Kier Construction Limited October 2021

SITE NAME:

RCHT

West Cornwall Hospital St Clare Street

Penzance Cornwall TR18 2PF

TITLE:

Ecological Impact Assessment Report

FOR:

Kier Construction Limited

October 2021

Colmer Ecology ltd

The Senate – 3rd Floor Southernhay Gardens

Exeter Devon

EX1 1UG

T: 01392 758 325

E: [email protected]

W: www.colmer-ecology.co.uk

Colmer Ecology ltd

2021-46 RCHT – EcIA Report

CONTENTS Page

Summary 1

1.0 Introduction 3

2.0 Methodology 6

3.0 Results 13

4.0 Evaluation 21

5.0 Recommendations and Constraints, Mitigation and Enhancements 28

6.0 Biodiversity Offsetting Calculations (Biodiversity Net Gain) 34

7.0 Conclusion 36

References 38

Tables

Table 1: Ecological features including designated sites, habitats on Site as well as protected or

noteworthy species and their associated ecological importance (within text).

Table 2: Summary of residual effects (within text).

Table 3: Biodiversity Offset Calculations (Small Sites Metric JP040, based on Site area of 2,098 sq m) (within text).

Figures

Figure 1: Habitat plan

Figure 2: Annotated photographs – internal and external (18th May 2021)

Figure 3: Evidence of bats and birds noted internally and externally

Figure 4: Emergence survey – 1st July 2021

Figure 5: Emergence survey – 1st August 2021

Figure 6: Emergence survey – 19th August 2021

Figure 7: Mitigation, compensation and enhancements – bat and swift

Appendices

Appendix 1: Indicative Latin names

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2021-46 RCHT – EcIA Report

© The content and layout of this report are subject to copyright owned by Colmer Ecology ltd. This report may not be copied

or used without our prior written agreement for any purpose other than the purpose indicated in this report. This report was

prepared by Colmer Ecology ltd at the instruction of, and for use by, our client named on the front of the report. This report

is not to be used by any third part without the written agreement of Colmer Ecology ltd. We disclaim any responsibility to

the client and others in respect of any matters outside the scope of the above. We accept no responsibility of whatsoever

nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their

own risk.

Reference: RCHT, West Cornwall Hospital – EcIA Report Report Prepared by: Mr J. Hawksley BSc (Hons)

PhD ACIEEM

Position: Assistant Ecologist

Mr H. Colmer BSc (Hons)

Dip MCIEEM FLS

Position: Director/Associate Ecologist

Report Reviewed by: Mr H. Colmer BSc (Hons)

Dip MCIEEM FLS

Position: Director/Associate Ecologist

Dr J. Rabineau BSc (Hons)

PhD ACIEEM

Position: Senior Ecologist

Date 23/09/2021 Report Issue No: 1 – DRAFT

Date 19/10/2021 Report Issue No: 2 - FINAL

File Reference: 2021-46_R_RCHT, West Cornwall Hospital – EcIA

Colmer Ecology ltd

2021-46 1 RCHT – EcIA Report

Summary

An ecological impact assessment (EcIA) was undertaken of land and buildings at RCHT, West

Cornwall Hospital, Penzance, Cornwall. The proposals were for the redevelopment of the

hospital to include demolition of the existing cottages and construction of new outpatient

facilities. In addition, re-arrangement of the existing car park, the creation of a two-storey link

from the new outpatient facilities to the current hospital building, as well as impact to habitats

for potential services routing from the boiler rooms/plant space.

The EcIA comprised two main elements. Stage 1 was a preliminary ecological appraisal (PEA)

including a biological desk study, a phase 1 habitat survey with a protected species habitat

assessment, a preliminary ground level bat tree roost assessment and a protected species

building assessment. Stage 2 comprised a bat roost characterisation survey undertaken due to

the evidence of, and potential for, protected species noted during the Stage 1 PEA. In addition,

a Biodiversity Net Gain (BNG) calculation was completed, following the DEFRA Small Sites

Metric (SSM) (JP040).

Located approximately 900 m north-west of Penzance town centre, the land and buildings

were approximately 0.3 ha in size and surrounded by residential properties with Penalverne

Drive forming the eastern boundary, with St Clare Street to the north, Parc Wartha Avenue to

the west and Parc Wartha Crescent to the south. The wider landscape comprised Penzance and

residential properties with pastoral fields connected by woodland and mature hedgerows

further to the west and north.

All habitat types were mapped, with the dominant habitats being hardstanding and buildings,

with the addition of amenity grassland, introduced shrub, intact species poor hedge and

scattered trees.

As a result of a single bat observed roosting in situ within the cottages during the Stage 1 PEA,

and further bat roost potential, a Stage 2 bat roost characterisation survey was conducted

between July and August 2021. No bats were recorded emerging/re-entering during the Stage

2 survey.

Due to the numbers of bats, the amount of evidence recorded during Stage 1 and subsequent

Stage 2 bat survey results, the cottages were considered to be an infrequent day, non-breeding

roost for single/low numbers of common pipistrelle bats.

The development works will result in the destruction (demolition) of the roost, with the

potential to kill/injure and disturb bats during some of the works, as well as disturbance, and

therefore, a European protected species licence was considered necessary.

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Mitigation and compensation measures for the loss/alteration of the bat roost was proposed,

which, if followed, would ensure that the favourable conservation status is maintained for this

bat species with the continued ecological functionality of its roost.

Evidence of breeding birds was noted during the Stage 1 PEA, and therefore, suitable mitigation

and enhancements measures have been recommended and will be adopted during the

development/demolition works.

In the absence of mitigation measures, the proposed development was considered likely to

have, at worst, long-term, adverse effect at the ‘Site’ level. However, by following the proposed

mitigation and precautionary measure, the development was not considered to have any

significant residual effect to important ecological features within or adjacent to the land and

buildings at RCHT. Provided the proposed mitigation, compensation and enhancement

measures are followed, the development was considered to be consistent to relevant

conservation legislation, National Planning Policy Framework (2021) and local policies. In

addition, an increase above 10 % biodiversity net gain was calculated.

This report is valid for a period of 12 months from the date of the last survey.

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1.0 Introduction

1.1 Colmer Ecology was commissioned by Kier Construction Limited to undertake an

ecological impact assessment (EcIA) of land and buildings at RCHT, West Cornwall Hospital,

Penzance, Cornwall, hereinafter referred to as the Site. The EcIA comprised two main

elements. Stage 1 was a preliminary ecological appraisal (PEA) including a biological desk

study, a phase 1 habitat survey with protected species habitat assessment, a preliminary

ground level bat tree roost assessment and a protected species building assessment (PSBA).

Stage 2 comprised a bat roost characterisation survey undertaken due to the evidence of,

and potential for, protected species noted during the Stage 1 PEA. In addition, a Biodiversity

Net Gain (BNG) calculation was completed, following the DEFRA Small Sites Metric (SSM)

(JP040).

1.2 It is understood that proposals for the redevelopment of the hospital include the demolition

of the existing cottages and construction of new outpatient facilities. In addition, re-

arrangement of the existing car park, the creation of a two-storey link from the new

outpatient facilities to the current hospital building, as well as impact to habitats for

potential services routing from the boiler rooms/plant space.

Site Description

1.3 The Site was approximately 0.3 ha in size and located at National Grid Reference (NGR) SW

46878 30625, approximately 900 m north-west of Penzance town centre. The Site was

surrounded by residential properties with Penalverne Drive forming the eastern boundary,

with St Clare Street to the north, Parc Wartha Avenue to the west and Parc Wartha Crescent

to the south. The wider landscape comprised Penzance and residential properties with

pastoral fields connected by woodland and mature hedgerows further to the west and

north.

