Appropriate Assessment for Bats – Land south of Westwells Road, Westwells, Neston, Corsham, Wiltshire
Cotswold Wildlife Surveys
March 2019
Planning Reference No. 18/09884/OUT
Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
CONTENTS
Page No. SUMMARY ...... 2 1. INTRODUCTION ...... 3 1.1 Background ...... 3 1.2 Site Description ...... 5 1.2.1 Bat roosting ...... 5 1.2.2 Bat commuting/foraging habitat ...... 6 1.3 Project Proposal ...... 6 2. CITATION FEATURES AND CONSERVATION OBJECTIVES ...... 7 2.1 Bath and Bradford-on-Avon SAC ...... 7 3. RELEVANT PLANS OR PROJECTS ...... 10 3.1 Local ...... 10 3.2 Wider area ...... 10 4. POTENTIAL IMPACTS ...... 11 4.1 Physical changes ...... 11 4.2 Lighting ...... 13 4.3 Noise and vibration ...... 14 4.4 Recreational disturbance ...... 14 4.5 Increased air pollution ...... 16 4.6 Mortality ...... 16 5. ECOLOGICAL ENHANCEMENTS ...... 18 6. CONCLUSIONS AND RECOMMENDATIONS ...... 19 7. REFERENCES ...... 20
Cotswold Wildlife Surveys Ltd (CWS) has prepared this report in accordance with the instructions of Richard Brown Planning, on behalf of Summix SRD Developments Ltd (“the Client”), by email dated 20th March 2019 and under the terms of appointment for CWS. This report is confidential and non- assignable by the Client and CWS shall not be responsible for any use of the report or its contents for any purpose other than that for which it was prepared and provided. Should the Client require to pass copies of the report to other parties for information, the whole of the report should be so copied, but no professional liability or warranty shall be extended to other parties by CWS in this connection without the explicit written agreement thereto by CWS. The report may be assigned by the Client by way of absolute legal assignment to a purchaser of all or part of the site to which the report refers (“The Site”) without the consent of CWS being required and such assignment shall be effective upon written notice thereof being given to CWS. No further assignment shall be permitted. In the event of the Client entering into a legal joint venture to develop The Site, the report can be regarded as having been issued by CWS jointly in favour of the Client and the joint venture partner, and in respect of the report CWS would owe the joint venture partner the same duty of care that we owed to the Client when we were instructed to prepare the report subject to all the matters contained or referred to in the report.
______Cotswold Wildlife Surveys 1 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
SUMMARY
On land south of Westwells Road in Westwells, Neston near Corsham in Wiltshire, planning permission is being sought from Wiltshire Council for a residential development of up to 95 dwellings, including roads, footpaths, balancing areas and open space (Planning Reference No. 18/09884/OUT).
A consultation response was received from the Abbey Sanders, the County Ecologist, that due to the proximity of the Bath and Bradford-on-Avon (Bats) Special Area of Conservation (SAC), and in light of the judgement in Case C 323/17 CJEU ‘People over Wind’ (12th April 2018), a pre-determinative Appropriate Assessment would be required to determine whether the scheme will lead to an adverse effect on the integrity of the SAC, either alone or in-combination with other schemes.
Such an assessment is required by Regulation 6(3) of the Habitats Regulations 2017.
The primary reasons for the designation of the SAC are the hibernation sites associated with 15% of the UK’s population of Greater Horseshoe Bats Rhinolophus ferrumequinum and small numbers of hibernating Bechstein’s Bat Myotis bechsteinii. Lesser Horseshoe Bats R. hipposideros are also stated as being present but are not a primary reason for site selection.
Box Mine Site of Special Scientific Interest (SSSI) is also part of the Bath and Bradford on Avon Bats SAC. Box Mine is an extensive network of man-made tunnels, most important for bats during the hibernation period, but used throughout the year. The site seasonally holds up to 10% of the total British population of Greater Horseshoe Bats. The SSSI site boundary includes all the known subterranean workings believed to be significant for bats.
The land south of Westwells Road also lies on a known flightpath of Greater and Lesser Horseshoe Bats, with a roost of the latter species close to the development area.
This report provides details of the assessment.
______Cotswold Wildlife Surveys 2 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
1. INTRODUCTION
1.1 Background
The Conservation of Habitats and Species Regulations 2017, SI 2017/1012 (the “Habitats Regulations 2017”) consolidate and update the Conservation of Habitats and Species Regulations 2010 (the “Habitats Regulations 2010”). The Habitats Regulations 2017 consolidate all the various amendments made to the Habitats Regulations 2010 and also introduce a small number of minor amendments designed to take account of changes to other related legislation, such as amendments to Town and Country Planning legislation, rectify previous omissions, or improve the clarity of drafting.
