cranleigh village hospital and health centre, surrey 1 bat surveys… · mace group ltd cranleigh...

Ref: ZPCT101/VMAC102/ 001 / 002

November 2009

Thomson Ecology Ltd, Compass House, 60 Priestley Road, Guildford, Surrey GU2 7YU.

Tel 01483 466000 or visit www.thomsonecology.com

Cranleigh Village

Hospital and Health

Centre, Surrey

For

Mace Group Ltd

Desk Study,

Phase 1 Habitat Survey and Bat Surveys

Mace Group Ltd Cranleigh Village Hospital and Health Centre Surrey

Desk Study, Phase 1 Habitat Survey and Bat Surveys _________________________________________________________________________________

_________________________________________________________________________________ Thomson Ecology Ltd 2 Ref: ZPCT101/VMAC102 / 001 / 002

Contents 1 ...... SUMMARY AND MAIN RECOMMENDATIONS 4

1.1 Summary 4

1.2 Main Recommendations 5

2 ...... INTRODUCTION 6 2.1 Development Background 6

2.2 The Brief and Objectives 6

2.3 Limitations 7

3 ...... DESK STUDY AND EXTENDED PHASE 1 HABITAT SURVEY 8 3.1 Desk Study Methodology 8

3.2 Field Survey Methodology 8

3.3 Desk Study and Extended Phase 1 Habitat Survey Results 10

3.4 Legislation and Planning Policy Issues 18

3.5 Potential Further Ecological Issues 20

3.6 Recommendations 21

3.7 Conclusion 22

4 ...... BAT SURVEYS 23 4.1 Methodology 23

4.2 Results 27

4.3 Legal and Planning Policy Issues 32

4.4 Recommendations 33

4.5 Conclusion 36

5 ...... REFERENCES 37

6 ...... APPENDIX 1 38

7 ...... APPENDIX 2 41 7.1 Phase 1 Habitat Survey Species List 41

8 ...... APPENDIX 3 44 8.1 Table 9: Incidental Bat Records 44

9 ...... APPENDIX 4 - BRITISH BATS 47




FIGURE 1 SITE LOCATION AND DESK STUDY RESULTS FIGURE 2 EXTENDED PHASE 1 HABITAT SURVEY RESULTS FIGURE 3 BAT SCOPING SURVEY RESULTS FIGURE 4A BAT ACCESS / EGRESS POINTS OF BUILDING B1 FIGURE 4B BAT ACCESS / EGRESS POINTS OF BUILDINGS B2 AND B3 FIGURE 5 INTERNAL INSPECTION SURVEY RESULTS FIGURE 6A SURVEYOR LOCATIONS AND INCIDENTAL SURVEY RESULTS (11-12/08/09) FIGURE 6B SURVEYOR LOCATIONS AND INCIDENTAL SURVEY RESULTS (27 – 28/08/09) FIGURE 7A PHOTOGRAPHS 1 – 4 OF THE CRANLEIGH HOSPITAL AND NHS CENTRE SITE FIGURE 7B PHOTOGRAPHS 5 – 8 POTENTIAL BAT ACCESS / EGRESS POINTS




1 SUMMARY AND MAIN RECOMMENDATIONS 1.1 SUMMARY

1.1.1 Mace Group Ltd on behalf of the Surrey Primary Care Trust is seeking planning permission to construct a new hospital / healthcare facility and demolish parts of the existing healthcare facilities present at the Cranleigh Village Hospital and Health centre site.

1.1.2 The brief was to undertake a preliminary ecological assessment of the site and discuss the legal and planning policy issues associated with the proposed development and biodiversity. To that end, a desk study and Phase 1 habitat survey were undertaken to gather baseline ecological data for the site. In addition to this, a bat scoping survey, bat internal inspection of all buildings on site and two dusk emergence / dawn return to roost surveys were also requested to determine the presence / likely absence of roosting bats.

1.1.3 The main findings of the desk study were that there are no statutory designated sites within 2km of the development site. Ten non-statutory nature conservation sites lie outside but within 2km of the site (See Figure 1). In addition, the desk study provided records of species of conservation concern within a 1km radius, including five species of bat and great crested newts.

1.1.4 During the field survey, the site was found to support scattered broadleaved trees, amenity grassland, ephemeral short perennial vegetation, introduced shrub beds, a species poor hedgerow, bare ground and ephemeral short perennial mosaics, ephemeral short perennial and amenity grassland mosaics and buildings and hard-standing (See Figure 2). A number of common breeding birds were found on the site. During the bat scoping survey, three of the buildings on site were deemed to have the potential to support roosting bats. During the subsequent internal inspection survey and dusk emergence / dawn return to roost surveys, two bat roosts were confirmed in building B2.

1.1.5 All birds and their nests are protected under the Wildlife and Countryside Act 1981 (as amended) and bats and their roosts are fully protected under the Conservation Regulations 1994 (as amended 2007), the Wildlife and Countryside Act 1981 (as amended), and Countryside and Rights of Way Act 2000 as amended.

1.1.6 The development should not have a significant effect on any of the non-statutory nature conservation sites. Habitat for breeding birds could be lost and the bat roosts present in building B2 could be disturbed during subsequent development works. The mitigation proposals set out below




should ensure that the development is compliant with the law and planning policy with respect to birds and bats. Great crested newts, toads, hedgehogs, stag beetles, brown hairstreak butterflies and tawny owls were also recorded within 1km of the site. However there is no suitable habitat present on site to support these species.

1.2 MAIN RECOMMENDATIONS

1.2.1 The following measures are recommended for the development to comply with relevant biodiversity legislation and policy:

• Any necessary clearance of trees and shrubs should be undertaken outside the bird breeding season;

• To enable the lawful development of building B2 a European Protected Species Licence (EPSL) should be acquired from Natural England. The licence application will require a method statement detailing how bats will be protected during each phase of development and how the loss or damage to their roosts will be mitigated;

• Native trees and shrubs should be used in the landscape design for the redeveloped site;

• Wild flower areas could be created to provide foraging habitat for bird and invertebrate species. Vegetation should be allowed to grow from January through to July or August and then cut during the other months of the year; and

• Bird boxes and bat boxes could be incorporated in the structure of the new buildings.

1.2.2 Following best practice guidelines and in order to further inform a European Protected Species Licence application (EPSL), a further survey for bats is recommended between mid May and August 2010.

1.2.3 Note that further mitigation measures may be required following the results of the further surveys.

Firtree Wood Complex SNCI

Upper Canford and Lambs Wood SNCI

Vachery Pond Woodland Complex SNCI

Ashen Copse SNCI

White MeadsCopse SNCI

High Canfold Brook SNCI

Fishpond Copse SNCI

Bushy Copse SNCI

Sparrow Copse and Little Sparrow Copse SNCI

BookhurstSNCI

Data originates from different sources and scales of mapping and should therefore be considered indicative of position and extent.Reproduced from 1:50,000 Ordnance Survey colour raster.Crown copyright. All rights reserved. Licence number 100045975This map must not be copied or reproduced by any means without prior written permission from Thomson Ecology Limited.

Figure: 1Site Location and Desk Study Results

Drawing Ref: ZPCT101/VMAC102/5001/1Drawing Size: A4Drawn By: Thomson Ecology (KQ)Checked By: Thomson Ecology (NS)Date: 02/09/2009

LegendSite of Nature Conservation Importance (SNCI)

1Km Search Area

2Km Search Area

Survey Boundary

0 0.2 0.40.1

Kilometers

B1

B3

AM1

AM3

AM1

AM2AM2

AM3

AM2

AM3

B4

ESP/IS1

AM2

B5

ESP/AM1

BG/ESP1

BG/ESP1

AM3

BG/ESP1BG/ESP1

PH1

P1

P2

P4

P3

AM3

B2

IS1

IS1

IS1

IS1IS1

IS1

IS1

IS1

IS1IS1

IS1

ESP1

A

A

A

A

A

AA

A

A

A

A

A

This map has been drawn at a sufficient accuracy to fulfill the requirements of a Phase 1 baseline habitat survey. This map is not intended to represent a scaled landscape survey so should not be used to pin-point accurate engineering work or as a basis for detailed site planning.

Base map supplied by Mace Group Ltd. This map must not be copied or reproduced by any means without prior written permission from Thomson Ecology Limited.

Figure: 2Extended Phase 1 Habitat Survey Results

Surveyed For: Mace Group LtdDrawing Ref: ZPCT101/VMAC102/5002/1Drawing Size: A3Drawn By: Thomson Ecology (KQ)Checked By: Thomson Ecology (NS)Date: 05/08/2009

LegendLocation and Direction of Photograph

Broadleaved Scattered Trees

Species Poor Intact Hedge

Wall

Amenity Grassland (A)

Ephemeral / Short Perennial

Introduced Shrub

Buildings

Hard Standing

Bare Ground

Survey Boundary

0 5 102.5

Metres

B1

B2

B3

B4

B5


Figure: 3Bat Scoping Survey Results


LegendBat Potential of Buildings

High

Medium

Low

Negligible

Survey Boundary

0 5 102.5

Metres

B1


Figure: 4aBat Access / Egress points of Building B1


LegendBat Access Points

Access to soffit

Building Surveyed

0 4 82

Metres

B2

B3

P8

P5

P7

P6


Figure: 4bBat Access / Egress points of Buildings B2 and B3


LegendLocation and Direction of Photograph

Bat Access PointsGap in gable end of building

Gap by chimney

Gap in dormer window

Gap in lead flashing

Gap in soffit

Damaged wooden boarding

Ivy cover

Lead pipe

Missing or slipped hanging tile

Missing or slipped roof tile

Roof grille

Buildings Surveyed

0 4 82

Metres

B2

B3

B4

B5

43

5

83

1

24

Loft 5

Loft 2

Loft 4

Loft 1

Loft 6

Loft 3

Base map supplied by Mace Group LtdThis map must not be copied or reproduced by any means without prior written permission from Thomson Ecology Limited.

