BAT SURVEY SADDLEWORTH. Report No 1 Draft September E3 Ecology Ltd Pasture House, Wark, Hexham, Northumberland, NE48 3DG.

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1 BAT SURVEY SADDLEWORTH Report No 1 Draft September 2014 Produced by: E3 Ecology Ltd Pasture House, Wark, Hexham, Northumberland, NE48 3DG T: E: mail@e3ecology.co.uk W:

2 Principal Contact: Jessica Andrews BSc MSc GradCIEEM Graduate Ecologist Team Leader/Checked by: Neil Beamsley BSc MCIEEM Associate Director Client Revision Status Date Author Proof Read Checked R01 Draft JA EB NB R02 Draft EB JA MO EC Harris LLP Job No Copyright to all written or recorded work howsoever held on whatever medium is vested in E3 Ecology Ltd. On settlement of all agreed fees, written work produced specifically for the named clients is thereafter regarded as joint copyright between the named client and E3 Ecology Ltd. No attempts should be made to reproduce any element of this report for commercial or other purposes, without explicit prior written permission from E3 Ecology Ltd. 2 E3 Ecology Ltd.

3 CONTENTS SUMMARY... 4 A INTRODUCTION... 7 A.1 Background to development... 7 A.2 Personnel... 8 A.3 Objectives of study... 9 B RELEVANT LEGISLATION AND PLANNING CONTEXT B.1 National Planning Policy Framework B.2 Protected species legislation C SURVEY AREA AND METHODOLOGY C.1 Survey area C.2 Methodology C.2.1 Desktop study C.2.2 Survey equipment C.2.3 Survey methods C.2.4 Timing C.2.5 Weather conditions D RESULTS D.1 Desktop study D.1.1 Pre-existing information D.1.2 Consultation D.1.3 Bat risk assessment D.2 Field survey D.2.1 Habitats D.2.2 Trees D.2.3 Built structures D.2.4 Activity Surveys D.2.5 Remote monitoring D.2.6 Other species E ASSESSMENT E.1 Assessment of survey findings E.2 Impacts E.3 Constraints F MITIGATION AND RECOMMENDATIONS F.1 Further survey F.2 Mitigation requirements G APPENDICES G.1 Appendix 1: Bat Ecology G.2 Appendix 2: Raw Transect Data G.3 Appendix 3: Remote Monitoring Data E3 Ecology Ltd.

4 SUMMARY E3 Ecology Ltd was commissioned by EC Harris LLP to undertake six dusk transect surveys of land proposed for the new Saddleworth School in February Initial proposals did not include the area to the north of the site, which includes several buildings. A daytime bat risk assessment of these buildings was undertaken in August The proposed development comprises the demolition of buildings on site in order to construct a new secondary school. The gatehouse building is to be retained. Consultation with the local records centre provided no records of bat roosts from within 500m of the site. However, there are 27 records of roosts from within 2km of brown long-eared, unidentified, common, soprano, Natterer s and whiskered bats. Survey work comprised a daytime assessment of the original survey area in September 2013, followed by monthly dusk transect surveys between April and September Remote monitoring was also undertaken at a fixed point each month. Initial inspection of the buildings to the north was undertaken on 5 th August Internal access had previously been arranged between E3 Ecology and a representative from the local Council, however was not upheld at the agreed time, therefore access could not be gained into all of the buildings. Habitats and setting around the site suggest a moderate to high risk of bats being present, due to the proximity to watercourses the Diggle Brook and Huddersfield narrow canal, and areas of woodland immediately adjacent to the site, which also provide excellent commuting routes between the site and the local area. Buildings on site represent a range of potential suitability for bats. The large complexes of industrial buildings to the north, a large, open sided storage shed and bridge connecting two other buildings on site are considered to have a low risk of supporting roosting bats. These buildings provide access to a number of potential roosting features, although internal conditions are largely unsuitable. The remaining buildings on site are considered to have a moderate to high risk of supporting roosting bats, and also have the potential to support low numbers of hibernating bats. This includes the Grade II listed gatehouse, which will be retained as part of the development. There are two structures within the western field, which are considered to be of negligible potential for roosting bats, comprising a small portacabin and a substation. In addition, there is a stone and concrete bridge over the brook along the access track into the industrial area. This is considered to have low potential to support roosting bats, with a small number of crevices within the stonework noted. Thorough external and, where possible, internal inspection of the buildings recorded no bat field signs. As not all of the buildings could be inspected internally, there is a risk that field signs in these areas were missed, and further survey work will be required to fully assess bat use of the structures on site. There therefore remains a risk that the buildings to the north of the site could support a maternity roost, and several of the buildings and the bridge have the potential to support hibernating bats. Further survey work, as described below will be required to confirm the presence or otherwise of roosting bats. Transect surveys of the southern half of the site recorded generally low levels of predominantly common activity, with very low numbers of soprano, noctule, Natterer s bat, Myotis and brown long-eared bats recorded. Survey work indicated 4 E3 Ecology Ltd.

