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or used without our prior written agreement for any purpose other than the purpose indicated in this report. This report was
prepared by Colmer Ecology ltd at the instruction of, and for use by, our client named on the front of the report. This report
is not to be used by any third part without the written agreement of Colmer Ecology ltd. We disclaim any responsibility to
the client and others in respect of any matters outside the scope of the above. We accept no responsibility of whatsoever
nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their
own risk.
Reference: RCHT, West Cornwall Hospital – EcIA Report Report Prepared by: Mr J. Hawksley BSc (Hons)
PhD ACIEEM
Position: Assistant Ecologist
Mr H. Colmer BSc (Hons)
Dip MCIEEM FLS
Position: Director/Associate Ecologist
Report Reviewed by: Mr H. Colmer BSc (Hons)
Dip MCIEEM FLS
Position: Director/Associate Ecologist
Dr J. Rabineau BSc (Hons)
PhD ACIEEM
Position: Senior Ecologist
Date 23/09/2021 Report Issue No: 1 – DRAFT
Date 19/10/2021 Report Issue No: 2 - FINAL
File Reference: 2021-46_R_RCHT, West Cornwall Hospital – EcIA
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Summary
An ecological impact assessment (EcIA) was undertaken of land and buildings at RCHT, West
Cornwall Hospital, Penzance, Cornwall. The proposals were for the redevelopment of the
hospital to include demolition of the existing cottages and construction of new outpatient
facilities. In addition, re-arrangement of the existing car park, the creation of a two-storey link
from the new outpatient facilities to the current hospital building, as well as impact to habitats
for potential services routing from the boiler rooms/plant space.
The EcIA comprised two main elements. Stage 1 was a preliminary ecological appraisal (PEA)
including a biological desk study, a phase 1 habitat survey with a protected species habitat
assessment, a preliminary ground level bat tree roost assessment and a protected species
building assessment. Stage 2 comprised a bat roost characterisation survey undertaken due to
the evidence of, and potential for, protected species noted during the Stage 1 PEA. In addition,
a Biodiversity Net Gain (BNG) calculation was completed, following the DEFRA Small Sites
Metric (SSM) (JP040).
Located approximately 900 m north-west of Penzance town centre, the land and buildings
were approximately 0.3 ha in size and surrounded by residential properties with Penalverne
Drive forming the eastern boundary, with St Clare Street to the north, Parc Wartha Avenue to
the west and Parc Wartha Crescent to the south. The wider landscape comprised Penzance and
residential properties with pastoral fields connected by woodland and mature hedgerows
further to the west and north.
All habitat types were mapped, with the dominant habitats being hardstanding and buildings,
with the addition of amenity grassland, introduced shrub, intact species poor hedge and
scattered trees.
As a result of a single bat observed roosting in situ within the cottages during the Stage 1 PEA,
and further bat roost potential, a Stage 2 bat roost characterisation survey was conducted
between July and August 2021. No bats were recorded emerging/re-entering during the Stage
2 survey.
Due to the numbers of bats, the amount of evidence recorded during Stage 1 and subsequent
Stage 2 bat survey results, the cottages were considered to be an infrequent day, non-breeding
roost for single/low numbers of common pipistrelle bats.
The development works will result in the destruction (demolition) of the roost, with the
potential to kill/injure and disturb bats during some of the works, as well as disturbance, and
therefore, a European protected species licence was considered necessary.
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Mitigation and compensation measures for the loss/alteration of the bat roost was proposed,
which, if followed, would ensure that the favourable conservation status is maintained for this
bat species with the continued ecological functionality of its roost.
Evidence of breeding birds was noted during the Stage 1 PEA, and therefore, suitable mitigation
and enhancements measures have been recommended and will be adopted during the
development/demolition works.
In the absence of mitigation measures, the proposed development was considered likely to
have, at worst, long-term, adverse effect at the ‘Site’ level. However, by following the proposed
mitigation and precautionary measure, the development was not considered to have any
significant residual effect to important ecological features within or adjacent to the land and
buildings at RCHT. Provided the proposed mitigation, compensation and enhancement
measures are followed, the development was considered to be consistent to relevant
conservation legislation, National Planning Policy Framework (2021) and local policies. In
addition, an increase above 10 % biodiversity net gain was calculated.
This report is valid for a period of 12 months from the date of the last survey.
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1.0 Introduction
1.1 Colmer Ecology was commissioned by Kier Construction Limited to undertake an
ecological impact assessment (EcIA) of land and buildings at RCHT, West Cornwall Hospital,
Penzance, Cornwall, hereinafter referred to as the Site. The EcIA comprised two main
elements. Stage 1 was a preliminary ecological appraisal (PEA) including a biological desk
study, a phase 1 habitat survey with protected species habitat assessment, a preliminary
ground level bat tree roost assessment and a protected species building assessment (PSBA).
Stage 2 comprised a bat roost characterisation survey undertaken due to the evidence of,
and potential for, protected species noted during the Stage 1 PEA. In addition, a Biodiversity
Net Gain (BNG) calculation was completed, following the DEFRA Small Sites Metric (SSM)
(JP040).
1.2 It is understood that proposals for the redevelopment of the hospital include the demolition
of the existing cottages and construction of new outpatient facilities. In addition, re-
arrangement of the existing car park, the creation of a two-storey link from the new
outpatient facilities to the current hospital building, as well as impact to habitats for
potential services routing from the boiler rooms/plant space.
Site Description
1.3 The Site was approximately 0.3 ha in size and located at National Grid Reference (NGR) SW
46878 30625, approximately 900 m north-west of Penzance town centre. The Site was
surrounded by residential properties with Penalverne Drive forming the eastern boundary,
with St Clare Street to the north, Parc Wartha Avenue to the west and Parc Wartha Crescent
to the south. The wider landscape comprised Penzance and residential properties with
pastoral fields connected by woodland and mature hedgerows further to the west and
north.
Scope of Surveys
1.4 The objectives were to:
Stage 1
• Carry out a biological desk study within 1 km of the Site;
• Carry out a phase 1 habitat survey and map all habitat types within the Site and
where possible, described those immediately adjacent;
• Carry out a protected species habitat assessment;
• Carry out a preliminary ground level bat tree roost assessment; and
• Carry out an internal and external protected species building assessment,
specifically for bats and birds.
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Stage 2
• Carry out a bat roost characterisation survey in the form of three evening
emergence surveys;
• Propose suitable mitigation where necessary and advise on the need for any
European protected species licences or translocation; and
• Complete a BNG calculation following the DEFRA SSM (JP040).
Scope of Evaluation/Assessment of Ecological Features
1.5 The following were considered regarding the findings from the baseline ecological survey,
and the evaluation and assessment of impacts:
Evaluation
• Evaluate the significance of ecological features using criteria set out by the
Chartered Institute of Ecology and Environmental Management (CIEEM, 2018)
based on a geographical scale of importance from Negligible to International and
European (i.e. high importance).
Impact Assessment
• Assess whether important ecological features will be subject to impacts, to
characterise these impacts and their effects.