Scope of Surveys

1.4 The objectives were to:

Stage 1

• Carry out a biological desk study within 1 km of the Site;

• Carry out a phase 1 habitat survey and map all habitat types within the Site and

where possible, described those immediately adjacent;

• Carry out a protected species habitat assessment;

• Carry out a preliminary ground level bat tree roost assessment; and

• Carry out an internal and external protected species building assessment,

specifically for bats and birds.

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Stage 2

• Carry out a bat roost characterisation survey in the form of three evening

emergence surveys;

• Propose suitable mitigation where necessary and advise on the need for any

European protected species licences or translocation; and

• Complete a BNG calculation following the DEFRA SSM (JP040).

Scope of Evaluation/Assessment of Ecological Features

1.5 The following were considered regarding the findings from the baseline ecological survey,

and the evaluation and assessment of impacts:

Evaluation

• Evaluate the significance of ecological features using criteria set out by the

Chartered Institute of Ecology and Environmental Management (CIEEM, 2018)

based on a geographical scale of importance from Negligible to International and

European (i.e. high importance).

Impact Assessment

• Assess whether important ecological features will be subject to impacts, to

characterise these impacts and their effects.

Mitigation, Compensation, Enhancement and Monitoring Measures

• Propose suitable mitigation/compensation/enhancements where necessary and

advise on the need for any European protected species licences; and

• Set out the requirements for post-construction monitoring.

Residual Effects

• To provide an assessment of the significance of any residual effects following

development.

Legislation and Planning Context

1.6 Although it was not the purpose of this report to present legislation and planning context in

relation to the proposal, their applicability was explained where appropriate.

1.7 The following wildlife legislation and policy was considered:

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

amended by The Conservation of Habitats and Species (Amendment) (EU exit)

Regulations 2019;

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

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

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

• National Planning Policy Framework 2021 (NPPF); and

• Any Cornwall Biodiversity Action Plan(s) (BAP).

1.8 This report was written following the Chartered Institute of Ecology and Environmental

Management (CIEEM) guidelines for ecological report writing (2017a). Relevant Site plans

and landscape plans were provided where necessary for review.

Caveat

1.9 It should be noted that a phase 1 habitat survey does not aim to identify all botanical species

within a site, or constitute a full contaminated land/invasive species assessment. In addition,

protected species can be highly mobile and can be found in buildings/structures or habitats

at any time of year. Although Colmer Ecology is confident in the survey results, we cannot

ensure that protected species will/will not be present on Site at any other time. Descriptions

of Site conditions and photographs are based on the Stage 1 PEA survey undertaken in May

2021 with updates during Stage 2 survey. In addition, assessments of ecological impacts

were based on the information supplied by Kier Construction Limited and/or the associated

design team.

Nomenclature

1.10 For ease, common names were used throughout this report, however, where no common

name existed or it was not possible to identify to species level, genus/family names were

used. Details of indicative Latin names were provided in Appendix 1.

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2.0 Methodology

2.1 Stage 1

Biological Desk Study

2.1.1 Following guidance produced by the CIEEM (2017b), records of statutory and non-statutory

designated sites, ‘Priority Habitat Inventory’ areas, ancient woodland and granted European

protected species licence (EPSL) applications were reviewed from the government-based

website MagicMap within a 1 km desk study area based on the central grid reference SW

46878 30625. Colmer Ecology’s own biological records, protected species licences and

knowledge of local ecological designations were also reviewed. In addition, records of

statutory and non-statutory designated habitats and protected or noteworthy species were

sought from the Environmental Records Centre for Cornwall and the Isles of Scilly (ERCCIS)

within a 1 km desk study area.

Phase 1 Habitat Survey

2.1.2 The Site was subject to a phase 1 habitat survey on 18th May 2021 by Mr H. Colmer BSc

(Hons) Dip MCIEEM1 FLS2 a Natural England licensed3 associate ecologist. Each habitat

present within, and where possible, surrounding the Site was mapped in accordance with

the, ‘Handbook for Phase 1 Habitat Survey – a Technique for Environmental Audit’ (Joint

Nature Conservation Committee, 2010 [Revised in 2016 with minor corrections]). Habitats

and features of interest were described, with botanical species recorded. In addition, a

colour coded habitat map (Figure 1) and annotated photographs of the Site were produced.

Non-native invasive species were also identified (where possible) and mapped where

appropriate.

Protected Species Habitat Assessment

2.1.3 The Stage 1 PEA also included an assessment of the potential for the Site to support

protected species due to the habitat types present. This was based on professional

experience, but also reviewing industry standard habitat assessment methodologies,

however, the Stage 1 PEA did not include any specific survey methods designed to

demonstrate presence/likely absence of protected species themselves.

Preliminary Ground Level Bat Tree Roost Assessment

2.1.4 Any tree likely to be impacted by the proposed works was subject to a preliminary ground

level bat tree roost assessment by Dr J. Rabineau BSc (Hons) PhD ACIEEM4 (bat class 2 survey

licence and registered bat mitigation class [low impact] licence consultant Annex B and D)

following methodology described in Bat Conservation Trust (BCT), Bat Surveys for

1 Full Member of the Chartered Institute of Ecology and Environmental Management (MCIEEM) 2 Fellow of the Linnaean Society (FLS) 3 Great crested newt licence. Barn owl licence. Dormouse licence. Accredited agent under bat licence. 4 Associate Member of the Chartered Institute of Ecology and Environmental Management (ACIEEM)

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Professional Ecologists: Good Practice Guidelines 3rd Edition (Collins, 2016) as well as the

Bat Tree Habitat Key (Andrews et al., 2016). Each tree within the likely zone of impact was

searched for any potential roosting features (PRF) for bats including cracks (from

catastrophic fractures or tears), extending holes, partially detached ivy (> 50 mm), cankers

with cavities, and splits or flaking bark that may be suitable for roosting bats. Other field

signs searched for included dark streaking below holes and cracks, droppings and staining,

as well as bat themselves.

2.1.5 Any PRF was assessed and inspected where possible using high powered LED torches and

close focussing binoculars only at this stage. Where a suitable PRF was present, a general

description, height above ground, orientation and location with respect to the stem (Collins,

2016) was recorded.

2.1.6 The potential of each tree to support roosting bats was decided based on the presence,

number and suitability of each PRF. Trees of ‘Low’ potential were considered to be, ‘a tree

of sufficient size and age to contain PRF but with none seen from the ground’ (Collins, 2016).

Trees of ‘Moderate’ potential were defined as, ‘trees with one or more potential roost sites

that could be used by bats…but unlikely to support a roost of high conservation status’

(Collins, 2016). Finally, trees with ‘High’ potential were defined as, ‘trees with one or more

potential roost sites that are obviously suitable for usage by large numbers of bats…’ (Collins,

2016). Where bats or evidence of bats were found, for example bat droppings or a roosting

bat, the tree was considered to be a confirmed roost. Where no suitable features were noted

for roosting bats, the tree was considered to offer ‘No/Negligible’ potential (Collins, 2016).

Protected Species Building Assessment – Bats

2.1.7 An external and internal daylight PSBA of several unoccupied cottages within the Site was

carried out on 18th May 2021 by Dr J. Rabineau with assistance from Mr H. Colmer.

