Site: Dinton Castle, Dinton, Aylesbury, Buckinghamshire, HP17 8UX

Transcription

1 Site: Dinton Castle, Dinton, Aylesbury, Buckinghamshire, HP17 8UX Client: Mr Jaime Fernandez Bat Survey Emergence and Activity Surveys 30/09/2016 1

2 Status Issue Name of Author/Reviewer Date Draft 0.1 Lauren Fear BSc (Hons) MSc 14/09/2016 Reviewed 0.2 Julie Powell MCIEEM, Technical Lead 15/09/2016 Final 1.0 Lauren Fear BSc (Hons) MSc 15/09/2016 Updated with DNA results 2.0 Lauren Fear BSc (Hons) MSc 30/09/2016 Limitations Arbtech Consulting Limited has prepared this report for the sole use of the above named Client or his agents in accordance with our General Terms and Conditions, under which our services are performed. It is expressly stated that no other warranty, expressed or implied, is made as to the professional advice included in this Report or any other services provided by us. This report may not be relied upon by any other party without the prior and express written agreement of Arbtech Consulting Limited. The assessments made assume that the sites and facilities will continue to be used for their current purpose without significant change. The conclusions and recommendations contained in this report are based upon information provided by third parties. Information obtained from third parties has not been independently verified by Arbtech Consulting Limited. Copyright This report is the copyright of Arbtech Consulting Limited. Any unauthorised reproduction or usage by any person other than the addressee is strictly prohibited. 2

3 Contents Page Executive Summary Introduction and Context Background Aims and Objectives Scope of the Report Site Context Project Description Methodology Site Survey Surveyors and weather conditions Timing Equipment Limitations Results Survey Results Presence/absence and roost characterisation surveys Conclusions and Impact Assessment Conclusions Impact Assessment Recommendations Mitigation Enhancement Bibliography Appendix 1: Survey Plan

4 Plan showing proposed bat box positions for mitigation and enhancement: Appendix 2: Proposed Site Plan Appendix 3: Photos Appendix 4: Legislation and Planning Policy related to bats LEGAL PROTECTION Effect on development works: NATIONAL PLANNING POLICY (ENGLAND) National Planning Policy Framework The Natural Environment and Rural Communities Act 2006 and The Biodiversity Duty

5 Executive Summary Arbtech Consulting Ltd. undertook a suite of emergence and activity surveys at on 22 nd July and 8 th August and 12 th September The aim of the assessment is to determine the presence or likely absence of bats, and to gain an understanding of the activity of bats using the building in the local landscape. The development proposals briefly comprise the restoration and renovation of the derelict existing structure into a residential dwelling. Presence/likely absence of roosting Confirmed roost Roost character One unidentified bat was seen performing dawn swarming behavior before re-entering the structure using a crevice on southern elevation, and one nonecho-locating bat was observed emerging from crevice in a similar area during an emergence survey. Two bat droppings found on the southern external wall were sent for DNA analysis and have been confirmed as soprano pipistrelle Pipistrellus pygmaeus. The building is suspected of being a summer roost for a low number (<5) of soprano pipistrelles and is therefore is interpreted to be of low conservation value. Recommendations for further survey and/or mitigation A European Protected Species Licence (EPSL) is required to undertake the proposed works to the building. Mitigation may include the inspection of any crevices for bats prior to works to fix and fill them; a delay between erecting scaffolding and works on the building to allow bats to move from the area; works to fill in the gaps and crevices on the walls of the structure should be undertaken by hand rather than by machine; bats may be excluding from crevices prior to works taking place on sections of the walls; altering of the timing of works to reduce the potential impacts of any bats using the building over the year. 5

6 Trees T1 and T2 The mature oak labelled T2 is a confirmed bat roost supporting common pipistrelles Pipistrellus pipistrellus. The tree roost supports a low number (<10) of common pipistrelles and forms a summer day roost of low conservation value. There is also a bat box located in tree T1 which was not observed directly during this survey but is suspected of supporting roosting bats. No expected direct impacts on the trees from the proposed works. No lights during development or post-development should shine into the tree line around the site. Lighting should be in-line with the BCT lighting guidelines (Bats and Lighting in the UK (Bat conservation trust, 2008). 6