Figure: 5Internal Inspection Survey ResultsSurveyed For: Mace Group LtdDrawing Ref: ZPCT101/VMAC102/5093/1Drawing Size: A3Drawn By: Thomson Ecology (KQ)Checked By: Thomson Ecology (NS)Date: 01/09/2009

LegendLocation and Number of Bat DroppingsLofts Surveyed

0 2 41

Metres

Note: Roof lines are indicative and are for representation purposes only.

Photograph 1: Amenity grassland (AM2) and building B1.

Photograph 2: The north of building B2 showing the oldest part of the village hospital building in the left of the photograph and the most recent construction on the right.

Photograph 4: Amenity grassland (AM3) and some of the introduced shrub beds located to the southeast of building B2.

Photograph 3: The hard standing “garden area” in the south of building B2. Introduced shrub (IS1) can be seen in the left of this photograph with the edge of building B3 in the right of the photograph and the green metal shed (building B5) in the back left of the photograph.

ZPCT101/VMAC102/001/001 Surveyed for Mace Group Ltd. August 2009 Figure 7a: Photographs 1 - 4 of the Cranleigh Village Hospital and NHS Centre site.

Roof grille

Gap in dormer window

Photograph 5: Gap in dormer window (see Figure 4b) on eastern side of building B3.

Photograph 6: Missing roof tile (see Figure 4b) on southern side of building B2.

Photograph 8: The northern side of building B2 showing slipped/missing hanging tiles and gaps in the dormer windows.

Photograph 7: Roof grille allowing access into roof space. On the southern roof of building B2 (see Figure 4b).

ZPCT101/VMAC102/001/001 Surveyed for Mace Group Ltd. August 2009 Figure 7b: Photographs 5 – 8. Potential Bat Access / Egress Points.




2 INTRODUCTION 2.1 DEVELOPMENT BACKGROUND

2.1.1 Mace Group Ltd on behalf of the Surrey Primary Care Trust proposes to construct new health care facilities upon the site of the existing Cranleigh NHS healthcare centre and village hospital. They plan to completely demolish the healthcare centre building, the mental healthcare building and most recent additions to the hospital building that were constructed in the 1960s and 1980s. The “Victorian extensions” to the hospital building will be retained though they will be completely refurbished internally. The front section of the village hospital building is a grade II listed building and will be completely retained during the subsequent development.

2.1.2 The development proposals include a degree of soft landscaping although the extent of this is yet to be finalised.

2.1.3 The proposals described above are hereafter referred to collectively as ’the development’.

2.1.4 The development will be located on a 0.43ha area of land consisting of three main buildings including the Cranleigh village hospital and the Cranleigh health centre (Grid Reference TQ 059 390), adjacent to the High Street, Cranleigh, Surrey, see Figure 1. The area affected by the development is hereafter referred to as ‘the site’.

2.1.5 Planning permission for the development is to be applied for in late November/early December 2009.

2.2 THE BRIEF AND OBJECTIVES

2.2.1 Mace Group Ltd commissioned Thomson Ecology on 27th July 2009 to undertake a preliminary ecological assessment of the site. The brief was to:

• Carry out an ecological desk study to obtain records of designated sites and protected species held by third parties;

• Undertake an extended Phase 1 habitat survey of the site, recording the main habitats present on site;

• Make an assessment of the potential of the site to support protected species or species of conservation concern;

• Conduct an external bat scoping survey of the buildings on site to assess their potential to support roosting bats. The results of the survey will determine the requirement for further bat survey work on the buildings on site;




• Provide a combined report giving the methods and results of the survey, discussion of the legal and planning policy issues and our recommendations, including opportunities for biodiversity enhancement; and

• Provide digitised maps of the survey results.

2.2.2 Following the initial findings of the bat scoping survey Mace Group Ltd commissioned Thomson Ecology on 10th August 2009 to undertake bat surveys on the site. The brief was to:

• Carry out two dusk emergence / return to roost surveys on all buildings on site deemed to have potential to support roosting bats;

• Undertake internal inspections of the loft spaces and roof voids of buildings B2 and B3; and

• Include the methodology, the results of the surveys, discussion of the legal and planning policy issues with regard to bats and our recommendations as to how these may be overcome within the combined report commissioned on 27th July 2009.

2.3 LIMITATIONS

2.3.1 The species data collated during the desk study is mainly derived from records submitted by members of the public and ad hoc surveys undertaken by volunteers. Therefore, it should not be taken as a definitive list of the protected species and other species of conservation concern that occur in the local area. In addition to this, the location of some records is limited to grid squares rather than specific points.

2.3.2 The survey was conducted at an optimal time of year for extended Phase 1 habitat surveys and bat scoping surveys.

2.3.3 The bat emergence / return to roost surveys and the internal inspection survey were conducted at an optimal time of year.

2.3.4 The dusk emergence / dawn return to roost surveys were conducted in optimal weather conditions.




3 DESK STUDY AND EXTENDED PHASE 1 HABITAT SURVEY

3.1 DESK STUDY METHODOLOGY

3.1.1 A study area was defined that encompasses the site and all land within 2km of the perimeter of the site, see Figure 1. Nature conservation organisations with interests in the study area were then approached and asked to provide up-to-date information on sites designated for their nature conservation value, local nature reserves, records of protected species and other species of conservation concern and any other information that they considered relevant. Records of designated sites were sought for the full study area, whereas records for species were sought for part of the study area encompassing the site and within 1km of the perimeter of the site.

3.1.2 The organisations contacted include:

• Surrey Biological Record Centre

• Surrey Bat Group

• Surrey Amphibian and Reptile Group

3.1.3 Letters requesting information were sent on 3rd August 2009 with responses requested as soon as possible.

3.1.4 In addition, published data was consulted including the following:

• The Multi- Agency Geographical Information for the Countryside (MAGIC)

• Natural England’s Nature on the Map

3.2 FIELD SURVEY METHODOLOGY

3.2.1 A survey area was defined that encompassed the village hospital building and healthcare centre building including surrounding grounds. The survey area is shown on Figure 2.

3.2.2 An extended Phase 1 habitat survey (JNCC, 1993; IEA, 1995) was conducted throughout the survey area. Phase 1 habitat survey is a standard technique for rapidly obtaining baseline ecological information over a large area of land. It is primarily a mapping technique and uses a standard set of habitat definitions for classifying areas of land on the basis of the vegetation present. For this survey, the technique was modified (or extended) to provide more detail over a smaller area, and give further consideration to fauna. The standard habitat definitions were used with an additional category of coarse grassland for unmanaged, secondary grasslands that are species poor.




3.2.3 The dominant and readily identified species of higher plant species from each habitat type within the survey area were recorded and their abundance was assessed on the DAFOR scale:

D Dominant

A Abundant

F Frequent

O Occasional

R Rare

3.2.4 These scores represent the abundance within the defined area only and do not reflect national or regional abundances. Plant species nomenclature follows Stace (1997).

3.2.5 Incidental records of fauna were also made during the survey and the habitats identified were evaluated for their potential to support protected species and other species of conservation concern, including Biodiversity Action Plan Priority species. However, no specific faunal surveys were undertaken.

3.2.6 The survey was conducted on 4th August 2009.




3.3 DESK STUDY AND EXTENDED PHASE 1 HABITAT SURVEY RESULTS

3.3.1 The contents of the results section are the factual results of the desk study and extended Phase 1 habitat survey. Excluded from this section is the assessment of the site to support species of conservation concern not recorded during the survey. Instead, potential further ecological issues are discussed in Section 3.5.

Desk Study Results

3.3.2 Responses were received from the following organisations:

• Surrey Biological Record Centre

• Surrey Bat Group

• Surrey Amphibian and Reptile Group

3.3.3 The results are summarised below. The locations of designated sites are shown on Figure 1.

Designated Sites

3.3.4 There are no sites with a statutory designation for nature conservation within the site or within 2km of the site perimeter. However, 10 non-statutory designated sites (Sites of Nature Conservation Importance or SNCI’s) were recorded within 2km of the site boundary. The details of these are listed in Table 1.

Table 1: Designated sites within 2km of the site

Site Designation Grid Reference

Area (ha)

Distance to site (km)

Description

County and Local Sites (SNCIs, LNRs, etc)

Firtree Wood Complex SNCI

TQ 080 390 84.3 1.6 Mixture of semi-natural broadleaved woodland with grassland, ponds and a conifer plantation.

Fishpond Copse SNCI

TQ 073 401 4.1 1.6 Ancient semi-natural woodland with 26 ancient woodland indicator species.

Ashen Copse SNCI TQ 073 403 8.8 1.7 Ancient semi-natural woodland with 23 ancient woodland indicator species.

Sparrow Copse and Little Sparrow Copse SNCI

TQ 047 380 4.2 1.4 Ancient semi-natural woodland with a number of indicator species.




Site Designation Grid Reference

Area (ha)


Description

Vachery Pond and Woodland Complex SNCI

TQ 070 373 33.6 1.7 Species-rich woodland with stream and a large lake an important site for breeding and wintering wildfowl.

Bushy Copse SNCI TQ 054 378 2.2 1.3 Ancient semi-natural woodland with a number of indicator species.

White Meads Copse SNCI

TQ 055 376 8.8 1.4 Old secondary semi-natural woodland.

Upper Canfold and Lambs Woods SNCI

TQ 080 399 54.2 1.7 Large area of ancient semi-natural woodland with 34 ancient woodland indicators.

Bookhurst SNCI TQ 076 392 15.4 1.5 Ancient semi-natural woodland with 25 ancient woodland indicator species recorded.

High Canfold Brook SNCI

TQ 072 410 6.9 1.9 Ancient semi–natural woodland and secondary ghyll woodland with hornbeam coppice. A number of indicator species and protected species are present.

Biodiversity Action Plan Habitats

3.3.5 There are ten parcels of wet woodland, a UK Biodiversity Action Plan Priority Habitat and Local BAP habitat, located within 2km of the site boundary. The closest of these is situated 1.3km from the perimeter of the site boundary.

