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St Mary Redcliffe Ecological Impact Assessment

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Ecological Assessment for St. Mary’s Church,

Redcliffe

Prepared by LUC

October 2019


Project Title: St. Mary’s Church, Redcliffe

Client: Purcell UK

Version Date Version Details Prepared by Checked by Approved by

1. 25/10/19 Draft Isaac Hogan Greg

Nightingale

Greg

Nightingale


Ecological Assessment for St. Mary's Church,

Redcliffe

Prepared by LUC

October 2019

Planning & EIA

Design

Landscape Planning

Landscape Management

Ecology

Mapping & Visualisation

LUC BRISTOL

12 th Floor Colston Tower

Colston Street Bristol

BS1 4XE

T +44 (0)117 929 1997

bristol@landuse.co.uk

Offices also in:

London

Glasgow

Edinburgh

FS 566056 EMS 566057

Land Use Consultants Ltd

Registered in England

Registered number: 2549296

Registered Office:

43 Chalton Street

London NW1 1JD

LUC uses 100% recycled paper


Contents

1 Introduction 5

Site description 5

Project Description 5

Purpose 5

Policy and Legal Considerations 6

2 Method 7

Desk Study 7

Extended Phase 1 Habitat Survey 7

Bats 8

Limitations 10

3 Results 11

Desk Study 11

Extended Phase 1 Habitat Survey 16

Bats 16

Birds 17

Badgers 17

Other Notable Species 17

4 Discussion 18

Statutory Designated Sites and Non-Statutory Designated Sites 18

Habitats 18

Bats 18

Birds 19

Enhancements 20

5 Conclusion 21

Appendix 1 22

Site Plan 22

Appendix 2 22

Policy & Legal Considerations 23

Appendix 3 26

Phase 1 Habitat Survey Results 26

Appendix 4 27

Phase 1 Habitat Survey Target Notes 27

Appendix 5 28

BRP Features on T5 28

Tables

Table 2.1: Guidelines for assessing the suitability of structures and trees for bats to roost within 9

Table 3.1 Desk Study Findings – Site Search 11

Table 3.2 Desk Study Findings – Species Search 13


1 Introduction

1.1 LUC was appointed by Purcell UK on behalf of St. Mary’s Church to provide ecological support and

input into development plans to redesign and re-landscape aspects of St. Mary’s Church,

Redcliffe. This report sets out an Ecological Assessment to establish whether work undertaken on

St. Mary’s Church (referred to from here on out as ‘the Site’), would have any effect on the

ecology of the Site and the surrounding area.

Site description

1.2 Site consists of amenity grassland lawns in front of the church, intersected with hardstanding

walkways. In the rear garden on each side of the perimeter are two rows of mature trees. The

east is joined by an adjacent area of shrub and immature trees.

1.3 The Site sits near the centre of Bristol, on a popular east-west axis for public transport, cycling

and walking; connecting Temple Meads to the city centre and the Harbourside (central grid

reference ST 591723). Being a gothic parish church used from the 12 th century and listed by

Historic England as a Grade 1 listed building, it serves a popular destination for people transiting

through the city. Due to its centrally geographic, urban, location the Site is considered relatively

ecologically isolated and as an area of potential importance for wildlife living in the city of Bristol.

Project Description

1.4 A planning application will be submitted in the near future for proposed works, designed to

expand the area within the church grounds that can be utilised by visitors. This involves the

northern formal lawns being removed, replaced on the north-eastern boundary with large

oversized stone steps and new areas of planting. Between the steps and the original church

building a newly constructed structure will be built to house an exhibition space, gallery area, gift

shop, café and toilet facilities. This will extend one storey up from ground level, but will also

include a below ground level.

1.5 In the south-east corner, a single storey, raised, lightweight building will run in parallel with Pump

Lane. An area of scrub will have to be removed for construction to take place. The building will be

raised by being built on wooden support structures that will elevate it off the floor, the space will

be used as an educational facility and studio space. The design will be largely glazed to allow for

the garden setting to be viewed from within the building.

Purpose

1.6 This report is designed to provide an ecological assessment of the Site, assessing the impacts of

the proposals and outlining mitigation where needed.

1.7 This report will contain the ecological information needed to help the local planning authority

make a decision regarding the development plans to the Site.

Ecological Impact Assessment for St.Marys Church, Redcliffe 5 September 2019


Policy and Legal Considerations

1.8 This report has been prepared in accordance with the relevant legislation and planning policy.

Further details are given in Appendix 2, the following documents are of relevance:

• The Wildlife and Countryside Act 1981 (as amended);

• The Countryside and Rights of Way Act (CRoW Act), 2000 (as amended);

• The Natural Environment and Rural Communities Act (NERC Act), 2006;

• The Conservation of Habitats and Species Regulations 2017 (as amended);

• The Protection of Badgers Act 1992 (as amended);

• Bristol Central Area Plan (2015); and

• Bristol Biodiversity Action Plan (BAP) (2018)

Ecological Impact Assessment for St.Marys Church, Redcliffe 6 September 2019


2 Method

2.1 The methods adopted in the survey throughout the assessment are outlined below. They accord

with the good practice guidance documents for ecological survey and assessment produced by the

Chartered Institute of Ecology and Environmental Management 1 and the British Standards

Institute 2 .

Desk Study

2.2 To provide additional background information to the report, and to highlight any potential habitat

and/or species that may be influenced over the proposed changes to the Site, an evaluation of

pre-existing biological records was undertaken. A data search for statutory designated sites within

a 5km of the Site was undertaken as well as a data search for non-statutory designated sites, bat

records and other notable species groups within 2km of the Site.

2.3 Data was both requested and collated from the following sources:

• Bristol Regional Environmental Records Centre (BRERC); and

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

2.4 Absence of species records within the desk study from the biological records does not equate to

absence in reality. Species distributions were interpreted with caution as they may reflect surveyreporting

effort rather than actual distributions.