The Habitats Regulations 2010 were the principal means by which Council Directive 92/43/EEC on the conservation of natural habitats of wild fauna and flora (the “Habitats Directive”) is transposed in England and Wales and the adjacent territorial seas. They also transposed elements of the EU Wild Birds Directive in England and Wales. The objective of the Habitats Directive is to protect biodiversity through the conservation of natural habitats and species of wild fauna and flora. The Directive lays down rules for the protection, management and exploitation of such habitats and species.
These are known as the network of Natura 2000 Sites or "European Sites". The UK Government Guidance on HRA from the Department of Communities and Local Government (DCLG), August 2006 states that areas designated as globally important wetlands under the Ramsar Convention (1971) should also be given the same level of protection as SAC and SPA designations.
The UK is bound by the terms of the EC Habitats Directive (and EC Birds Directive and the Ramsar Convention).
The aim of the Habitats Directive is to conserve natural habitats and wild species across Europe by establishing a network of sites known as Natura 2000 sites (for the purpose of this report, and as defined under the 2017 Habitats Regulations, these are referred to as European site(s)).
Under Article 6(3) of the Habitats Directive, an Appropriate Assessment is required where a plan or project is likely to have a significant effect upon a European site, either individually or in combination with other projects.
“Any plan or project not directly connected with or necessary to the management of the site but likely to have a significant effect thereon, either individually or in combination with other plans or projects, shall be subject to Appropriate Assessment of its implications for the site in view of the site’s conservation objectives” Article 6(3).
This Article has been interpreted as meaning that any project is to be subject to an Appropriate Assessment if it cannot be proven, beyond reasonable scientific doubt, that there is no significant effect on that site (a precautionary approach), either alone or in combination with other plans or projects. ______Cotswold Wildlife Surveys 3 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
Further to this, Article 6(4) states that where an Appropriate Assessment has been carried out and results in a negative assessment, (in other words, any proposed avoidance or mitigation measures anticipated are unable to reduce the potential impact so it is no longer significant), or if uncertainty remains over the significant effect, consent will only be granted if there are no alternative solutions, and there are imperative reasons of over-riding public interest (IROPI), for the development and compensatory measures have been secured.
If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted Article 6(4).
A Habitats Regulations Assessment (HRA) is a recognised step by step process which helps determine likely significant effect and (where appropriate) assess adverse impacts on the integrity of a European site. The HRA also examines alternative solutions, and provides justification for IROPI.
European guidance describes a four stage process to HRA which is summarised in Table 1 below.
Stage 1 Screening The process to identify the likely impacts of a project upon a European site, either alone or in combination with other plans and projects, and consider whether the impacts are likely to be significant.
Stage 2 Appropriate The consideration of the impacts on the integrity of the assessment European site, either alone or in combination with other plans and projects, with regard to the site’s structure and
function and its conservation objectives. Where there are adverse impacts, an assessment of mitigation options is carried out to determine adverse effect on the integrity of the site. If these mitigation options cannot avoid adverse effects then development consent can only be given if stages 3 and 4 are followed.
Stage 3 Assessment of Examining alternative ways of achieving the objectives alternative solutions of the project to establish whether there are solutions that would avoid or have a lesser effect on European
sites.
Stage 4 IROPI This is the assessment where no alternative solution exists and where adverse impacts remain. The process to assess whether the development is necessary for IROPI and, if so, the potential compensatory measures needed to maintain the overall coherence of the site or integrity of the European site network.
Table 1: Four stage process to the HRA
______Cotswold Wildlife Surveys 4 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
The Local Authority Ecologist has concluded that due to the proximity of the application site to the Bath and Bradford-on-Avon (Bats) Special Area of Conservation (SAC), including Box Mine Site of Special Scientific Interest (SSSI), as well as the known flightpath of Greater and Lesser Horseshoe Bats, with a roost of the latter species close to the development area, and in light of the judgement in Case C 323/17 CJEU ‘People over Wind’ (12th April 2018), a pre-determinative Appropriate Assessment would be required to determine whether the scheme will lead to an adverse effect on the integrity of the SAC, either alone or in-combination with other schemes.
1.2 Site Description
The land south of Westwells Road is brownfield and had previously formed part of MOD Corsham.