Mitigation, Compensation, Enhancement and Monitoring Measures
• Propose suitable mitigation/compensation/enhancements where necessary and
advise on the need for any European protected species licences; and
• Set out the requirements for post-construction monitoring.
Residual Effects
• To provide an assessment of the significance of any residual effects following
development.
Legislation and Planning Context
1.6 Although it was not the purpose of this report to present legislation and planning context in
relation to the proposal, their applicability was explained where appropriate.
1.7 The following wildlife legislation and policy was considered:
• The Conservation of Habitats and Species Regulations (as amended) 2017
amended by The Conservation of Habitats and Species (Amendment) (EU exit)
Regulations 2019;
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• The Wildlife and Countryside Act 1981 (WCA) (as amended);
• The Countryside and Rights of Way Act 2000 (CRoW);
• The Natural Environment and Rural Communities Act 2006 (NERC);
• National Planning Policy Framework 2021 (NPPF); and
• Any Cornwall Biodiversity Action Plan(s) (BAP).
1.8 This report was written following the Chartered Institute of Ecology and Environmental
Management (CIEEM) guidelines for ecological report writing (2017a). Relevant Site plans
and landscape plans were provided where necessary for review.
Caveat
1.9 It should be noted that a phase 1 habitat survey does not aim to identify all botanical species
within a site, or constitute a full contaminated land/invasive species assessment. In addition,
protected species can be highly mobile and can be found in buildings/structures or habitats
at any time of year. Although Colmer Ecology is confident in the survey results, we cannot
ensure that protected species will/will not be present on Site at any other time. Descriptions
of Site conditions and photographs are based on the Stage 1 PEA survey undertaken in May
2021 with updates during Stage 2 survey. In addition, assessments of ecological impacts
were based on the information supplied by Kier Construction Limited and/or the associated
design team.
Nomenclature
1.10 For ease, common names were used throughout this report, however, where no common
name existed or it was not possible to identify to species level, genus/family names were
used. Details of indicative Latin names were provided in Appendix 1.
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2.0 Methodology
2.1 Stage 1
Biological Desk Study
2.1.1 Following guidance produced by the CIEEM (2017b), records of statutory and non-statutory
designated sites, ‘Priority Habitat Inventory’ areas, ancient woodland and granted European
protected species licence (EPSL) applications were reviewed from the government-based
website MagicMap within a 1 km desk study area based on the central grid reference SW
46878 30625. Colmer Ecology’s own biological records, protected species licences and
knowledge of local ecological designations were also reviewed. In addition, records of
statutory and non-statutory designated habitats and protected or noteworthy species were
sought from the Environmental Records Centre for Cornwall and the Isles of Scilly (ERCCIS)
within a 1 km desk study area.
Phase 1 Habitat Survey
2.1.2 The Site was subject to a phase 1 habitat survey on 18th May 2021 by Mr H. Colmer BSc
(Hons) Dip MCIEEM1 FLS2 a Natural England licensed3 associate ecologist. Each habitat
present within, and where possible, surrounding the Site was mapped in accordance with
the, ‘Handbook for Phase 1 Habitat Survey – a Technique for Environmental Audit’ (Joint
Nature Conservation Committee, 2010 [Revised in 2016 with minor corrections]). Habitats
and features of interest were described, with botanical species recorded. In addition, a
colour coded habitat map (Figure 1) and annotated photographs of the Site were produced.
Non-native invasive species were also identified (where possible) and mapped where
appropriate.
Protected Species Habitat Assessment
2.1.3 The Stage 1 PEA also included an assessment of the potential for the Site to support
protected species due to the habitat types present. This was based on professional
experience, but also reviewing industry standard habitat assessment methodologies,
however, the Stage 1 PEA did not include any specific survey methods designed to
demonstrate presence/likely absence of protected species themselves.
Preliminary Ground Level Bat Tree Roost Assessment
2.1.4 Any tree likely to be impacted by the proposed works was subject to a preliminary ground
level bat tree roost assessment by Dr J. Rabineau BSc (Hons) PhD ACIEEM4 (bat class 2 survey
licence and registered bat mitigation class [low impact] licence consultant Annex B and D)
following methodology described in Bat Conservation Trust (BCT), Bat Surveys for
1 Full Member of the Chartered Institute of Ecology and Environmental Management (MCIEEM) 2 Fellow of the Linnaean Society (FLS) 3 Great crested newt licence. Barn owl licence. Dormouse licence. Accredited agent under bat licence. 4 Associate Member of the Chartered Institute of Ecology and Environmental Management (ACIEEM)
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Professional Ecologists: Good Practice Guidelines 3rd Edition (Collins, 2016) as well as the
Bat Tree Habitat Key (Andrews et al., 2016). Each tree within the likely zone of impact was
searched for any potential roosting features (PRF) for bats including cracks (from
thistle species, common nettle and lesser burdock were also present in places.
3.1.20 Intact species-poor hedge: Along part of the eastern boundary was a small section of intact
species poor hedge, with botanical composition including sycamore, cleavers, ivy, bramble,
thistle species, red valerian, ash saplings, false-oat grass and other unidentified ornamental
species. A second section of intact species poor hedge was evident at the southern part of
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the Site, with botanical species including holly, bramble, sycamore, ivy and other
unidentified ornamental species. A ground layer was present comprising three-cornered
lee, red valerian, dandelion, ash saplings and herb-robert.
3.1.21 Fence: Fences were present within the Site, largely of wooden palisade affording no
ecological interest.
3.1.22 Buildings: The Site was dominated by buildings, some of which were further assessed in
Section 3.1.33.
3.1.23 Other habitat: The dominant habitat within the Site was hardstanding (parking and paths)
of no ecological value.
Protected Species Habitat Assessment
3.1.24 Badgers: The Site and surrounding habitats (where possible) were searched for signs of
badgers but none were found. In addition, no records of badgers were provided by ERCCIS
within the Site boundary.
3.1.25 Bats (foraging habitat): The Site was assessed for its suitability to support bats following
methodology described in Collins (2016) and also using professional judgement. The
habitats within the Site were dominated by buildings, hardstanding and amenity grassland,
of limited potential for foraging bats although the presence of synanthropic species (such
as pipistrelle) was considered likely. In addition, no records of bats were provided by ERCCIS
within the Site boundary, although some were noted in proximity.
3.1.26 Bats (roosting potential): The trees and buildings were assessed separately for their bat
roosting potential (see Section 3.1.32 and 3.1.33 respectively).
3.1.27 Breeding birds (excluding buildings): Areas of scattered trees, hedges and shrub provided
suitable breeding bird habitat. Although no records of birds were provided by ERCCIS within
the Site boundary, a large number was noted within the 1 km desk study.
3.1.28 Dormice: No suitable dormouse habitat was present within or surrounding the Site with no
records of dormice provided by ERCCIS.
3.1.29 Great crested newts: No suitable great crested newt habitat was present within or
surrounding the Site, with no records provided by ERCCIS.
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3.1.30 Invertebrates: While suitable terrestrial habitats were present within the Site which could
potentially support a varied assemblage of invertebrates, these were likely to support
common and widespread species, as noted from the ERCCIS 1 km data search results.