5 that the brook through the centre of the site is used by foraging bats and from remote monitoring indicated that this feature is also used by bats commuting between nearby roosts, potentially within the buildings in the north of the site, and foraging habitats further afield. The potential presence of other protected species has been assessed within a separate extended phase 1 report. Detailed impact assessment with regard to roosting bats cannot be completed until additional survey work has been carried out, however, potential impacts include: Harm/disturbance to individual bats roosting within the buildings at the time of works. Harm/disturbance to individual bats that may be roosting within the bridge, should works be required to this. Risk of harm/disturbance to hibernating bats should works be carried out during the hibernation period. Loss of a number of crevice roost locations suitable for use by bats. Increased disturbance to bats foraging/commuting in the local area, particularly along Diggle brook, due to a change in lighting regime on site. Severance of commuting routes around the site as a result of the development. Detailed mitigation requirements with regards to the buildings within the north of the site cannot be outlined until further survey work has been completed. However, key mitigation requirements should bat roosts be confirmed may include: Should bat roosts be confirmed within the buildings or bridge on site, works to those structures will not commence until a Natural England development licence has been obtained. Demolition of buildings with risk of hibernating bats being present and any repointing works to the bridge will not be completed during the hibernation period (November to March inclusive). The two structures within the western field can be demolished without constraint. Prior to works commencing a site induction meeting will be held, attended by the project ecologist and lead contractors. Once scaffolding is in place the project ecologist will carry out a detailed inspection of the structures. Where evidence of current use is recorded, the project ecologist will install standard one-way exclusion valves. If one-way valves are used these will be left in place for a minimum of 2 nights when temperatures remain higher than 10 o C for at least one hour after dusk. No exclusion will be undertaken during the hibernation period. A copy of the relevant Natural England licence method statement will be provided to contractors as part of the induction process at the start of works. The project ecologist will review all key points with contractors during the induction and provide all necessary training. Works to buildings where bats roosts are not proven will be undertaken to a precautionary method statement, drawn up following additional survey work. If bats are found during works, works will stop in that area and the ecological consultant will be contacted immediately. If it is necessary to move the bats for their safety, this will be undertaken by a licensed bat handler. Bat boxes will be provided on site prior to works commencing to provide roosting opportunities during the works. Bat access routes into the new build will be created through incorporation of bat slates, access to the underside of ridge tiles etc. 5 E3 Ecology Ltd.

6 Lighting post development will be low level and low lux during and post development, where possible and any light spill onto the Diggle brook corridor, the adjacent canal and adjacent woodland habitats will be kept to a minimum. The local planning authority and Natural England are likely to require the means of delivery of the mitigation to be identified. It is recommended that mitigation and enhancement proposals are incorporated into the master-planning documents. Before this report can be used to support a planning application it is recommended that - Internal inspection of areas where access was unavailable is carried out. Three dusk/dawn activity surveys are carried out of moderate to high risk buildings between May and August. A single dusk activity survey is carried out of low risk buildings and bridge on site. If you are assessing this report for a local planning authority and have any difficulties interpreting plans and figures from a scanned version of the report, E3 Ecology Ltd would be happy to a PDF copy to you. Please contact us on E3 Ecology Ltd.

7 A INTRODUCTION E3 Ecology Ltd was commissioned by EC Harris LLP to undertake six dusk transect surveys of land proposed for the new Saddleworth School in February Initial proposals did not include the area to the north of the site, which includes several buildings. A daytime bat risk assessment of these buildings was undertaken in August As bats are small nocturnal species that can roost in inaccessible crevices only 16mm wide, it can be very hard to demonstrate that they are absent from a site, particularly given a limited number of visits during part of the year. As a result, assessment and development approaches are based on an informed risk assessment, and where appropriate a reasonable worst-case scenario, in order to ensure that bats are not recklessly harmed by the proposals. A.1 Background to development The site is situated to the south of Diggle, Greater Manchester at an approximate central grid reference of SE Site location is illustrated below in Figure 1. Figure 1 Site Location (Contains Ordnance Survey data Crown copyright and database right [2014]. It is proposed to demolish the buildings to the north of the site in order to build a new secondary school, with associated car parking, bus drop off and hard and soft play areas. The gatehouse building is to be retained. These proposals are not currently finalised, but the most recent revision is shown in figure 2, below. 7 E3 Ecology Ltd.

8 Figure 2. Development proposals (produced by HLM architects). A.2 Personnel Survey work and reporting was undertaken by: Jessica Andrews BSc MSc GradCIEEM Emma Barnes BSc MSc ACIEEM James Streets BSc MSc MCIEEM Mark Osborne Btech (Hons) MCIEEM Rebecca Melville BSc Ben Crossman BSc MRes GradCIEEM Susanna Lewis BSc Susanna Lewis BSc The project was supervised/checked by: Neil Beamsley BSc MCIEEM (Natural England licence No. CLS00815) Details of experience and qualifications are available at 8 E3 Ecology Ltd.