Scattered across it are a number of concrete pads associated with the foundations of former buildings, whilst a metalled track also runs through the centre of the land, this a public footpath. Other footpaths run across the centre of the site and along the southern boundary, the latter outside the site curtilage.
The southwestern corner of the site is dominated by broadleaved woodland, which extends in a strip along the northern boundary, with mature trees and species poor hedgerows running virtually all the way around.
At the time of the initial walkover in November 2017 the land was largely clear of vegetation, but during 2018 it became increasingly overgrown with tall ruderal vegetation and dense Bramble Rubus fruticosus scrub. Only small areas of poor, semi-improved grassland were present at the northeastern end of the site.
Within the woodland in the southwestern corner there is an entrance to an old stone mine lying under the adjacent operational MOD site. Known as the Slope Shaft, this is permanently fenced off and the mine system is inaccessible to people.
The site is poor in floristic diversity, with no rare vascular plants recorded, and all species are common and widespread. There are no invasive or notifiable species.
1.2.1 Bat roosting
Surveys in 2008/09 revealed high levels of Common Pipistrelle Pipistrellus pipistrellus foraging throughout the site, as well as Brown Long-eared Plecotus auritus, Serotine Eptesicus serotinus, Noctule Nyctalus noctula, Leisler’s N. leisleri and Soprano Pipistrelle P. pygmaeus.
Lesser Horseshoe bats were roosting inside the Slope Shaft on the site all year round, including hibernation, with a peak of 14 bats recorded in March 2009. They were generally recorded foraging around the woodland, with only low levels of foraging along the hedgerows.
A single Greater Horseshoe Bat was suspected to be roosting inside the Slope Shaft on an occasional basis, as it was recorded emerging but not seen during the internal inspections. ______Cotswold Wildlife Surveys 5 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
Myotis bats were thought to use the Slope Shaft as a swarming site, and although numbers could not be confirmed, they were considered to be low.
No bats were confirmed as roosting within any of the trees in 2018, although a peak count of up to 10 Lesser Horseshoe Bats were seen to emerge from the Slope Shaft on 2nd July 2018, with a single Greater Horseshoe Bat recorded on two occasions along the southern boundary of the site.
1.2.2 Bat commuting/foraging habitat
Bat activity was almost exclusively restricted to the woodland around the Slope Shaft, along Rowan Lane, and along the footpath outside the southern boundary. Very little activity was recorded along the northern boundary, with no bats observed or detected in the open area of the site.
In addition to the two horseshoe species, other bats recorded in 2018 included Common Pipistrelle, Soprano Pipistrelle, Daubenton’s Myotis daubentonii, Whiskered/Brandt’s M. mystacinus/M. brandtii, Serotine, Leisler’s, Noctule, Brown Long-eared, and Barbastelle Barbastella barbastellus. These were also noted around the site boundaries, with limited activity along the woodland edge inside the site curtilage.
Full details of the 2018 survey results are given in the Habitat and Protected Species Surveys report (Report No. 3032-CWS-01, version 02, dated 23rd October 2018).
1.3 Project Proposal
The site is proposed for a residential development of up to 95 dwellings including roads, footpaths, balancing areas and open space (Fig. 1).
Fig. 1 Illustrative Masterplan ______Cotswold Wildlife Surveys 6 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
2. CITATION FEATURES AND CONSERVATION OBJECTIVES
2.1 Bath and Bradford-on-Avon SAC
The internationally important designation of Bath and Bradford-on-Avon Bats SAC is comprised of a network of significant underground sites, including four nationally important Sites of Special Scientific Interest (SSSIs), namely Box Mine, Winsley Mines, Combe Down and Bathampton Down Mines, and Brown’s Folly.
These component sites comprise extensive networks of caves, mines and man-made tunnels which are used by bats for hibernation, breeding, mating and as a staging post prior to dispersal.
The grassland, watercourses, scrub and woodland surrounding them are used by bats for feeding and commuting. Although these habitats are not included in the SAC designation, they are vital to support the bats which are features of the SAC.
Bat species using these sites include the rare Bechstein’s Bat, Greater Horseshoe Bat and Lesser Horseshoe Bat.
All three are Annex II species and are highly mobile throughout the year, using a network of other important roost sites in the surrounding landscape including Iford Manor SSSI, which is the fourth largest breeding colony of Greater Horseshoe Bats in England and one of only 15 breeding roosts in the country.
Bats which use the above hibernation sites are known to breed at Iford Manor each year.