3.1.31 Reptiles: No suitable reptile habitat occurred within the Site with no records provided by
ERCCIS within the boundary or in close proximity.
Preliminary Ground Level Bat Tree Roost Assessment
3.1.32 All the scattered trees were subject to a preliminary ground level bat tree assessment and
considered to provide ‘No/Negligible’ potential (Collins, 2016) for roosting bats.
Protected Species Building Assessment – Bats
3.1.33 The Site consisted of the main hospital with terraced cottages (numbers 35 – 38),
immediately to the south. Due to the demolition of the cottages and proposed tie into the
main hospital by the new outpatient facility, both were surveyed individually and described
below.
3.1.34 Cottages – external: The cottages were of a render finish throughout, which was generally
tight. Windows and doors were of wooden construction, with no exposed lintels. Although
some of the windowpanes were broken, the majority were boarded up (all the ground floor
windows as well as some on the first floor). Soffit and fascia boards were present, generally
tight although gaps were evident at the south-western and south-eastern corners. The roof
was covered in slate, raised throughout with some missing in places, providing internal
access. The ridge tiles were raised in places, providing potential access and/or cavities for
bats. A total of two chimneystacks were present, with the lead finish generally tight. Of note,
two gables were evident at the southern elevation, where access was present between the
bargeboards and roof slates. Small porch extensions were to the rear of the cottages, with
the gables generally tight with intact verges. All the soffit and fascia boards were tight,
providing no potential for roosting bats. The porch roofs were covered with slate, some
raised in places although fixed with external cement mix. The ridge tiles were generally tight.
Dividing walls were noted between each cottage, capped and providing no potential for
roosting bats. A thorough inspection of all walls and windows/boards revealed no evidence
of bat use externally.
3.1.35 Cottages – internal: Internally, all cottages were of a similar construction and derelict. Each
loft included a simple truss of exposed purlin and rafter construction. The floor of each loft
was covered in old fiberglass insulation throughout. The gables were of block construction,
with a ridge board present. Slates were exposed with no underfelt lining, with cement
mortar evident throughout, some of which was crumbling or missing in places, creating
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potential cavities for bats. The lofts were generally dusty with detritus present and mouse
and rat droppings scattered throughout. No evidence of bat use was noted in any of the
lofts. All the lofts were partially connected via small gaps in the internal gable wall divides,
noted at the internal chimneys between number 38 and 37, as well as between number 36
and 35. In some of the lofts, areas of slates were missing creating a draughty and light
environment as well as exposure to rain crating patches of rotten floor/trusses, especially in
numbers 36 and 37. Some of the lofts also contained water tanks, covered or dry, with no
evidence of drowned bats. A thorough inspection of all loft walls, floor area, water tanks
and discarded stored belonging revealed no evidence of bat use.
3.1.36 In addition to the loft inspection, each room was visually assessed, with special attention to
the cavities created between the boarded-up windows, which is a common place used by
roosting crack and crevices bats. In number 38, a single common pipistrelle was found
roosting in the cavity between the board and window on the first floor.
3.1.37 Main hospital tie-in: The new two-storey link from the proposed new outpatient facility will
tie into the current hospital building. The area to be impacted contained walls of very tight
render finish with PVCu windows throughout providing no potential for roosting bats. The
soffit was very tight throughout, with no access with all vents intact. The small porch area
at the front entrance contained hanging tiles, but very tight with lead finish and intact verge
finish. No evidence or potential bat roosting features were noted or bat(s) recorded in situ.
Protected Species Building Assessment – Birds
3.1.38 At the time of the survey, evidence of breeding birds was noted at the cottages in the form
of an active herring gull nest by the chimneypot between numbers 35 and 36. In addition,
house sparrows were noted re-entering a hole in the soffit at the south-western corner of
the cottages, likely feeding young. In addition, a total of 10 – 14 swifts were noted flying
above the Site during the July Stage 2 survey.
3.2 Stage 2
Bat Roost Characterisation Survey
Visit 1: Emergence Survey – 1st July 2021
3.2.1 Sunset was 21:35 h with temperature at the start of the survey 19.9 ˚C with no precipitation,
wind or cloud cover, and 63.5 % relative humidity. Temperature fell to 13.7 ˚C at the end of
the survey with no precipitation, wind or cloud cover, and 87.0 % relative humidity.
Conditions were considered suitable for the detection of bats.
3.2.2 No bats were observed emerging from the Site.
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3.2.3 The first bat recorded flying over the Site was a common pipistrelle seen by the surveyor at
the northern elevation of the Site at 22:19 h, flying in a north-easterly direction in front of
the main hospital. Subsequent activity was minimal and entirely dominated by common
pipistrelle bats.
Visit 2: Emergence Survey – 1st August 2021
3.2.4 Sunset was 21:06 h with temperature at the start of the survey 16.2 ˚C with no precipitation,
0.0 – 3.0 mph wind, 95 % cloud cover and 82.0 % relative humidity. Temperature fell to 14.4
˚C at the end of the survey with no precipitation or cloud cover, 0.0 – 3.0 mph wind, and
88.0 % relative humidity. Conditions were considered suitable for the detection of bats
3.2.5 No bats were observed emerging from the Site.
3.2.6 The first bat recorded flying over the Site was a common pipistrelle, heard not seen by the
surveyor at the south-western elevation of the Site at 21:44 h. Subsequent activity was
minimal and entirely dominated by common pipistrelle.
Visit 3: Emergence Survey – 19th August 2021
3.2.7 Sunset was 20:34 h with temperature at the start of the survey 20.8 ˚C with no precipitation,
0.0 – 2.4 mph wind, 100 % cloud cover, and 76.0 % relative humidity. Temperature fell to
18.2 ˚C at the end of the survey with no precipitation, 0.0 – 0.9 mph wind, 80 % cloud cover
and 80.8 % relative humidity. Conditions were considered suitable for the detection of bats.
3.2.8 No bats were observed emerging from the Site.
3.2.9 The first bat recorded flying over the Site was a common pipistrelle heard not seen by the
surveyor at the north-eastern elevation of the Site at 20:53 h. Subsequent activity was
minimal and entirely dominated by common pipistrelle.
Biodiversity Net Gain
3.2.10 For ease and clarity, the results of the DEFRA SSM for the Site are presented in Section 6.0.
3.3 Evaluation/Assessment of Ecological Features
3.3.1 The importance of all ecological features including designated sites, habitats on and off Site,
as well as protected or noteworthy species were summarised in Table 1.
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Table 1: Ecological features including designated sites, habitats on and off Site as well as protected
or noteworthy species and their associated ecological importance.