Extended Phase 1 Habitat Survey

2.5 A Phase 1 Habitat Survey was undertaken. This survey is a rapid, standardised approach to

categorising different habitat types within any given terrestrial site, and was carried out within the

Site boundary.

2.6 A DAFOR scale was applied to the species listed within each habitat type. A DAFOR scale assigns a

letter to a species based on how prominent they are within that particular habitat, it is at the

discretion of the surveyor to decide what label to assign to a particular species. DAFOR translates

as:

• D – Dominant

• A – Abundant

• F – Frequent

• O – Occasional

• R – Rare

2.7 The survey was ‘extended’ by considering the suitability of the Site for notable or protected fauna

and flora. Species considered included those identified within the desk study, or those considered

appropriate by the surveyor whilst on Site. The survey was conducted by Greg Nightingale BSc,

ACIEEM and Isaac Hogan BSc, MSc, QCIEEM on 12 th August 2019. Weather conditions were sunny

and dry.

1 Survey guidance is available at http://www.cieem.net/sources-of-survey-methods-sosm- and appraisal guidance is available at

http://www.cieem.net/guidance-on-preliminary-ecological-appraisal-gpea-

2 British Standards Institute (2013). BS42020:2013 Biodiversity – Code of Practice for Planning and Development. BSI, London.

Ecological Impact Assessment for St.Marys Church, Redcliffe 7 September 2019


2.8 A list of other species considered during the Extended Phase 1 Habitat Survey are listed below:

• Badger

• Dormice

• Great Crested Newt (GCN)

• Nesting Birds

• Reptiles

Bats

2.9 Several different bat surveys were carried out as to assess the Site’s suitability to support bat

roosts. The following surveys were undertaken: Preliminary Roost Assessment, Preliminary

Hibernation Assessment, Ground Level Assessment (GLA) and Endoscope Surveys.

2.10 All features were examined using a torch (CB2-L1) Clubman Deluxe Li-Ion 12V 8.8 AH and

binoculars (Pentax Papilio ll 5x21)). The search took place on the 12 th August 2019, conducted by

Greg Nightingale (Class 2 Bat Licence holder) and Isaac Hogan. The survey methods used is in

accordance with Bat Conservation Trust (BCT) guidelines 3 .

2.11 Only the areas of the Site to be affected by the proposals were assessed (i.e. a complete survey

of the church was not carried out as the church would largely be unaffected by the proposals).

Information gathered was then used to evaluate the Bat Roost Potential (BRP, for designation see

Table 2.1) of each feature.

Preliminary Roost Assessment (PRA)

2.12 A PRA of the exterior of the church was undertaken to determine if the building had the potential

to support bat roosts. The PRA on Site included inspecting the north-east and south-east church

walls up to one storey high from the courtyard area only, as these were the areas to be affected

by the proposals. In addition, and external and internal survey of a small outbuilding, located to

the south-east of the church, was undertaken. This is the first step towards establishing whether

there are roosts present in, or access points available on structures or buildings. Features

searched for included: gaps in brickwork/stonework, lifting damaged rendering on walls and lifted,

or under tiles and slates. A thorough search for actual and potential signs, including bats,

droppings, urine splashes ect, were searched for.

Preliminary Hibernation Survey Assessment

2.13 Proposals include below ground work, as a result preliminary hibernation surveys were conducted

in underground spaces beneath the church and northern lawn, including the cellar; the vault; and

a third underground space, to evaluate the suitability for use by bats over winter. A thorough

search for actual and potential signs, including bats, droppings, urine splashes ect, were searched

looked for as well as potential access points into the underground area. including all vents, ducts,

and surfaces.

Ground Level Assessment (GLA)

2.14 All trees within the Site underwent a GLA. This included all trees found within the southern lawn.

The assessment involved a detailed inspection of a tree from ground level to identify any Potential

Roost Features (PRFs) that could be used by bats to roost. PRF searched for included: woodpecker

holes, loose bark, hollow trunks, cavities, splits and cracks along branches, and dense ivy lattices.

Endoscope Survey

2.15 PRFs found during the GLA, which were within close proximity to the proposed works was subject

to an endoscope survey (Video Borescope N85NH). This enabled a detailed review of the potential

for the PRF to support a bat roost. Evidence such as: droppings, grease marks and staining,

3 Collins, J. (ed.) (2016) Bat Surveys for Professional Ecologists: Good Practice Guidelines (3rd ed). The Bat Conservation Trust,

London.

Ecological Impact Assessment for St.Marys Church, Redcliffe 8 September 2019


feeding remains and bats were searched for. The survey was carried out on the 26 th September

2019 by Greg Nightingale (Class 2 Bat Licence holder) and Isaac Hogan. The weather conditions

for this survey were dry and cloudy, although there was a short burst of rain on route to the

survey.

Table 2.1: Guidelines for assessing the suitability of structures and trees for bats to

roost within

BRP

Category

Negligible

Low

Roosting Habitat Features

Negligible habitat features likely to support

roosting, commuting or foraging bats

Structures in this category offer one or more

potential roost sites for individual,

opportunistically roosting bats. These sites do not

offer the space, shelter or appropriate conditions

to support large numbers of bats or maternity

roosts.

Survey Requirement

No surveys required

1 dusk or dawn survey

required for structures.

No surveys required for

trees.

Tree in this category include those of sufficient

size and age to support suitable roosting features,

but none are visible from the ground

Moderate

Structures and trees in this category offer one or

more roost site that, due to their space, shelter or

conditions, offer roosting potential for a range of

species. Roosts may be more permanent, rather

than opportunistic. Small maternity roosts of

common species may form in one of these roost

sites.

1 dusk and 1 dawn survey

required for both structures

and trees.

Tree-climbing may be an

appropriate alternative to

dusk and dawn surveys.

High

Structures and trees in this category have one or

more potential roost sites that are suitable for

large number of bats. Roosts are likely to be

permanent and include maternity roosts.

Potential roost sites exist for a wide range of

species or species of particular conservation

interest.