The network of significant roosts includes sites that are not covered by any statutory designation, such as the breeding colonies of Bechstein’s Bats at Biss Wood and Green Lane Wood, a pair of ancient woodlands to the east of Trowbridge. This colony is known to hibernate at Box Mine SSSI and uses the intervening landscape to commute between these sites.
Figure 2 overleaf shows the SAC areas, key County Wildlife Sites (including the two woodlands listed above), and a series of buffers for the key species.
It can be seen that the application site lies within the buffer zones of all three key species of the SAC.
______Cotswold Wildlife Surveys 7 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
Fig. 2 Bath & Bradford-on-Avon SAC in relation to application site
______Cotswold Wildlife Surveys 8 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
Conservation objectives
The conservation objectives are to ensure that the integrity of the SAC is maintained or restored as appropriate, and to ensure that the site contributes to achieving the Favourable Conservation Status of its Qualifying Features, by maintaining or restoring;
❑ The extent and distribution of the habitats of qualifying species; ❑ The structure and function of the habitats of qualifying species; ❑ The supporting processes on which the habitats of qualifying species rely; ❑ The populations of qualifying species, and, ❑ The distribution of qualifying species within the site.
Qualifying species:
S1303. Rhinolophus hipposideros; Lesser Horseshoe Bat S1304. Rhinolophus ferrumequinum; Greater Horseshoe Bat S1323. Myotis bechsteinii; Bechstein’s Bat
______Cotswold Wildlife Surveys 9 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
3. RELEVANT PLANS OR PROJECTS
3.1 Local
❑ N/04/02548/FUL Land at former Royal Arthur Park Corsham; ❑ 17/08760/FUL Land at Spring Park, Westwells Road, Corsham; ❑ N/11/01613/OUT Sands Quarry Site, Westwells Road; ❑ N/04410/445FUL 31 Moor Green, Neston; ❑ N/12/012106/FUL Former Bath & Portland Stoneworks, Westwells; ❑ 07/01614/FUL Basil Hill Barracks; ❑ 14/11354/OUT, Westwells Road, Rudloe; ❑ 14/11354/OUT Rudloe 2 Former MOD site.
3.2 Wider area
❑ W/13/00643/FUL – Land south and west of Kingston Farm Buildings, Holt Road, Bradford on Avon; ❑ 13/05188/OUT - Land North of Bath Road, Corsham; ❑ 14/04179/OUT Land at Bradford Road, Corsham; ❑ 15/00712/WCM Bradford Road, Corsham; ❑ N/11/02034/S73 Spring Park, Corsham; ❑ Wiltshire Core Strategy; ❑ Wiltshire Housing Site Allocations Plan (Submission draft) (WHSAP); ❑ Bath and North East Somerset Core Strategy; ❑ Great Western Mainline Electrification.
Mitigation for Annex II bat species associated with the SAC/key wildlife sites has been provided for the relevant local development schemes, and includes the breeding sites for Lesser Horseshoe Bats not covered by the SAC.
The current scheme south of Westwells Road could have a detrimental impact to the mitigation at these other sites if commuting routes along the site boundaries, or levels of disturbance at the Slope Shaft, affects bat movement through this area.
______Cotswold Wildlife Surveys 10 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
4. POTENTIAL IMPACTS
Referring to Wiltshire Council’s Planning Guidance on Bat Special Areas of Conservation (2015), the potential impacts (including cumulative where relevant) of the proposed development of the land south of Westwells Road have been considered in relation to the SAC and key wildlife sites. These include:
❑ Physical changes – alteration/demolition/removal of a potential roost feature including environmental conditions (temperature, humidity, internals light levels etc), loss, damage or change of management of potential foraging habitat, removal/fragmentation/modification of habitats in a potential commuting corridor; ❑ Lighting – artificial lighting close to potential roosting, foraging and commuting features; ❑ Noise and vibration – construction/demolition activities close to potential roost features; ❑ Recreational disturbance – increasing the risk of recreational visits both organised and informal, and assessing the cumulative impacts of other housing schemes; ❑ Pollution – dust and fumes close to potential roost features; and, ❑ Mortality – predation by domestic cats at roost entrances, collision risk from wind turbines, traffic, etc.
4.1 Physical changes
As well as the two horseshoe species (Greater and Lesser) and Bechstein’s Bats, there are extensive bat records for the area, with other bat species including Serotine, Barbastelle, Natterer’s Myotis nattereri, Daubenton’s, Whiskered, Leisler’s, Noctule, Soprano Pipistrelle, Common Pipistrelle and Brown Long-eared.