Ancient Woodland

3.3.6 A total of 10 areas of ancient woodland within a 2km search area of the site were identified during the desk study from MAGIC and the Surrey Biological Records Centre (SBRC). These are listed in Table 2. Any area of land which has been under continuous woodland cover since at least 1600 AD is classified as ancient woodland. This includes ancient semi-natural and replanted woodland, however excludes ancient woodlands less than 2ha in size.




Table 2: Ancient Woodland Parcels within 2km of the Site

Woodland Name

Description Grid Reference


Source of Information

Sparrow Copse Ancient and semi- natural woodland (2ha).

TQ 046 379 1.4 SBRC

Rowgardens Copse

Ancient and semi-natural woodland (6ha).

TQ 071 382 1.3 SBRC

Lower Canfold Wood

Ancient and semi-natural woodland (5ha) and replanted woodland (23ha).

TQ 082 392 1.7 SBRC

Upper Canfold Wood

Ancient and semi-natural woodland (62ha) and replanted woodland (5ha).

TQ 080 400 1.7 SBRC

Bookhurst Ancient and semi-natural woodland and replanted woodland (14.1ha).

TQ 076 392

1.5 www.magic.gov.uk

Unknown Ancient and semi-natural woodland (12ha).

TQ 072 401

1.7 www.magic.gov.uk

Bushy Copse Ancient and semi-natural woodland (2ha).

TQ 053 378 1.3 www.magic.gov.uk

Horsham Road Wood

Ancient and semi-natural woodland and replanted ancient woodland (8ha)


Coneyhurst Gill Ancient semi-natural woodland and replanted ancient woodland (55ha)





Woodland Name

Description Grid Reference


Source of Information

Holdhurst Copse

Replanted ancient woodland (2.6ha)


Protected Species and Other Species of Conservation Concern

3.3.7 Five species of bat were recorded within 1km of the development including a brown long-eared bat roost within the church opposite the site. Other protected species and UKBAP species were also recorded. The details of these species including their distance from the site are listed in table 3.


Desk Study, Phase 1 Habitat Survey and Bat Surveys ________________________________________________________________________________________________________________________________

_______________________________________________________________________________________________________________________________ Thomson Ecology Ltd 14 Ref: ZPCT101/VMAC102 / 001 / 001

Table 3: Records of Protected and Other Species of Conservation Concern derived from the desk study

Common Name Scientific Name HR Sch 2 or 4

WCA Sch1, 5 or

8

UKBAP Priority

Local BAP

species

Red Data Book

Other Grid Ref. Distance from site

Source

Great crested newt

Triturus cristatus Sch 2 Sch 5 NERC TQ 053 393 0.7km SARG

Common toad Bufo bufo Sch 5 (sale only)

NERC TQ 053 395 0.8km SARG

Brown hairstreak butterfly

Thecla betulae NERC TQ 04 39 <1km SBRC

Stag beetle Lucanus cervus Sch 5 (sale only)

NERC TQ 05 39 <1km SBRC

Common pipistrelle bat

Pipistrellus pipistrellus

Sch 2 Sch 5 TQ 064 394 0.5km SBG

Brown long eared bat (roost)

Plecotus auritus Sch 2 Sch 5 TQ 061 393 0.4km SBG

Brown long-eared bat

Plecotus auritus Sch 2 Sch 5 NERC TQ 058 391 0.1km SBG

Whiskered bat Myotis mystacinus

Sch 2 Sch 5 TQ 057 391 0.3km SBG

Soprano pipistrelle bat

Pipistrellus pygmaeus

Sch 2 Sch 5 NERC TQ 067 394 0.7km SBG


Desk Study, Phase 1 Habitat Survey and Bat Surveys ________________________________________________________________________________________________________________________________

_______________________________________________________________________________________________________________________________ Thomson Ecology Ltd 15 Ref: ZPCT101/VMAC102 / 001 / 001

Common Name Scientific Name HR Sch 2 or 4

WCA Sch1, 5 or

8

UKBAP Priority

Local BAP

species

Red Data Book

Other Grid Ref. Distance from site

Source

Hedgehog Erinaceus europaeus

NERC TQ 05 39 <1km SBRC

Tawny owl Strix aluco BoCC Amber

List

TQ 05 38 <1km SBRC

HR = Conservation (Habitats &c) Regulations 1994 WCA = Wildlife and Countryside Act 1981, as amended NERC = Species of Principal Importance listed under the Natural Environment and Rural Communities Act 2006 BAP = UK Biodiversity Action Plan SARG = Surrey Amphibian and Reptile Group SBRC = Surrey Biological Records Centre SBG = Surrey Bat Group BoCC = Bird of Conservation Concern Other to include red and amber list birds, nationally scarce species and species listed on Annex II of the Habitats Directive.


Desk Study, Phase 1 Habitat Survey and Bat Surveys

Thomson Ecology Ltd 16 Ref: ZPCT101/VMAC102 / 001 / 001

Field Survey Results

Habitats and Flora

3.3.8 The following Phase 1 habitat types were identified:

• Scattered broad leaved trees;

• Amenity grassland;

• Ephemeral short perennial;

• Introduced shrub;

• Species poor hedgerow;

• Bare ground / ephemeral short perennial mosaic;

• Ephemeral short perennial / amenity grassland mosaic; and

• Buildings and hard – standing.

3.3.9 These habitats are described below and their distribution is given on Figure 2. Photographs depicting a sample of these habitats can be seen in Figure 7a.

Scattered broadleaved trees – SBW1

3.3.10 A number of native and introduced tree species are scattered across the site predominantly occurring as saplings within the introduced shrub beds. These include ash (sapling) (Fraxinus excelsior), sycamore (mature tree and sapling) (Acer pseudoplatanus), cherry (Prunus sp.) and yew (Taxus baccata).

Amenity grassland – AM1 – AM3

3.3.11 There are three distinct parcels of amenity grassland upon the site. AM1 is split into two floristically similar areas of grassland, located within the inner courtyards of building B1. This habitat parcel covers approximately 126m². Perennial rye-grass (Lolium perenne) dominates these grassland areas with frequent dandelion (Taraxacum agg.). Self heal (Prunella vulgaris), white clover (Trifolium repens) and procumbent yellow sorrel (Oxalis corniculata) were occasional with red dead nettle (Lamium purpureum) and creeping thistle (Cirsium arvense) rarely recorded.

3.3.12 AM2 consists of four areas of mown grassland immediately north of building B1 (approximately 129m²). Perennial rye-grass was abundant within these areas of grassland with red fescue (Festuca rubra), white clover and dandelion also frequently recorded. Common mallow (Malva sylvestris) and dove’s foot crane’s bill (Geranium molle) were also occasionally recorded.




3.3.13 AM3 consists of five areas of lawn within the front and rear garden areas of the hospital building (B2), covering a total area of 273m². These lawns all had a similar floral community consisting of abundant perennial rye-grass and red fescue, frequent Yorkshire fog (Holcus lanatus) and occasional occurrence of white clover, ribwort plantain (Plantago lanceolata) and bird’s-foot trefoil (Lotus corniculatus).

Ephemeral short perennial – ESP1

3.3.14 There is limited ephemeral vegetation growing from cracks in the concrete car-park in the west of the site, covering an area of approximately 12m². Dandelion was occasional with rare instances of annual meadow grass (Poa annua) and hedge mustard (Sisymbrium officinale).

Introduced shrub – IS1

3.3.15 There are eleven shrub beds located throughout the site. The majority of these beds are located in the east of the site in the front and rear gardens of the hospital building (B2). This habitat parcel covers a combined area of approximately 146m² of the site. There are a large range of non-native species planted within these shrub beds with hebe (Hebe sp.) and hollyhock (Alcea sp.) frequently recorded. St John’s wort (Hypericum sp.), cherry laurel (Prunus laurocerasus), skimmia (Skimmia sp.), fennel (Foeniculum vulgare) and passion flower (Passiflora caerulea) were occasionally recorded with rare occurrence of yucca (Yucca sp.) and fatsia (Fatsia sp.). Native species recorded within these shrub beds include locally abundant ivy (Hedera helix) and occasional broad-leaved willowherb (Epilobium montanum).

Species poor hedgerow – PH1

3.3.16 There is a small length of species poor hedgerow (approximately 5m in length) in the south of the site adjacent to building B3. This hedgerow consists of cotoneaster (Cotoneaster horizontalis) with rare instances of sycamore (sapling).

Bare ground / ephemeral short perennial mosaic – BG/ESP1

3.3.17 There are four areas of BG/ESP1 on the site covering a total area of 62m². Two are located within the courtyards of building B1 and the others are located in the north eastern portion of the site. All areas consist of gravel with occasional dandelion and rare instances of groundsel (Senecio vulgaris).

Ephemeral short perennial / Amenity grassland mosaic – ESP/AM1

3.3.18 There is an area of ESP/AM1 located in the eastern extent of building B1. This habitat parcel covers an area of approximately (49m²). Dandelion and moss are abundant with locally abundant procumbent yellow sorrel and




frequent creeping cinquefoil (Potentilla reptans). Creeping buttercup (Ranunculus repens) and self heal were also occasionally recorded.

Buildings and hard - standing – B1 – B4 and HS

3.3.19 There are four buildings on site covering an area of 1971m². Building B1 is the healthcare centre building located in the west of the site. B2 is the old village hospital building located in the east of the site. B3 is a mental health facility in the south of the site, B4 is a garden shed in the far south – east of the site and B5 is a metal shed adjacent to building B3. The buildings on site are explored in more detail in Section 4.

3.3.20 The remainder of the site consists of areas of hard standing (1479m²) including the car parks and the concrete and paved paths and walkways associated with the buildings on site. Walls enclose the southern survey boundary around building B2.