3 surveys, including both

dusk and dawn elements.

Tree-climbing may be an

appropriate alternative to

dusk and dawn surveys.

Ecological Impact Assessment for St.Marys Church, Redcliffe 9 September 2019


Limitations

2.16 It is important to note that ecological surveys provide information regarding the ecological

baseline of a site for only a ‘snapshot’ of time. Therefore, if significant time lapses between the

surveys; if further development or implementation of proposals have been updated; or if there

has been significant changes to habitat present on Site then ecological surveys may be required

to identify any change in the baseline, such as natural succession of habitats, or local extinction

or colonisation of species. Therefore, if a year lapses between the progressions of development

proposals, it is recommended that ecological advice is sought regarding the applicability of the

survey findings 4 .

4 CIEEM (2019). Advice Note: On the Lifespan of Ecological Reports and Surveys. Chartered Institute for Ecology and Environmental

Management, Winchester. Available from:https://cieem.net/wp-content/uploads/2019/04/Advice-Note.pdf

Ecological Impact Assessment for St.Marys Church, Redcliffe 10 September 2019


3 Results

Desk Study

3.1 The findings of the desk study are presented below. A description of all statutory designated sites

within a 5km buffer radius, and non-statutory sites within a 2km buffer are listed in Table 3.1.

Statutory designated sites include:

• Special Protection Areas (SPAs), Special Areas of Conservation (SACs) and Ramsar Sites which

are of European importance;

• Sites of Special Scientific Interest (SSSI) and National Nature Reserves (NNR) which are of

National importance; and

• Local Nature Reserves (LNR), which are of Local importance.

3.2 Non-Statutory designated sites include:

• Site of Nature Conservation Interest (SNCI), which are of County importance; and

• Avon Wildlife Trust Reserves (AWTR).

Table 3.1 Desk Study Findings – Site Search

Site Name and

Designation

Description

Distance to Site

Statutory Sites

Ashton Court

SSSI

Important for its saproxylic coleoptera and other

invertebrate fauna, many species of which are

nationally scarce. Has a complex underlying geology.

Above ground ancient trees, including: ash Fraxinus

excelsior, wych elm Ulmus glabra, and beech Fagus

sylvatica, although most of the ancient trees are oak

Quercus robur. These ancient oak pollards are

important for saproxylic invertebrates. Species such

as Ctesias serra beetle, false darkling beetle

Phloiotrya vaudouer, darkling beetle Eledona

agricola, all with very adapted to extremely specific

conditions found on this site.

2,780m West

Avon gorge

SSSI

SAC

The Gorge has natural cliffs and quarry exposures of

Carboniferous limestone, which are of great

geological interest and, together with the screes,

scrub, pockets of grassland and adjacent woodland,

support an exceptional number of nationally rare and

scarce plant species. Rare plants are found in species

rich neutral grassland, such as such as: Bristol rockcress

Arabis stricta, compact brome Bromus

madritensis, nit-grass Gastridium ventricosum, and

honewort Trinia glauca. Scarce plants include: dwarf

mouse-ear Cerastium pumilum and spring cinquefoil

Potentilla tabernaemontani. Woodland is present,

mainly semi-natural broadleaf woodland, but

includes areas of mixed and broadleaf plantation,

3,380m North-west

Ecological Impact Assessment for St.Marys Church, Redcliffe 11 September 2019


with some parts ancient woodland. The canopy

contains oak, both pedunculate and sessile, Quercus

robur, Q. petraea, ash, small-leaved lime Tilia

cordata, birch Betula spp., whitebeams Sorbus spp.,

beech and hornbeam Carpinus betulus. An

exceptional diversity of whitebeams including two

which are unique to Avon Gorge Sorbus bristoliensis

and Sorbus wilmottiana.

Leigh Woods

NNR

Found on the western slope of Avon gorge, a very

similar assemblage to Avon Gorge, including also

wild cherry Prunus avium, Spanish chestnut

Castanea sativa, and occasional lime hybrids Tilia

spp. Shrub layer is discontinuous, frequented with

hazel Corylus avellana and field maple Acer

campestre, privet Ligustrum vulgare, hawthorn

Crataegus monogyna, spindle Eunymus europeaus,

dogwood Cornus sanguinea, and yew Taxus

baccatta.

2,600m North-west

Quarry Steps Durdham

Down

SSSI

A key site designated for its reptilian history. Two

species of saurischian dinosaur were found in fissure

fillings from the old quarry site.

3,000m North-west

Royate Hill

LNR

Bordered by a railway embankment, creates a varied

topography. Mosaic of habitats, including calcareous

grasslands, secondary woodland and scrub.

3,630m North-east

Troopers Hill

LNR

Old quarry and mining site that has created unusual

acidic soils for the area, containing as a result a

unique invertebrate assemblage. Endangered mining

bee Monada guttualata is present.

3,780m East

Avon Valley Woodland

LNR

Noted for its underlying geology, specifically the

Carboniferous Downend Group strata. Woodland is

predominantly oak, containing willow, Salix spp.

Scrub, pasture and grassland.

3,580m East

Stockwood Open Space

LNR

Majority of area is old grassland and unploughed

meadows, housing numerous species of butterflies.

An old woodland, with many thick hedgerows and

several farm ponds. Nesting whitethroats Sylvia

communis are found here.

4,360m South-east

Non-statutory Sites

Brandon Hill

AWTR and SNCI

Site located close to the centre of Bristol. Mosaic

habitat, consisting largely of parkland, areas of

wildflower meadows, with scattered trees, areas of

scrub, and presence of ponds. Small areas of

woodland to the north-west of the site.

1,200m North-west

Arno’s Vale Cemetery

SNCI

Large, 22.85ha, overgrown Victorian Cemetery with

adjacent area of broadleaf woodland, grasslands

present supporting invertebrate assemblage.