Inspections were made of the outer aspects of the Site looking for signs of potential bat

roosting opportunities, such as raised ridge tiles, hanging or roof slates/tiles, raised timber

frames/bargeboards/cladding, lintels, loose masonry and any internal access points. Where

possible, ledges and windowpanes were also searched for any signs of bat droppings.

Internally, the survey concentrated on looking for potential bat entry points, a search for

bat droppings, staining and individual bats themselves. In addition, other signs searched for

included discarded insect remains, which are a feature indicative of night roosts and/or

feeding perch. Finally, a distinctive smell is sometimes present in large, confined roosts and

chattering emitted by bats may also be heard. Inspections were aided by the use of both

small and large handheld Cree LED torches, ladders, adjustable mirrors, a Ridgid CA-330

endoscope, close focusing binoculars and a Hikvision handheld thermal imagining camera.

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Survey methodology followed that suggested within Bat Conservation Trust (BCT), Bat

Surveys for Professional Ecologists – Good Practice Guidelines 3rd Edition (Collins, 2016).

2.1.8 The potential of the Site to support roosting bats was based on the presence, number and

suitability of potential roost features (PRF). Structures of ‘Low’ potential were considered to

be, ‘a structure with one or more potential roost sites that could be used by individual bats

opportunistically…unlikely to be suitable for maternity or hibernation’ (Collins, 2016).

Structures of ‘Moderate’ potential were defined as, ‘a structure with one or more potential

roost sites that could be used by bats…but unlikely to support a roost of high conservation

status’ (Collins, 2016). Finally, structures of ‘High’ potential were defined as, ‘structures with

one or more potential roost sites that are obviously suitable for usage by large numbers of

bats…’ (Collins, 2016). Where bats or evidence of bats were found, for example bat

droppings or a roosting bat, the Site was considered to be a confirmed roost. Where no

suitable features were noted for roosting bats, the Site was considered to offer

‘No/Negligible’ potential (Collins, 2016).

Protected Species Building Assessment – Birds

2.1.9 In combination with the survey for bats, the Site was assessed for its suitability to support

roosting and breeding birds. This involved specifically looking for evidence of house

sparrow, starling, swift and hirundine species.

2.2 Stage 2

Bat Roost Characterisation Survey

2.2.1 Due to the confirmed evidence of a roosting common pipistrelle bat within the Site during

the Stage 1 PEA, and potential for additional roosting bat species, a Stage 2 bat roost

characterisation survey was conducted and comprising three emergence surveys (Collins,

2016). The Stage 2 survey was carried out between July and August 2021, within the optimal

survey season for bats (Table 7.1 – Collins, 2016) in order to confirm the status of the bat

roost, determine access points and to assess the level of bat activity within/surrounding the

Site. The surveys were undertaken a minimum of two weeks apart following methodology

described in Collins (2016).

2.2.2 Due to the orientation of the Site and proposed area of works, three surveyors were

positioned to cover all relevant aspects sufficiently. Each surveyor was equipped with either

a Wildlife Acoustics Echo Meter 3 (EM3), EM3+, EM Touch Pro, or Elekon Batlogger M bat

detectors. These detectors are capable of recording bat calls to portable memory cards

using real time expansion (as well as heterodyne) and provide high quality sonograms

suitable for later analysis and bat call identification.

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2.2.3 The emergence survey started 15 minutes prior to sunset and continued for 1 h 30 minutes

after sunset, as specified in Collins (2016). Weather parameters were recorded using a JDC

Skywatch Atmos or Extech 45170 hand-held weather station.

2.2.4 Each surveyor recorded the time of each individual bat pass as well as species (where

possible) and any characteristic behaviour, namely emerging/re-entering bat, foraging, fly

pass and direction, heard not seen, feeding and social calling. Groups of bats seen were also

counted where possible.

Bat Sound Data Analysis

2.2.5 Where necessary, bat call data was extracted from raw sound files using Kaleidoscope Pro

(v. 5.4.3), with bat sonograms analysed using Kaleidoscope Pro, BatSound v 3.31, AnalookW

0.3.9.6, BatExplorer 2.1 and/or Audacity 2.0.5. The sonograms were examined using a variety

of identification parameters such as those described in Russ (2012), Middleton et al. (2014),

the Bat Conservation Trust (2006), Barataud (2012) and personal experience as well as

reference library calls. It should be noted that calls are not always identifiable to species

level due to either poor sound quality or similarities of calls between different bat species,

preventing confidence in identification. Where identification was not possible, suggestions

of likely bat species have been provided to at least genus or family.

2.2.6 The Myotis group are generally the hardest to separate to species level due to overlapping

call characteristics between the different species. This group of species was simply referred

to as Myotis.

Biodiversity Net Gain

2.2.7 In order to assess biodiversity offsetting, the Small Sites Metric (SSM) (JP040) (DEFRA 2021)

was used in this instance as the Site met both (highlighted in bold) of the following SSM

criteria:

‘1. Development sites where;

For residential developments the number of dwellings to be provided is between one and

nine inclusive on a site having an area of less than one hectare;

Where the number of dwellings to be provided is not known the site area is less than 0.5

hectares:

For all other development types where the site area is less than 0.5 hectares or less than

5000 metres squared.

2. Where there is no priority habitat present within the development area (excluding

hedgerows and arable margins).

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2.3 Evaluation/Assessment of Ecological Features

2.3.1 Following CIEEM (2018), each ecological feature (i.e. designated sites, habitats on and off

Site and protected/noteworthy species) was evaluated using the following geographical

scale:

• International value (internationally designated sites or those meeting criteria for

international designations);

• National (such as Site of Special Scientific Interest [SSSI] or those meeting criteria

for national designations – sites with significant Priority Habitat or sustaining Red

Data Book species);

• Regional (regional designation – sites with significant regional Biodiversity Action

Plan [BAP] habitats or sustaining regional BAP species);

• County (county designation – sites with significant county Biodiversity Action Plan

[BAP] habitats or sustaining county BAP species or rarities species, County Wildlife

Sites [CWS]);

• District (district level designation);

• Local/Parish (local/parish/neighbourhood level designation);

• Site (interest at the site level only); and

• Negligible.

2.3.2 In addition, schedules and annexes under the Conservation of Habitats and Species

Regulations (as amended) 2017, amended by the Conservation of Habitats and Species

(Amendment) (EU exit) Regulations 2019, WCA 1981 (as amended), any local designation or

conservation lists were also utilised/reviewed.

Assessment of Effects

2.3.3 Following CIEEM (2018), an assessment of effects without mitigation of each ecological

feature (i.e. designated sites, habitats on and off Site and protected/noteworthy species) was

undertaken using the following timescale:

• Acute (immediate and discrete);

• Short term (0 – 3 years);

• Medium term (3 – 10 years); and

• Long term (> 10 years).

2.3.4 Following the description of suitable mitigation measures, compensation and enhancement

measures, the residual effects were also established, as suggested by CIEEM (2018).

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2.4 Survey Constraints

Stage 1 – Biological Desk Study

2.4.1 It should be noted that an absence of desk study records for particular species does not

necessarily convey an absence of such species in that area, but is often a facet of under-

recording. Because the desk study was designed to give an overview of the species already

recorded in the local area, and used as indicative data prior to more detailed surveys, it was

not considered to be a significant constraint.

Stage 1 – Phase 1 Habitat Survey

2.4.2 The Stage 1 PEA was undertaken at a suitable time of year and under good weather

conditions with methodology proposed following industry standards and recommended

guidelines. No constraints were encountered during the survey with all parts of the Site

accessible and with good visibility.