Surveys of land adjacent to the application site, on the other side of Rowan Lane, were carried out between 2007 and 2015. These included hibernation surveys, building inspections, habitat and tree assessments, emergence surveys and activity surveys.
These revealed summer non-breeding roosts for two Myotis species, a single Lesser Horseshoe and a single Brown Long-eared, as well as a hibernation roost for a single Whiskered Bat.
In 2010 an artificial bat cave was constructed on the Rowan Lane site, and a Greater Horseshoe relocated from a shaft into the cave. Greater Horseshoes and Lesser Horseshoes were recorded roosting inside the cave in 2014. Other species were noted inside the cave during the night, but were only thought to be foraging.
In June 2016 at least 10 and possibly up to 14 species of bats were recorded on the Rowan Lane site, including three Annex II species; Greater Horseshoe, Lesser Horseshoe and Barbastelle, as well as possible Bechstein’s.
______Cotswold Wildlife Surveys 11 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
Surveys in 2008/09 of the land off Westwells Road itself, i.e. the application site, revealed high levels of Common Pipistrelle foraging throughout the site, as well as Brown Long-eared, Serotine, Noctule, Leisler’s and Soprano Pipistrelle.
Lesser Horseshoe bats were roosting inside the Slope Shaft on the site all year round, including hibernation, with a peak of 14 bats recorded in March. They were generally recorded foraging around the woodland, with only low levels of foraging along the hedgerows.
A single Greater Horseshoe Bat was suspected to be roosting inside the Slope Shaft on an occasional basis, as it was recorded emerging and not seen during the internal inspections.
Myotis bats were thought to use the Slope Shaft as a swarming site, and although numbers could not be confirmed, they were considered to be low.
To confirm the species and numbers of bats that might be using the Westwells Road site currently, a series of surveys were carried out as follows:
th st th nd th ❑ Nocturnal bat activity surveys – 10 and 21 May, 20 June, 2 and 16 July, 2nd, 13th and 28th August, 11th and 19th September 2018; st th th th ❑ Emergence surveys of the Slope Shaft – 21 May, 20 June, 16 July, 11 September and 19th September 2018.
During the 10 bat activity and five Slope Shaft emergence surveys, no bats were confirmed as roosting within any of the trees, although a peak count of up to 10 Lesser Horseshoe Bats were seen to emerge from the Slope Shaft on 2nd July 2018. In addition to this, a Greater Horseshoe Bat was detected along the southern hedgerow on two occasions.
Bat activity was almost exclusively restricted to the woodland around the Slope Shaft, along Rowan Lane, and along the footpath outside the southern boundary. Very little activity was recorded along the northern boundary, with no bats observed or detected in the open area of the site.
In addition to the two horseshoe species, other bats recorded in 2018 included Common Pipistrelle, Soprano Pipistrelle, Daubenton’s, Whiskered/Brandt’s Myotis brandtii, Serotine, Leisler’s, Noctule, Brown Long-eared, and Barbastelle. These were also noted around the site boundaries, with limited activity along the woodland edge inside the site curtilage.
Despite these records, there is no direct or indirect connectivity between the SAC/key wildlife sites and application site, and they are separated by intervening land use, which includes a large MOD establishment, industrial and residential areas, main and local roads, woodland and arable farmland under continuous, intensive cultivation.
The proposed development does not include any infrastructure which will cause physical damage to the SAC, and there will be no woodland or hedgerow removal, although two or three poor quality trees with no bat roost potential will be removed at the site entrance off Rowan Lane.
______Cotswold Wildlife Surveys 12 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
The proposed development will therefore not impact upon any potential Bechstein’s Bat tree roosts.
Although not part of the SAC, the Slope Shaft lies at the southern end of a mine system, and no tunnels extend underneath the application site. Instead, the sections of mine supporting roosting and hibernating bats extend north and west away from the development site. As such, any bats roosting or hibernating within the mine system are considered highly unlikely to be affected by construction works such as piling.
Taking the above into account, there will be no direct or significant effect upon the integrity of the SAC/key wildlife sites arising from the proposed residential development off Westwells Road.
4.2 Lighting
The distance between the application site and SAC/key wildlife sites means that artificial lighting arising from the residential development will have no direct effect on the SAC/key wildlife sites, especially as there is a brightly illuminated MOD base and existing housing and industrial areas in between the Westwells Road site and the SAC/key wildlife sites.