Ecological Features Ecological Importance
Explanation
Designated Sites SPA International As per designation status SSSI National As per designation status Habitats on Site Scattered trees Site Common and widespread habitat of some ecological interest at the
site level Amenity grassland Negligible Common and widespread habitat of limited ecological interest at the
site level Introduced shrub Site Common and widespread habitat of some ecological interest at the
site level Intact species-poor hedge
Site Common and widespread habitat of some ecological interest at the site level
Fences Negligible No ecological interest Building Site Ecological interest in relation to the bat roost and breeding birds
only Other habitat Negligible No ecological interest Habitats off Site Ephemeral with bare ground
Negligible Common and widespread habitat of limited ecological interest at the site level
Protected and Noteworthy Species on Site Badgers Negligible No evidence of badger or potential Bats (Foraging/Commuting)
Site Potential for foraging by synanthropic species
Bats (Roosting) Site Single common pipistrelle found roosting during Stage 1 survey with low activity levels during Stage 2 survey
Birds Site Breeding birds found during Stage 1 survey within building, as well as potential within habitat for common species
Dormice Negligible No suitable habitat within Site Great crested newt Negligible No ponds or suitable terrestrial habitat within the Site Invertebrates Site Limited potential for common and widespread species Reptiles Negligible No potential within the Site
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4.0 Evaluation and Recommendations
4.1 Summary
4.1.1 The current proposals for the redevelopment of the hospital include the demolition of the
existing cottages and construction of new outpatient facilities. In addition, re-arrangement
of the existing car park, the creation of a two-storey link from the new outpatient facilities
to the current hospital building, as well as impact to habitats for potential services routing
from the boiler rooms/plant space. Stage 1 and Stage 2 ecological assessments were carried
out in order to evaluate impacts on biodiversity and protected species from the proposed
works. The location, proposed development and likely level of works have been reviewed
(where possible) against current standing advice and legislation. In addition, professional
judgment has also been used.
4.2 Biological Desk Study
4.2.1 The Site was within the impact risk zones of several SSSI and within 10 km of a SPA. These
designated sites were classified for their habitats, geology and associated flora and fauna
and any development in close proximity to these sites may have a detrimental impact on
their ecological functionalities. This may result from the development activities themselves,
or increased visitors and subsequent pressure on ecological resources of species linked to
the designated sites.
4.2.2 The Local Planning Authority (LPA) or ‘competent authority’ will need to review the
proposed development against each citation and/or impact risk zone criteria to ascertain
whether the proposed development is likely to have a significant effect on these
designations. The LPA will be required to consider the development alone, but also in
conjunction with other proposals or local plans. In determining impacts on these
designations, the location, nature of the proposal and plans for the Site will all be assessed.
If the proposed development was considered likely to have significant impact on the SAC
SPA and Ramsar, the LPA/competent authority will be required to conduct a formal
assessment of the ecological implications of the proposed works. Generally termed a
Habitat Regulations Assessment (HRA), the proposed works may require a formal screening
to the LPA for any likely significant effects (alone or in combination with other projects).
4.2.3 Natural England suggests, ‘Where these effects cannot be excluded, assessing them in more
detail through an appropriate assessment (AA) is required to ascertain whether an adverse
effect on the integrity of the site can be ruled out. Where such an adverse effect on the site
cannot be ruled out, and no alternative solutions can be identified, then the project can only
then proceed if there are imperative reasons of over-riding public interest and if the
necessary compensatory measures can be secured’. (Natural England).
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4.3 Phase 1 Habitat Survey
4.3.1 The dominant habitats within the Site were hardstanding and buildings, with the addition of
amenity grassland, introduced shrub, intact species poor hedge and scattered trees. At the
time of the survey, no rare or nationally scarce botanical species were identified, however,
it should be noted that a Stage 1 PEA does not aim to identify all botanical species. This
report does not constitute a full contaminated land or invasive species survey.
4.3.2 Based on the impacts of the development being restricted to a relatively small working
footprint with a large proportion of the associated engineering works undertaken on
concrete hardstanding, ecological impacts were considered low in this instance with no
additional habitat survey considered necessary.
4.3.3 All the habitats proposed for removal on Site were of limited ecological value and qualified
as ‘Site’ or ‘Negligible’ ecological importance. Without mitigation, the impact would lead, at
worst, to an adverse effect in the long-term, at the ‘Site’ level. Mitigation measures and
additional planting was proposed in Sections 5.0 and 6.0 to assess overall net gain in habitat
value.
4.3.4 Some of the introduced shrub and intact species poor hedges within the Site will be
retained. However, accidental damage could occur during construction, with root
compaction, particularly from vehicular access, removal of materials and digging activities
as well as damage from contaminant run-off. Without mitigation, the impact would lead to
an adverse effect in the long-term, at the ‘Site’ level. Therefore, suitable precautionary
measures were proposed in Section 5.0.
4.3.5 In addition, dust created from the proposed works and removal of materials, may be
deposited on adjacent trees or vegetation, which would lead to an adverse, short-term
effect at the ‘Site’ level for the habitats adjacent to the Site. Therefore, suitable precautionary
measures were proposed in Section 5.0.
4.4 Protected Species Habitat Assessment
4.4.1 The habitats and features within the Site were assessed for their potential to support
protected species with the following evaluation.
4.4.2 Badgers: In England, badgers are listed under Appendix III of the Bern Convention, and
protected under the Protection of Badgers Act 1992, which makes it an offence to
intentionally kill, injure or capture a badger, damage, destroy or block access to their setts,
disturb badgers when occupying their sett, as well as treat them cruelly, deliberately send
or intentionally allow a dog into a set, and bait or dig for them. At the time of the survey no
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evidence of badgers was found within the Site with limited potential for this species.
Therefore, based on current proposals, no further badger surveys were considered
necessary at the present time, however, suitable precautionary measures were proposed in
Section 5.0.
4.4.3 Bats: In England, all bat species are fully protected and listed under Schedule 2 of The
Conservation of Habitats and Species Regulations (as amended) 2017, amended by The
Conservation of Habitats and Species (Amendment) (EU exit) Regulations 2019, Schedule 5
of the WCA (as amended) 1981, and listed under Section 41 (S41) of the NERC Act (2006) as
well as included in the CRoW (2000). All UK bat species are also listed under Appendix II of
the Bern Convention (with the exception of common pipistrelle, which is on Appendix III)
and Appendix II of the Bonn Convention. In addition, greater and lesser horseshoes,
Bechstein’s, noctule, soprano pipistrelle, brown long-eared and barbastelle bats are also
listed as UKBAP.
4.4.4 The protection afforded to bats is such that the animals and their roosts (used for rest or
shelter) are legally protected. It is a criminal offence to deliberately take, injure, or kill a bat,
intentionally or recklessly disturb a bat in its roost or deliberately disturb a group of bats,
damage or destroy a place used by bats for breeding or resting (even if bats are not present),
possess or advertise/sell/exchange a bat of a species found in the wild (dead or alive), whole
or any part of a bat, as well as intentionally or recklessly obstruct access to a bat roost.
Important populations of greater and lesser horseshoes, Bechstein’s and barbastelle require
the designation of SAC.
4.4.5 Therefore, unlicensed works that may cause disturbance, killing, injury or blocking access
to a place of rest and shelter has the potential to cause an offence. Following the withdrawal
of Planning Policy Statement 9 (PPS9): Biodiversity and Geological Conservation, the NPPF
was published as its replacement in 2012. Although Circular ODPM 06/2005: Biodiversity
and Geological Conservation – Statutory Obligations and their impact within the Planning
System, was a guidance document that accompanied PPS9, it is still valid in its interpretation
by local planning authorities on the impact a development may have on protected species.