Stage 1 – Preliminary Ground Level Bat Tree Roost Assessment

2.4.3 The preliminary ground level bat tree roost assessment was undertaken at the sub-optimal

time of the year although visibility of the tree features based on location, foliage and

condition was good. Although a preliminary ground level bat tree roost assessment aims to

evaluate each tree present, it can sometimes be difficult to locate roosts within trees

(Collins, 2016). This is largely due to the behaviour of bats using tree roosts (for example

switching between roosts, limited echolocation or varying emergence and re-entry

patterns), as well as lack of persistent bat evidence. This assessment does not include an

evaluation of tree condition, or any arboricultural survey.

Stage 1 – Protected Species Building Assessment

2.4.4 The Site consisted of the main hospital with terraced cottages (numbers 35 – 38). No

constraints were encountered during the survey with all parts of the Site accessible and with

good visibility.

Stage 2 – Bat Surveys

2.4.5 The roost characterisation surveys were undertaken at a suitable time of year and under

good weather conditions with methodology proposed following industry standards and

recommended guidelines. No constraints were encountered during the survey with all parts

of the Site accessible and with good visibility. The only deviation from the guidelines was in

the form of three emergence surveys instead of two emergence surveys and one pre-dawn.

Although pre-dawn re-entry surveys can be valuable to pinpoint exact access points for

complex sites with discreet species, they have also been shown to potentially miss the

return of bats depending on season and species. Andrews and Pearsons (2017) undertook a

review of available data for bats in the UK with widely varying return times, particularly for

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long-eared species Plecotus sp., Daubenton's, barbastelle and common pipistrelle, which

could likely have returned to roost long before the start of any pre-dawn re-entry survey, or

certainly early enough to be in complete darkness. Finally, the resulting changing sleep

patterns between undertaking late night emergence surveys and early pre-dawns were

considered sufficiently detrimental to ecologists health and were avoided where necessary.

Colmer Ecology considered the Health and Safety of its staff as a matter of priority, with the

use and support from technology such as infra-red and thermal cameras to obtain quality

survey data, paramount.

2.4.6 Bat surveys undertaken using bat detectors are inherently biased. Bats with louder calls

(such as the Nyctalus species) will be recorded at a greater distance (and therefore each bat

will be recorded more frequently) than species that use quiet calls such as Plecotus sp. This

affects the results of all surveys undertaken for each species type recorded. In order to limit

these impacts, Colmer Ecology’s recording equipment was serviced weekly using the

Wildlife Acoustics Ultrasonic Calibrator to limit technical/microphone deficiency.

2.4.7 Species identification by sonogram is limited (to a certain extent) by similarities in call

structure. In addition all bats can modulate their calls according to the habitats they are

navigating, their behaviour and the information they require at the time. This imposes

limitations on reliable analysis particularly between species of the same genus in the genera

Plecotus sp., Myotis sp. and Nyctalus sp.

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3.0 Results

3.1 Stage 1

Biological Desk Study

Statutory Designated Sites

3.1.1 According to data held on MagicMap and ERCCIS, the Site was not within any designated

sites, although within the impact risk zones of several Sites of Special Scientific Interest

(SSSI) including Chyenhal Moor SSSI and Marazion Marsh SSSI, as well as 3.5 km south-east

of Marazion Marsh Special Protection Area (SPA). Chyenhal Moor SSSI was designated for its

diverse range of habitats and flora including rare species, and their associated fauna (in

particular dragonfly species). Marazion Marsh SSSI and SPA was designated primarily for its

flora including rare species, and important feeding ground for passage waders as well as

breeding passerines. The marshes are also important for wintering passage birds and high

number of dragonfly species. According to ERCCIS, the Site was not within an Area of

Outstanding Natural Beauty (AONB).

Other Designated Sites/Information

3.1.2 Several Priority Habitats were provided by ERCCIS within the 1 km desk study area, including

coastal vegetated shingle. In addition, while reviewing MagicMap, additional areas of habitat

on the Priority Habitat Inventory included wood pasture and parkland, as well as deciduous

woodland (the closest being along the eastern boundary).

3.1.3 Reviewing the data from ERCCIS, the Site was not a CWS, with only a single County

Geological Site (CGS) (Mounts Bay Fossil Forest CGS), recorded within the 1 km desk study

area. A single unnamed ancient and semi-natural woodland (ASNW) was located within the

desk study area, located approximately 1 km west of the Site. ERCCIS also provided data for

two ‘monuments’ and five tree preservation orders within 1 km of the Site.

European Protected Species Licence Applications

3.1.4 When reviewing the most recent (2019) Natural England licence update on MagicMap, a

single granted EPSL application was noted within the desk study area. This licence was for

common pipistrelle and brown long-eared between 2010 to 2012, and approximately 290

m north-west of the Site.

Fauna and Flora Data

3.1.5 In total, 31,020 records were provided by ERCCIS within the desk study area. Records

spanned a date range from 1960 to 2021. Of these, none were located within the Site

although the majority of the records were provided at the four figure grid reference only,

with 1 km precision. Marine records were excluded from the desk study review in this

instance.

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3.1.6 Amphibians: In total, ERCCIS provided 20 records of amphibians between 1960 and 2017,

none within or in close proximity to the Site. These included 11 common frog, five common

toad, one unidentified newt, and three palmate newt records.

3.1.7 Bats: A total of 136 records between 1972 and 2018 were provided by ERCCIS and for 11

confirmed species, two genera and unknown bat species/families. Of these, 90 were old

records from the ‘Cornwall bat hospital’, Penzance, between 1990 and 1991 (with the same

co-ordinates in Penzance town centre). None of the records were from within the Site

boundary. The closest records of roosts were that of a long-eared roost (three bats) at York

House, St Clare and a single greater horseshoe in the boiler room at Penwith, both

approximately 150 m west of the Site at its closest.

3.1.8 Birds: In total, ERCCIS provided 12,386 records from 1960 to 2021, none of which were

within the Site boundary. It should be noted, the majority of the bird records originated from

Penzance beach and harbour, Battery Rocks and Mounts Bay.

3.1.9 Dormice: No records were provided by ERCCIS within the 1 km desk data search.

3.1.10 Flora records: A total of 4,322 records including conifers, fern, flowering plants, ginkgo,

horsetail, lichen, liverwort, and moss were provided between 1960 and 2019 within the desk

study area, none of which were within the Site boundary. Of these records, only 86 had

Priority designation, being Nationally Scarce.

3.1.11 Fungi: A total of 255 records were provided between 1963 and 2019, none of which were

within the Site boundary. None of these species had associated designations.

3.1.12 Invertebrates (not including marine): A total of 13,528 records were provided by ERCCIS

between 1960 to 2020, for acarines, annelids, centipedes, harvestmen, insects, molluscs,

spiders and springtails, with none within the Site boundary. Of these records, 1,150 had

Priority designation under NERC Section 41 and BAP 2007, Nationally Scarce or as Nationally

Notable B species. An additional species (monarch butterfly) were protected under the

Convention on Migratory Species (CMS).

3.1.13 Reptiles: A total of five reptile records were provided by ERCCIS from 1963 to 2018, although

none were located within the Site boundary.

3.1.14 Terrestrial mammals (excluding bats): In total, 124 records of terrestrial mammal were

provided by ERCCIS including 47 of European hedgehog, 41 grey squirrel, seven Eurasian

badger, six otter, six brown rat, five red fox, four common shrew, three European rabbit, two

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wood mouse, two Eurasian red squirrel, and a single record of American mink. Of these,

none were located within the Site boundary.