1,600m South-east

Ecological Impact Assessment for St.Marys Church, Redcliffe 12 September 2019


Clifton Wood

SNCI

Woodland area forms part of the larger grounds of

Goldney Gardens in Clifton, Bristol. Mainly broadleaf

woodland noted for feeding bats.

1,700m West

Easton-Staple Hill

Disused Railway

SNCI

It is a linear site that runs through dense housing

and industrial areas. The variety of habitats include

grassland, scrub, secondary woodland, tall ruderal

vegetation, planted trees and flower beds.

1,920m North-east

Feeder Side

SCNI

An artificial canal-like water channel connected to

the River Avon at both ends, banked with semiimproved

neutral grassland, with patches of scrub

and small areas of wet crack willow Salix fragilis.

990m East

Glyn Vale

SCNI

Consisting mainly of neutral grassland, with

occasional patches of calcareous patches, areas of

scrub and planted trees, both native and exotic,

within the 9.17ha site.

1,820m South

Novers Common

SNCI

Site found to the South of Bristol City Centre.

Predominantly semi-improved neutral grassland with

pockets of semi-improved calcareous grassland.

Areas of woodland present.

2,000m South-west

Wedmore Vale

SNCI

Range of habitats including grassland, amenity

grassland, scrub woodland and streams. Small,

scattered patches on semi-improved calcareous

grassland.

1,710m South

3.3 Table 3.2 list all protected and notable species found also within a 2km buffer around the Site.

Table 3.2 Desk Study Findings – Species Search

Species Name Designation Approx. distance of

record to Site (m)

Amphibians

Common Toad

Bufo bufo

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

1,100m South

Great Crested Newt

Triturus cristatus

Habitats Directive Annex 2

Habitats Directive Annex 4

Wildlife and Countryside Act 1981 (Schedule 5) Sec

9.4b

NERC Act Section 41

Local Biodiversity Action Plan - Priority Species

United Kingdom Biodiversity Action Plan - Priority

Species

The Bern Convention (Appendix 2)

1,300m North-west

Birds One list of birds and mention NBN Atlas with 2km buffer

Brambling

Fringilla montifringilla

Wildlife and Countryside Act 1981 (Schedule 1)

IUCN Red List - Red

1,320m West

Ecological Impact Assessment for St.Marys Church, Redcliffe 13 September 2019


Fieldfare

Turdus pilaris

Wildlife and Countryside Act 1981 (Schedule 1)

IUCN Red List - Red

1,600m South-east

Firecrest

Regulus ignicapilla

Wildlife and Countryside Act 1981 (Schedule 1)

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

1,260m West

House Sparrow

Parsus domesticus

NERC Act Section 41

Bristol Biodiversity Action Plan – Priority Species

520m West

Kingfisher

Alcedo atthis

Wildlife and Countryside Act 1981 (Schedule 1)

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

600m West

Lapwing

Vanellus vanellus

Wildlife and Countryside Act 1981 (Schedule 1)

NERC Act Section 41

IUCN Red List - Red

The Bonn Convention (Appendix 2)

1,770m West

Redwing

Turdus iliacus

Wildlife and Countryside Act 1981 (Schedule 1)

United Kingdom Biodiversity Action Plan - Priority

Species

IUCN Red List - Red

1,600m South-east

Red Kite

Milvus milvus

Wildlife and Countryside Act 1981 (Schedule 1)

NERC Act Section 41

1,400m North-west

Scaup

Aythya marila

Wildlife and Countryside Act 1981 (Schedule 1)

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

The Bonn Convention (Appendix 2)

600m West

Whimbrel

Numenius phaeopus

Wildlife and Countryside Act 1981 (Schedule 1)

IUCN Red List - Red

600m West

Woodlark

Lullula arborea

Wildlife and Countryside Act 1981 (Schedule 1)

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

1,600m South-east

Wryneck

Jynx torquilla

Wildlife and Countryside Act 1981 (Schedule 1)

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

IUCN Red List - Red

The Bonn Convention (Appendix 2)

1,320m West

Mammals (non-bats)

Roe Deer

Capreolus capreolus

The Deer Act 1991

1,950m South-east

European Otter

Lutra lutra

Wildlife and Countryside Act 1981 (Schedule 9 & 11)

Bristol Biodiversity Action Plan – Priority Species

1,400m East

Ecological Impact Assessment for St.Marys Church, Redcliffe 14 September 2019


Eurasian Badger

Meles meles

The Protection of badgers Act 1984

1,620m West

Mammals (bats)

Serotine

Eptesicus serotinus

Habitats Directive Annex 4

Wildlife and Countryside Act 1981 (Schedule 5)

Section 9.4b

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

1,200m West

Bechstein’s bat

Myotis bechsteinii

Habitats Directive Annex 4

Wildlife and Countryside Act 1981 Schedule 5)

Section 9.4b

910m South

Daubenton’s bat

Myotis daubentonii

Habitats Directive Annex 4

Wildlife and Countryside Act 1981 (Schedule 5)

Section 9.4b

1,600m South-east

Leisler’s bat

Nyctalus leisleri

Habitats Directive Annex 4

Wildlife and Countryside Act 1981 (Schedule 5)

Section 9.4b

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

1,520m West

Noctule

Nyctalus noctula

Habitats Directive Annex 4

Wildlife and Countryside Act 1981 (Schedule 5)

Section 9.4b

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

1,730m South-West

Common Pipistrelle

Pipistrellus pipistrellus

Habitats Directive Annex 4

Wildlife and Countryside Act 1981 (Schedule 5)

Section 9.4b

1,780m South-West

Soprano Pipistrelle

Pipestrellus pygmaeus

Habitats Directive Annex 4

Wildlife and Countryside Act 1981 (Schedule 5)

Section 9.4b

NERC Act Section 41

United Kingdom Biodiversity Action Plan - Priority

Species

1,600m South-east

Reptiles

Grass Snake

Natrix Helvetica

Wildlife and Countryside Act 1981 (Schedule 5)

Section 9.1 & 9.5

NERC Act Section 41

1,400m North-west

Adder

Vipera berus

Wildlife and Countryside Act 1981 (Schedule 5)

Section 9.1 & 9.5

NERC Act Section 41

1,520m West

Slow worm

Anguis fragilis

Wildlife and Countryside Act 1981 (Schedule 5)

Section 9.1 & 9.5

1,020m South-west

Ecological Impact Assessment for St.Marys Church, Redcliffe 15 September 2019


Extended Phase 1 Habitat Survey

3.4 A visual representation of the results from the Phase 1 Habitat Survey with colour coded habitat

labels can be found in Appendix 3, target notes are given in Appendix 4

3.5 The habitats within the Site include: approximately 185m 2 amenity grassland is present in the

north and south; three rows of trees; ornamental planting with a mixture of native and non-native

species; and hardstanding surrounding the church and forming various paths.