Fauna

3.3.21 A robin (Erithacus rubecula) and a blackbird (Turdus merula) were recorded on site during the field survey.

3.4 LEGISLATION AND PLANNING POLICY ISSUES

3.4.1 The content of the legislation and planning policy section is the legislation and planning policy issues that we know are relevant based on this desk study and extended Phase 1 habitat survey. The legislation and policy issues that might arise following further surveys are excluded. Potential further ecological issues are discussed in Section 3.5. A detailed description of the method for this section is given in Appendix 1.

Designated Sites

3.4.2 The closest non-statutory designated site is Bushy Copse SNCI. The proposals are unlikely to have a significant negative effect on this SNCI and its important attributes because:

• Bushy Copse SNCI and the proposed development is separated by a minimum of 1.3km of urban and sub urban landscape;

• The development will not result in significant increase in emissions to air; and

• The development will be contained within the site boundary.

3.4.3 The development should therefore be compliant with the relevant planning policy with respect to non - statutory designated sites.




Biodiversity Action Plan Priority Habitats

3.4.4 The closest parcel of wet woodland is approximately 1.3km from the proposed development. For the same reasons detailed in section 3.4.2 the development proposals should therefore be compliant with the relevant planning policy with respect to UK Biodiversity Action Plan Priority Habitats.

Ancient Woodland

3.4.5 Ten areas of ancient woodland were found to be present within the 2km desk study search area. The closest of these areas of ancient woodland is separated by approximately 1.2km of urban and suburban landscape. For the same reasons listed in section 3.4.2 the development is unlikely to have an affect on any local areas of ancient woodland and should be consistent with PPS9, Policy NRM7 of the South East Plan (2009) and Policy C7 of the Waverley Borough Local Plan (2002 saved policies) which seek to protect ancient woodland from the adverse effects of development.

Protected Species

3.4.6 A number of common bird species were recorded on the site, some of which are likely to breed on the site as suitable habitat is present. All birds, eggs and nests are protected from damage and destruction under the Wildlife and Countryside Act 1981, as amended.

3.4.7 In addition, the ODPM circular 05/2006 states that the presence of protected species is a material consideration in the planning process, which is addressed by Policy NRM5 of the South East Plan. This states that, “local planning authorities shall avoid a net loss of biodiversity, and actively pursue opportunities to achieve a net gain across the region”.

3.4.8 The mitigation measures set out in Section 3.6 should ensure that the development proposals are compliant with the law and Policy NRM5 with respect to birds. It should be noted, however that other protected species may be present as set out in Section 3.5.

Ecological Enhancement

3.4.9 Central and local government policy now points towards ecological enhancement on development sites. For example, PPS9 states that “plan policies should promote opportunities for the incorporation of beneficial biodiversity and geological features within the design of development” and Policy NRM5 of the South East Plan states that “Opportunities for biodiversity improvement, including connection of sites, large-scale habitat restoration, enhancement and re-creation in the areas of strategic opportunity for biodiversity improvement should be pursued”. Policy D5 of the Waverley Borough Council Local Plan also advocates ecological




enhancement where possible. The development proposals include measures to enhance biodiversity by creating areas of soft landscaping as mentioned in Section 2.1.2 and should therefore consistent with these policies.

3.5 POTENTIAL FURTHER ECOLOGICAL ISSUES

3.5.1 The potential further ecological issues section sets out our assessment of the potential of the site to support protected species and other species of conservation concern which were not detected during the extended Phase 1 habitat survey, either because their presence is seasonal or because specialist survey techniques are required. Further survey work or appropriate mitigation is likely to be required before these issues can be addressed. Further information on the methods of assessment are given in Appendix 1.

3.5.2 The survey area also has the potential to support some species of conservation concern, including protected species that were not identified during the survey. These are as follows:

Great crested newts

3.5.3 Great crested newts have been recorded within 1km (0.7km) of the site. Great crested newts and their habitats are fully protected under European and national legislation. However, there is no aquatic and limited terrestrial great crested newt habitat present on site. In addition walls enclose the garden area to the south of building B2 and the site is bordered by Cranleigh High Street making possible migration of newts into the garden area unlikely. Therefore, there should be no issues regarding great crested newts and the proposed development.

Bats

3.5.4 The potential issues pertaining to bats are detailed fully in Section 4 of this report.

UKBAP Priority Species

3.5.5 Common toads, hedgehogs, brown hairstreak butterflies and stag beetles have also been recorded within 1km of the development site. As UKBAP priority species they are also listed as species of principal importance under section 41 of the NERC act (2006). This places a duty on all government departments to have regard for the conservation of these species and on the Secretary of State to further, or promote others to further, the conservation of this species. However, as in the case of great crested newts, there is no habitat present on site to support these species. Therefore, there should be no issues regarding these UKBAP priority species and the proposed development.




Other Species of Conservation Concern

3.5.6 Tawny owls have been recorded within 1km of the site. This species is on the amber list for birds of conservation concern; however, it receives no specific legal or policy protection over and above the general protection of all birds by the Wildlife and Countryside Act. In addition, the site does not offer significant habitat for this species.

3.6 RECOMMENDATIONS

Mitigation

3.6.1 The recommendations for mitigation (including avoidance, mitigation and compensation) measures given in this section are based on the findings of the desk study and extended Phase 1 habitat survey. It may include precautionary mitigation measures for some species which could occur on the site but excludes discussion of the mitigation measures that may be required following the results of the further surveys recommended in Section 3.6.4 and 4.4.8.

Protected Species

Breeding Birds

3.6.2 To mitigate for the potential killing or injuring of birds or destruction of their eggs and nest, any necessary clearance of trees or areas of scrub and introduced shrub should be undertaken outside of the breeding bird season (i.e. clearance work should be undertaken between September to February inclusive). If site clearance occurs within the breeding bird season, it should be conducted carefully, and the presence of birds and their nests checked for immediately before and throughout the process. If an active nest is discovered, then work in that area should cease until such a time that the young have fledged or the nest is no longer active.

Ecological Enhancements

3.6.3 The site offers scope for ecological enhancement in line with PPS9 and Policy D5 of the Waverley Local Plan. The following suggestions listed below are not required by law but implementing a selection would contribute to the enhancement of biodiversity on the site and as such should allow the development to comply with PPS9 and Policy D5 of the Waverley Local Plan.

• Provision of bird boxes on the outside of new buildings or on mature trees. Starling and house sparrow nest boxes can be attached to the buildings, while boxes for barn owls, blue and great tits can be attached to trees;




• Use of native trees and shrubs in the landscaping proposals. Suitable species may include field maple (Acer campestre), hornbeam (Carpinus betulus) and dogwood (Cornus sanguinea);

• Planting of hedgerows at site boundaries using native species such as hawthorn (Crataegus monogyna), blackthorn (Prunus spinosa) and elder (Sambucus nigra) and management of existing hedgerows to enhance their biodiversity; and

• Wildflower areas could be planted around the new properties, providing foraging habitat for bird and invertebrate species. Vegetation should be allowed to grow from January through to July or August and then cut during the other months of the year.

Further Survey

Bats

3.6.4 The issue of bats on site is dealt with in section 4 of this report.

3.7 CONCLUSION

3.7.1 Suitable habitat for breeding birds was recorded on site. Additionally the site is considered to provide suitable habitat for bats. Providing recommendations made within this report relating to mitigation for breeding birds and ecological enhancements are followed, the development should be compliant with the relevant planning policy and legislation with regards to birds. The issue of bats is explored further in section 4 of this report.




4 BAT SURVEYS 4.1 METHODOLOGY

General Approach

4.1.1 A survey area was defined that encompassed the buildings (B1- B5) within the grounds of the Cranleigh Village hospital and the Surrey health centre, Cranleigh, Surrey. The survey boundary is shown on Figure 1.

Daytime Survey of Potential Roosts

4.1.2 A preliminary inspection of potential bat roosts was made from the ground with the aid of binoculars and a powerful torch. All potential roost sites that could be investigated in this way were searched for bats themselves and evidence of current or past bat use.

4.1.3 Buildings B1 – B5 were assessed for their potential to support roosting bats. Potential roost and access points noted included:

• Gaps around windows, doors and lintels;

• Lifted lead flashing;

• Loose or missing tiles;

• Gaps between stone or brickwork where mortar has fallen out;

• Other gaps or cracks between various elements of building structure;

• Presence or absence of cavity wall and potential access points; and

• Suitable access points around eaves, soffits, barge board, fascia, flashing and hanging tiles.

4.1.4 The information recorded for the building included the building type and a description of the potential roost and its location.

4.1.5 The buildings were then graded and placed into a category for their level of potential for roosting bats (see Table 4). This was dependent on the degree of exposure, cavity dimensions and the presence or absence of crevices considered suitable for bats to use as roosts. In addition the following factors were also considered:

• Setting and locality;

• Level of disturbance;

• Age of building or structure;




• Proximity of nearest woodland and / or water;

• Presence or absence of substantial linear features linking to woodland or other commuting and foraging habitat; and

• Size, particularly when considering potential for winter hibernation sites.

Table 4: Outline of categories of bat potential.

Type of roost Level of potential

Summer or transitional roost used by non breeding bats

Maternity roost Hibernation roost

Confirmed Presence of bats or evidence of bats. Confirmation of roost status may require further survey.

High Bat Potential

Feature with multiple roosting opportunities for one or more species of bat. With good connectivity to high quality foraging habitat.

Feature with multiple roosting opportunities for breeding bats (size, temperature). With proximity and connectivity to high quality foraging habitat.

Large site that offers cool stable conditions with multiple roosting opportunities. With proximity and connectivity to high quality foraging habitat.

Medium Bat Potential

Feature with some roosting opportunities. With connectivity to moderate – high quality foraging habitat.

Feature providing some roosting opportunities. With some connectivity and proximity to moderate or high quality foraging habitat.

Medium sized feature with a number of roosting opportunities. With some connectivity and proximity to moderate or high quality foraging habitat.

Low Bat Potential

Feature with a limited number of roosting opportunities. With poor connectivity to foraging habitat.

Feature with a limited number of roosting opportunities for breeding bats. With low proximity and connectivity to low – moderate quality foraging habitat.