Phase 1 Habitat Survey

3.1.15 The habitats present within and where possible, immediately adjacent to the Site were

identified and described below. A colour coded habitat plan (Figure 1) with associated target

notes (TN) and annotated photographs were also provided.

3.1.16 Scattered trees: Scattered trees were noted throughout the Site boundary with species

dominated by immature cherries with other species including silver birch and semi-mature

ash. Trees were further assessed for their bat roosting potential in Section 3.1.32.

3.1.17 Amenity grassland: Short amenity grassland with a poor botanical composition was noted

throughout the Site, with grasses dominated by perennial rye-grass, annual meadow grass,

creeping bent and false oat-grass. Additional botanical species included dandelion,

buttercup species, common daisy, thistle species, hawkbit, dock species, red clover,

germander speedwell, yarrow, chickweed, ribwort plantain and rare occurrences of birds-

foot trefoil, Spanish bluebell, catmint and three-cornered leek. Although likely outside the

Site boundary, a small section of amenity grassland was noted by the entrance of the

hospital with grasses including perennial rye-grass, annual meadow grass and creeping

bent, with other botanical species comprising dandelion, common daisy, dock species,

buttercup, clover species and saplings of hazel, ash and hawthorn. This grassland was being

cut at the time of the survey.

3.1.18 Ephemeral with bare ground: Although likely outside the Site boundary, a small section of

ephemeral with bare ground was recorded adjacent to a building with cut vegetation, laurel,

red valerian, ivy, thistle species and Hydrangea noted.

3.1.19 Introduced shrub: Several areas of introduced species mixed with dense shrubs were noted

throughout the Site. Botanical species included Hydrangea, holm oak, Vibernum sp.,

ornamental honeysuckle, sumac, fuchsia, red and white valerian, three-cornered leek,

Spanish bluebell and other unidentified ornamental planting. In addition, ash saplings,

laurel, pendulum sedge, bindweed, thistle, chickweed, ivy, dandelion, herb-robert, cleavers,

thistle species, common nettle and lesser burdock were also present in places.

3.1.20 Intact species-poor hedge: Along part of the eastern boundary was a small section of intact

species poor hedge, with botanical composition including sycamore, cleavers, ivy, bramble,

thistle species, red valerian, ash saplings, false-oat grass and other unidentified ornamental

species. A second section of intact species poor hedge was evident at the southern part of

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the Site, with botanical species including holly, bramble, sycamore, ivy and other

unidentified ornamental species. A ground layer was present comprising three-cornered

lee, red valerian, dandelion, ash saplings and herb-robert.

3.1.21 Fence: Fences were present within the Site, largely of wooden palisade affording no

ecological interest.

3.1.22 Buildings: The Site was dominated by buildings, some of which were further assessed in

Section 3.1.33.

3.1.23 Other habitat: The dominant habitat within the Site was hardstanding (parking and paths)

of no ecological value.

Protected Species Habitat Assessment

3.1.24 Badgers: The Site and surrounding habitats (where possible) were searched for signs of

badgers but none were found. In addition, no records of badgers were provided by ERCCIS

within the Site boundary.

3.1.25 Bats (foraging habitat): The Site was assessed for its suitability to support bats following

methodology described in Collins (2016) and also using professional judgement. The

habitats within the Site were dominated by buildings, hardstanding and amenity grassland,

of limited potential for foraging bats although the presence of synanthropic species (such

as pipistrelle) was considered likely. In addition, no records of bats were provided by ERCCIS

within the Site boundary, although some were noted in proximity.

3.1.26 Bats (roosting potential): The trees and buildings were assessed separately for their bat

roosting potential (see Section 3.1.32 and 3.1.33 respectively).

3.1.27 Breeding birds (excluding buildings): Areas of scattered trees, hedges and shrub provided

suitable breeding bird habitat. Although no records of birds were provided by ERCCIS within

the Site boundary, a large number was noted within the 1 km desk study.

3.1.28 Dormice: No suitable dormouse habitat was present within or surrounding the Site with no

records of dormice provided by ERCCIS.

3.1.29 Great crested newts: No suitable great crested newt habitat was present within or

surrounding the Site, with no records provided by ERCCIS.

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3.1.30 Invertebrates: While suitable terrestrial habitats were present within the Site which could

potentially support a varied assemblage of invertebrates, these were likely to support

common and widespread species, as noted from the ERCCIS 1 km data search results.

3.1.31 Reptiles: No suitable reptile habitat occurred within the Site with no records provided by

ERCCIS within the boundary or in close proximity.

Preliminary Ground Level Bat Tree Roost Assessment

3.1.32 All the scattered trees were subject to a preliminary ground level bat tree assessment and

considered to provide ‘No/Negligible’ potential (Collins, 2016) for roosting bats.

Protected Species Building Assessment – Bats

3.1.33 The Site consisted of the main hospital with terraced cottages (numbers 35 – 38),

immediately to the south. Due to the demolition of the cottages and proposed tie into the

main hospital by the new outpatient facility, both were surveyed individually and described

below.

3.1.34 Cottages – external: The cottages were of a render finish throughout, which was generally

tight. Windows and doors were of wooden construction, with no exposed lintels. Although

some of the windowpanes were broken, the majority were boarded up (all the ground floor

windows as well as some on the first floor). Soffit and fascia boards were present, generally

tight although gaps were evident at the south-western and south-eastern corners. The roof

was covered in slate, raised throughout with some missing in places, providing internal

access. The ridge tiles were raised in places, providing potential access and/or cavities for

bats. A total of two chimneystacks were present, with the lead finish generally tight. Of note,

two gables were evident at the southern elevation, where access was present between the

bargeboards and roof slates. Small porch extensions were to the rear of the cottages, with

the gables generally tight with intact verges. All the soffit and fascia boards were tight,

providing no potential for roosting bats. The porch roofs were covered with slate, some

raised in places although fixed with external cement mix. The ridge tiles were generally tight.

Dividing walls were noted between each cottage, capped and providing no potential for

roosting bats. A thorough inspection of all walls and windows/boards revealed no evidence

of bat use externally.

3.1.35 Cottages – internal: Internally, all cottages were of a similar construction and derelict. Each

loft included a simple truss of exposed purlin and rafter construction. The floor of each loft

was covered in old fiberglass insulation throughout. The gables were of block construction,

with a ridge board present. Slates were exposed with no underfelt lining, with cement

mortar evident throughout, some of which was crumbling or missing in places, creating

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potential cavities for bats. The lofts were generally dusty with detritus present and mouse

and rat droppings scattered throughout. No evidence of bat use was noted in any of the

lofts. All the lofts were partially connected via small gaps in the internal gable wall divides,

noted at the internal chimneys between number 38 and 37, as well as between number 36

and 35. In some of the lofts, areas of slates were missing creating a draughty and light

environment as well as exposure to rain crating patches of rotten floor/trusses, especially in

numbers 36 and 37. Some of the lofts also contained water tanks, covered or dry, with no

evidence of drowned bats. A thorough inspection of all loft walls, floor area, water tanks

and discarded stored belonging revealed no evidence of bat use.

3.1.36 In addition to the loft inspection, each room was visually assessed, with special attention to

the cavities created between the boarded-up windows, which is a common place used by

roosting crack and crevices bats. In number 38, a single common pipistrelle was found

roosting in the cavity between the board and window on the first floor.