3.6 Amenity grassland consisted of perennial rye-grass Lolium perenne (D), white clover Trifolium

repens (D), daisy Bellis perennis (F), ribwort plantain Plantago lanceolate (O), creeping buttercup

Ranunculus repens (O).

3.7 Three rows of trees, delineated as: treeline 1 comprising 9 trees of small-leaved lime Tilia cordata

with a single silver birch Betula pendula; treeline 2 comprising 13 trees of small-leaved lime; and

treeline 3 comprising 5 trees small-leaved lime with a single horse chestnut Aesculus

hippocastanum at the eastern boundary. All trees were semi-mature or mature with large crowns.

3.8 An area of ornamental planting, consisting of mainly native, non-mature specimens was present

along the south-west boundary. Species included: elder Sambucus nigra (O), yew Taxus baccata

(O), wild cherry Prunus avium (R), bramble Rubus fruticosus (R), buckthorn Rhamnus cathartica

(R), ash Fraxinus excelsior (R), small-leaved lime (A) and ivy Hedera helix (A).

Bats

Preliminary Roost Assessment (PRA)

3.9 A search took place of the exterior of the church (areas within proximity of the proposals) as well

as a small, brick walled, outbuilding with a corrugated roof, located on the eastern boundary of

the Site next to Pump Lane. No evidence of bats was observed on the exterior of the buildings or

the interior of the outbuilding and no features with the potential to support bat roosts were

observed on either building. The stonework of the church in good repair with no cracks or cavities

present and limited other features or materials were present. The exterior of the church was

assessed as having negligible suitability to support bat roosts. The outbuilding was assessed as

having negligible suitability to support a bat roost.

Preliminary Hibernation Survey

3.10 All underground areas: the cellar, the vault and third underground space, were searched. No

evidence of bats was found in any of the areas. All the vents were sealed with shutters and no

other potential access points for bats to enter the underground areas were observed. The

underground areas were assessed as having negligible potential to support bat roosts.

Preliminary Ground Level Roost Assessment (GLA)

3.11 All trees within the Site were assessed for their potential to support bat roosts. One tree was

assessed as having the potential to support bat roosts. The remaining trees did not support PRFs,

with the majority of the trees being of a smaller size and in good health. Two PRFs were found on

the mature small-leaved lime (T5). The PRFS were vertical splits with cavities extending up into

the trunk. The first was at a height of one metre from the ground, the second at two metres from

the ground. Both were facing north-east and exhibited good space for flight from the tree and

sufficient shelter from weather and light as a result of the large tree crown. Images of both

features can be found in Appendix 5. These two PRFs were assessed as having high suitability to

support a bat roost.

Endoscope Survey

3.12 Both PRFs were examined. The first feature opened immediately into a wide cavity that extended

approximately 12cm back into the trunk, average diameter 8cm. The cavity then extended

upwards 120cm with a slight right inclination tightening towards the top. The interior of the

feature was smooth, with no debris or detritus found as the camera moved through the cavity.

Ecological Impact Assessment for St.Marys Church, Redcliffe 16 September 2019


Approximately 90% of the cavity was searched with no signs of bats found. The second feature,

found at 2m from the ground, travelled straight up for approximately 100cm, exhibiting a

cylindrical spire extending back 5cm at the opening with an average diameter of 4cm. Smooth

textures recorded, no debris or detritus. Unlike the first, the top of the cavity was reached and

there was no evidence to suggest presence of bats.

Birds

3.13 All areas were assessed for their suitability to foraging and nesting birds. The trees and shrubs

have the potential to support nesting birds during the nesting bird season. Within the area of

shrub on the eastern side of the southern lawn there are a number of existing bird boxes present

on the row of trees. Therefore, the Site is likely to support nesting and foraging of low numbers of

common and widespread birds.

Badgers

3.14 No evidence of badgers was observed within the Site. The desk study returned results of badgers,

but at a distance of 1,620m to the west of the Site, and no latrines, setts or other evidence of

badgers was found. The Site is located in a highly urban area and therefore it is highly unlikely

that badgers are present within the local landscape surrounding the Site. Badgers will not be

discussed any further within this report.

Other Notable Species

3.15 Other species searched for during the extended Phase 1 Habitat Survey were dormice, GCN and

reptiles. No evidence or suitable habitat was found within the Site to consider these species

relevant to the development proposals. In relation to GCN and reptiles, lawns were kept tidy

through regular mowing regimes, free from refuge piles, and other suitable terrestrial habitat for

these species. Furthermore, the closest records of GCN and reptiles species were recorded over

1,000m away and no records of dormice were present. As a result, there will be no further

mention of dormice, GCN, or reptiles throughout the remainder of the report.

Ecological Impact Assessment for St.Marys Church, Redcliffe 17 September 2019


4 Discussion

4.1 Relevant legislation afforded to protected species, habitats and designated sites is detailed in

Appendix 2.