Small sized feature or feature which may be subject to disturbance or environmental variations, with a limited number of roosting opportunities. With limited connectivity to foraging habitat.

Negligible Bat Potential

Feature with no or very limited roosting opportunities for bats or where the feature is isolated from foraging habitat.

Feature with no suitable roosting opportunities for breeding bats.

Feature with no suitable roosting opportunities for hibernating bats.




Building External Inspections

4.1.6 In addition, the buildings (B1, B2 and B3) were inspected from ground level to look for bats or evidence of bats. Evidence searched for included:

• Dark staining below an access point that may be caused by bat faeces;

• Staining around a hole that may be caused by the natural oils in bat fur;

• Scratch marks around the hole made by bat claws;

• Bat droppings; and

• Noises made by bats.

Building Internal Inspections

4.1.7 Where permission for access had been obtained and it was safe to do so the interior and any roof void of buildings B2 and B3 were thoroughly inspected for bats and evidence of bats. The following techniques were used within the roof void:

• A torch and/or endoscope was used to inspect for bats themselves and evidence of bats along ridge beams and over brick work etc;

• Droppings were searched for, concentrating on the area beneath the ridge beam, the junctions between two ridges and around the chimneys, gables and all around the eaves;

• Feeding remains, such as moth wings were searched for; and

• Remains of bats were searched for, including inspecting uncovered water tanks for drowned bats.

Emergence / Return to Roost Surveys

4.1.8 Ecologists were stationed at various locations around the site. Locations were selected to allow potential access or egress points to be watched. At dusk potential egress points were watched constantly by the ecologist. At dawn bats were tracked back to any access points within the view of the ecologist. A Duet frequency division bat detector with an Mp3 recording device attached was used by the ecologist to detect bats emerging from or returning to the potential roost site. Bat calls were then retained for later analysis using Adobe Audition software where necessary.

4.1.9 The dusk survey began 30 minutes before sunset and ended 90 minutes after sunset (or up to 2 hours after the first bats are seen emerging). The dawn survey began 90 minutes before sunrise and ended at sunrise (or 15




minutes after last bat recorded). The cloud cover, wind strength, rain and temperature were all noted.

Incidental Records

4.1.10 During the dusk emergence / dawn return to roost surveys, incidental bat activity within the vicinity of the potential roost was also recorded. For each location the species of bat and number of passes was recorded. As a gauge to the overall level of activity the total number of passes for all species during each survey event at each location is divided by the duration time of the survey. This is then multiplied by 100 to give an activity score. The activity score is then compared to those in Table 5 below. A bat pass was defined as an unbroken stream of echolocation calls, heard as a series of ‘clicks’ on a bat detector as the bat passes in and out of the detector’s range.

Table 5: Categorisation of activity level (based on analysis of bat surveys undertaken by Thomson Ecology in 2006 and 2007).

Activity Score Assessment of Activity Level

Up to 5 Very Low

6 – 30 Low

31-50 Medium

51-90 High

90 plus Very High

Dates of Survey

4.1.11 The potential roost survey was undertaken on 4th August 2009. The internal inspection of the buildings was undertaken on 24th August 2009. One dusk emergence and dawn return to roost survey was undertaken on 11th August 2009 and 12th August 2009. A second dusk emergence and dawn return to roost survey were undertaken on 27th August 2009 and 28th August 2009. The weather conditions during the emergence / return to roost surveys are detailed in table 6.

Weather Conditions

Table 6: Weather conditions during the emergence/return to roost surveys

Temperature oC Survey Date

Max Min

Cloud cover

Rain Wind (Beaufort scale)

Dusk 11/08/09 26.8 18.8 0% Dry 0

Dawn 12/08/09 17.5 13.5 33% Dry 0

Dusk 27/08/09 17.0 14.0 60% Dry 2

Dawn 28/08/09 13.0 14.0 0% Dry 1




4.2 RESULTS

Daytime Survey of Potential Roosts

4.2.1 The overall potential of the five buildings on site to support roosting bats is detailed in table 7 and shown on Figure 3.

Table 7: Overall potential of the buildings surveyed to support roosting bats

Overall potential to support roosting bats Building

Summer/ transitional

Maternity Hibernation

B1 Low Negligible Negligible

B2 High High Negligible

B3 Medium Low Negligible

B4 Negligible Negligible Negligible

B5 Negligible Negligible Negligible

Building External Inspections

4.2.2 The results of the external inspection of the buildings are given in table 8 which details the potential roost features and access points within the buildings along with details of environmental factors.

4.2.3 Potential access / egress points are shown in Figures 4a (for building B1) and Figure 4b (for buildings B2 and B3). Photographs of potential access / egress points can be seen in Figure 7b.

Building Internal Inspections

4.2.4 The results of the internal inspection of the buildings are also included in table 8. Forty-seven brown long-eared bat droppings were found in loft space 4 of building B2 and one brown long-eared bat dropping was found in loft space 5 of building B2 (see the numbers and distribution of droppings in Figure 5).



Thomson Ecology Ltd 28 Ref: ZPCT101/VMAC102/ 001 / 002

Table 8: Details of potential access points, roost spaces and environmental factors

Description Building

External Internal

Potential Access Points

Potential Roost Points Evidence of Bats Environmental Factors

1 This building is a detached, flat roofed (bitumen) single storey structure. Solid brick wall with no cavity. The building is approximately 40 - 50 years old.

N/A The potential access points for this building are shown in Figure 4a. This building could be accessed by bats via gaps within the soffit boxes.

Bats could roost beneath or within the soffit boxes.

There was no evidence of bats found.

Located within a sub-urban setting on Cranleigh High Street. There is a church and church yard opposite the building with good roosting and foraging opportunities. The site is also close to woodland. The property is in use at present.

2 The village hospital building. Complex, 2 storey structure with multiple gable ended tiled roofs. Partial solid and cavity brick walled with hanging tiles. The age of the building ranges from 30 – 150 years old.

This building is split into 5 loft spaces (see Figure 5). Loft 1: Located in the north-east of the building which is the oldest part and is Grade 2 listed. -There is no insulation (can see to the outside via gaps in roof and ridge tiles).

The potential access points for this building are shown in Figure 4b. Loft 1: Gaps in roof tiles and hanging tiles and around the edges of the dormer windows.

Loft 1: Bats could roost beneath the ridge tiles, within the joints of the internal wooden beam structure or along the ridge line. Loft 2: Beneath roof tiles, along the ridge line or between the

Loft 4: 47 brown long-eared bat droppings were found within this loft space beneath the ridge line (see Figure 5) Loft 5: A single brown long eared bat dropping was found in the south

As in building B1. Though only part of the building is in current use.





External Internal



- 0.5m – 1.5m high, 5m x 4m. Loft 2: Located in the south-east of the building. - Plastic lined. - 3-4m high x 10m x 5m. Loft 3: Is north of loft 2. -“Mansard” roof construction. - Felt lined. - 0.5m high x 8m x 2m. Loft 4: Located in the centre of the building. - Complicated loft space. - Lined with wooden sarking. - 2m high x 8m x 8m. Loft 5: This loft space is located within the newest part of the building in the west of the building. - Bitumen felt lined. - 2.5m high x 25m x 8m.

Loft 2: Gaps in roof tiles, in the gable end of the building and through a grill. Loft 3: Gaps in roof tiles, hanging tiles and through gaps around the dormer windows. Loft 4: Access through gaps in roof tiles, around lead flashing on the edges of the skylight through a roof grille. Loft 5: Access to roof via gaps in lead flashing and broken wooden boarding.

wood and bricks at the gable end of this loft. Loft 3: Between the roof tiles and the felt lining within the loft interior. Loft 4: Beneath the roof tiles, or along the ridge line. Loft 5: Beneath the roof tiles, or along the ridge line.

of the loft space beneath the ridge line (see Figure 5)





External Internal



3 Mental healthcare building. Single storey with tiled roof. The building has 5 dormer windows restricting the size of the loft space. Solid brick wall. Approximately 70 – 80 years old.

This building has one internal loft space (see Loft 6 on Figure 5). Loft 6: An uncomplicated loft space. - A boiler is present. - Internal wooden sarking. - 3m high x 8m x 3m.

The potential access points for the building are shown in Figure 4b. Potential access through grilles on the south and west of the building or via gaps around the dormer windows and around the chimneys.

In the roof void via access from the grilles located on the sides of the building or between the tiles and the wooden sarking that lines the interior of the loft void.

There was no evidence of bats found.

As in building B1. This building is currently not in use.

4 A small wooden garden shed with a felt roof.

N/A None None There was no evidence of bats found.

As in building B1.

5 Small steel shed N/A None None There was no evidence of bats found.

As in building B1.




Emergence Survey Results

4.2.5 No bats were seen to emerge or return to roost at any of the five buildings B1 – B5 during either the dusk or dawn survey.

4.2.6 Surveyor locations are given on Figures 6a and 6b. The surveyor locations were slightly altered for the second set of surveys in light of the results of the first survey and the internal inspection survey. Two of the surveyors (locations 10 and 5) were stationed on the first floor balcony at the rear of building B2 in the second set of surveys.

Incidental Records

4.2.7 During the surveys incidental records of bat activity were recorded at all locations, these records are summarised in table 9 and in Appendix 3, and observed bat passes are shown on Figures 6a and 6b. Bat activity throughout the site ranged from very low to low.

4.2.8 The bat species recorded were:

• Common pipistrelle (Pipistrellus pipistrellus);

• Soprano pipistrelle (Pipistrellus pygmaeus);

• Brown long-eared (Plecotus auritus); and

• Noctule bat (Nyctalus noctula)


Desk Study, Phase 1 Habitat Survey and Bat Survey _________________________________________________________________________________

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4.3 LEGAL AND PLANNING POLICY ISSUES

4.3.1 The content of the legislation and planning policy section are the legal and planning policy issues that we know are relevant based on this bat survey.