9 A.3 Objectives of study The objective of the study was to gain a sufficiently detailed picture of bat populations to allow an assessment of the likely impacts of the proposed development on these species, and where necessary to allow mitigation to be designed which minimises the risk of harm and maintains their conservation status in the local area (for example by ensuring that there is no net reduction in the number of available roost sites). Comments on the state of the structures within the site relate solely to their potential use by bats and must not be taken as a professional assessment of the structural integrity or safety of the structures. For example, descriptions of walls and roofs being in good or poor condition relate to likely provision of roost sites for bats, potential access routes to roost sites, and likely persistence of field signs such as droppings and feeding remains, which will not persist in exposed conditions. Maternity roosts are less likely to be present in cool, exposed, damp and draughty locations which may develop in a building in poor condition. 9 E3 Ecology Ltd.

10 B RELEVANT LEGISLATION AND PLANNING CONTEXT B.1 National Planning Policy Framework The National Planning Policy Framework (NPPF) states the following: Plan policies and planning decisions should be based upon up-to-date information about the natural environment (Paragraph 158 and 165). Plan policies should promote the preservation, restoration and recreation of priority habitats, ecological networks and the recovery of priority species (Paragraph 117). Local planning authorities should set out a strategic approach in their Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure. (Paragraph 114). When determining planning applications in accordance with the Local Plan and the presumption in favour of sustainable development local planning authorities should aim to conserve and enhance biodiversity by applying a number of principles, including if significant harm resulting from a development cannot be avoided, adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused. (Paragraph 118). B.2 Protected species legislation Bats Within England all bat species are specially protected under the Conservation of Habitats and Species Regulations (2010). As a result there is a requirement to consult with Natural England before undertaking any works that may disturb bats or their roost, and under the Conservation of Habitats and Species Regulations it is illegal to. Deliberately kill, injure or capture bats. Deliberately disturb bats; in particular any disturbance which is likely to impair their ability: (i) to survive, to breed or reproduce, or to rear or nurture their young; or (ii) in the case of animals of a hibernating or migratory species, to hibernate or migrate; or (iii) to affect significantly the local distribution or abundance of the species to which they belong. Deliberately obstruct access to a bat roost. Damage or destroy a bat roost. Under the Wildlife and Countryside Act (1981) the above offence of disturbing bats includes low level disturbance and as such under this act it is also an offence to: Intentionally or recklessly disturb at bat while it is occupying a roost. Intentionally or recklessly obstruct access to a roost. 10 E3 Ecology Ltd.

11 Under the above legal protection, only the offences under the Conservation of Habitats and Species Regulations (2010) are strict liability offences; the remaining offences, under the Wildlife and Countryside Act (1981), are offences only where they are carried out "intentionally or recklessly". Defences that were previously available under the Conservation (Natural Habitats, &c.) Regulations 1994, legislation which is superseded by the Conservation of Habitats and Species Regulations (2010), have now been removed. Specifically the 'dwelling-house' defence and the 'incidental result of a lawful operation' defence no longer apply. However the 'incidental result' defence persists within the Wildlife and Countryside Act and so disturbing bats or obstructing access to a roost and activities that cause low level disturbance may be able to rely on this defence. Under the Countryside and Rights of Way Act 2000 (CROW Act) the offence in section 9(4) of the 1981 Act of disturbing bats is extended to cover reckless damage or disturbance. The Hedgerow Regulations 1997 provide for the conservation of important hedgerows and their constituent trees. The presence of a protected species such as bats is a relevant consideration when assessing whether a hedgerow is important and may influence a local planning authority s decision on whether to approve removal of such hedges. As of October , public authorities have a duty to conserve biodiversity under the Natural Environment and Rural Communities (NERC) Act E3 Ecology Ltd.

12 C SURVEY AREA AND METHODOLOGY C.1 Survey area Figure 3 illustrates the site boundary whilst Figure 4 illustrates the broad habitats present on site and within an approximate 500m buffer zone. Figure 3 Aerial photograph illustrating the extent of the site with a redline boundary (Reproduced under licence from Google Earth Pro.) Figure 4 Aerial photograph centred on the site with a 500m radius illustrating the setting and the habitats it supports (Reproduced under licence from Google Earth Pro.) The study area includes the site and adjacent land to allow for possible secondary impacts in line with Natural England recommendations. C.2 Methodology C.2.1 Desktop study Initially, the site was assessed from aerial photographs and 1:25000 OS plans. Following this, consultation was undertaken with the Local Records Centre, and the MAGIC website was checked for any notable sites or habitat records. C.2.2 Survey equipment The following items of equipment were utilised during survey work and analysis: 8x40 binoculars 320 lumen torch Anabat recorder and GPS Analook software 12 E3 Ecology Ltd.