However, there is potential for lighting to impact on bats using the strategic flyway and other commuting and foraging routes around the area, although it should be noted that there are street lamps along Westwells Road which runs along part of the northern boundary, whilst the fence line along Rowan Lane is illuminated at night, with lights attached to the lower rail for its entire length. This affects the woodland containing the Slope Shaft.
It can be confirmed that there will be no illumination over and above that already present along the section of Rowan Lane where it passes through the woodland areas to the west of the site.
There will be new lighting in the proposed residential area, but given the presence of three Annex II bat species, the lighting strategy will be sympathetic to bats.
It is not possible to produce lux plans for the residential scheme at this stage, as the application is only in Outline form and the masterplan is just an illustrative layout and will evolve.
Instead, it can be stated that in order to comply with paragraph 125 of the National Planning Policy Framework and the Corsham Neighbourhood Plan Batscape Strategy, the development will aim to limit the impact of light pollution on bats by maintaining dark routes for commuting and foraging where possible.
Full details of layout and lighting will thus be submitted at the Reserved Matters stage and will confirm how light spill will be reduced along commuting corridors to ensure that this does not exceed 0.5 lux, in particular along the southern boundary which is the main strategic flyway.
To achieve this, any lighting installed will follow the current guidance provided by the Bat Conservation Trust and the Institute of Lighting Engineers. ______Cotswold Wildlife Surveys 13 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
Latest research from the Netherlands has shown that spectral composition does impact biodiversity. It is therefore recommended to:
❑ Use narrow spectrum light sources to lower the range of species affected by lighting; ❑ Use light sources that emit minimal ultra-violet light; ❑ Lights should peak higher than 550 nm; ❑ Avoid white and blue wavelengths of the light spectrum to reduce insect attraction and where white light sources are required in order to manage the blue short wave length content they should be of a warm/neutral colour temperature <4,200 kelvin.
All of the above recommendations make LED luminaires the only source that meet the majority of the guidance, as emit no UV, can peak high than 550nm and can easily be <4200k in colour temperature.
Where necessary, hoods or cowls will be used on the road lamps, and the latter will be restricted as far as possible to the access road and side lanes, with no lighting along the drives, especially where these run alongside the woodlands and boundary hedgerows, in particular the southern boundary, where light levels will be kept at 0.5 lux or below.
The Batscape Strategy also refers to migration routes and strategic flyways for bats in relation to the Bath & Bradford-on-Avon SAC. Indeed, the Drews Pond Wood Direct Migration Route (illustrated in Phase 2 Batscape Maps – SW Section on page 32) is shown passing over the application site, although the strategic flyway for the area is noted along the southern boundary hedgerow.
The results of the nocturnal activity surveys in 2008/09 and 2018 clearly show bats following the southern boundary, in particular along the southern side of the hedgerow where it forms a tunnel of trees and bushes.
There was virtually no bat activity over the centre of the application site, this unsurprising given that it consists of open ground covered in low Bramble scrub, tall ruderal vegetation, bare ground, an existing road and concrete bases from the former military barracks.
As such, it is considered highly unlikely that the development will affect the Dews Pond Wood Direct Migration Route, as the line of the route also passes right over the MOD base, which is brightly illuminated at night.
4.3 Noise and vibration
As stated above, the distance between the application site and SAC/key wildlife sites means that there will be no impact arising from noise or vibration.
4.4 Recreational disturbance
Significant increases in the numbers of visitors to areas of public open space can have the potential to damage sensitive habitats and disturb wildlife.
______Cotswold Wildlife Surveys 14 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
Furthermore, invasive species could be introduced accidentally which subsequently overrun vulnerable native biological assemblages.
With up to 95 new dwellings, the proposed development could potentially house up to 223 or more residents. Not all householders will be from outside the district, and some may already live in other properties in Corsham or surrounding communities.
However, a number of residents will be new to the area, although what proportion is unknown. Furthermore there is a cumulative effect, with additional population increases associated with other development schemes in the area (Ref. Section 3).
Nevertheless, taking the current application, which is relatively modest when compared to other schemes such as Ashton Park near Trowbridge, it is thought likely that most people will chose to exercise their dogs or participate in informal recreation on the site itself, or on land immediately next to the application site, as this consists of open fields and woodlands accessed by a network of public footpaths.
There will also be public open space on the application land itself where there is currently no formal provision, and as such the scheme represents an increase in the recreational carrying capacity of the area.