Statutory Designated Sites and Non-Statutory Designated Sites

4.2 A number of statutory and non-statutory designated sites are located within the wider landscape.

These include three SSSIs: Ashton Court, Avon Gorge, and Quarry Steps Durdham Downs; one

NNR; four LNRs and seven SNCI were also located nearby Site. The nearest designated site is

located over 900m from the Site boundary. Habitats within the designated sites include: seminatural

broadleaf woodland, including patches of ancient woodland, ancient pollards, species-rich

neutral grassland and patches of calcareous grassland.

4.3 It is not considered that the proposals will result in any impacts on the statutory designated sites

and non-statutory designated sites within the wider area as: the Site is spatially separated from

the designated sites, the proposals are small in scale; and any impacts as a result of the proposal

will be contained to within and adjacent to the Site. In addition, the proposals do not relate to

residential development and therefore will not result in increased recreational pressure on the

designated sites within the wider area.

Habitats

4.4 The proposals will result in the loss of all the amenity grassland in the north of the Site and

approximately 45m 2 of amenity grassland in the south of the Site. The ornamental planting and

shrubs, and one mature tree along the tree line (T5 - the tree identified to have two BRP features)

will be removed. The habitats to be removed are of negligible – low ecological value. The value of

the tree in relation to bats is discussed below.

4.5 As compensation for the loss of amenity grassland, a green roof and an area of terrace planting

has been proposed in the northern area of the Site and a wildflower meadow and wildflower green

roof have been proposed in the southern area of the Site. To replace the value of the loss of

mature trees within the Site, a formal line of trees will be planted along the northern perimeter of

the Site. Overall, these habitats will provide a significant increase in the ecological value of the

Site.

Bats

4.6 The buildings within the Site have negligible suitability to support roosting bats.

4.7 One tree within the Site has the potential to support a bat roost (T5, small-leaved lime). The tree

has been subject to a single endoscope survey which confirmed that bats were not present during

the survey and that the PRFs can be suitably surveyed using an endoscope as opposed to

requiring emergence surveys.

4.8 Tree T5 will be removed as a result of the proposals. Therefore, further surveys are required to

determine if this tree supports a bat roost. The further surveys can either be emergence/re-entry

surveys or endoscope surveys. The surveys should be undertaken during the bat survey season

(May - September, with September being sub-optimal).

4.9 All bats and their roosts are subject to the highest level of protection afforded to species in the UK

as European Protected Species (EPS), regardless of the number or species of bats affected. A bat

Ecological Impact Assessment for St.Marys Church, Redcliffe 18 September 2019


oost is defined as any structure or place which is used for shelter or protection, irrespective of

whether or not bats are resident.

4.10 Should a bat roost be present then a Natural England European Protected Species (EPS) Licence

to fell the tree will be required.

Bat Mitigation Strategy

4.11 Given the urban location of the Site and the type of the PRFs, it is anticipated, that should a bat

roost be present within T5, it is likely to be of a common and widespread species that utilises

urban areas, such as common pipistrelle or soprano pipistrelle, as opposed to the UKs rarer bats.

The mitigation and compensation for common and widespread species (such as common

pipistrelle and soprano pipistrelle) is well understood, well-practiced and considered generally

deliverable.

4.12 The presence of a bat roost within T5 has not been confirmed. However, within the Site there

exists opportunity to compensate for the removal of tree T5. The proposals would allow for bat

tubes or lifted/raised weatherboarding to be installed on the eastern or south-west facing aspect

of the proposed studio building that is to be constructed on the eastern boundary of the southern

garden. In this area, the mature trees provide sufficient shelter from both weather conditions and

visitor disturbance, whilst also providing clear flight paths for entrance/exit. Alternatively, bat

boxes could be installed within mature trees within the Site, which would provide a similar

function as the PRFs that are present on T5.

4.13 The exact details of the bat mitigation and compensation would be determined by the results of

the further surveys and if a bat roost is present then mitigation and compensation would be

secured by a European Protected Species licence.

4.14 Based on the above premise, if a bat roost is present within T5, then bat mitigation and

compensation can be delivered within the Site and would be secured by EPS licence. Therefore,

the further survey work, outlined in 4.8, could be conditioned via a Grampian (precommencement)

planning condition as part of any planning application granted for the Site,

without jeopardizing the favourable conservation status of any bat species using T5 as a bat roost

(if determined as present by the conditioned surveys). This is reasoned in line with guidelines put

forward by the British Standards Institute (BSI) 5 and CIEEM 6 .

Birds

4.15 The proposals have the potential to harm nesting birds via the removal of scattered shrubs and

one lime (T5). Disturbance of works could also have an effect on nesting birds, works are

proposed within 5m of two nesting bird boxes found on the large horse chestnut tree (T2), which

are suitable for both finches, and sparrows and tits.

4.16 In order to mitigate for this any of the vegetation to be removed and any construction works

occurring within the southern are of the Site should be carried out outside the nesting bird season

(from March-August inclusive). Should it be necessary to remove conduct work during the bird

nesting season, the area must be checked in advance for the presence of bird's nests by a

suitably competent person. If there is no evidence of breeding birds, the works can, starting no

later than 48 hours after inspection, be carried out. If active nests are identified, any of the

vegetation clearance must cease and an appropriate buffer zone must be established around the

5 BSI (2013). Biodiversity – code of practice for planning and development, BS 42020:2013. British Standards Institution, Bristol.

Section 9.24c. Page 36.

6 CIEEM (2017). Guidelines for Preliminary Ecological Appraisal. 2

nd

Edition. Chartered Institute for Ecology and Environmental

Management, Winchester. Box 4 – Point C. Page 11.

Ecological Impact Assessment for St.Marys Church, Redcliffe 19 September 2019


nest (distance to be decided at the ecologist's discretion). This buffer must remain intact until is

has been confirmed that that the young have fledged, and the nest is no longer in use.

4.17 The tree housing the current bird boxes is not scheduled for removal or disturbance. New tree

planting is proposed within the Site which will provide additional nesting opportunities within the

Site in the long term. In addition, wildflower meadow is proposed which will support a greater

abundance and more diverse invertebrate assemblage, thereby increasing food provision for

birds.

