The original Ecological Impact Assessment is here:
"1119.Ecological.Impact.Assessment.November.2021 08.12.2021.pdf"
https://app.box.com/embed/preview/6vgy492d2kd4zlrdd7cts3kgh70ycr6d?direction=ASC&theme=dark
The Revised Ecological Impact Assessment is here:
"Revised - 1119.Ecological.Impact.Assessment.March.2022 - 22.03.22.pdf"
https://app.box.com/embed/preview/hqw128ix3f27uv60gk1q8auh0mjmvrmz?direction=ASC&theme=dark
Sections of interest include the following:
Hedgerows:
4.15 Being generally species-poor none of the hedgerows are not judged to qualify as being ‘important’ under the wildlife and landscape criteria of the Hedgerows Regulations 1997. However, being composed of native species the hedgerowsand trees do qualify as a habitat of principal importance under Schedule 42 of the NERC Act.
4.16 The hedgerows and trees are afforded some value within the context of the application site, mainly for the opportunities provided for foraging bats and nesting birds and their connectively within the wider network outside of the survey area rather than for any particular species-richness.Accordingly, these habitats are judged to be of importance to nature conservation at a local level.
Note that the Tree survey states that almost all of the hedgerows are to be removed.
Bats:
4.27 Following the survey work performed, the application site is judged to be ofimportance to foraging and commuting bats at the site level only.
Badger:
4.29 As the application sitesupports a good range of habitat available for foraging and potential sett building, it is judged to be of value to local Badger populations at the local level.
Great Crested Newts:
4.30 Survey work relating to this protected species is illustrated on Plan GRE 3. Whilst it was not possible to obtain access to the neighbouring ponds at Briarwood as part of this planning application, eDNA survey work conducted in 2019 as part of an adjacent planning application (CB/21/01121/FULL) confirmed eDNA attributed to this protected speciesto be absent.That said, populations are known in the wider area with a low/medium population confirmed to be present within a field pond situated approximately 450m to the south of the application site. However, at this distance, habitat within the application site is unlikely to form part of this populations’ ‘home-range’. Indeed, no sightings were recorded as part of the various reptile surveysperformed in 2018 and 2021.
4.31 In light of the above, the likelihood of encountering this protected species within the application site is judged to be very low.That said, precautionary measures are offeredin the following section.
Note: The statement above claiming that it was not possible to gain access has been shown to be false. [OPINION] It is more likely that that the applicant was did not wish to carry out a survey because of the likelyhood of finding Great Crested Newts. [/OPINION]
Birds:
4.36 Overall, it is judged that the application siteisof importance for breeding and foraging birdsat the local level only with comparable areas of habitat located in the immediate surrounding area.
Reptiles:
4.37 No reptiles were found following the specific survey work conducted in 2019 and 2021. As such, the application site is judged to be of negligible/low value for this faunal group. However, suitable avoidance measures are recommended in the following section on a precautionary basis.
Hazel Dormouse:
4.38 Whilst no records for Hazel Dormice were returned as part of the data search, consideration has been given to the likelihood of encountering this protected species within the application site.
4.39 The hedgerows within the application site are managedon a regular basisand tend tolack the structural diversity that is favoured by this protected species. Moreover, the favoured woody species are also generally absent. Habitat connectivity with other areas of suitable habitat outside of the application site is also verypoorsuch thatthe likelihood of encountering Hazel Dormice is judged to be very low. Accordingly, no further consideration is given to this protected species within this ecological impact assessment.
Adjacent Habitats:
The revised assessment has increased the importance of 2 adjecacent habitats:
Orchard BAP habitat to the immediate north of the application site.
In the November document was listed as:
This adjacent habitat is judged to be of medium value (County-level importance) on account of its BAP status.
In the Revised March Document:
This adjacent habitat is judged to be of importance at the County levelon account of its BAP status.
Briarwood ponds:
In the November document was listed as:
Accordingly, its ecological value is judged to be of low-medium value (local-level importance).
In the Revised March Document:
Accordingly, they are judged to be of importance to nature conservation at the site/locallevel.
Those areas are immediately adjacent to, but outside of the site area. The council's ecologist highlighted the importance of these areas in the previous consultation. The fact that these have now had to be updated brings into question the rest of the content and claims made in this so called ecological assessment.
Impacts:
Despite the importance of the site's habitats for the above species, the potential impacts are then played down in the next section:
5.IMPACTS, MITIGATION AND ENHANCEMENTS
Habitats
Potential Impacts5.1 Overall, the application siteis considered to be of low value in ecological terms, being dominated by agricultural land under intensive management.
5.2 The proposals would resultin the loss of the arable habitat as well as removal of some lengths of hedgerow and associated trees to facilitate vehicular access off Toddington Road and Westoning Road. All remaining habitats (hedgerows, ditches and trees) would be retained.
5.3 In the absence of mitigation, the retained habitats (hedgerows, trees and drainage ditches) could suffer physical damage as well as impacts from dust deposition, contaminated run-off and other pollution sourcesduring the construction phase and this could lead to an adverse impact of minor–moderate significance.Adjacent habitats (widerdrainage ditch network, adjacent ponds and orchard habitat off Westoning Road) could be equally adversely affected.
5.4 In terms of the operation of the proposals, the absence of appropriate management could lead to a general decline in the ecological value of the retained and new habitats–an adverse impact of minor significance.
The Residual impacts section quoted below even goes on to claim a net gain in biodiversity of at least 12%!!
[OPINION] How can the destruction of 18 hectares of field, mature hedgerows and trees and then with covering the area with houses, roads and concrete possibly even come close to providing any form of biodiversity net gain? [/OPINION]
6.RESIDUAL IMPACTS
Habitats6.1 In terms of biodiversity net gain, completion of DEFRA’s Biodiversity Metric 3.0 confirms that the proposalsat this outline planning stagecanachieve a measurable habitat net gain of at least 12% based on the submitted Land Use Parameter Plan (see below). This calculation has assumed that 50% of the green spaces are given to species-rich grassland (or other equivalent habitat), 20% of the residential development area is garden and 50% of the school area represents amenity grassland. In terms of hedgerow net gain, the calculations have shown that anything beyond 300m of new native hedgerow planting would achieve a 10% net gain.
6.2 Further gains would be achieved at the detailed design stageand implementation of a Landscape and Ecological Management Planwould secure further long-term gains for biodiversity.
6.3 Following the aforementioned precautions during construction, together with the intrinsic design measures already incorporated into the proposals and recommendations for further detailed design and future management, it is judged that habitats within the application sitewould achieve a minor-moderate beneficial enhancement.
Reading on from section 6.3 above reveals even more fantastic claims about "no residual adverse impacts" or even "beneficial residual impact" to the variouse species listed previously.