It is considered unlikely that new residents will chose to walk to the nearest part of the SAC at Box Hill, as this will entail walking along local and main roads past the MOD base and industrial areas. The key wildlife sites lie over 11.0 km distant, and there would be no reason to walk that far when there are woodlands much closer to Westwells.
It is also doubted that new residents will drive to Green Lane Wood or Biss Wood (the key wildlife sites), or other SAC sites, just for exercise or to walk their dog, as they are not promoted on recreational websites, and there are other facilities in the area offering similar or better opportunities for informal recreation.
These include various recreation grounds around Corsham, Westwells, Leafield and Gastard, and Corsham Court Estate and Park 3.0 km to the northeast.
Away from the designated sites, the Slope Shaft is permanently fenced off with 2.5 m high chainlink fencing topped with barbed wire. There is a gate but this is securely padlocked.
Irrespective of this, the shaft itself cannot be accessed, as it is permanently grilled with palisade fencing bolted to the side walls.
As an extra precaution, checks of the fence integrity are carried out by MOD security personnel from the adjacent military establishment every 2-4 hours, day and night, 365 days a year. This is to ensure that caving enthusiasts have not tried to enter the mine system beneath the army base.
It is unlikely that people will deliberately loiter around the Slope Shaft at night during the bat roosting season, as there is nothing to see due to the high chainlink fence, whilst the entrance cannot be accessed, and there are the regular MOD checks.
______Cotswold Wildlife Surveys 15 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
There is plenty of room for bats to fly around inside the fenced area before moving off, so unless there is a spotlight shone into the shaft for a long period (unlikely given the MOD presence), bats will not be disturbed, even if people do occasionally hang around the woodland outside the fence.
4.5 Increased air pollution
An increase in the volume of traffic, especially where the flow becomes congested, can result in a localised increase in air pollution from vehicle emissions. Exhaust gases include nitrogen dioxide (NO₂) and particulate matter (PM10).
In addition there are similar gases produced by the treatment of waste water, and an increase in population, such as that associated with a new residential area, will inevitably lead to a rise in the amount of waste water requiring treating. However, emissions produced by treatment processes are generally negligible.
Once in the atmosphere, the gases react with rainwater to create a dilute acidic solution. In sufficient concentration, the acid can adversely affect sensitive plants, in particular fragile communities such as those associated with fen, mere and bog.
The proposed development includes the provision of up to 95 houses. As such there is a potential to generate an increase in the volume of polluting gases over and above those already produced in Corsham.
There will not be any new waste water treatment plant on site, and if any additional capacity is required, it will be achieved through the existing sewer network.
Atmospheric gases will therefore largely be restricted to vehicle emissions. However, the strongest effects on plant communities are only observed in the first 50-100 m away from roads, and this is consistent with the nitrogen dioxide pollution profile, which decreases to background levels at a distance of 100-125 m (Bignal et al, 2008). Thus only those habitats within 125 m of a major road are considered to be at risk from increased air pollution at sufficient levels, to alter the composition of vulnerable plant communities.
Given that the application site is largely surrounded by residential housing and the MOD base, it is considered that the potential impacts of increased air pollution from traffic originating at the new residential development will have a negligible effect on the integrity of the Natura 2000 site habitat.
4.6 Mortality
The number of households with pets is also unknown, but irrespective of this, given the distance to the SAC/key wildlife sites, there will be no impact from cats or dogs, even if they wander freely around the neighbourhood.
Indeed, it is unlikely that cats from the new development will be encountered so far from home, and they would have to negotiate some busy roads, the MOD establishment, the industrial and residential areas first. The latter will contain an existing territorial population of cats, so the extra numbers of animals associated with the new development will be negligible.
______Cotswold Wildlife Surveys 16 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
Dogs are usually walked by their owners, and with the adjacent fields being so accessible, it is anticipated that this will be the focus of dog exercising.
As such, there will be little or no impact of pets on the SAC or key wildlife sites.
The chainlink fence around the Slope Shaft provides an effective barrier against domestic pets, so the population of bats using the shaft is fully protected. If a cat did climb up and over the fence (there is no access beneath), it would not be able to snatch bats out of the air as the Slope Shaft is several metres wide and high with nowhere for a cat to sit close enough to the tunnel entrance.
There are no wind turbines associated with the proposed development, so this aspect is not an issue.
Mortality arising from traffic is unlikely to occur, as vehicles will not be travelling at speed, nor will they be using the bat commuting and foraging routes. Those bats which encounter traffic within the proposed residential area will easily be able to take avoiding action.