Enhancements

4.18 A number of additional measures are proposed within the scheme, which will further enhance the

ecological value of the Site:

• Planting of scattered trees in the southern garden, creating a woodland feel, providing areas of

shading;

• Wildflower meadow planted in the eastern side of the southern garden; and

• A wildflower seed mix also used to create a green roof on the studio building proposed to be built

in the south garden.

• Extra bird boxes installed on additional, suitable trees within the southern part of the Site.

4.19 These enhancement measures, along with the mitigation and compensation measures outlined

above would significantly increase the ecological value of the Site.

Ecological Impact Assessment for St.Marys Church, Redcliffe 20 September 2019


5 Conclusion

5.1 The Site is of low ecological value, supporting a range of urban typical habitats: amenity

grassland, several mature trees, a small area of shrubbery and ornamental planting, and several

formal lines of trees, with the grounds intersected with hardstanding.

5.2 A tree (T5) was found with the potential to support a bat roost. One survey of this tree has been

undertaken, however further surveys are required to determine if this tree supports a bat roost.

This tree is scheduled to be removed as a result of the proposals and therefore a bat mitigation

strategy, including the conditioning of further bat surveys, has been outlined.

5.3 Migration and compensation has been outlined for all habitats and species to be effected by the

proposals. Enhancement measures provided to increase the ecological value of the site.

Ecological Impact Assessment for St.Marys Church, Redcliffe 21 September 2019


Appendix 1

Site Plan

Ecological Impact Assessment for St.Marys Church, Redcliffe 22 September 2019


Appendix 2

Policy & Legal Considerations

Planning Policy Legislation

Statutory nature conservation sites and protected species are a ‘material consideration’ in the UK planning

process (DCLG 2018). Where planning permission is not required, for example on proposals for external

repair to structures, consideration of protected species remains necessary given their protection under UK

and EU law.

Natural England Standing Advice aims to support Local Planning Authorities decision making in respect of

protected species (Natural England 2012). Standing advice is a material consideration in determining

the outcome of applications, in the same way as any individual response received from Natural England

following consultation.

The Conservation of Habitats and Species Regulations 2017 transpose the requirements of the

European Habitats Directive (Council Directive 92/43/EEC) and Birds Directive (Council Directive

79/409/EEC) into UK law, enabling the designation of protected sites and species at a European level.

The Wildlife and Countryside Act 1981 (as amended) forms the key piece of UK legislation relating to

the protection of habitats and species.

The Countryside Rights of Way Act 2000 provides additional support to the Wildlife and Countryside

Act 1981; for example, increasing the level of protection for certain species of reptiles.

The Wild Mammals (Protection) Act 1996 sets out the welfare framework in respect to wild mammals,

prohibiting a range of activities that may cause unnecessary suffering.

Species and Habitats of Principal Importance for Conservation in England and Wales and priority

habitats and species listed on the Surrey Biodiversity Action Plans (BAP) are species which are targeted for

conservation. The government has a duty to ensure that involved parties take reasonable practice steps

to further the conservation of such species under Section 41 of the Natural Environment and Rural

Communities Bill 2006. In addition, the Act places a biodiversity duty on public authorities who ‘must, in

exercising their functions, have regard, so far as is consistent with the proper exercise of those functions,

to the purpose of conserving biodiversity’ (Section 40 [1]). Criteria for selection of national priority habitats

and species in the UK include international threat and marked national decline.

The National Planning Policy Framework (DCLG 2018) states (Section 11), that the planning system

should minimise impacts on biodiversity, providing net gains in biodiversity where possible. It also states

that local planning authorities and planning policies should:

• Plan positively for the creation, protection, enhancement and management of networks of biodiversity

and green infrastructure.

• Take account of the need to plan for biodiversity at a landscape-scale across local authority

boundaries.

• Identify and map components of the local ecological networks, including: international, national and

local sites of importance for biodiversity, and areas identified by local partnerships for habitat

restoration or creation.

• Promote the preservation, restoration and re-creation of priority habitats, ecological networks and the

recovery of priority species populations, linked to national and local targets and identify suitable

indicators for monitoring biodiversity in the plan.

Protected Species Legislation

Bats

All British species of bat are listed on the Wildlife and Countryside Act 1981 (as amended) Schedule 5. It

is an offence to deliberately kill, damage, take (Section 9(1)) a bat; to intentionally or recklessly disturb a

bat whilst it occupies a place of shelter or protection (Section 9(4)(b)); or to deliberately or recklessly

Ecological Impact Assessment for St.Marys Church, Redcliffe 23 September 2019


damage, destroy or obstruct access to a bat roost (Section 9(4)(c)). Given the strict nature of these

offences, there is an obligation on the developer and owner of a site to consider the presence of bats.

All British bats are listed on the Conservation of Habitats and Species Regulations 2010, Schedule

2. Regulation 41 strengthens the protection of bats under the 1981 Act against deliberate capture or killing

(Regulation 41(1) (a)), deliberate disturbance (Regulation 41(1) (b)) [1] and damage or destruction of a

resting place (Regulation 41(1) (d)).

A bat roost is defined as any structure or place which is used for shelter or protection, irrespective of

whether or not bats are resident. Buildings and trees may be used by bats for a number of different

purposes throughout the year including resting, sleeping, breeding, raising young and hibernating. Use

depends on bat age, sex, condition and species as well as the external factors of season and weather

conditions. A roost used during one season is therefore protected throughout the year and any proposed

works that may result in disturbance to bats, and loss, obstruction of or damage to a roost are licensable.

Application for a Natural England EPS Licence

Development works that may cause killing or injury of bats or that would result in the damage, loss or

disturbance of a bat roost would require a Natural England (NE) Bat Mitigation Licence.

For a Mitigation licence to be granted three tests must be met. Evidence is needed to determine these three

tests: whether there is a need for the development which justifies the impact on the European Protected

Species (EPS); whether there is an alternative which would avoid the impact and need for an EPS licence;

and whether mitigation proposed is sufficient to maintain the conservation status of the EPS in question.