7 1.0 Introduction and Context 1.1 Background Arbtech were commissioned by Mr Jaime Fernandez to undertake a suite of emergence/re-entry and activity surveys at Dinton Castle, Dinton, Aylesbury, Buckinghamshire, HP17 8UX. The assessment is informed by the Bat Conservation Trust publication Bat Surveys for Professional Ecologists: Good Practice Guidelines (Collins, J, (ed.), 2016). The Preliminary Roost Assessment, undertaken in April 2016, did not rule out the reasonable likelihood of a roost being present in the structure. As such, presence/absence surveys were recommended. The report concluded that the structure had a moderate likelihood of supporting roosting bats and two emergence/re-entrance surveys were recommended. Table 1: PRA recommendations Value of building for roosting bats Moderate Habitat Value Recommendations for further survey and assessment Two emergence surveys to establish likely presence/absence of bats in the structure. These surveys will require three surveyors to cover all angles and features of the structure. These surveys can take place between May-September with at least one of these surveys taking place between May-August. At least one of these surveys should be a dawn survey, to follow best practise guidelines. After the initial re-entrance survey, the structure was confirmed as a bat roost and a third emergence survey was undertaken. 1.2 Aims and Objectives This report provides a description of the bat activity observed and recorded during each survey, notably the egress and entrance points on the buildings, trees and other structures; the numbers and species of bats using the roosts; and the type and levels of activity in and around the roost sites. The aim of the assessment was to determine the presence or likely absence of roosting bats and to gain an understanding of how bats use the building, tree or structure. The objectives of the surveys were to gain an 7

8 understanding of the species, numbers and access points, roosting locations, timing of use and type of roost. Robust data has been collected, following good practice guidelines, to inform an assessment of the potential impacts of the proposed development on bats, and inform mitigation and enhancement. This report provides information on constraints to the proposals as a result of roosting bats, and summarises any mitigation required to achieve Planning or other statutory consent, and to comply with wildlife legislation. 1.3 Scope of the Report Survey plans are presented in Appendix 1, showing the location of each surveyor and the bat activity observed and recorded during each survey; site plans showing the current site layout and proposed development are in Appendix 2; and a summary of relevant legislation can be found in Appendix 3. This report should be read in conjunction with the Preliminary Roost Assessment (L.Fear, Arbtech Consulting Ltd). 1.4 Site Context The site is located at National Grid Reference SP , and comprises an area of approximately 0.3ha. There is one structure within the site boundaries. The site is situated south-west of Stone, Buckinghamshire. The site is located in a largely rural area with arable land dominating the landscape. There are fragments of woodland to the north of the site, and areas of floodplain and grazing marsh either side of the banks of the River Thame, north of the site. 1.4 Project Description This report is prepared in support of a planning application for. It is proposed that the structure is restored and refurbished into a residential dwelling. The proposed plan is included in Appendix 2. All works areas, storage and haul routes will be included within the site boundaries; access will be provided by existing roads and as such, no additional working footprints are anticipated. 8

9 2.0 Methodology 2.1 Site Survey Surveyors and weather conditions The lead surveyor is Lauren Fear BSc (Hons) MSc [bat licence: CLS-CLS] and was assisted by: Laura McLellan experienced bat surveyor of at least 4 years Hanna Grimsdale experienced bat surveyor of at least 1 year Rhianna Dix experienced bat surveyor of at least 3 years The survey methods were informed by the preliminary roost assessment by Arbtech Consulting Ltd in April 2016 All features that were assessed as being suitable for roosting and affected by the development were subject to survey. Three surveyors were used to provide sufficient cover of the structure. The position of each surveyor during each survey is shown on the plan in Appendix Timing The dates and times of each survey are shown in Table 2 below. Table 2: Survey dates and timings Building reference B1 Roost value Survey date(s) Sunset/sunrise time 22/07/2016 Dawn 05:12 Confirmed 08/08/2016 Dusk 20:35 start time end time 03:30 05:22 20:05 22:05 12/09/2016 Dusk 19:23 19:05 21:05 The dates of survey and weather conditions are shown in Table 3. 9

