities (NERC) Act (2006). Section 41 of the NERC Act lists the habitats and species of principle importance. This places a statutory duty on all public bodies, including planning authorities, under Section 40, to take, or promote the taking by others, steps to further the conservation of habitats and species of principal importance for the conservation of biodiversity in England (commonly referred to as the ‘Biodiversity Duty’). This duty extends to all public bodies the biodiversity duty of Section 74 of the Countryside and Rights of Way (CROW) Act 2000, which placed a duty only on Government and Ministers.

Under the above legislation it is an offence to: • kill, injure or take any individual bat of any species; • possess any part of an individual bat, either alive or dead; • intentionally or recklessly damage, destroy or obstruct access to any place or structure used by bats for shelter, rest, protection, or breeding; • intentionally or recklessly disturb these species whilst using any place of shelter or protection; or • deliberately disturb bats in such a way as to be likely to impair their ability to: - survive, to breed or reproduce, to rear or nurture their young; to hibernate or migrate; or to affect significantly the local distribution or abundance of the species to which they belong; • keep (possess), transport, sell or exchange, or offer for sale or exchange, any live or dead bat, or any part of, or anything derived from a bat.

It is also an offence to set and use articles capable of catching, injuring, or killing bats (for example a trap or poison), or knowingly cause or permit such an action. There is also protection under Schedule 6 of The Wildlife and Countryside Act 1981 (as amended) relating specifically to trapping and direct pursuit of bats.

A European Protected Species Licence (EPSL) in relation to bats is required from Natural England for

23 Mill House – BAT SCOPING REPORT AND PEA any work that would result in an otherwise unlawful activity (e.g. damage to a bat roost). A license can only be issued to permit otherwise prohibited acts if Natural England are satisfied that all the following three tests are met: • The proposal is for ‘preserving public health or public safety, or other imperative reasons of overriding public interest including those of a social or economic nature and beneficial consequences of primary importance for the environment’; • There is no satisfactory alternative; and • The action authorised by the license will not be detrimental to the maintenance of bat populations at a favourable conservation status in their natural range.

A bat roost is defined by the Bat Conservation Trust’s Bat Surveys—Good Practice Guidelines 3rd Edition as “the resting place of a bat”. In general, the word roost is interpreted as “any structure or place, which any wild bat uses for shelter or protection.”

Bats tend to re-use the same roosts; therefore, legal opinion is guided by recent case law precedents, that a roost is protected, whether or not the bats are present at the time. This includes summer roosts used for resting during the day and/or breeding; or winter roosts, used for hibernating.

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APPENDIX 2 – Reducing Impacts of Artificial Light

Bright external lighting can have a detrimental impact upon foraging and commuting bat flight paths, but more importantly can also cause bats to remain in their roosts for longer. Artificial lighting can also cause significant impacts on other nocturnal species, most notably moths and other nocturnal insects. It can also result in disruption of the circadian rhythms of birds, reducing their fitness. Guidelines issued by the Bat Conservation Trust6 should be considered while designing the lighting scheme. A simple process which should be followed where the impact on bats is being considered as part of a proposed lighting scheme. It contains techniques which can be used on all sites, whether a small domestic project or larger mixed- use, commercial or infrastructure development. This includes the following measures:

Avoid lighting on key habitats and features altogether there is no legal duty requiring any place to be lit. British Standards and other policy documents allow for deviation from their own guidance where there are significant ecological/environmental reasons for doing so. It is acknowledged that in certain situations lighting is critical in maintaining safety, such as some industrial sites with 24-hour operation. However, in the public realm, while lighting can increase the perception of safety and security, measurable benefits can be subjective. Consequently, lighting design should be flexible and be able to fully consider the presence of protected species

Apply mitigation methods to reduce lighting to agreed limits in other sensitive locations – lighting design considerations Where bat habitats and features are considered to be of lower importance or sensitivity to illumination, the need to provide lighting may outweigh the needs of bats. Consequently, a balance between a reduced lighting level appropriate to the ecological importance of each feature and species, and the lighting objectives for that area will need to be achieved. The following are techniques which have been successfully used on projects and are often used in combination for best results: • Dark buffers, illuminance limits and zonation • Sensitive site configuration, whereby the location, orientation and height of newly built structures and hard standing can have a considerable impact on light spill • Consider the design of the light and fittings, whereby the spread of light is minimised ensuring that only the task area is lit. Flat cut-off lanterns or accessories should be used to shield or direct light to where it is required. Consider the height of lighting columns. It should be noted that a lower mounting height is not always better. A lower mounting height can create more light-spill or require more columns. Column height should be carefully considered to balance task and mitigation measures. Consider no lighting solutions where possible such as white lining, good signage, and LED cats eyes. For example, light only high-risk stretches of roads, such as crossings and junctions, allowing headlights to provide any necessary illumination at other times. • Screening, whereby light spill can be successfully screened through soft landscaping and the installation of walls, fences and bunding • Glazing treatments, whereby glazing should be restricted or redesigned wherever the ecologist and lighting professional determine there is a likely significant effect upon key bat habitat and features. • Creation of alternative valuable bat habitat on site, whereby additional or alternative bat flightpaths, commuting habitat or foraging habitat could result in appropriate compensation for any such habitat being lost to the development. • Dimming and part-night lighting. Depending on the pattern of bat activity across the key features

6 Bat Conservation Trust and Institute for Lighting Professionals (2018) Guidance note 8. Bats and Artificial Lighting. https://www.theilp.org.uk/documents/guidance-note-8-bats-and-artificial-lighting/

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identified on site it may be appropriate for an element of on-site lighting to be controlled either diurnally, seasonally or according to human activity. A control management system can be used to dim (typically to 25% or less) or turn off groups of lights when not in use.

Demonstrate compliance with illuminance limits and buffers • Design and pre-planning phase; It may be necessary to demonstrate that the proposed lighting will comply with any agreed light-limitation or screening measures set as a result of your ecologist’s recommendations and evaluation. This is especially likely to be requested if planning permission is required. • Baseline and post-completion light monitoring surveys; baseline, pre-development lighting surveys may be useful where existing on or off-site lighting is suspected to be acting on key habitats and features and so may prevent the agreed or modelled illuminance limits being achieved. • Post-construction/operational phase compliance-checking; as a condition of planning, post- completion lighting surveys by a suitably qualified person should be undertaken and a report produced for the local planning authority to confirm compliance. Any form of non-compliance must be clearly reported, and remedial measures outlined. Ongoing monitoring may be necessary, especially for systems with automated lighting/dimming or physical screening solutions.