13 C.2.3 Survey methods Initial Inspection A daytime assessment was made of all structures and trees affected by the proposed development, in order to evaluate their potential for supporting bat roosts, and where present to record signs of use by bats. Structures were inspected both externally and internally where access was available. Binoculars were used to assist with the inspection for droppings and other field signs. Where present, soffits, purlins and ridge boards were searched thoroughly, together with the floor under potential roost sites. Wherever practicable, roof spaces and attic areas were surveyed for signs of droppings, which persist all year in dry conditions, food debris, entry points and bats themselves. Externally, the buildings were examined for potential roost access points indicated by clean crevices, urine marks, polished wood or stonework and droppings. Particular attention was given to sheltered areas under the eaves of buildings, window ledges and towards the tops of windows where droppings are less likely to have been washed off. Transect Survey The transect route was assessed during the daytime site visit in order to fully assess any health and safety issues, the time it takes and to determine the best places to include fixed monitoring points. Habitats were assessed and mapped at the same time. The transect route and location of fixed monitoring points is shown in figure 5, below. Transects were completed within two hours of sunset and incorporated easily identifiable landscape features to aid navigation and to divide the route into sections of similar habitat type. Survey was only undertaken when conditions were suitable for bat activity. The route was chosen to incorporate habitat features with potential for use by foraging and commuting bats as well as potential low value habitats, giving a good sample of the site and its setting as a whole. The route incorporated fixed monitoring points at important features such as watercourses and woodland along route but also sought to sample all habitat types within survey area, not just higher value features. The fixed monitoring points give a better assessment of use of habitats by species such as Daubenton s bat and woodland bat species that may otherwise be missed. At each monitoring point, the surveyor recorded the number of bat passes per species for 3 minutes, together with light level. Weather conditions were recorded at the start and end of the survey, together with any significant changes during the survey, which may have influenced bat activity. Analysis Transects were undertaken using Anabat detectors linked to GPS to provide location data at regular intervals. Data were recorded to allow confirmation of species identification through analysis using Analook software, and to capture brief echolocation calls that could not be reliably identified in the field. Field survey recorded numbers of bats detected, feeding activity, flight paths, species (as far as is practicable), and social calls. Given good calls many species, including common and soprano s, and noctule can be identified with a good degree of confidence. The Myotis genus of bats are much harder to separate reliably as their frequency modulated calls are very similar. For these species a 13 E3 Ecology Ltd.

14 combination of call loudness, frequency range, habitat and flight characteristics can be used to provide a best estimate. With Anabat recordings slope analysis was used to help indicate likely species. In the text bats are identified as accurately as possible, within the constraints identified above. If the species name is given without qualification, the record was of good quality. If there is a degree of uncertainty this is indicated by a question mark, e.g.?brown long-eared. If identification to species is not practicable then just the Genus or bats is used. Records of generally refer to bats with a like call but with the peak energy around 50KHz. C.2.4 Timing An initial site walkover of the southern half of the site was undertaken on the 10 th September A total of 2 hours was spent assessing the site. Initial site inspection of the additional area to the north was undertaken on the 5 th August A total of 3.5 hours was spent inspecting the buildings within the north of the site. Transect surveys were undertaken on the following dates: Date Start Time End Time Time of No.of Sunset/rise Surveyors :53 20:35 19: :24 23:21 21: :43 23:32 21: :34 23:30 21: :00 22:15 20: :45 21:24 19:59 2 C.2.5 Weather conditions Weather conditions recorded on each survey are provided in the table below. Date Start Temp. End Temp. Cloud Precipitation Wind Cover Conditions C 7 C 30% None % Light showers C - 5% None % None C 19 C 30% None C 13 C 100% None 0 14 E3 Ecology Ltd.

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16 D RESULTS D.1 Desktop study D.1.1 Pre-existing information OS map & aerial photographs Figures 1 (A1) and 4 (C1) show that the general land use in the surrounding area is dominated by pasture fields, with some areas of scrub and woodland. The residential area of Diggle is present to the west of the site. The Diggle Brook runs through the site, and the Huddersfield narrow canal is present to the eastern boundary. The most recent aerial photograph of the site suggests that habitats on site comprise pasture fields, woodland and areas of hard standing, as well as the group of buildings to be demolished. Historic imagery suggests that land use on site has remained the same since at least the year D.1.2 Consultation Local Records Centre Consultation with the Greater Manchester Ecology Unit indicated there are 27 recorded bat roosts of species including brown long-eared, common, Natterer s, soprano s, whiskered bat and unidentified bats within 2km of the site. There are no records of roosts from within 500m of the site. The location of these roosts and of other records of bat signs are shown in figure 6, below. 16 E3 Ecology Ltd.