10 Table 3: Weather conditions Weather conditions Date of survey Factor Start End Dawn 22/07/2016 Dusk 08/08/2016 Dusk 12/09/2016 Temperature: Cloud Cover: Wind speed: Humidity Precipitation Temperature: Cloud Cover: Wind speed: Humidity Precipitation Temperature: Cloud Cover: Wind speed: Humidity Precipitation 18.6 o C 16 o C 10% 100% 0.4m/s 0.4m/s 74% 88% none none 19.8 o C 19.1 o C 95% 95% 0.1m/s 0.1m/s 45% 46% none none 21 o C 19 o C 10% 0% 1.6 m/s 0.2 m/s 67% 77% none none Equipment Inspections are both internal (where possible) and external, and make use of Torches Broadband Bat Detectors (Echometre Touch, bat box duet) Anemometers 10

11 Ladders Endoscopes where applicable Binoculars Cameras Sample bags 2.2 Limitations This survey follows best practice guidance to confirm presence/absence of roosting bats and where present, characterise the roost. However, this information is collected at finite dates and times, and provides an indication of the conditions on site only. The use of the structures and trees, and site as a whole, by bats, at all times cannot be established based on this information. There were no specific limitations to the survey regarding weather, access or safety. 11

12 3.0 Results 3.1 Survey Results Presence/absence and roost characterisation surveys Dinton Castle One non-echolocating bat was observed performing dawn swarming behaviour before re-entering the structure during the dawn survey, and one non-echolocating bat was observed emerging from the structure during a dusk survey. Bat droppings found on the southern elevation of the structure have been identified by DNA analysis as belonging to soprano pipistrelles. The structure is suspected of being a summer roost for a low number of soprano pipistrelles. Mature oak Approximately seven common pipistrelles were observed to emerge from the mature oak to the northeast of the structure. The oak is expected to be a summer day roost for a low number of common pipistrelles (<10). Common and soprano Pipistrellus pygmaeus pipistrelles were observed foraging around the site constantly over the three emergence / re-entry surveys. Occasionally other species such as Myotis nattereri, Myotis spp., Plecotus auritus and Nyctalus noctula were also heard around the area. This information is shown on the plans in Appendix 1 and in Table 4. 12

13 Table 4: Summary of survey results Date 22/07/2016 Sunset 05:12 Duration 03:30-05:22 Surveyor location on Survey subject (on plan (appendix I) plan in appendix I) Dawn Brief summary of passes and behaviour observed Common pipistrelle was heard but not seen passing at 03:46, 03:49, 04:56, 04:12 and 04:18. Common pipistrelle was observed flying north-east between the trees to the west of the structure at 04:29. Common pipistrelle was observed flying from the east to the south of the structure at 04:26. Soprano pipistrelle Pipistrellus pygmaeus was heard but not seen at 03:53. Two soprano 1 B1 looking north pipistrelles were observed flying north between the trees at 04:26. Soprano pipistrelle was heard foraging to the west of the structure at 04:28. One Myotis spp. was heard but not seen at 04:29. One non-echolocating bat performed re-entrance behaviour of circling the interior stone walls of the southern elevation of the structure between 04:32 and 04:40. One non-echolocating bat re-entered the structure at the highest large crevice on the southern wall. 2 B1 looking south Common pipistrelle was heard but not seen at 03:46, 03:48, 03:50, 03:57, 03:59 and 04:06. Common pipistrelle was seen flying south-west to the western side of the structure at 04:16 13

14 and 04:24. Common pipistrelle was heard foraging to the northern area of the building at 04:18. Soprano pipistrelle was heard but not seen at 04:28. Soprano pipistrelle was seen flying east at 04:35 and 04:40. One non-echolocating bat performed re-entrance behaviour of circling the interior stone walls of the southern elevation of the structure between 04:32 and 04:40. One non-echolocating bat re-entered the structure at the highest large crevice on the southern wall. Common pipistrelle was heard but not seen at 03:46, 03:57 and 03:59. Common pipistrelle was observed flying south of the structure, heading west at 04:26. 3 B1 looking west Soprano pipistrelle was heard foraging to the south of the structure at 04:35 and 04:37. One non-echolocating bat performed re-entrance behaviour of circling the interior stone walls of the southern elevation of the structure between 04:32 and 04:40. One non-echolocating bas re-entered the structure at the highest large crevice on the southern wall. Date 08/08/2016 Sunset 20:35 Duration 20:05 22:05 Dusk 14