3.1.37 Main hospital tie-in: The new two-storey link from the proposed new outpatient facility will

tie into the current hospital building. The area to be impacted contained walls of very tight

render finish with PVCu windows throughout providing no potential for roosting bats. The

soffit was very tight throughout, with no access with all vents intact. The small porch area

at the front entrance contained hanging tiles, but very tight with lead finish and intact verge

finish. No evidence or potential bat roosting features were noted or bat(s) recorded in situ.

Protected Species Building Assessment – Birds

3.1.38 At the time of the survey, evidence of breeding birds was noted at the cottages in the form

of an active herring gull nest by the chimneypot between numbers 35 and 36. In addition,

house sparrows were noted re-entering a hole in the soffit at the south-western corner of

the cottages, likely feeding young. In addition, a total of 10 – 14 swifts were noted flying

above the Site during the July Stage 2 survey.

3.2 Stage 2

Bat Roost Characterisation Survey

Visit 1: Emergence Survey – 1st July 2021

3.2.1 Sunset was 21:35 h with temperature at the start of the survey 19.9 ˚C with no precipitation,

wind or cloud cover, and 63.5 % relative humidity. Temperature fell to 13.7 ˚C at the end of

the survey with no precipitation, wind or cloud cover, and 87.0 % relative humidity.

Conditions were considered suitable for the detection of bats.

3.2.2 No bats were observed emerging from the Site.

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3.2.3 The first bat recorded flying over the Site was a common pipistrelle seen by the surveyor at

the northern elevation of the Site at 22:19 h, flying in a north-easterly direction in front of

the main hospital. Subsequent activity was minimal and entirely dominated by common

pipistrelle bats.

Visit 2: Emergence Survey – 1st August 2021


0.0 – 3.0 mph wind, 95 % cloud cover and 82.0 % relative humidity. Temperature fell to 14.4

˚C at the end of the survey with no precipitation or cloud cover, 0.0 – 3.0 mph wind, and

88.0 % relative humidity. Conditions were considered suitable for the detection of bats


3.2.6 The first bat recorded flying over the Site was a common pipistrelle, heard not seen by the

surveyor at the south-western elevation of the Site at 21:44 h. Subsequent activity was

minimal and entirely dominated by common pipistrelle.

Visit 3: Emergence Survey – 19th August 2021


0.0 – 2.4 mph wind, 100 % cloud cover, and 76.0 % relative humidity. Temperature fell to

18.2 ˚C at the end of the survey with no precipitation, 0.0 – 0.9 mph wind, 80 % cloud cover

and 80.8 % relative humidity. Conditions were considered suitable for the detection of bats.


3.2.9 The first bat recorded flying over the Site was a common pipistrelle heard not seen by the

surveyor at the north-eastern elevation of the Site at 20:53 h. Subsequent activity was

minimal and entirely dominated by common pipistrelle.

Biodiversity Net Gain

3.2.10 For ease and clarity, the results of the DEFRA SSM for the Site are presented in Section 6.0.

3.3 Evaluation/Assessment of Ecological Features

3.3.1 The importance of all ecological features including designated sites, habitats on and off Site,

as well as protected or noteworthy species were summarised in Table 1.

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Table 1: Ecological features including designated sites, habitats on and off Site as well as protected

or noteworthy species and their associated ecological importance.

Ecological Features Ecological Importance

Explanation

Designated Sites SPA International As per designation status SSSI National As per designation status Habitats on Site Scattered trees Site Common and widespread habitat of some ecological interest at the

site level Amenity grassland Negligible Common and widespread habitat of limited ecological interest at the

site level Introduced shrub Site Common and widespread habitat of some ecological interest at the

site level Intact species-poor hedge

Site Common and widespread habitat of some ecological interest at the site level

Fences Negligible No ecological interest Building Site Ecological interest in relation to the bat roost and breeding birds

only Other habitat Negligible No ecological interest Habitats off Site Ephemeral with bare ground

Negligible Common and widespread habitat of limited ecological interest at the site level

Protected and Noteworthy Species on Site Badgers Negligible No evidence of badger or potential Bats (Foraging/Commuting)

Site Potential for foraging by synanthropic species

Bats (Roosting) Site Single common pipistrelle found roosting during Stage 1 survey with low activity levels during Stage 2 survey

Birds Site Breeding birds found during Stage 1 survey within building, as well as potential within habitat for common species

Dormice Negligible No suitable habitat within Site Great crested newt Negligible No ponds or suitable terrestrial habitat within the Site Invertebrates Site Limited potential for common and widespread species Reptiles Negligible No potential within the Site

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4.0 Evaluation and Recommendations

4.1 Summary

4.1.1 The current proposals for the redevelopment of the hospital include the demolition of the

existing cottages and construction of new outpatient facilities. In addition, re-arrangement

of the existing car park, the creation of a two-storey link from the new outpatient facilities

to the current hospital building, as well as impact to habitats for potential services routing

from the boiler rooms/plant space. Stage 1 and Stage 2 ecological assessments were carried

out in order to evaluate impacts on biodiversity and protected species from the proposed

works. The location, proposed development and likely level of works have been reviewed

(where possible) against current standing advice and legislation. In addition, professional

judgment has also been used.

4.2 Biological Desk Study

4.2.1 The Site was within the impact risk zones of several SSSI and within 10 km of a SPA. These

designated sites were classified for their habitats, geology and associated flora and fauna

and any development in close proximity to these sites may have a detrimental impact on

their ecological functionalities. This may result from the development activities themselves,

or increased visitors and subsequent pressure on ecological resources of species linked to

the designated sites.

4.2.2 The Local Planning Authority (LPA) or ‘competent authority’ will need to review the

proposed development against each citation and/or impact risk zone criteria to ascertain

whether the proposed development is likely to have a significant effect on these

designations. The LPA will be required to consider the development alone, but also in

conjunction with other proposals or local plans. In determining impacts on these

designations, the location, nature of the proposal and plans for the Site will all be assessed.

If the proposed development was considered likely to have significant impact on the SAC

SPA and Ramsar, the LPA/competent authority will be required to conduct a formal

assessment of the ecological implications of the proposed works. Generally termed a

Habitat Regulations Assessment (HRA), the proposed works may require a formal screening

to the LPA for any likely significant effects (alone or in combination with other projects).

4.2.3 Natural England suggests, ‘Where these effects cannot be excluded, assessing them in more

detail through an appropriate assessment (AA) is required to ascertain whether an adverse

effect on the integrity of the site can be ruled out. Where such an adverse effect on the site

cannot be ruled out, and no alternative solutions can be identified, then the project can only

then proceed if there are imperative reasons of over-riding public interest and if the

necessary compensatory measures can be secured’. (Natural England).

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4.3 Phase 1 Habitat Survey

4.3.1 The dominant habitats within the Site were hardstanding and buildings, with the addition of

amenity grassland, introduced shrub, intact species poor hedge and scattered trees. At the

time of the survey, no rare or nationally scarce botanical species were identified, however,

it should be noted that a Stage 1 PEA does not aim to identify all botanical species. This

report does not constitute a full contaminated land or invasive species survey.

4.3.2 Based on the impacts of the development being restricted to a relatively small working

footprint with a large proportion of the associated engineering works undertaken on

concrete hardstanding, ecological impacts were considered low in this instance with no

additional habitat survey considered necessary.