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18 D.1.3 Bat risk assessment Habitats and cover within 200m Habitats within 1km Alternative roosts within 1km Setting Risk of supporting roosting bats 1 Minimal Low Medium High City Centre City Centre City centre Inner city Habitats and Setting Open, exposed arable, amenity grass or pasture Little tree cover, few hedges, arable dominated Numerous alternative roost sites of a similar nature Urban with little green space Hedges and trees linking site to wider countryside Some seminatural habitats, trees hedges etc A number of similar buildings in the local area Build development with greenspace, wetland, trees Excellent cover with mature trees and/or good hedges Good network of woods, wetland and hedges Few alternative buildings and site of good quality for roosts Rural Lowland with woodland and trees. Distance to water/marsh >1km 500m-1000m 200m-500m <200m Distance to woodland/scrub Distance to species-rich grassland Commuting routes Approximate age Building/complex type >1km 500m-1000m 200m-500m <200m >1km 500m-1000m 200m-500m <200m Isolated by development, major roads, large scale agriculture Modern well sealed Industrial complex of modern design No potential flyways linking site to wider countryside Buildings Some potential commuting routes to and from site Site is well connected to surrounding area with multiple flyways Post 1940 s Pre 20 th C Single, small building Several buildings, large old single structure Building - storeys Single storey Multiple storeys Stone/brick work Framework timbers/steel Roof void No detectable crevices Modern sheet materials, steel frame steel sheet cladding Fully sealed or flat roof Well pointed timber purlins, sheet asbestos Small, cluttered void Some cracks and crevices Timbers kingpost or similar Medium, relatively open Set of traditional farm buildings, country house, castle, hospital Multiple storeys, large roof voids Poor condition, many crevices, thick walls Large timbers traditional joints Large, open, interconnected 1 This risk assessment technique has been audited through aresearch project with York University which compared the risk assessment scoring with the results of detailed field assessment for over 100 sites. Statistically significant associations were found between habitat setting and building features and the presence of absence of different bat species. For example habitat connections and nearby woodland were significant for brown long-eared bats and the presence of species-rich grassland is important for many species. 18 E3 Ecology Ltd.

19 Roof covering Additional features External lighting Risk of supporting roosting bats 1 Minimal Low Medium High Modern sheet materials and Tightly sealed Very well maintained and tightly sealed Extensive security lights covering much of the site Good condition, no gaps or very open not weatherproof modern sheet materials No features with potential access Widespread areas above 2 lux at night Some potential access routes, slates, tiles Some features with potential access Intermittent lights of low intensity Uneven with gaps, not too open, stone slates Hanging tiles, cladding, barge boards, soffits with access gaps Minimal Building use Very noisy, dusty Regular use Intermittent use Disused Overall, there is considered to be a moderate to high risk of bats being present in the local area due to the proximity of the buildings to watercourses, areas of standing water and woodland, which will provide good quality foraging habitat, as well as providing commuting routes to and from the site. Buildings on site represent a range of suitability to bats. Some buildings remain in use, or are of modern sheet material construction, therefore are likely to be poorly suited to supporting roosting bats. Other buildings on site are of stone or brick construction, with pitched roofs and loft spaces, and will provide more potential roosting opportunities. This is discussed further within full building descriptions below. D.2 Field survey D.2.1 Habitats Foraging habitats Habitats within the site will provide good quality foraging habitats, potentially to a range of bat species, due to the presence of woodland immediately to the west of the buildings, and the proximity of the Diggle Brook and Huddersfield narrow canal. Pasture fields to the south are likely to provide lower quality opportunities. Commuting routes The brook and canal will provide commuting routes to good quality habitats in the wider area. There is also a potentially valuable commuting link provided by the woodland edge immediately to the west of the buildings, to further areas of woodland and standing water to the north. Exposed/sheltered The site as a whole is in a relatively exposed location, being largely surrounded by open pasture fields. However, woodland to the west of the site will provide more sheltered foraging opportunities, with some of the open sided buildings on site also potentially providing foul weather foraging areas. 19 E3 Ecology Ltd.

20 Potential alternative roost locations The residential area of Diggle to the north and west and scattered farm buildings and houses to the north and east provide potential alternative roost locations. D.2.2 Trees There is a small area of broadleaf woodland to the north of the site. The trees within are semimature to mature and well-sealed therefore offering no roosting opportunities. Species present include willow (Salix sp.), ash (Fraxinus excelsior), lime (Tilia sp.), sycamore (Acer pseudoplatanus), silver birch (Betula pendula), alder (Alnus glutinosa), rowan (Sorbus aucuparia) and cherry (Prunus sp.). D.2.3 Built structures Figure 7 below provides a numbered plan of buildings within the northern half of the site, which were assessed during the bat risk assessment. In addition, there are two small structures within the western field to the south. These comprise a small, well sealed portacabin and a small concrete building, with a flat felt roof. The felt overlaps at the edges with the felt either missing or raised at the overlap. Where it is raised the gaps are likely to be too large to be used by roosting bats. These structures are both considered to have negligible potential to support roosting bats. There is also a small road bridge over Diggle Brook, which the access road to the industrial area runs over. This has stone walls, with a small number of gaps noted in the pointing. The underside of the deck comprises concrete arches, which are well sealed. There are large gaps around where pipes enter the walls, but these show use by nesting birds, potentially dipper. The bridge is considered to have low potential to support roosting bats. 20 E3 Ecology Ltd.