A Mitigation Licence application will generally only be considered by NE on receipt of planning consent, and

once any pre-commencement conditions of relevance to ecology have been discharged.

There are two licensing routes now available for bats, which comprise:

Full NE England EPS Mitigation Licence:

• NE aim to determine the application within six weeks (although this can take longer).

• The application comprises three components including an application form (broad details of the

applicant, site and proposals); a detailed Method Statement providing the survey methods and

findings, impact assessment and mitigation measures (including detailed maps and schedule of

works); and a Reasoned Statement outlining the ‘need’ for the development and consideration of

alternatives.

NE Low Impact Class Licence

• This new route provides an alternative, quicker route (with a much-reduced application form, and a

target of 10 days to determine an application).

• This Low Impact Class Licence is only available to Registered Consultants identified by NE.

• This is available for sites which support up to three low status roosts (day roosts, night roosts, feeding

roosts and transitional roosts) of a maximum of three common species. The common species which

can be covered by this licence include common pipistrelle, soprano pipistrelle, brown long-eared,

whiskered, Brandts, Daubenton’s and Natterer’s bat.

• All licensed works require evidence that there is a need for the development and that appropriate

mitigation, including seasonal constraints and provision of alternative habitat and/or roosting

structures is considered.

• Before Natural England can confirm the site is registered and licensable works can commence, an

assessment of the three tests must be undertaken by the Registered Consultant. Although this does

not need to be submitted to NE, NE may subsequently undertake a review of the project and request

to see all evidence as collected by the Consultant. This can only be undertaken following a survey and

impact assessment which must be carried out in accordance with licence conditions and BCT survey

guidelines.

[1] Relates specifically to deliberate disturbance in such a way as to be likely to significantly affect i) the ability of any significant group

of animals of that species to survive, breed or rear or nurture their young or ii) the local distribution of that species.

Ecological Impact Assessment for St.Marys Church, Redcliffe 24 September 2019


• This licence cannot be used in relation to trees.

Several species of bat, including brown long-eared and soprano pipistrelle are listed as species of principal

importance under the NERC Act (2006). Section 41 of the Act is used to guide decision-makers such as

public bodies, including local and regional authorities, in implementing their duty under section 40 of the

Natural Environment and Rural Communities Act 2006, to have regard to the conservation of biodiversity

in England, when carrying out their normal functions.

Great Crested Newt

GCN and their places of shelter are subject to the same level of protection as bats as a European Protected

Species (see above).

Reptiles

All UK reptiles and amphibians are legally protected from intentional and reckless killing and injury under

the Wildlife and Countryside Act 1981 (as amended).

Hedgehog

Hedgehogs are protected by Schedule 6 of the Wildlife and Countryside Act 1981 (as amended). This Act

gives protection to hedgehog with regard to killing and taking by certain methods.

Nesting Birds

Birds and their nests are protected by the Wildlife and Countryside Act 1981 (as amended). This Act gives

protection to all species of bird with regard to killing and injury, and to their nests and eggs with regard to

taking, damaging and destruction. Certain species listed on Schedule 1 of the Act, are afforded additional

protection against protection.

Ecological Impact Assessment for St.Marys Church, Redcliffe 25 September 2019


Appendix 3

Phase 1 Habitat Survey Results

Ecological Impact Assessment for St.Marys Church, Redcliffe 26 September 2019


A A A A A

A A A A A

A A A A A

A A A A A

A A A A

A A A A

A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A

A A A A A A A A A

A A A A A A A A A

A A A A A A A A A

A A A A A A A A A

A A A A A

A A A A A

St Mary Redclifffe

Ecology Survey

A

A

Figure 1: Phase 1 Habitat Survey

A

A

Hard Standing

J1.2 Amenity Grassland

J1.4 Introduced Shrub

Tree Line

. Target Note

A A A A A A A A A

A A A A A A A A A

A A A A A A A A A

A A A A A A

4

A A A

A A A A A A A A A

.

A A A A A A A A A

A A A A A A A A A

A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A 1

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

.

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A

5

A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A 2

A A A A A A A A A A A A A A6

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

E

A A A A A A A A A A A A A A A A A A A A A A A A A A A A A A

0 25 50

Metres

Sources: Esri, HERE, Garmin, Intermap, increment P Corp., GEBCO, USGS, FAO, NPS, NRCAN, GeoBase, IGN, Kadaster NL, Ordnance Survey, Esri Japan, METI, Esri China (Hong Kong), (c) OpenStreetMap contributors, and the GIS User Community CB:CB EB:Bean_C LUC FIGX_10802_Phase1_r0_A3L 29/10/2019

.

.

.

3

.

Map Scale @A3: 1:500

Source: LUC, OS


Appendix 4

Phase 1 Habitat Survey Target Notes

Target Note Number

Description

1 Treeline 1 consisting of predominantly small-leaved lime trees except

for one silver birch. Trees are semi-mature.

2 Tree line 2 made entirely of lime trees of a similar age to trees in

treeline 1, assumed planting at the same time.

3 Treeline 3 – row of four mature trees labelled T2-T5, from north to

south the individuals are lime, horse chestnut, lime, lime. The trees

are mature.

4 A single mature London plane Platanus × acerifolia mature.

5 Area of ornamental planting, all at shrub level, 2-4m high. Species

include: elder, yew, cherry, bramble, buckthorn, ash, lime, ivy.

6 Bird box and bird feeder attached to Horse Chestnut

Ecological Impact Assessment for St.Marys Church, Redcliffe 27 September 2019


Appendix 5

BRP Features on T5

First feature on Tilia cordata, one metre from the ground

Ecological Impact Assessment for St.Marys Church, Redcliffe 28 September 2019


Second feature on Tilia cordata, two metres from the ground

Ecological Impact Assessment for St.Marys Church, Redcliffe 29 September 2019

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