15 Surveyor location on plan (appendix I) Survey subject (on plan in appendix I) Brief summary of passes and behaviour observed A silent bat was seen flying above the building towards the south-east at 20:57. A common pipistrelle was heard to pass close to the building at 20:57. Two common pipistrelles, were observed over the building at 21:01 where they displayed constant feeding activity for ten minutes around the oak that overhangs the north-east of the building. 1 B1 looking north An unidentified number of common pipistrelles and soprano pipistrelles were heard passing and feeding near to the building at 22:12 for a continuous period of approximately 20 minutes. Three Pipistrellus spp. were observed passing through the building at 21:12, 21:15 and 21:18. At 21:36 common pipistrelles and soprano pipistrelles were continuously heard passing the building until 21:50. 2 B1 looking south Myotis spp. were also heard at 21:12 for a continuous period of three minutes and then again at 21:18 and 21:20. A Pipistrellus spp. was observed to pass from south-west to north-east at 21:00 hours. Multiple Pipistrellus spp. passes were also heard at 21:25, 21:26, 21:28 and 21:33. A common pipistrelle was observed to pass, probably emerging from oak on south-west side of building, at 21:02. Between 21:02 and 21:13, approximately another 6 common pipistrelles were observed to pass, probably emerging from oak on north-east side of building, towards the north 15

16 section of the building. Constant Pipistrellus spp. activity was observed around the building between 21:13 and 21:19 A Pipistrellus spp. was observed foraging on south-west side of building at 20:57. A common pipistrelle was observed foraging at 21:10, 21:14 and 21:20. Constant foraging activity of two common pipistrelles was heard between 21:20 and 21:30. Two common pipistrelles were heard at 21:33. At 21:01 soprano pipistrelle was observed foraging on the east of the building. At 21:02 two soprano pipistrelles were also observed foraging on the east of the building. A soprano pipistrelle 3 B1 looking west was heard at 21:07. At 21:05 a silent bat was observed flying through the building from the direction of south-west to north-west. Myotis spp. was heard at 21:08 and 21:16 and was also heard at 21:12 and 21:18 whilst passing in the direction of south-west to north-east. Two Myotis spp. were observed at 21:20 in the direction of west to east. 16

17 Date 12/09/2016 Sunset 19:23 Duration 19:05-21:05 Surveyor location on Survey subject plan (appendix I) (on plan in appendix I) Dusk Brief summary of passes and behaviour observed One common pipistrelle was observed passing from the east to the west along the southern area of the structure at 19:40, 20:03, 20:15 and 20:33. Common pipistrelles were observed foraging around the area to the south of the structure at 19:44, 19:43-19:44, 19:45, 19:52, 19:54, 19:55, 19:57, 20:00, 20:07, 20:28 and 20:30. At least two bats were observed at any one time. One common pipistrelle was heard but not seen at 20:34, 20:44 and 20:46. 1 B1 looking north One soprano pipistrelle was heard and seen passing to the east around the southern area of the structure at 19:41 and observed foraging to the south of the structure between 19:48-19:56. One Natterer s bat was heard passing but not seen at 19:49. One brown long-eared was heard passing but not seen at 20:35 and 20:36. One noctule was heard but not seen passing at 20:44. One non-echolocating bat was observed emerging from a crevice on the interior southern wall at 19:46. 17

18 2 B1 looking south Common pipistrelles were observed foraging to the north of the structure at 19:39, 19:56, 20:08, 20:11, 20:18 and 20:33. At least two bats were observed at any one time. One soprano pipistrelle was observed foraging around the northern area of the structure at 19:48, 19:52, 19:54, 19:58, 20:29, 20:40 and 20:44. One non-echolocating bat was observed emerging from a crevice high on the interior wall of the southern elevation and flying through the window on that elevation at 19:46. Common pipistrelles were observed foraging around the trees to the south and east of the structure at 19:39-19:51, 19:53, 19:54, 20:20-20:25 and 20:33. A maximum of two bats were observed at any one time. Two common pipistrelles were observed emerging from the mature oak labelled T2 at 19:39 3 B1 looking west and 19:41. One soprano pipistrelle was observed foraging around the trees to the east and south of the structure at 19:52, 19:57-19:59, 20:08, 20:18, 20:22-20:25 and 20:34. One brown long-eared was heard but not seen at 20:37. 18