Circular 06/2005 stated that the presence of a protected species is a, ‘material consideration
when a planning authority is considering a development proposal that, if carried out, would
be likely to result in harm to the species or its habitat’ (ODPM 06/2005). Furthermore,
habitats within the Site were assessed for their potential to support foraging and community
bats and whether the proposed development could impact bats.
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Bat Foraging
4.4.6 Based on ‘professional judgement’ (Collins, 2016), the dominant hardstanding, building and
amenity grassland habitats within the Site were not considered significantly diverse to
support a large assemblage of bats. Importantly, no significant changes to the connectivity
of the adjacent habitats or those in the wider landscape were likely. Based on the proposed
works, no further bat activity (transect for example) surveys to assess foraging or
commuting activity were considered necessary in this instance. Further information was
provided in Section 5.0, with a recommendation for preventing impacts associated with
lighting during works also proposed.
Bat Roosts
4.4.7 The buildings on Site were subject to a thorough internal and external Stage 1 survey to
search for evidence of bats, with a single common pipistrelle observed roosting in situ at
number 38. Therefore, a further Stage 2 bat roost characterisation survey was subsequently
undertaken to confirm the status of the bat roost, as outlined in Collins (2016). The survey
was undertaken at the optimal time of year and under suitable conditions, with no evidence
of bats emerging from the Site.
4.4.8 Based on the sound ecological survey undertaken and following best practice for ecological
assessment of bat roosts, Site was considered to be a day, non-breeding infrequent roost
for low numbers/singleton common pipistrelle.
4.4.9 In order to evaluate impacts on bats, the location, the proposed development and likely
level of works have been reviewed (where possible) against current standing advice,
legislation and importantly, professional ecological experience. Current proposals include
the complete demolition of the existing terrace cottages. It was therefore considered that
the proposals were likely to cause, ‘disturbance, killing or injury, blocking access or
destruction of a bat roost’ and that offences under the Conservation of Habitats and Species
Regulations (as amended) 2017, amended by the Conservation of Habitats and Species
(Amendment) (EU exit) Regulations 2019 and WCA (as amended) 1981 would be committed
without appropriate licensing. As a result, a European protected species licence (EPSL)
from Natural England will be required prior to any works commencing in areas where
bats were roosting. Appropriate mitigation/compensation shall be incorporated within the
design proposal to compensate for the loss of the roosts and maintain the bats’ favourable
conservation status with a working method adhered to. Specific details of
mitigation/compensation would be provided in any Method Statement and Reasoned
Statement (if requested) applied to Natural England once planning permission has been
granted, with suggested bat mitigation outlined in Section 5.0.
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4.4.10 When considering a planning (or other consent) application and impacts on European
protected species, Local Planning Authorities (LPAs) are under the obligation to consider
the three European protected species licensing tests. This was further emphasised by a High
Court judgement, which determined that the Habitats Regulations placed LPAs under the
obligation to consider protected species. The three licensing tests, which Natural England
also apply when considering granting an EPSL, are:
(i) Whether there are imperative reasons of overriding public interest for the planning
application;
(ii) Whether there are any satisfactory alternatives; and
(iii) Whether the species' favourable conservation status has been maintained.
4.4.11 With regard to ecology, provided recommendations outlined in Section 5.0 of this report
were implemented, it was considered that the third test might be met (species’ favourable
conservation status maintained). However, it is up to the LPA (as a statutory undertaker) to
decide whether this is applied or not and on the evidence (such as this ecology report)
provided. Tests one and two concern planning matters but for any EPSL to be applied for,
supporting information must be provided.
4.4.12 Assuming the development was granted planning permission, the following ecological
planning condition imposed on the development would be considered suitable:
‘Development to proceed with the bat mitigation scheme supplied with the application,
subject to any variation required by Natural England under any licence issued’.
4.4.13 Breeding birds: Under Section 1 of the WCA (as amended) 1981, wild birds (with exceptions)
are protected from being killed, injured or captured, while their nests and eggs are protected
from being damaged, destroyed or taken while in use. At the time of the survey evidence of
current breeding bird was recorded on Site, with additional breeding bird habitat identified
in scattered trees and thick, introduced shrub. Although no further breeding bird surveys
(for example walked transects) were considered necessary in this instance, suitable timing
restrictions and recommendations were provided in Section 5.0.
4.4.14 Dormice: In England, dormice are fully protected under Schedule 2 of The Conservation of
Habitats and Species Regulations (as amended) 2017, amended by The Conservation of
Habitats and Species (Amendment) (EU exit) Regulations 2019, Schedule 5 of the WCA (as
amended) 1981, and listed under S41 of the NERC Act (2006) and CROW Act (2000). In
addition, dormice are also listed as UKBAP species.
4.4.15 The protection afforded to dormice is such that the animals and the places they use for rest
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or shelter are legally protected. It is a criminal offence to deliberately or intentionally take,
injure, or kill a dormouse, damage or destroy a place used by dormice for breeding or
resting, deliberately or recklessly disturb a dormouse while in its structure or place of
shelter/protection, block access to structures or places of shelter/protection, possess or
sell, control or transport a dormouse (dead or alive, whole or in part).
4.4.16 Based on the surveyor’s experience5 in habitat assessments for this species, the habitats
within the Site provided no potential for this species. It was considered that a dormouse
survey following methodology proposed by Natural England (Bright et al., 2006) was not
necessary in this instance. In addition, no dormouse records were provided by ERCCIS
within the desk study area.
4.4.17 Great crested newt: In England, great crested newts are fully protected under Schedule 2 of
The Conservation of Habitats and Species Regulations (as amended) 2017, amended by The
Conservation of Habitats and Species (Amendment) (EU exit) Regulations 2019, Schedule 5
of the WCA (as amended) 1981, listed under S41 of the NERC Act (2006), and the CROW Act
(2000). In addition, great crested newts are also listed under Appendix II of the Bern
Convention and as a UKBAP species, with important populations of this species requiring
the designation of SAC.
4.4.18 The protection afforded to great crested newt is such that the animals and the places they
use for rest or shelter are legally protected. It is a criminal offence to deliberately or
intentionally take, injure, disturb or kill a great crested newt, damage or destroy their
breeding or resting places, deliberately or recklessly block access to structures or places of
shelter/protection, possess or sell, control or transport a great crested newt (dead or alive,
whole or in part) or take their eggs.
4.4.19 No ponds were recorded within the Site, and based on the surveyor’s experience6 in habitat
assessments for this species and reviewing Natural England’s standing advice, the habitat
within the Site provided negligible potential and no further surveys were considered
necessary. In addition, this species is considered absent from this part of Cornwall with no
records provided by ERCCIS within the desk study area.
4.4.20 Invertebrates: Habitats within the Site were not considered suitably diverse to support a
large or varied assemblage of invertebrates, and therefore, in this instance no further
surveys were considered necessary.