4.3.3 All the habitats proposed for removal on Site were of limited ecological value and qualified

as ‘Site’ or ‘Negligible’ ecological importance. Without mitigation, the impact would lead, at

worst, to an adverse effect in the long-term, at the ‘Site’ level. Mitigation measures and

additional planting was proposed in Sections 5.0 and 6.0 to assess overall net gain in habitat

value.

4.3.4 Some of the introduced shrub and intact species poor hedges within the Site will be

retained. However, accidental damage could occur during construction, with root

compaction, particularly from vehicular access, removal of materials and digging activities

as well as damage from contaminant run-off. Without mitigation, the impact would lead to

an adverse effect in the long-term, at the ‘Site’ level. Therefore, suitable precautionary

measures were proposed in Section 5.0.

4.3.5 In addition, dust created from the proposed works and removal of materials, may be

deposited on adjacent trees or vegetation, which would lead to an adverse, short-term

effect at the ‘Site’ level for the habitats adjacent to the Site. Therefore, suitable precautionary

measures were proposed in Section 5.0.

4.4 Protected Species Habitat Assessment

4.4.1 The habitats and features within the Site were assessed for their potential to support

protected species with the following evaluation.

4.4.2 Badgers: In England, badgers are listed under Appendix III of the Bern Convention, and

protected under the Protection of Badgers Act 1992, which makes it an offence to

intentionally kill, injure or capture a badger, damage, destroy or block access to their setts,

disturb badgers when occupying their sett, as well as treat them cruelly, deliberately send

or intentionally allow a dog into a set, and bait or dig for them. At the time of the survey no

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evidence of badgers was found within the Site with limited potential for this species.

Therefore, based on current proposals, no further badger surveys were considered

necessary at the present time, however, suitable precautionary measures were proposed in

Section 5.0.

4.4.3 Bats: In England, all bat species are fully protected and listed under Schedule 2 of The

Conservation of Habitats and Species Regulations (as amended) 2017, amended by The

Conservation of Habitats and Species (Amendment) (EU exit) Regulations 2019, Schedule 5

of the WCA (as amended) 1981, and listed under Section 41 (S41) of the NERC Act (2006) as

well as included in the CRoW (2000). All UK bat species are also listed under Appendix II of

the Bern Convention (with the exception of common pipistrelle, which is on Appendix III)

and Appendix II of the Bonn Convention. In addition, greater and lesser horseshoes,

Bechstein’s, noctule, soprano pipistrelle, brown long-eared and barbastelle bats are also

listed as UKBAP.

4.4.4 The protection afforded to bats is such that the animals and their roosts (used for rest or

shelter) are legally protected. It is a criminal offence to deliberately take, injure, or kill a bat,

intentionally or recklessly disturb a bat in its roost or deliberately disturb a group of bats,

damage or destroy a place used by bats for breeding or resting (even if bats are not present),

possess or advertise/sell/exchange a bat of a species found in the wild (dead or alive), whole

or any part of a bat, as well as intentionally or recklessly obstruct access to a bat roost.

Important populations of greater and lesser horseshoes, Bechstein’s and barbastelle require

the designation of SAC.

4.4.5 Therefore, unlicensed works that may cause disturbance, killing, injury or blocking access

to a place of rest and shelter has the potential to cause an offence. Following the withdrawal

of Planning Policy Statement 9 (PPS9): Biodiversity and Geological Conservation, the NPPF

was published as its replacement in 2012. Although Circular ODPM 06/2005: Biodiversity

and Geological Conservation – Statutory Obligations and their impact within the Planning

System, was a guidance document that accompanied PPS9, it is still valid in its interpretation

by local planning authorities on the impact a development may have on protected species.

Circular 06/2005 stated that the presence of a protected species is a, ‘material consideration

when a planning authority is considering a development proposal that, if carried out, would

be likely to result in harm to the species or its habitat’ (ODPM 06/2005). Furthermore,

habitats within the Site were assessed for their potential to support foraging and community

bats and whether the proposed development could impact bats.

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Bat Foraging

4.4.6 Based on ‘professional judgement’ (Collins, 2016), the dominant hardstanding, building and

amenity grassland habitats within the Site were not considered significantly diverse to

support a large assemblage of bats. Importantly, no significant changes to the connectivity

of the adjacent habitats or those in the wider landscape were likely. Based on the proposed

works, no further bat activity (transect for example) surveys to assess foraging or

commuting activity were considered necessary in this instance. Further information was

provided in Section 5.0, with a recommendation for preventing impacts associated with

lighting during works also proposed.

Bat Roosts

4.4.7 The buildings on Site were subject to a thorough internal and external Stage 1 survey to

search for evidence of bats, with a single common pipistrelle observed roosting in situ at

number 38. Therefore, a further Stage 2 bat roost characterisation survey was subsequently

undertaken to confirm the status of the bat roost, as outlined in Collins (2016). The survey

was undertaken at the optimal time of year and under suitable conditions, with no evidence

of bats emerging from the Site.

4.4.8 Based on the sound ecological survey undertaken and following best practice for ecological

assessment of bat roosts, Site was considered to be a day, non-breeding infrequent roost

for low numbers/singleton common pipistrelle.

4.4.9 In order to evaluate impacts on bats, the location, the proposed development and likely

level of works have been reviewed (where possible) against current standing advice,

legislation and importantly, professional ecological experience. Current proposals include

the complete demolition of the existing terrace cottages. It was therefore considered that

the proposals were likely to cause, ‘disturbance, killing or injury, blocking access or

destruction of a bat roost’ and that offences under the Conservation of Habitats and Species

Regulations (as amended) 2017, amended by the Conservation of Habitats and Species

(Amendment) (EU exit) Regulations 2019 and WCA (as amended) 1981 would be committed

without appropriate licensing. As a result, a European protected species licence (EPSL)

from Natural England will be required prior to any works commencing in areas where

bats were roosting. Appropriate mitigation/compensation shall be incorporated within the

design proposal to compensate for the loss of the roosts and maintain the bats’ favourable

conservation status with a working method adhered to. Specific details of

mitigation/compensation would be provided in any Method Statement and Reasoned

Statement (if requested) applied to Natural England once planning permission has been

granted, with suggested bat mitigation outlined in Section 5.0.

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4.4.10 When considering a planning (or other consent) application and impacts on European

protected species, Local Planning Authorities (LPAs) are under the obligation to consider

the three European protected species licensing tests. This was further emphasised by a High

Court judgement, which determined that the Habitats Regulations placed LPAs under the

obligation to consider protected species. The three licensing tests, which Natural England

also apply when considering granting an EPSL, are:

(i) Whether there are imperative reasons of overriding public interest for the planning

application;

(ii) Whether there are any satisfactory alternatives; and

(iii) Whether the species' favourable conservation status has been maintained.

4.4.11 With regard to ecology, provided recommendations outlined in Section 5.0 of this report

were implemented, it was considered that the third test might be met (species’ favourable

conservation status maintained). However, it is up to the LPA (as a statutory undertaker) to

decide whether this is applied or not and on the evidence (such as this ecology report)

provided. Tests one and two concern planning matters but for any EPSL to be applied for,

supporting information must be provided.

4.4.12 Assuming the development was granted planning permission, the following ecological

planning condition imposed on the development would be considered suitable:

‘Development to proceed with the bat mitigation scheme supplied with the application,

subject to any variation required by Natural England under any licence issued’.