19 4.0 Conclusions and Impact Assessment 4.1 Conclusions The main conclusions of the PRA and emergence surveys undertaken at this site are described below. One building was surveyed, following recommendations made in the PRA. The building was confirmed to support a low number of soprano pipistrelle bats. One bat was observed re-entering the building in a crevice high on the internal southern wall on the dawn survey, and one silent bat was observed emerging from a similar area during a dusk survey. Two droppings found on the external wall on the southern elevation were sent off for DNA analysis and were identified as soprano pipistrelle. The structure is a summer roost for a low number (<5) of soprano pipistrelles. At least seven common pipistrelles were recorded emerging from the mature oak labelled T2 in Appendix 1. This tree is thought to be a summer night roost for a low number of common pipistrelles. Foraging activity around the structure was recorded for both common and soprano pipistrelles. Other species recorded at the site were Natterer s bat, brown long-eared, common noctule and Myotis spp. 4.2 Impact Assessment As the proposals include the renovation and restoration of the building, the roost will be destroyed. The proposals include no works to the tree T2 at this time and hence no direct impact on the bat roost is expected, although some disturbance may occur during the works. This would result in a contravention of legislation protecting bats, and a European Protected Species Mitigation Licence issued by Natural England is required to ensure legal compliance. Bats are protected under the Wildlife and Countryside Act and Conservation Regulations; see Appendix 3 for a summary of legislation protecting bats in the UK. 4.3 Recommendations Mitigation The bat roost present at the site meets the criteria for a Low Impact Class Licence. Alternatively, the surveys undertaken to date in and around the building and the site provide sufficient information to inform a European Protected Species Mitigation license (EPSML). An EPSML will be required (if a Low Impact Class Licence is not used) to enable the proposed works to be undertaken on this building lawfully, whilst ensuring the maintenance of the populations of the species concerned at a 19

20 favourable conservation status in their natural range; detailed mitigation will be described in the EPSML Method Statement. Natural England s European Protected Species Guidance: How to get a licence states: In order to obtain a licence to allow for the capture of EPS, damage or destruction of breeding sites, etc., in advance of any otherwise legitimate activity which may impact on the favourable conservation status of the EPS concerned, you.must demonstrate that the damage will be adequately compensated for to satisfy Regulation 53(9)(b)... Current Natural England advice is that there should be no net loss in the local population status of the species concerned, taking into account factors such as population size, viability and connectivity. Hence, when it is unavoidable that an activity will affect an EPS population, the mitigation should aim to maintain a population of equivalent status on or near the original site. As such, Mitigation is likely to include: Seasonal constraints on renovation (the crevices should be filled in and renovated between September and October to avoid breeding and hibernation seasons). An inspection of any crevices to be filled in with an endoscope by a licensed ecologist. Potential exclusion using newspapers and cloths of bats from any inspected crevices prior to any works taking place in these sections. A time delay between erecting scaffolding on site and inspecting any crevices to give bats time to move away from the disturbance. The installation of bat tubes, or leaving crevices in the walls to be maintained as bat roosts. The creation of replacement roosting through the use of bat boxes in the trees on site (potential places shown in Appendix 1). These boxes should be of Schwegler type and one should include a hibernation box. At least two boxes should be installed, in addition to the existing Schwegler bat box on tree T1. Trees T1 and T2 should be protected during construction; no lights during or post development should shine directly on these trees. Any lighting near or shining onto any trees, especially those with bat boxes in should be designed to minimize the impact it has on potential bat roosting and commuting. Lighting should be in-line with the BCT lighting guidelines (Bats and Lighting in the UK (Bat conservation trust, 2008) 11.pdf. 20

21 If bats are found during any stage of the development, work should stop immediately and a suitably qualified ecologist should be contacted to seek further advice Enhancement The Local Planning Authority has a duty to ask for enhancement under the NPPF and circular 06/2005: Biodiversity and Geological Conservation. Para.99, therefore bat boxes should be installed in the grounds of the site to provide an enhancement. These should be of the Schweglar type e.g. 1FF and a minimum of one box can be installed on retained trees or the new building within the grounds. The box should be no less than three meters off ground level and face south/southwesterly. No artificial light should shine on the boxes and clear flight paths to and from the boxes should be considered. 21

22 5.0 Bibliography Collins, J., Bat Surveys Good Practice Guidelines, 3 rd edition, Bat Conservation Trust, London. Mitchell-Jones, A.J. (2004). Bat Mitigation Guidelines. English Nature, Peterborough. Garland & Markham (2008) Is important bat foraging and commuting Lake, S., Liley, D., Still, R. & Swash, A., (2015. Britain s Habitats: A guide to the Wildlife Habitats of Britain and Ireland. WildGuides Ltd, Hampshire UK. Berthinussen, A., Richardson, O.C. & Altringham, J.D., (2014).Bat Conservation: Global evidence for the effects of interventions. Exeter: Pelagic Publishing. 22