______Cotswold Wildlife Surveys 17 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
5. ECOLOGICAL ENHANCEMENTS
In addition to the protection of the bat roost in the Slope Shaft, and the commuting and foraging corridors, there will be large areas of public open space and green infrastructure within the curtilage of the site to maintain wildlife connectivity.
The open space areas will comprise new native tree, shrub and wildflower meadow planting, whilst the proposed surface water detention basin will be planted with native emergents such as Common Reed Phragmites australis, Bog Bean Menyanthes trifoliata, Arrowhead Sagittaria sagittifolia, Common Water Crowfoot Ranunculus aquatilis, and Water Speedwell Veronica anagallis-aquatica.
These features will all attract invertebrates and in turn the bats that will prey on them.
The installation of Schwegler 1FD, 1FF, 2F and 2FN bat boxes (3 of each) in the trees in the woodland areas will also provide bat roosting sites where no opportunities currently exist, as the majority of trees are too young and/or smooth barked to support features that could be used by bats.
Although the boxes are unlikely to be used by horseshoe bats, they will be attractive to myotis bats such as Bechstein’s which is one of the key Annex II species in the SAC.
Full details are contained in the Bat Mitigation Strategy (Report no. 3032-CWS-12, version 02, dated 28th March 2019).
______Cotswold Wildlife Surveys 18 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
6. CONCLUSIONS AND RECOMMENDATIONS
This report details the results of an Appropriate Assessment of the potential impacts on the Bath and Bradford-on-Avon Special Area of Conservation, arising from a proposed residential development on land south of Westwells Road in Westwells, Neston, Corsham in Wiltshire.
In addition to the current scheme, there are a number of development projects planned and pending in the local area, most of which lie within the identified buffer areas for the three citation species of the SAC, i.e. Greater and Lesser Horseshoe Bats and Bechstein’s Bats (Ref. Fig. 2).
It is therefore expected that the current proposals on the land south of Westwells Road will contribute to in-combination effects upon the SAC, especially when considered with other developments within the buffer areas, particularly those projects to the west of Corsham where development pressures are clearly focussed.
However, it is considered that these in-combination effects will not affect the integrity of the SAC, given the retention and protection of the commuting routes and strategic flyway which run past the application site, and the protection of the nearby bat roost and hibernation site in the Slope Shaft.
Indeed, any potential impacts will be reduced through habitat enhancement, landscaping and sensitive lighting, whilst new roosting opportunities will be provided though the installation of bat boxes in the woodland areas around the application site.
______Cotswold Wildlife Surveys 19 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
7. REFERENCES
Bignal, K.L., M.R. Ashmore, & A.D. Headley. 2008. Effects of air pollution from road transport on growth and physiology of six transplanted bryophyte species. Environmental Pollution. 156: 332-340.
Corsham Neighbourhood Plan, 2018. Corsham Batscape Strategy 2016-2026. 74 pp. Corsham Town Council.
European Commission (1995): Conservation (Natural Habitats, & c.) Regulations 1994, (or Northern Ireland 1995) (the Habitats Regulations).
European Commission (2001): Assessment of plans and projects significantly affecting Natura 2000 Sites: Methodological Guidance on the Provisions of Article 6(3) and 6(4) of the Habitats Directive.
Office of the Deputy Prime Minister (ODPM) (2005a): Planning Policy Statement 9: Biodiversity and Geological Conservation.
ODPM (2005b): Government Circular: Biodiversity and Geological Conservation – Statutory Obligations and their Impact within the Planning System.
Wiltshire Council (2015): Bat Special Areas of Conservation (SAC) – Planning Guidance for Wiltshire. 26 pp. Issue 3.0.
______Cotswold Wildlife Surveys 20 Land S of Westwells Rd, Neston, Corsham – Bat Appropriate Assessment 3032-CWS-13
Cotswold Wildlife Surveys Limited Company Reg. No. 6864285 (England & Wales)
Andy Warren BSc (Hons), MA (LM), Tech Cert (Arbor A), MCIEEM, TechArborA Withy Way, Charingworth, Chipping Campden, Gloucestershire, GL55 6NU
Tel: 01386 593056/07879 848449
Land south of Westwells Road, Westwells, Corsham – Bat Appropriate Assessment
To: Summix SRD Developments Ltd
Report Number: 3032-CWS-13
Version: 01
Date: 28th March 2019
______Cotswold Wildlife Surveys 21