4.3.2 As set out in Appendix 4, bats and their roost are strictly protected by a range of legislation and policy, including the following:

• Conservation (Habitats &c) Regulations 1994;

• Wildlife and Countryside Act 1981, as amended;

• Countryside and Rights of Way Act 2000;

• Natural Environment and Rural Communities Act 2006;

• Planning Policy Statement 9; and

• UK Biodiversity Action Plan.

4.3.3 In addition bats are protected by regional and local level planning policy. Policy NRM5 of the South East Plan (2009) seeks to avoid a net loss of biodiversity and actively pursue opportunities to achieve a net gain across the region through avoidance, protection and biodiversity improvement. Policy D5 of the Waverley Borough Council Local Plan states that “it will not permit development that would materially harm a protected species of animal or plant, or its habitat”.

4.3.4 Seven species of bats; barbastelle (Barbastella barbastellus), Bechstein’s (Myotis Bechsteini), greater horseshoe (Rhinolophus ferrumequinum) and lesser horseshoe (Rhinolophus hipposideros), brown long-eared (Plecotus auritus), noctule (Nyctalus noctula) and soprano pipistrelle (Pipistrellus pygmaeus) are priority species in the UK Biodiversity Action Plan (HM Government 1994 et seq.). The UK Biodiversity Action Plan was published in response to the 1992 International Convention on Biological Diversity.

4.3.5 As priority species in the UK Biodiversity Action Plan, these species are also Species of Principal Importance for nature conservation in England under Section 41 of the Natural Environment and Rural Communities Act 2006. This places a duty on all government departments to have regard for the conservation of these species and on the Secretary of State to further, or promote others to further, the conservation of these species.

4.3.6 As buildings B4 and B5 have a negligible potential for supporting roosting bats there are no known legal or planning policy issues regarding bats and the development.



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4.3.7 No bats were seen to emerge from building B1 during the two dusk emergence surveys undertaken on the 11th August 2009 and the 27th August 2009. In addition a very low level of activity was recorded around this building during the two survey visits. Therefore there are no known legal or planning policy issues regarding bats and the demolition of this building.

4.3.8 No bats were seen to emerge from or return to roost at building B3 in either of the dusk emergence / dawn return to roost surveys undertaken on 11th – 12th August 2009 and the 27th – 28th August 2009. Therefore there are no known legal or planning policy issues regarding bats and the demolition of this building.

4.3.9 Building B2 was confirmed as a roost by the presence of droppings in loft 4 and 5 (see Figure 5), and as such further development may only occur under licence from Natural England. Without mitigation and licensing, the development would contravene the legislation and policy set out above with respect to bats. The planned development works could result in harm to individual bats and the loss of roosts present within building B2. However, using established techniques it should be possible to:

• Avoid harm to individual bats during the development; and

• Maintain the population of bats at a favourable conservation status through the creation of replacement roosting opportunities.

4.3.10 To comply with planning policy, the mitigation measures outlined in Section 4.4 should be adopted as part of the development proposal. Once planning permission has been granted, a licence will need to be obtained from Natural England in order for the mitigation measures to be legally implemented and the development to proceed legally.

4.4 RECOMMENDATIONS

4.4.1 It is understood from the development proposal that buildings B1 and B3 are to be entirely demolished. The original hospital building (comprising the northern section of building B2) will be retained and the “Victorian extensions” are to be remodelled. The most recent extensions to this building will be demolished. A new hospital facility is to be constructed in place of the demolished buildings and incorporated into the remaining existing structures. These works are likely to disturb the bat roosts on site hence, without mitigation, will constitute an offence under the legislation protecting bat species and their roosts.



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Recommendations for Mitigation

4.4.2 In order to comply with the relevant legislation, all activities, which may result in the killing and injury of bats and the disturbance or destruction of a bat roost, may only occur under a European Protected Species Licence (EPSL) granted by Natural England.

4.4.3 EPSL applications for works affecting bats are subject to very close scrutiny and must satisfy regulations set out in the Conservation (Natural Habitats, &c.) Regulations 1994 that;

• The actions are essential for ‘imperative reasons of overriding public interest’;

• ‘There is no satisfactory alternative’; and

• ‘The action authorised will not be detrimental to the maintenance of the population of the species conserved at a favourable conservation status in their natural range’.

4.4.4 The EPSL application must demonstrate compliance with these regulations and be accompanied by a detailed Reasoned Statement and a Method Statement which sets out a mitigation strategy to ensure the proposed development is not detrimental to the favourable conservation status of bats in their natural range.

4.4.5 Loft space 4 in building B2, where the majority of the brown long-eared bat droppings were recorded, is to be completely remodelled during the proposed development works. Loft space 5 is to be demolished. It is therefore recommended that a Method Statement should be prepared in support of an EPSL application detailing how the risk of killing or injuring individual bats will be minimised, and how the bat roosts will be either conserved or replaced. The statement should cover all activities with the potential to affect the bat roosts and bat activity on site.

4.4.6 It is recommended that the following elements are included or given consideration in the method statement:

• Exclusion of bats from the existing roost prior to removal, or removal of existing roost when bats are least likely to be present;

• Provision of permanent, alternative roosting opportunities for bats, to replace those being removed to allow redevelopment. New roosts must be suitable for the species and numbers of bats known to use the existing roosts;



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• Bats should not be left without a roost (during the summer season for maternity roosts etc.) and time should be allowed for bats to locate the alternative roost;

• Disturbance to existing roosts should be minimised, for example changes in noise and lighting during, and following, development phases;

• Flight-lines used by bats using the site should be protected; and

• All site workers associated with the development of the site must be informed of the presence of a bat roost and briefed to undertake actions in line with the Method Statement protecting the bat roost within the building.

Opportunities for Enhancement

4.4.7 The following enhancements could be carried out specifically for bats in order to comply with PPS9, Policy NRM5 of the South East Plan (2009) and Policy D5 of the Waverley Borough Council Local Plan:

• Purpose built wall cavities and access points, suitable for roosting bats, could be included into the design of the new building in order to increase the roosting opportunities for bats on site;

• Bat boxes could be secured to the outside of the new building to increase the number of roosting opportunities on site;

• Nectar-rich plants with flowers that are scented at night (e.g. honeysuckle) could be used in any landscaping in order to enhance bat foraging opportunities (by attracting insects); and

• Low pressure sodium lights and high pressure sodium lights could be used instead of mercury and metal halides to reduce the impact of light pollution on commuting bats; light spillage can be further reduced through the use of luminaires or directional light accessories.

Further Survey

4.4.8 In order to further inform the EPSL application to Natural England an additional dusk emergence and dawn return to roost survey of building B2 should be undertaken to gain additional information about the roosts present including number of bats using the roosts, the species of bats present and



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the seasonality of the roosts. The further survey should be carried out next year (2010) between mid May and August.

4.5 CONCLUSION

4.5.1 The internal inspection survey has shown that parts of the old hospital building (lofts 4 and 5 of building B2) have been confirmed to support roosting bats. Due to the high level of protection afforded to all bat species, works which would otherwise lead to an offence may only be conducted under licence from Natural England.

4.5.2 It is recommended that a further survey of the building is undertaken and an EPSL is sought prior to the commencement of the development. Providing the development affecting the known bat roosts is conducted under licence the development should comply with the relevant legislation and planning policy regarding bats.



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5 REFERENCES 5.1.1 Bat Conservation Trust (2007). Bat Surveys, Good Practice Guidelines.

BCT, London.

5.1.2 British Standard 5837 Trees in Relation to Construction.

5.1.3 Collingwood Environmental Planning and Land Use Consultants (2009) South East Plan. South East England Regional Assembly.

5.1.4 HM Government (2005) Planning Policy Statement 9 - Biodiversity and Geological Conservation.

5.1.5 HM Government (2005) Government Circular: Biodiversity and Geological Conservation – Statutory obligations and their impact within the planning system.

5.1.6 HM Government (2006) Planning for Biodiversity and Geological Conservation – A Guide to Good Practice.

5.1.7 Institute of Environmental Assessment (1995) Guidelines for Baseline Ecological Assessment. E & FN Spon, London.

5.1.8 JNCC (1993) Handbook for Phase 1 habitat survey: A technique for environmental audit. Joint Nature Conservancy Committee, Peterborough.

5.1.9 Mitchell-Jones, A.J. & McLeish, A.P. (1999). Bat Workers' Manual (2nd Edition). Joint Nature Conservancy Committee, Peterborough

5.1.10 Mitchell-Jones (2004) Bat Mitigation Guidelines. English Nature, Peterborough

5.1.11 Russ, J. (1999). The Bats of Britain and Ireland. Alana Ecology, Shropshire.

5.1.12 Stace C (1997) New Flora of the British Isles (second edition). Cambridge University Press, Cambridge.

5.1.13 Waverley Borough Council (2002) Waverley Local Plan (saved policies)



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6 APPENDIX 1 6.1 IDENTIFICATION OF LEGAL AND PLANNING POLICY ISSUES IN ENGLAND

Scope of Assessment

6.1.1 The first step is to identify any biodiversity features found on the site that are subject to legal or policy controls, as follows:

Designated Sites

6.1.2 The location of the site is compared to the distribution of sites with a statutory or non-statutory nature conservation designation using information derived from the desk study. Consideration is given to designated sites that could be affected directly or indirectly by the proposed development.

Habitats outside Designated Sites

6.1.3 The habitats known to occur on the site are compared to those which receive some protection, in law or policy, outside of designated sites i.e. hedgerows, uncultivated land and semi-natural areas, habitats listed as Priorities in the UKBAP, habitats listed as Habitats of Principal Importance for the Conservation of Biodiversity by the Secretary of State and habitats listed as requiring action in the Local Biodiversity Action Plan.

Ancient Woodland

6.1.4 The ancient woodland inventory is checked to determine whether any known ancient woodland occurs either on the site or nearby.