5 Mr H. Colmer BSc (Hons) Dip MCIEEM FLS – Dormouse licence. 6 Mr H. Colmer BSc (Hons) Dip MCIEEM FLS – Great crested newt licence.
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4.4.21 Reptiles: In England, the four widespread species of reptiles (common lizard, slow-worm,
adder and grass snakes) are listed under S41 of the NERC Act (2006) and protected under
Schedule 5 of The WCA (as amended) 1981. In addition, these four species are also listed as
UKBAP.
4.4.22 The protection afforded to slow-worms, common lizards, adders and grass snakes is such
that the animals are protected from intentional killing or injuring, as well as being sold,
offered for sale or held or transported for sale (dead or alive, whole or in part) as well as
protected from being published or advertised as being for sale.
4.4.23 No suitable reptile habitat was present and therefore no further reptile surveys were
considered necessary.
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5.0 Recommendations and Constraints, Mitigation and Enhancements
5.1 Detailed Bat Mitigation, Compensation and Enhancements
5.1.1 The Bat Mitigation Guidelines (Mitchell-Jones, 2004) suggests that for, ‘Individual bats or
small numbers of common species (common pipistrelle) not a maternity site: flexibility over
the provision of bat boxes or access to new building for mitigation and compensation. No
condition about timing or monitoring’. It should be noted that nationally, common
pipistrelles are considered common species (Wray et al., 2010). In order to compensate for
the loss of the common pipistrelle roost on Site, bat roosting features will be incorporated
within the Site and on an immediately adjacent existing building.
5.1.2 To mitigate/compensate for the loss of roosting opportunities for common pipistrelles, the
bat mitigation and compensation outlined below were suggested (and subject to
confirmation via an EPSL application to NE). This is based on current understanding and
proposals for the development and the habitat characteristics of crevice bat species, as well
as professional experience of working with these species. The ecological
mitigation/compensation were based on the Stage 2 surveys conducted and proposed in
order to maintain the favourable conservation status of protected species on Site. �
5.1.3 As common pipistrelles are crevice dwellers, the bat box system was considered to be
suitable in this instance. Therefore, mitigation and compensation were proposed with the
following details:
1. An external bat box (erected at the south-eastern wall of the existing hospital building)
will be fitted at height, and to provide a suitable alternative roosting provision for the
species identified. Any external box to be of durable, insulating block/woodcrete
construction (e.g. Schwegler 1FQ), which provide a long lasting and internal roosting
space for a vast number of UK bat species. Following the bat mitigation guidelines
(Mitchell-Jones, 2004), the replacement roost suggested was, ‘situated as close as
possible to the roost to be lost’ and was, ‘chosen to maximise the chances of the bats
finding and adopting it....close to existing flight lines and entrance close to appropriate
habitat’ (Mitchell-Jones, 2004). It should be noted that it is not possible to provide
compensation into the proposed new outpatients building due to the cladding design
(Pers. comm. Stride Treglown to Colmer Ecology, 24th September 2021). Figure 7
highlights the proposed location and compensation suggested;
2. The soft demolition/stripping of all key bat features of the cottages (fascia and barge
boards, ridge tiles, and boarded-up windows), or the blocking of any access points will
require supervision by a licenced bat ecologist and need to be carried out in a slow
and careful removal process under a granted EPSL. Once all bat features or areas of
high risk to bats have been cleared, works can continue uninterrupted;
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3. Contractors will be made aware of the new bat roosting location (bat box) during soft
demolition/stripping and how it will need to be fitted (with the aid of photography and
mapping) before and during the toolbox talk required as part of the EPSL for the Site.
Installation of the bat box must be overseen by an ecologist, to comply with the licence
requirements; and
4. If external lighting was required, this will be kept to a minimum and should consist of
LED luminaries, ideally of a warm white spectrum (< 2,700 Kelvin), upward light ratio of
0 % and with good optical control, with any external security lighting to be set on
motion-sensors and short (1 minute) timers (Institution of Lighting Professionals and Bat
Conservation Trust, 2018). No additional lighting to be fitted in close proximity
(adjacent, immediately above and/or below) to the bat box fitted at the south-eastern
wall of the existing hospital building (downward lighting proposed at basement level
only). New internal lighting to be recessed, where possible, to avoid additional glare and
light spill particularly along the boundary habitats. Refer to Guidance Note 08/18 on
Bats and Artificial Lighting in the UK for further details (Institution of Lighting
Professionals and Bat Conservation Trust, 2018). A lighting study or lighting plan may be
required and conditioned by the LPA.
5.2 Recommendations and Constraints – Other Protected Species
5.2.1 In reviewing development proposals, the following were also recommended:
1. Land mammals: During construction, any open dug trenches must be covered overnight
to prevent any mammals (such as foxes, hedgehogs or domestic pets) from being
trapped. If this was not possible, suitable mammal ladders, in the form of simple wooden
planks with a maximum gradient of 1:2 must be provided. In addition, any piping with
the potential to entrap badgers or other mammals will be capped at the end of each
working day. The contractor shall implement an auditing system, documenting mammal
ladder installation or the capping of pipes. Details should be made available to an
ecologist on request, although monitoring during or post construction was not
proposed; and
2. Birds: Should any suitable breeding bird habitat require removal during the bird breeding
season of 1st March – 31st August inclusive, a suitably qualified individual would need to
undertake an inspection for breeding birds within 48 hours prior to any clearance. This
must involve a survey of each loft, but also a survey of any flat roof area (chimneystack
for example) to identify nesting gulls. If breeding birds were identified, these must
remain in place until breeding has ceased and dependent young have fledged, with a
suitable exclusion zone implemented where necessary. The advising ecologist will
periodically monitor any occupied nest, until young have fledged. No inspection or
supervised clearance would be required for removal of breeding birds habitat between
1st September – 28th February (or 29th in any leap year).
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5.3 General Site Mitigation Measures
5.3.1 In order to avoid any adverse impacts to habitats on and in the vicinity of the Site, the
following ecological avoidance measures/mitigation were made at the Site level:
1. Contractors must work in accordance with the Environment Agency pollution
prevention for businesses guidance (Defra and Environment Agency, 2016) and follow
guidelines for preventing adverse dust levels, minimising run off and using bunded
storage, for example when refuelling vehicles and storing oil and fuel. Contractors shall
be made aware of the potential that pollution incidents may occur, with spills kits to
remain on Site for the duration of the development and where necessary, tool box talks
to be given. It is the responsibility of the applicant and their contractors to supply
appropriate information and monitoring for the LPA to review; and
2. In order to prevent any ground works exposing tree roots of retained trees/hedgerows,
where required, a tree root protection zone will be implemented in accordance with
BS5837:2012 Trees in Relation to Design, Demolition and Construction. The tree root
protection zone(s) will be monitored throughout the construction phase and with
appropriate signage in place. In addition, any trees that require pruning to facilitate the
delivery of materials should be carried out following good silvicultural practices,
following consultation with a qualified arboriculturist where appropriate and only where
the lack of any Tree Preservation Order has been confirmed.