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22 Building 1: External: Complex of stone warehouses to the north of the site. Two storey in height, but ground floor is open to the roof in the majority of areas. Roofs comprise flat, felt covered areas, surrounding central pitched sections, or sheet plastic materials. Roof edges are raised, with a capping stone to the wall tops, providing no obvious crevices. Windows are generally boarded up, with gaps above some of the boarding that will allow potential access into the building. Stone lintels and window surrounds are generally well sealed. Stonework is in moderate condition, with some cracks, but no obvious crevices. A very small, single storey, flat roofed shed with felt covering is present adjoining the southern end of the complex, and is of negligible risk of supporting roosting bats. Internal: Internal light levels are very high due to transparent roof coverings. Most of the building complex is in use as storage areas, with the south eastern block in use as a factory. Internal conditions in this section are therefore very noisy and dusty, and hence unlikely to support roosting bats. Overall the building is considered to have a low risk of supporting roosting bats. Building 2: A large storage shed, constructed from sheet materials. The shed is open to 3 sides, with metal pillars on concrete supports. The western elevation comprises wooden slatting. Corrugated metal roof. Negligible risk of supporting roosting bats. Building 3: External: Second complex of stone built warehouses, which are now disused. Largely of two storey construction, with a single storey, flat, felt roofed section to the northern end. Main part of the building again has flat roofed sections surrounding central, pitched roofs of transparent sheet plastic material. Stonework is in good condition. Three storey tower present to eastern end of 22 E3 Ecology Ltd.

23 building. Connected to the southernmost warehouse are several other structures, including a timber shed, which has large rot holes, suggesting the interior is very exposed in nature. Internal: This building is now disused, and has become heavily infested with feral pigeons. Internal light conditions again very high due to transparent roof covering. Access to upstairs areas was not available due to health and safety concerns. Building 4: External: Pitched roof structure adjoining building 3. Internal: Two storey, stone construction, with slate tiled roof. The roof is in moderate condition, with the vast majority of tiles intact. A large section of lifted lead flashing is present which may provide crevice roost locations, although appears very exposed. Ridge tiles are damaged in places. Stone work generally in good condition. Windows present to the first floor are metal framed and are open to the western elevation. Internal access to this building identified that the first floor is open to the roof. The roof is timber lined, with two potential access holes identified. No bat signs recorded. The building is infested with feral pigeons. Overall considered to have moderate bat roosting potential. Building 5: External: Connecting bridge between building 4 and building 6. Constructed from sheet metal which has been riveted together. Flat, felt covered roof. Metal framed windows are present and appear well sealed. 23 E3 Ecology Ltd.

24 Internal: Timber lined internally, appears well sealed throughout. No bat field signs recorded. Negligible risk of supporting roosting bats. Building 6 (Gatehouse): Grade II listed gatehouse building, which will be retained as part of the development. Three storey, stone construction, with multiple pitched, slate tiled roofs. Four storey clock tower present to the western end of the building. Roof appears in good condition, although some tiles are lifted. Ridge looks as though it may have recently been replaced, although a broken ridge tile was present on the ground in front of the building. Two chimneys present, lead flashing is present, but appears well sealed. Stone work is in good condition throughout. Clock tower has metal railings to the third storey, potentially allowing bat access. Arched windows are tightly fitted into wooden surrounds throughout building. No bat field signs recorded. Moderate risk of supporting roosting bats. No internal access was available to this building. Building 7: Two storey brick and stone complex. Two pitched roof sections, with slate tiles. Flat roofed, stone section present to the eastern side. Roof is in moderate condition with some slipped and lifted slates, potentially creating crevices beneath. Some sections of building are timber clad, which is lifted and broken in places, potentially creating crevices. Windows have largely been bricked up or boarded up, and are well sealed. Some windows broken to the eastern section, potentially allowing access. An external, enclosed wooden staircase with flat, felt roof is present to the eastern elevation. Security lights present. 24 E3 Ecology Ltd.

25 No internal access was available, but it could be seen from the exterior that the first floor is open to the roof. No field signs recorded. Moderate to high risk of supporting roosting bats. D.2.4 Activity Surveys 8th April 2014 Transect survey on the 8 th April 2014 recorded no bat activity within the site. 20 th May 2014 Transect survey recorded low to moderate levels of common activity within the site. No other bat species were recorded. Bats were recorded foraging at the southern site boundary and a number were recorded but not seen along Diggle brook and the canal to the east, potentially indicating that they are commuting along these features. 12 th June 2014 Low levels of common activity were recorded within the site, with only seven bat passes recorded, all of which were common. All bats were recorded within the south western section of the site. 7 th July 2014 Transect survey recorded low levels of common activity, with bats mainly associated with the site boundaries or Diggle Brook. Bats were generally commuting along these boundaries, with small numbers foraging on site. 5 th August 2014 The transect survey recorded low levels of common activity within the site, again associated with the site boundaries and brook. 1 st September 2014 Low levels of common activity were recorded within the site, along with single Noctule and Natterer s bat passes. Records were spread along the boundary of the western field, with two bats recorded foraging along the brook through the centre. Figures 8, to 12 illustrate the location of bat passes recorded during the surveys in May, June, July, August and September respectively. No figure is provided for April as not bats were recorded. Raw data is provided within the appendices. 25 E3 Ecology Ltd.