Protected Species

6.1.5 The species known to occur on the site as a result of the desk study and Phase 1 habitat survey are compared with those listed in nature conservation legislation i.e. the Wildlife and Countryside Act 1981, as amended, the Conservation (Habitats &c) Regulations 1994.

6.1.6 In addition, the species known to occur on the site as a result of the desk study and Phase 1 habitat survey are compared with those listed in animal welfare legislation, i.e. the Badgers Act 1992 and the Wild Mammals (Protection) Act 1996.

Biodiversity Action Plan Priority Species

6.1.7 The species known to occur on the site are compared with those listed as Priorities in the UKBAP, Species of Principal Importance for the Conservation of Biodiversity by the Secretary of State or requiring action in the Local Biodiversity Action Plan.



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Other Species of Conservation Concern

6.1.8 The species known to occur on the site are compared with other nature conservation listings, such as red data books.

Invasive Plant Species

6.1.9 The species of plant present on the site are compared with those listed by government agencies as invasive non-natives, with particular attention given to those listed in the Wildlife and Countryside Act.

Review of Legislation and Policy

6.1.10 If any of the above are found to occur on or near the site and are likely to be affected by the development in any way, the relevant legislation and planning policy (including national, regional, county and borough policies) are examined to determine whether the proposed development is compliant.

Ecological Enhancement

6.1.11 Planning policy generally requires new developments to be enhanced for biodiversity. The existing proposals are considered to determine whether biodiversity enhancements are offered and whether they are adequate to meet the policy requirements. Again, national, regional, county and borough policies are considered.

6.2 IDENTIFICATION OF POTENTIAL FURTHER ECOLOGICAL ISSUES

6.2.1 Further ecological issues are those which can not be resolved during the desk study and extended Phase 1 habitat survey for any reason, including the following:

• The development is near a designated site and consultation with the relevant regulator is required in order to determine whether further assessment is required;

• Suitable habitat is present on or near the site for a protected species/species of conservation concern and specialist survey techniques are required for their detection;

• Suitable habitat is present on or near the site for a protected species/species of conservation concern and the extended Phase 1 habitat survey was not undertaken at a suitable time of year for their detection;

• A protected species/species of conservation concern was found on or near the site but further information on population size or



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distribution is required in order to resolve any legal and planning policy issues (such as obtaining licences).

6.2.2 Discussion of issues raised by 3rd parties, e.g. reports of protected species from the site by local people, may also be discussed under this heading.

6.2.3 The desk study is used as a guide to the protected species/species of conservation in the local area, however, the list is not taken to be exhaustive and it is borne in mind that some species may no longer occur in the locality.

6.2.4 No attempt is made to evaluate the importance of the site for species not yet confirmed to be on or near the site, nor to discuss the implications for the development if the species were to be found on the site.



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7 APPENDIX 2 7.1 PHASE 1 HABITAT SURVEY SPECIES LIST

Scattered broad leaved trees – SBW1

Common Name Species Name DAFOR

Ash (Y) Fraxinus excelsior R

Italian Maple Acer opalus R

Yew Taxus baccata O

Sycamore Acer pseudoplatanus O

Cherry Prunus sp. R

Amenity grassland – AM1


Perennial rye-grass Lolium perenne D

Dandelion Taraxacum agg. F

Ivy Hedera helix R

Yorkshire fog Holcus lanatus O

Prickly lettuce Lactuca serriola R

Red dead nettle Lamium purpureum R

Greater plantain Plantago major O

Self heal Prunella vulgaris O

Procumbent yellow sorrel Oxalis corniculata O

Common chickweed Stellaria media O

White clover Trifolium repens O

Creeping thistle Cirsium arvensis R

Amenity grassland – AM2


Red fescue Festuca rubra F

Common nettle Urtica dioica R

White clover Trifolium repens F

Dandelion Taraxacum agg. F

Creeping buttercup Ranunculus repens LA

Perennial rye-grass Lolium perenne A

Common mallow Malva sylvestris O

Dove’s foot crane’s bill Geranium molle O



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Daisy Bellis perennis F

Yarrow Achillea millefolium F

Amenity grassland – AM3 Common Name Species Name DAFOR

Red fescue Festuca rubra A

Yorkshire fog Holcus lanatus F

Perennial rye-grass Lolium perenne A

Dandelion Taraxacum agg. O


Ribwort plantain Plantago lanceolata O

Self heal Prunella vulgaris O

Common bird’s-foot trefoil Lotus corniculatus R

Introduced shrub – IS1


Pansy Viola sp. O

Fennel Foeniculum vulgare O

Ivy Hedera helix O

Hedge bindweed Calystegia sepium R

Bramble Rubus fruticosus R

Cherry Prunus sp. R

Holly Ilex aquifolium O

Cherry laurel Prunus laurocerasus O

Fuchsia Fuchsia sp. R

Oleria Oleria sp. O

Spearmint Menthe spicata O

Cotoneaster Cotoneaster horizontalis O

St John’s wort Hypericum sp. O

Lavender Lavendula sp. O

Honeysuckle Lonicera sp. O

Passion flower Passiflora caerulea O

Skimmia Skimmia sp. F

Hebe Hebe sp. O

Hollyhock Alcea sp. F

Privet Ligustrum ovalifolium O



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Montbretia Crocosmia x crocosmiiflora O

Allium Allium sp. O

Clematis Clematis sp. O

Camellia Camellia sp. O

Bamboo Arundinaria sp. R

Broad leaved willowherb Epliobium montanum O

Mahonia Mahonia sp. R

Fatsia Fatsia sp. R

Species-poor hedgerow – PH1


Cotoneaster Cotoneaster horizontalis D

Sycamore (Y) Acer pseudoplatanus O

Bare ground / ephemeral short perennial mosaic – BG/ESP1


Dandelion Taraxacum agg. O

Groundsel Senecio vulgaris R

Ephemeral short perennial / amenity grassland mosaic – ESP/AM1


Dandelion Taraxacum agg. A

Creeping cinquefoil Potentilla reptans F

Creeping buttercup Ranunculus repens O

Procumbent yellow sorrel Oxalis corniculatus LD


Daisy Bellis perennis O

Self heal Prunella vulgaris F

Perennial rye-grass Lolium perenne LA


Desk Study, Phase 1 Habitat Survey and Bat Survey


8 APPENDIX 3 8.1 TABLE 9: INCIDENTAL BAT RECORDS

Incidental results of return to roost survey Date Surveyor Location

Details of bats emerging from building Species and description of behaviour Overall level of activity

((Passes / survey time) 100)

1 No bats were seen to emerge

No bats were recorded at this survey location. 0


15 passes of a common pipistrelle (Pipistrellus pipistrellus) commuting and foraging around building B3.

12.5 = low

13 passes of a common pipistrelle commuting around the south of building B2. 10.83 = low 3

No bats were seen to emerge

2 passes of a brown long eared bat (Plecotus auritus) commuting around the southeast of building B2.

1.67 = very low


19 passes of a common pipistrelle foraging and commuting around the north of building B2. 15.83 = low

12 passes of a common pipistrelle foraging within the central courtyard of building B2. 10 = low

11/08/09 (dusk)


2 passes of a soprano pipistrelle (Pipistrellus pygmaeus) foraging and commuting in the same location.

1.67 = very low







6 No bats seen to return to roost

3 passes of a common pipistrelle commuting in the vicinity of building B3. 3.33 = very low

4 passes of a common pipistrelle commuting in the open at the south of building B2. 4.44 = very low

2 passes of a brown long eared bat commuting around the south of building B2. 2.22 = very low


5 passes of a soprano pipistrelle commuting around the south of building B2. 5.55 = low

19 passes of a common pipistrelle commuting along the south east of building B2. 21.1 = low 8 No bats seen to return to roost

6 passes of a brown long eared bat commuting along the south east of building B2. 6.67 = low

12 passes of a common pipistrelle commuting along building B2. 13.33 = low

1 pass of a noctule bat (Nyctalus noctula) commuting over the building. 1.11 = very low


2 passes of a brown long eared bat along the northern edge of building B2. 2.22 = very low

7 passes of a common pipistrelle commuting within the courtyard at the rear of building B2. 7.78 = low

2 passes of a brown long eared bat. 2.22 = very low

12/08/09 (dawn)


4 passes of a soprano pipistrelle circling the courtyard. 4.44 = very low


2 passes of a noctule bat commuting over the building B1. 1.67 = very low

7 passes of a common pipistrelle commuting and foraging around building B3. 5.83 = low

1 pass of a soprano pipistrelle commuting past building B3. 0.83 = very low

27/08/09 (dusk)


2 passes of a noctule bat commuting overhead. 1.67 = very low







12 passes of a common pipistrelle commuting and foraging along the south of building B2. 10 = low 3 No bats were seen to emerge 10 passes of a noctule bat foraging to the south of the site. 8.33 = low

11 passes of a common pipistrelle foraging and commuting around the north of building B2. 9.17 = low 4 No bats were seen to emerge 7 passes of a noctule bat commuting overhead. 5.83 = low

1 pass of a brown long-eared bat within the courtyard of building B2. 0.83 = very low

4 passes of a common pipistrelle commuting and foraging within the courtyard of building B2. 3.33 = very low


7 passes of a noctule bat commuting overhead. 5.83 = low


Recording equipment failure though incidental records are likely to have been similar to locations 9 and 10.

N/A

2 passes of a common pipistrelle commuting over the courtyard of building B2. 2.22 = very low 7 No bats seen to return to roost 3 passes of a soprano pipistrelle commuting over the courtyard of building B2. 2.5 = very low

11 passes of a common pipistrelle commuting in the north of building B2. 12.22 = low 8 No bats seen to return to roost 1 pass of a commuting soprano pipistrelle. 1.11 = very low


8 passes of a common pipistrelle around building B2. 6.67 = low

1 pass of a brown long-eared bat commuting over building B2. 1.11 = very low

28/08/09 (dawn)

10 No bats seen to return to roost 6 passes of a common pipistrelle foraging in the courtyard of building B2. 6.67 = low




9 APPENDIX 4 - BRITISH BATS 9.1 INTRODUCTION

9.1.1 A summary of the biology of British bats, the legislation that protects them and other mechanisms of highlighting species of conservation concern is provided below. For further information, the relevant source documents should be consulted.