5.4 Ecological Enhancements
5.4.1 In accordance with the NPPF (revised 2021), consideration should be sought to creating
new habitats or features of biodiversity gain within a sustainable development, or managing
existing features for ecological and biodiversity gain. Although this may be restricted with
the small-scale development proposal, one of the following enhancements were proposed
for swift:
1. Swifts (external OR retrofitted boxes): As it is not possible to integrate swift boxes into
the new outpatients building (Pers. comm. Stride Treglown to Colmer Ecology, 24th
September 2021), four external OR retrofitted swift boxes will be fitted at the south-
eastern wall of the existing hospital building (Figure 7). External boxes to be installed at
eaves height, at least 5 m high, away from windows in an uncluttered environment and
in clusters (1 m apart) due to the colonial nesting of this species. Swift box installation
must be overseen and signed off by an ecologist with a ‘tool-box’ talk to contractors
(Day et al., 2019). External or retro fitted swift boxes will comprise either:
External
• John Stimpson external swift box model 30 with internal nest chamber; or
• John Stimpson external swift box model 31 with internal nest chamber; or
• WoodStone swift nest box.
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Retrofitted
• Ibstock Eco-habitat for swift brick; or
• Habibat 003 or Habibat swift box; or
• Manthorpe swift nesting ‘brick’.
5.5 Residual effects
5.5.1 The residual effects following implementation of mitigation and compensation were
summarised in Table 2 for each ecological feature following CIEEM (2018).
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Tab
le 2: Sum
mary o
f residu
al effects
Eco
log
ical Features
Imp
act Level
Mitig
ation
Measu
res C
om
pen
sation
/En
han
cemen
t Measu
res R
esidu
al E
ffects D
esignated Sites SPA
LP
A to
assess if H
RA
is requ
ired
Intern
ation
al -
- -
SSSI N
o im
pact
Natio
nal
Measu
res to in
clud
e site wid
e mitig
ation
-
- H
abitats on Site (B
ased on JN
CC
Phase 1 Habitat C
lassification)
Scattered trees R
emo
val Site
Co
ntracto
rs to w
ork in
accord
ance w
ith th
e p
ollu
tion
preven
tion
for b
usin
ess gu
idan
ce (D
EFRA
and
EA, 20
19)
Ad
ditio
nal n
ative tree plan
ting
(mo
re th
an p
rop
osed
to b
e remo
ved)
Po
sitive
Am
enity grassland R
emo
val N
eglig
ible
Co
ntracto
rs to w
ork in
accord
ance w
ith th
e p
ollu
tion
preven
tion
for b
usin
ess gu
idan
ce (D
EFRA
and
EA, 20
19)
Existing
amen
ity grasslan
d to
be rep
laced
with
a mix o
f flow
ering
lawn
with
w
ildflo
wer areas, n
ative hed
gero
w sh
rub
p
lantin
g an
d o
rnam
ental p
ollin
ator sh
rub
p
lantin
g
Po
sitive
Introduced shrub
Partial rem
oval
Site C
on
tractors to
wo
rk in acco
rdan
ce with
the
po
llutio
n p
reventio
n fo
r bu
siness g
uid
ance
(DEFR
A an
d EA
, 2019
) T
ree roo
t pro
tection
zon
e imp
lemen
ted in
acco
rdan
ce with
BS58
37:2012 T
rees in R
elation
to
Desig
n, D
emo
lition
and
Co
nstru
ction
New
area of o
rnam
ental p
ollin
ator sh
rub
p
lantin
g w
ith existin
g sh
rub
plan
ting
to
be retain
ed in
places
Neu
tral
Intact species poo
r hedge P
artial remo
val Site
Co
ntracto
rs to w
ork in
accord
ance w
ith th
e p
ollu
tion
preven
tion
for b
usin
ess gu
idan
ce (D
EFRA
and
EA, 20
19)
Tree ro
ot p
rotectio
n zo
ne im
plem
ented
in
accord
ance w
ith B
S5837:20
12 Trees in
Relatio
n
to D
esign
, Dem
olitio
n an
d C
on
structio
n
Som
e area to b
e lost to
the
develo
pm
ents w
ith n
ew n
ative hed
gero
w
shru
b p
lantin
g
Neu
tral
Fences R
emo
val N
eglig
ible
- -
Neu
tral B
uilding R
emo
val Site
See belo
w fo
r bats an
d b
irds
mitig
ation
/com
pen
sation
/enh
ancem
ents
- N
eutral
Other habitat
Partial rem
oval
Neg
ligib
le -
- N
eutral
Habitats o
ff Site (Based o
n JNC
C Phase 1 H
abitat Classificatio
n) Ephem
eral with bare
ground
No
imp
act Site
Co
ntracto
rs to w
ork in
accord
ance w
ith th
e p
ollu
tion
preven
tion
for b
usin
ess gu
idan
ce (D
EFRA
and
EA, 20
19)
- N
eutral
Protected and N
otew
orthy Species
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Eco
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Imp
act Level
Mitig
ation
Measu
res C
om
pen
sation
/En
han
cemen
t Measu
res R
esidu
al E
ffects B
adgers P
oten
tial to
beco
me en
trapp
ed
in excavatio
n/
pip
ing
du
ring
co
nstru
ction
p
eriod
Neg
ligib
le T
rench
es to b
e covered
at nig
ht o
r fitting
su
itable m
amm
al ladd
ers, as well as cap
pin
g
pip
es
- N
eutral
Bats
(Foraging/C
om
muting)
No
imp
act Site
No
add
ition
al ligh
ting
on
to ad
jacent h
abitats.
LED lu
min
aries, ideally o
f a warm
wh
ite sp
ectrum
(< 2,700
Kelvin
), up
ward
ligh
t ratio o
f 0
% an
d w
ith g
oo
d o
ptical co
ntro
l, with
any
external secu
rity ligh
ting
to b
e set on
mo
tion
-sen
sors an
d sh
ort (1 m
inu
te) timers.
Po
tential fo
r new
plan
ting
of eco
log
ical in
terest N
eutral
Bats (R
oo
sting) R
emo
val of
roo
sting
o
pp
ortu
nities
Site E
PSL req
uired
with
too
lbo
x talk and
soft
dem
olitio
n p
roced
ures u
nd
er ecolo
gical
sup
ervision
Pro
po
sed b
at bo
x installed
N
eutral
Birds
Rem
oval o
f nestin
g
op
po
rtun
ities Site
Tim
ing
restriction
with
insp
ection
with
in 4
8 h
of
start of an
y hab
itat clearance (w
here req
uired
) A
dd
ition
al plan
ting
in th
e form
of
scattered trees, n
ative hed
gero
w sh
rub
p
lantin
g an
d o
rnam
ental p
ollin
ator sh
rub
p
lantin
g
Pro
po
sed b
ird b
oxes fo
r swifts w
ithin
the
new
ou
tpatien
t facilities OR
on
existing
b
uild
ing
Po
sitive
Do
rmice
No
imp
act N
eglig
ible
No
imp
act -
Neu
tral G
reat crested newt
No
imp
act N
eglig
ible
No
great crested
new
t po
tential w
ithin
Site -
Neu
tral Invertebrates
Rem
oval o
f som
e h
abitat
Site -
New
areas of flo
werin
g law
n w
ith
wild
flow
er areas, native h
edg
erow
shru
b
plan
ting
and
orn
amen
tal po
llinato
r shru
b
plan
ting
Po
sitive
Reptiles
No
imp
act N
eglig
ible
No
reptile p
oten
tial with
in Site
- N
eutral
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6.0 Biodiversity Offsetting Calculations (Biodiversity Net Gain)
6.1 In order to assess biodiversity offsetting, the Small Sites Metric (SSM) (JP040) (DEFRA 2021)
was used in this instance as the Site met both (highlighted in bold) of the following SSM
criteria:
‘1. Development sites where;
For residential developments the number of dwellings to be provided is between one and
nine inclusive on a site having an area of less than one hectare;
Where the number of dwellings to be provided is not known the site area is less than 0.5
hectares:
For all other development types where the site area is less than 0.5 hectares or less than
5000 metres squared.