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31 D.2.5 Remote monitoring Remote monitoring was undertaken in April (8 nights), May (4 nights), June (14 nights), July (22 nights), August (27 nights) and September (6 nights). The location of the remote detector is shown in figure 5. The table below details the average bat passes per night, per month and the proportion of species that were recorded. Bat passes were predominantly common, with occasional passes of other species. The average number of passes per hour shows some variation between months, but is generally quite low, with the exception of June. In this month there were three consecutive nights with unusually high numbers of common passes ( ), which may indicate that these bats were foraging within the group of trees in which the detector was located. If these nights are excluded from the calculations, the average number of passes falls to 5.12, similar to the other months. A table providing the first and last records of bat activity, passes per hour and per night of each species is provided within the appendices. Bat activity commenced within 30 minutes of sunset on the majority of nights, with peaks in activity seen in the first 1-3 hours after sunset and prior to sunrise on occasion. This indicates that roosting bats are present within close proximity, potentially within the buildings to the north, and that the brook provides a commuting route to habitats further afield. Month Average passes/hour Soprano Species composition Pipistrelle sp. Noctule Natterer's?Brown longeared April % 0.2% - 0.2% May % June 13.17* 99.8% 0.1% % - - Myotis July % 0.9% 0.2% 0.2% % August % 1.6% 10.9% % 1.2% September % - 2.2% % D.2.6 Other species Other protected species are considered within a separate extended phase 1 report. 31 E3 Ecology Ltd.

32 E ASSESSMENT The value and significance of the habitats and species found was assessed against the following criteria developed from the Guidelines for Ecological Impact Assessment produced by the Institute of Ecology and Environmental Management 2. Level of Value International National Regional County District Parish Examples An internationally designated site or candidate site. A viable area of a habitat type listed in Annex I of the Habitats Directive, or smaller areas of such habitat, which are essential to maintain the viability of a larger whole. Any regularly occurring population of an internationally important species, which is threatened or rare in the UK. Any regularly occurring, nationally significant population/number of any internationally important species. A nationally designated site. A viable area of a priority habitat identified in the UK BAP, or smaller areas of such habitat, which are essential to maintain the viability of a larger whole. Any regularly occurring population of a nationally important species, which is threatened or rare in the region or county. A regularly occurring regionally or county significant population/number of any nationally important species. A feature identified as of critical importance in the UK BAP. Viable areas of key habitat identified in the Regional BAP or smaller areas of such habitat, which are essential to maintain the viability of a larger whole. A regularly occurring, locally significant number of a regionally important species. Bats: large maternity sites used by rare species in the region, including Nathusius, Leislers and Brandts bats. County designated sites. A viable area of a habitat type identified in the County BAP. Any regularly occurring, locally significant population of a species which is listed in a County red data book or BAP on account of its regional rarity or localisation. A regularly occurring, locally significant number of a species important in a County context. Bats: large maternity sites used by uncommon species in the region, including Daubenton, Natterers, soprano, noctule, brown long eared and whiskered bats; or small to moderate maternity roosts, hibernation and autumn swarming roosts used by rare species Areas of habitat identified in a District level BAP. Sites designated at a District level. Sites/features that are scarce within the District or which appreciably enrich the District habitat resource. A population of a species that is listed in a District BAP because of its rarity in the locality. Bats: small numbers of non-breeding rare species (5+); small-moderate maternity or hibernation roosts used by uncommon species, large maternity roost of common species to the region (common ) Area of habitat considered to appreciably enrich the habitat resource within the context of the Parish. Local Nature Reserves. Bats: large hibernation, small-moderate maternity and autumn swarming roosts of common species; small numbers of uncommon species or occasional (1-4) roost of rare species 2 Institute for Ecology and Environmental Management (2006) Guidelines for Ecological Impact Assessment in the United Kingdom (Version 7 July 2006) E3 Ecology Ltd.

33 Level of Value Local Low Examples Habitats and species that contribute to local biodiversity, could only be replicated in the medium term, but are common in the local area. Loss of such habitats would ideally be mitigated if local biodiversity is to be conserved and enhanced. Bats: small numbers of common species, feeding/individual roosts of uncommon species or feeding roosts of rare species. Habitats of poor to moderate diversity such as established conifer plantations, species poor hedgerows and unintensively managed grassland that may support a range of Local BAP species but which are unexceptional, common to the local area and whose loss can generally be readily mitigated. 33 E3 Ecology Ltd.