9.2 BIOLOGY

9.2.1 There are seventeen British species of bats of two families, the horseshoe bats (Rhinolophidae) and vesper bats (Vespertilionidae). In Britain, there are two species of horseshoe bat both of which belong to the genus Rhinolophus, and the fifteen species of vesper belonging to six genera (Myotis, Eptesicus, Nyctalus, Pipistrellus, Plecotus and Barbastella). Whilst there are many differences in the biology of the different species, all share certain characteristics and these are described below.

Roosting

9.2.2 Bat species utilise roost sites of varying character; some preferring tree roosts whilst others are thought to be almost entirely dependent on built structures. Most bats will have a range of available roosting sites within their range which they move between throughout the year. They are generally faithful to their roosts and a colony of bats may use the same roost site(s) year after year.

9.2.3 In winter bats hibernate, often animals gather to hibernate communally remaining in the same hibernation roost from November to February/March. Hibernation roost sites typically have a constant low temperature and high humidity levels, sites include caves, mines, thick walled buildings and hollow trees. As the temperature and day length increase in spring bats leave their hibernation roosts, either moving immediately to summer roost sites or utilising occasional, transitional roosts.

9.2.4 By June breeding females congregate in maternity roost sites where they will give birth to, and nurture young. Male bats are also occasionally found roosting in maternity roosts but during this period they mostly roost alone. Maternity roost sites include hollowed out trees, buildings and bridges. Male bats may use similar sites but also cracks and crevices in trees, under loose tiles or even amongst dense ivy growth during the summer period. Similar sites may be used by bats for brief periods during the night when they are resting or eating recently caught prey. In autumn, male bats establish mating




roosts and are visited by females and then a variety of roost sites may be used until the bats return to their hibernation roosts.

Foraging

9.2.5 All British bat species feed on invertebrates, with flies, beetles, moths and other insects making up much of their diet. Areas rich in insects are therefore favoured foraging sites for bats, with woodlands, scrub, wetlands, river corridors and flower rich grasslands being favoured foraging habitats. Habitats such as intensively farmed arable land, and amenity grassland support a much lower invertebrate diversity and is therefore unfavourable foraging habitat for bats.

Commuting

9.2.6 Bats favour roost sites in close proximity to suitable foraging habitat, however given variation in prey availability, land-use change, and competition with other bats, for at least part of the year bats must commute between their roosts and foraging habitat.

9.2.7 Commuting routes tend to follow linear features in the landscape such as hedgerows, woodland edges, rivers and other watercourses, particularly when crossing areas of less favourable habitat. The distance that bats commute between roost sites and foraging areas is dependent on local geography and also the species of bat. Some species will travel up to 18km, though shorter distances are more typical.

9.3 SITE DESIGNATION

9.3.1 All bat roosts in the UK receive protection under the following legislation:

• Conservation (Habitats etc.) Regulations 1994 (as amended 2007);

• Wildlife and Countryside Act 1981, as amended;

• The Countryside and Rights of Way Act 2000; and

• Natural Environment and Rural Communities (NERC) Act 2006.

9.3.2 This is described in more detail under ‘Species Protection’ below. In addition, the most important sites for certain bat species in the UK receive further statutory protection by being designated as Special Areas of Conservation (SACs) and or Sites of Special Scientific Interest (SSSIs).

9.3.3 Four bat species, greater and lesser horseshoe, barbastelle and Bechstein’s bats, in the UK are included on Annex II of the European Community




Directive of the Conservation of Natural Habitats and of Wild Fauna and Flora, referred to as the Habitats Directive. The Habitats Directive was transposed into UK law by the Conservation (Natural Habitats etc.) Regulations 1994 (as amended 2007). This legislation requires that areas are designated as Special Areas of Conservation (SACs) to protect populations of these bat species. To date, 23 SACs have been designated specifically to protect these species, with a further 6 SACs where their presence is a qualifying feature but not the primary reason that the site was designated.

9.3.4 Sites designated under the Wildlife and Countryside Act 1981 (WCA) are known as Sites of Special Scientific Interest (SSSIs). SSSIs received further protection under the Countryside and Rights of Way Act 2000 (CRoW).

9.3.5 Some SSSIs are designated for the population(s) of bats that they support. The criteria for selecting SSSIs on the basis of their bat populations are provided in Guidelines for the Selection of Biological SSSIs (NCC, 1989):

• Greater horseshoe bat – all main breeding roosts and all winter roosts with 50 or more adult bats;

• Lesser horseshoe bat - all main breeding roosts containing 100 or more adult bats and all winter roosts containing 50 or more bats;

• Barbastelle, Bechstein’s and grey long-eared bats – any traditional breeding roosts;

• Natterer’s, Daubenton’s whiskered, Brandt’s, serotine, noctule and Leisler’s bats – only exceptionally large breeding roosts or those with a long history of use.

• Mixed Roost sites – all hibernacula containing 4 or more species and more than 50 individuals or 3 species and 100 or more individuals or 2 species and 150 or more individuals, though these criteria may be lower in some parts of the UK.

9.3.6 Sites that qualify as SSSIs for the bat populations they support are considered to be of at least national importance for the bats they support.

9.3.7 Sites designated for nature conservation at the county level may also include bat populations as part of the site qualifying criteria, although the criteria used may vary from county to county. Such sites are protected through the planning system and there is generally a presumption against development that affects such sites in local authority development plans.




9.4 SPECIES PROTECTION

Legislation

9.4.1 Both within and outside designated sites, all bat species are fully protected under the Conservation Regulations 1994 (as amended 2007), the Wildlife and Countryside Act 1981, and Countryside and Rights of Way Act 2000 as amended. Taken together, these make it an offence to:

• Deliberately capture, injure or kill a bat;

• Damage or destroy a breeding site or resting place of a bat;

• Intentionally, deliberately or recklessly damage, destroy, disturb, or obstruct access to any structure or place used for shelter or protection by a bat;

• Possess or control any live or dead specimen or anything derived from a bat, unless acquired lawfully; and

• Sell, barter, exchange or transport or offer for sale bats or part of them.

9.4.2 A roost is any structure or place used by bats for shelter or protection. As bats tend to re-use the same roosts year after year, the roost is protected whether bats are present or not at the time.

9.4.3 In this context, ‘damage’ would include such operations as treatment of wood with toxic preservatives or use of rodenticides near roosting bats while ‘disturbance’ includes any work in or affecting a bat roost.

9.4.4 If proposed actions, such as redevelopment of an existing building may lead to an offence under the above legislation, appropriate mitigation which seeks to avoid these impacts should be devised and implemented under licence from Natural England to allow the activity to proceed legally.

9.4.5 In addition to the above legislation, all bats are protected under the Bonn Convention, within which the Agreement on the Conservation of Bats in Europe (1991) or EUROBAT, establishes a mechanism for international collaboration to conserve bats and their habitats, including foraging habitats. All European bat species are covered under Appendix II of the Conservation of Migratory Species of Wild Animals (CMS).

9.4.6 The Hedgerow Regulations 1997 provide for the conservation of ‘important’ hedgerows and their constituent trees. The presence of a protected species such as bats is included in the assessment of whether a hedgerow is




considered ‘important’ and applications to remove such hedgerows must be made to the planning authority.

Planning Policy

9.4.7 Planning Policy Statement 9 Biodiversity and Geological Conservation (PPS9) gives further direction with respect to biodiversity conservation and land use change / development. PPS9 states that not only should existing biodiversity, including bat species, be conserved but importantly that habitats supporting such species should be enhanced or restored where possible. The policies contained within PPS9 may be material to decisions on individual planning applications.

9.5 UK BIODIVERSITY ACTION PLAN AND SPECIES OF PRINCIPAL IMPORTANCE

9.5.1 Seven species of bats (Barbastelle, Bechstein’s, greater and lesser horseshoe, brown long-eared, noctule and soprano pipistrelle) are listed as Priority species in the UK Biodiversity Action Plan (HM Government 1994 et seq.). The UK Biodiversity Action Plan was published in response to the 1992 International Convention on Biological Diversity.

9.5.2 As a Priority Species in the UK Biodiversity Action Plan, these species are also listed as Species of Principal Importance for the Conservation of Biodiversity in England under Section 41 of the NERC Act 2006. This places a duty on all government departments to have regard for the conservation of these species and on the Secretary of State to further, or promote others to further, the conservation of these species.

9.6 REFERENCES

9.6.1 Altringham, J. (2003) British Bats. New Naturalist Series No. 93.

9.6.2 Bat Conservation Trust (2007). Bat Surveys, Good Practice Guidelines. BCT, London.

9.6.3 Entwistle, A. C., Harris, S., Hutson, A., Racey, P., Walsh, A., Gibson, S., Hepburn, I., and Johnston, J. (2002) Habitat management for bats: A guide for land managers, land owners and their advisors. JNCC, Peterborough.

9.6.4 Highways Agency (1996 et seq) Design Manual for Roads and Bridges, Volume 10 Environmental Design and Management,Section 4 The Good Roads Guide- Nature Conservation, Part 6 Nature Conservation Management Advice in Relation to Bats.

9.6.5 HM Government (1995) Biodiversity: The UK Steering Group Volume 2: Action Plans. JNCC, Peterborough.




9.6.6 HM Government (1998) Tranche 2 Action Plans: Volumes I and II. English Nature, Peterborough.

9.6.7 Mitchell-Jones, A.J. & McLeish, A.P. (1999). Bat Workers' Manual (2nd Edition). Joint Nature Conservancy Committee, Peterborough

9.6.8 NCC (1989) Guidelines for Selection of Biological SSSIs. Nature Conservancy Council, Peterborough

9.6.9 Office of the Deputy Prime Minister (2005) Planning Policy Statement 9; Biodiversity and Geological Conservation.

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