2. Where there is no priority habitat present within the development area (excluding
hedgerows and arable margins).
6.2 The SSM is a simplified version of the Biodiversity Metric 3.0, and was reviewed to measure
and account for, biodiversity losses and gains resulting from development or land
management within the Site. The SSM encompasses habitat areas pre and post
development, and also linear features such as hedgerows, tree lines, rivers and
watercourses.
6.3 As highlighted by Natural England and DEFRA advice, it should be noted that the SSM is still
currently in BETA7 format and its use (until agreed) and subsequent calculations/results
should be used with caution. Furthermore, the Biodiversity Metric 3.0 and SSM use the UK
Habitat Classification8 system, as opposed to JNCC, 2010 (updated 2016) phase 1 habitat
survey habitat typologies. As the Site was surveyed following the phase 1 habitat survey
classification, the habitat typologies recorded were therefore converted to UK Habitat
Classification using the DEFRA Biodiversity Metric 3.0 conversion table within the
biodiversity metric ‘Technical Data’.
6.4 The DEFRA biodiversity metric calculations of habitats post development have been based
on the suggested an provided landscaping plans. In addition, the SSM appears to consider
proposed habitat enhancements where the targeted increase in units at baseline were zero.
Finally, the metric does not consider biodiversity enhancements such as bat or bird boxes
incorporated into/onto a development, or physical enhancements for other terrestrial
animals.
7 The ‘beta’ label means the first version of a new service or web page. The beta label is displayed on a new service to show it is being tested – DEFRA website, 2021. 8 http://ecountability.co.uk/ukhabworkinggroup-ukhab/
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6.5 Based on the landscape plans provided and reviewed (Stride Treglown, Landscape GA,
154345-STL-XX-ZZ-DR-L-XXXX-90000) each habitat type was accurately measured pre
and post development using AuotCAD software with the habitat distinctiveness and
condition assessed and habitat units lost evaluated. The mitigation hierarchy was used
throughout. Table 3 outlines the SSM biodiversity offset calculations.
Table 3: Biodiversity Offset Calculations (Small Sites Metric JP040, based on Site area of 2,098 sq m)
Headline BNG Targets Met Trading Rules Trading Rules Satisfied
Detailed Results
Baseline value Habitat units 0.2745 Hedgerow units Zero Units Baseline River units Zero Units Baseline
Post development value Habitat Units 0.3025
Hedgerow Units 0.5791 River Units 0.0000
Net gain targets Habitat Units 0.3019
Hedgerow Units 0.0000 River Units 0.0000
Total net unit change Habitat Units 0.0280
Hedgerow Units 0.5791 River Units 0.0000
Total net % change: Including all on-site and off-site habitat creation and retained habitats
Habitat Units 10.22 % Hedgerow Units % target not appropriate River Units % target not appropriate
6.6 From the information gathered and landscape plans provided, a 10.22 % total net change in
habitat units will occur, which is greater than the suggested 10 %. Provided the proposed
mitigation, compensation and enhancement measures are followed within this report, there
will be some net positive benefit for wildlife in the form of creation of valuable habitats
within a relatively sub-urban location.
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7.0 Conclusion
7.1 An EcIA comprising two main elements (Stage 1 and Stage 2) was carried out of land and
buildings at RCHT, West Cornwall Hospital, Penzance, Cornwall, to assess impacts from the
proposed development. Stage 1 was a PEA including a biological desk study, a phase 1
habitat survey with a protected species habitat assessment, a preliminary ground level bat
tree roost assessment and a protected species building assessment. Stage 2 comprised a bat
roost characterisation survey undertaken due to the evidence of, and potential for,
protected species noted during the Stage 1 PEA. In addition, a Biodiversity Net Gain (BNG)
calculation was completed, following the DEFRA Small Sites Metric (SSM) (JP040).
7.2 All habitat types have been mapped, with the Site dominated by hardstanding and buildings,
with the addition of amenity grassland, introduced shrub, intact species poor hedge and
scattered trees. An assessment of site valuation and impact to habitats was undertaken with
suitable mitigation and compensation measures suggested as required.
7.3 In the absence of mitigation measures, the proposed development was considered likely to
have, at worst, long-term, adverse effect at the ‘Site’ level. However, by following the
proposed mitigation and precautionary measure, the development was not considered to
have any significant residual effect to important ecological features within or adjacent to
the Site. Provided the proposed mitigation, compensation and enhancement measures are
followed, the development was considered to be consistent to relevant conservation
legislation, NPPF (2021) and local policies. In addition, an increase above 10 % biodiversity
net gain was calculated.
7.4 The Stage 2 bat roost characterisation survey was conducted between July and August
2021, with no bats observed emerging/re-entering the structure. Due to the number of bats
(a single bat observed roosting in situ during Stage 1), and no subsequent bat emergence/re-
entry during Stage 2, the Site was considered to be an infrequent day, non-breeding roost
for singleton/low numbers of common pipistrelle bats. The development works will result
in the loss/alteration/blocking access of the roosts, the potential to kill/injure bats during
some of the works as well as disturbance, and therefore, an EPSL was considered
necessary.
7.5 Mitigation and compensation measures for the loss/alteration of the bat roost was
proposed, which, if followed would ensure that the favourable conservation status is
maintained for this bat species and the continued ecological functionality of its roost. An
EPSL will be necessary, which is applied for and granted by Natural England, once
planning permission has been approved. Construction work must proceed in accordance
with terms and details outlined in any EPSL method statement submitted to Natural England,
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2019-21 37 RCHT, West Cornwall Hospital – EcIA Report
and any deviation from a granted EPSL would constitute a breach of licence terms and
conditions. No works to the Site/areas where bats were roosting can commence until an
EPSL is in place.
7.6 As evidence of breeding birds was noted on Site, suitable mitigation, compensation
measures and enhancements were recommended and will be adopted during the
development works.
7.7 Additional ecological mitigation and enhancements at the Site level were proposed where
necessary.
7.8 This report is valid for a period of 12 months from the date of the last survey.
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2019-21 38 RCHT, West Cornwall Hospital – EcIA Report
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