34 E.1 Assessment of survey findings There are no trees within the site boundary considered suitable to support roosting bats. Buildings on the northern half of the site range from a low to moderate-high risk of supporting roosting bats, with the two structures within the southern half considered to be of negligible risk. It is considered that the large warehouse complexes, building 2 and building 5 are generally of low value to bats, given the limited number of access routes and unsuitable internal conditions. The remaining buildings on site are considered to have a moderate to high risk of supporting roosting bats. The road bridge on site is considered to have a low risk of supporting roosting bats. There is a risk that buildings on site may support a maternity roost, particularly given the high quality of habitats in the local area. Further internal inspection of areas which could not be accessed at the time of survey is recommended, alongside bat activity surveys, in order to fully assess this. Buildings 4, 6 and 7 and the bridge are also considered to have potential to support hibernating bats. Transect survey work of the southern half of the site recorded generally low levels of bat activity across the area. Bat passes recorded were predominantly common, with very small numbers of soprano, Natterer s, noctule, Myotis and brown long-eared bats recorded. The brook through the centre of the site is used by foraging bats and remote monitoring data indicates that it is used by bats commuting between nearby roosting locations to foraging habitats further afield. E.2 Impacts Bats are most vulnerable to disturbance during June, July and August, when they are breeding, and between November and March when they are hibernating. There is risk of a maternity roost being present on site, with further survey work required to determine whether such a roost is present. There are also considered to be some potential opportunities for hibernating bats to use buildings 4, 6 and 7 and the bridge. A full impact assessment cannot be completed until further bat activity surveys of the site have been undertaken, however, impacts are likely to include: Harm/disturbance to individual bats roosting within the buildings at the time of works. Risk of harm/disturbance to hibernating bats should works be carried out during the hibernation period. Loss of a number of crevice roost locations suitable for use by bats. Increased disturbance to bats foraging/commuting in the local area, particularly along Diggle brook, due to a change in lighting regime on site. Severance of commuting routes around the site as a result of the development. E.3 Constraints Internal access could not be gained into all of building 1, first floor areas of building 3, building 6 or building 7 at the time of initial inspection, therefore bat field signs may have been missed within these areas. 34 E3 Ecology Ltd.

35 F MITIGATION AND RECOMMENDATIONS F.1 Further survey The following further survey work is recommended: Internal daytime inspection of buildings 6 and 7. Three dusk or dawn activity surveys of moderate to high risk buildings (buildings 4, 6 and 7), between May and August. A single dusk activity survey of low risk buildings (buildings 1, 2, 3 and 5) and the bridge between May and August. F.2 Mitigation requirements Detailed mitigation requirements cannot be fully outlined until further survey work, detailed above has been completed. However, key mitigation requirements should bat roosts be confirmed may include: Timing of Works Should bat roosts be confirmed within the buildings or bridge on site, works to these structures will not commence until a Natural England development licence has been obtained. Demolition of buildings with risk of hibernating bats being present or any repointing works to the bridge will not be completed during the hibernation period (November to March inclusive). The two structures within the western field can be demolished without constraint. Prior to works commencing a site induction meeting will be held, attended by the project ecologist and lead contractors. Once scaffolding is in place the project ecologist will carry out a detailed inspection of the structures. Where evidence of current use is recorded, the project ecologist will install standard one-way exclusion valves. If one-way valves are used these will be left in place for a minimum of 2 nights when temperatures remain higher than 10 o C for at least one hour after dusk. Exclusion will not be undertake during the hibernation period. Working Methods Should a roost be confirmed, a copy of the relevant Natural England licence method statement will be provided to contractors as part of the induction process at the start of works. The project ecologist will review all key points with contractors during the induction and provide all necessary training. Works to buildings where bats roosts are not proven will be undertaken to a precautionary method statement, drawn up following additional survey work. If bats are found during works, works will stop in that area and the ecological consultant will be contacted immediately. If it is necessary to move the bats for their safety, this will be undertaken by a licensed bat handler. Lighting post development will be low level and low lux during and post development, where possible and any light spill onto the Diggle brook corridor, the adjacent canal and adjacent woodland habitats will be kept to a minimum. 35 E3 Ecology Ltd.

36 Habitat Creation and Enhancement Bat boxes will be provided on site prior to works commencing to provide roosting opportunities during the works. Bat access routes into the new build will be created through incorporation of bat slates, access to the underside of ridge tiles, bat boxes etc. Good working practices The following measures should be included as general good working practice: Timber treatments that are toxic to mammals will be avoided. If required, timber treatment will be carried out in the spring or autumn. Both pre-treated timbers and timber treatments will use chemicals classed as safe for use where bats may be present (see External lighting that may reduce bat use of the buildings will be avoided. High intensity security lights will be avoided as far as practical, and any lighting in areas identified as being important for bats will be low level (2m) and low wattage (50w). The landscape planting will be designed to enhance structural diversity, and will include plants bearing flowers, nectar and fruits which are attractive to invertebrates, thereby helping to maintain the food resource for bats and wildlife generally. 36 E3 Ecology Ltd.