23 Appendices 23

24 Appendix 1: Survey Plan 24

25 Plan showing proposed bat box positions for mitigation and enhancement: 25

26 Appendix 2: Proposed Site Plan 26

27 Appendix 3: Photos Photo 1: The eastern elevation of Dinton Castle. Photo 2: The southern elevation of Dinton Castle. 27

28 Photo 3: The north-western elevation of Dinton Castle. Photo 4: The stone work of Dinton Castle, with the emergency stabilisation works seen in the red bricks in the background. 28

29 Photo 5: The chimneys of Dinton Castle. Photo 6: The interior of a chimney flume. 29

30 Photo 7: Bat emergence/re-entrance points shown in circles on southern wall. Photo 8: The bat box attached to a tree to the west of Dinton Castle. 30

31 Appendix 4: Legislation and Planning Policy related to bats LEGAL PROTECTION All species of bat are fully protected under The Conservation of Habitats and Species Regulations 2010 (as amended) through their inclusion on Schedule 2. Regulation 41 prohibits: Deliberate killing, injuring or capturing of Schedule 2 species (e.g. all bats) Deliberate disturbance of bat species as: a) to impair their ability: (i) to survive, breed, or reproduce, or to rear or nurture young (ii) to hibernate or migrate b) to affect significantly the local distribution or abundance of the species Damage or destruction of a breeding site or resting place Bats are also protected under the Wildlife and Countryside Act 1981 (as amended) through their inclusion on Schedule 5. Under this Act, they are additionally protected from: Intentional or reckless disturbance (at any level) Intentional or reckless obstruction of access to any place of shelter or protection Selling, offering or exposing for sale, possession or transporting for purpose of sale Effect on development works: A European Protected Species Mitigation (EPSM) Licence issued by the relevant statutory authority (e.g. Natural England) will be required for works likely to affect a bat roost or for operations likely to result in a level of disturbance which might impair their ability to undertake those activities mentioned above (e.g. survive, breed, rear young and hibernate). The licence is to allow derogation from the relevant legislation but also to enable appropriate mitigation measures to be put in place and their efficiency/success to be monitored. The legislation may also be interpreted such that, in certain circumstances, important foraging areas and/or commuting routes can be regarded as being afforded de facto protection, for example, where it can be proven that the continued usage of such areas is crucial to maintaining the integrity and long-term viability of a bat roost (Garland & Markham, 2008) 31

32 NATIONAL PLANNING POLICY (ENGLAND) National Planning Policy Framework The National Planning Policy Framework promotes sustainable development. The Framework specifies the need for protection of designated sites and priority habitats and species. An emphasis is also made on the need for ecological infrastructure through protection, restoration and re-creation. The protection and recovery of priority species (considered likely to be those listed as UK Biodiversity Action Plan priority species) is also listed as a requirement of planning policy. In determining a planning application, planning authorities should aim to conserve and enhance biodiversity by ensuring that: designated sites are protected from harm; there is appropriate mitigation or compensation where significant harm cannot be avoided; opportunities to incorporate biodiversity in and around developments are encouraged; and planning permission is refused for development resulting in the loss or deterioration of irreplaceable habitats including aged or veteran trees and also ancient woodland. The Natural Environment and Rural Communities Act 2006 and The Biodiversity Duty Section 40 of the Natural Environment and Rural Communities (NERC) Act, 2006, requires all public bodies to have regard to biodiversity conservation when carrying out their functions. This is commonly referred to as the biodiversity duty. Section 41 of the Act (Section 42 in Wales) requires the Secretary of State to publish a list of habitats and species which are of principal importance for the conservation of biodiversity. This list is intended to assist decision makers such as public bodies in implementing their duty under Section 40 of the Act. Under the Act these habitats and species are regarded as a material consideration in determining planning applications. A developer must show that their protection has been adequately addressed within a development proposal. 32

33 Arbtech Consultant s Contact details: Lauren Fear MSc BSc (Hons) lf@arbtech.co.uk Arbtech Consulting Ltd 33