4.4.13 Breeding birds: Under Section 1 of the WCA (as amended) 1981, wild birds (with exceptions)

are protected from being killed, injured or captured, while their nests and eggs are protected

from being damaged, destroyed or taken while in use. At the time of the survey evidence of

current breeding bird was recorded on Site, with additional breeding bird habitat identified

in scattered trees and thick, introduced shrub. Although no further breeding bird surveys

(for example walked transects) were considered necessary in this instance, suitable timing

restrictions and recommendations were provided in Section 5.0.

4.4.14 Dormice: In England, dormice are fully protected under Schedule 2 of The Conservation of

Habitats and Species Regulations (as amended) 2017, amended by The Conservation of

Habitats and Species (Amendment) (EU exit) Regulations 2019, Schedule 5 of the WCA (as

amended) 1981, and listed under S41 of the NERC Act (2006) and CROW Act (2000). In

addition, dormice are also listed as UKBAP species.

4.4.15 The protection afforded to dormice is such that the animals and the places they use for rest

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or shelter are legally protected. It is a criminal offence to deliberately or intentionally take,

injure, or kill a dormouse, damage or destroy a place used by dormice for breeding or

resting, deliberately or recklessly disturb a dormouse while in its structure or place of

shelter/protection, block access to structures or places of shelter/protection, possess or

sell, control or transport a dormouse (dead or alive, whole or in part).

4.4.16 Based on the surveyor’s experience5 in habitat assessments for this species, the habitats

within the Site provided no potential for this species. It was considered that a dormouse

survey following methodology proposed by Natural England (Bright et al., 2006) was not

necessary in this instance. In addition, no dormouse records were provided by ERCCIS

within the desk study area.

4.4.17 Great crested newt: In England, great crested newts are fully protected under Schedule 2 of

The Conservation of Habitats and Species Regulations (as amended) 2017, amended by The

Conservation of Habitats and Species (Amendment) (EU exit) Regulations 2019, Schedule 5

of the WCA (as amended) 1981, listed under S41 of the NERC Act (2006), and the CROW Act

(2000). In addition, great crested newts are also listed under Appendix II of the Bern

Convention and as a UKBAP species, with important populations of this species requiring

the designation of SAC.

4.4.18 The protection afforded to great crested newt is such that the animals and the places they

use for rest or shelter are legally protected. It is a criminal offence to deliberately or

intentionally take, injure, disturb or kill a great crested newt, damage or destroy their

breeding or resting places, deliberately or recklessly block access to structures or places of

shelter/protection, possess or sell, control or transport a great crested newt (dead or alive,

whole or in part) or take their eggs.

4.4.19 No ponds were recorded within the Site, and based on the surveyor’s experience6 in habitat

assessments for this species and reviewing Natural England’s standing advice, the habitat

within the Site provided negligible potential and no further surveys were considered

necessary. In addition, this species is considered absent from this part of Cornwall with no

records provided by ERCCIS within the desk study area.

4.4.20 Invertebrates: Habitats within the Site were not considered suitably diverse to support a

large or varied assemblage of invertebrates, and therefore, in this instance no further

surveys were considered necessary.

5 Mr H. Colmer BSc (Hons) Dip MCIEEM FLS – Dormouse licence. 6 Mr H. Colmer BSc (Hons) Dip MCIEEM FLS – Great crested newt licence.

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4.4.21 Reptiles: In England, the four widespread species of reptiles (common lizard, slow-worm,

adder and grass snakes) are listed under S41 of the NERC Act (2006) and protected under

Schedule 5 of The WCA (as amended) 1981. In addition, these four species are also listed as

UKBAP.

4.4.22 The protection afforded to slow-worms, common lizards, adders and grass snakes is such

that the animals are protected from intentional killing or injuring, as well as being sold,

offered for sale or held or transported for sale (dead or alive, whole or in part) as well as

protected from being published or advertised as being for sale.

4.4.23 No suitable reptile habitat was present and therefore no further reptile surveys were

considered necessary.

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5.0 Recommendations and Constraints, Mitigation and Enhancements

5.1 Detailed Bat Mitigation, Compensation and Enhancements

5.1.1 The Bat Mitigation Guidelines (Mitchell-Jones, 2004) suggests that for, ‘Individual bats or

small numbers of common species (common pipistrelle) not a maternity site: flexibility over

the provision of bat boxes or access to new building for mitigation and compensation. No

condition about timing or monitoring’. It should be noted that nationally, common

pipistrelles are considered common species (Wray et al., 2010). In order to compensate for

the loss of the common pipistrelle roost on Site, bat roosting features will be incorporated

within the Site and on an immediately adjacent existing building.

5.1.2 To mitigate/compensate for the loss of roosting opportunities for common pipistrelles, the

bat mitigation and compensation outlined below were suggested (and subject to

confirmation via an EPSL application to NE). This is based on current understanding and

proposals for the development and the habitat characteristics of crevice bat species, as well

as professional experience of working with these species. The ecological

mitigation/compensation were based on the Stage 2 surveys conducted and proposed in

order to maintain the favourable conservation status of protected species on Site. �

5.1.3 As common pipistrelles are crevice dwellers, the bat box system was considered to be

suitable in this instance. Therefore, mitigation and compensation were proposed with the

following details:

1. An external bat box (erected at the south-eastern wall of the existing hospital building)

will be fitted at height, and to provide a suitable alternative roosting provision for the

species identified. Any external box to be of durable, insulating block/woodcrete

construction (e.g. Schwegler 1FQ), which provide a long lasting and internal roosting

space for a vast number of UK bat species. Following the bat mitigation guidelines

(Mitchell-Jones, 2004), the replacement roost suggested was, ‘situated as close as

possible to the roost to be lost’ and was, ‘chosen to maximise the chances of the bats

finding and adopting it....close to existing flight lines and entrance close to appropriate

habitat’ (Mitchell-Jones, 2004). It should be noted that it is not possible to provide

compensation into the proposed new outpatients building due to the cladding design

(Pers. comm. Stride Treglown to Colmer Ecology, 24th September 2021). Figure 7

highlights the proposed location and compensation suggested;

2. The soft demolition/stripping of all key bat features of the cottages (fascia and barge

boards, ridge tiles, and boarded-up windows), or the blocking of any access points will

require supervision by a licenced bat ecologist and need to be carried out in a slow

and careful removal process under a granted EPSL. Once all bat features or areas of

high risk to bats have been cleared, works can continue uninterrupted;

Colmer Ecology ltd


3. Contractors will be made aware of the new bat roosting location (bat box) during soft

demolition/stripping and how it will need to be fitted (with the aid of photography and

mapping) before and during the toolbox talk required as part of the EPSL for the Site.

Installation of the bat box must be overseen by an ecologist, to comply with the licence

requirements; and

4. If external lighting was required, this will be kept to a minimum and should consist of

LED luminaries, ideally of a warm white spectrum (< 2,700 Kelvin), upward light ratio of

0 % and with good optical control, with any external security lighting to be set on

motion-sensors and short (1 minute) timers (Institution of Lighting Professionals and Bat

Conservation Trust, 2018). No additional lighting to be fitted in close proximity

(adjacent, immediately above and/or below) to the bat box fitted at the south-eastern

wall of the existing hospital building (downward lighting proposed at basement level

only). New internal lighting to be recessed, where possible, to avoid additional glare and

light spill particularly along the boundary habitats. Refer to Guidance Note 08/18 on

Bats and Artificial Lighting in the UK for further details (Institution of Lighting

Professionals and Bat Conservation Trust, 2018). A lighting study or lighting plan may be

required and conditioned by the LPA.

5.2 Recommendations and Constraints – Other Protected Species

5.2.1 In reviewing development proposals, the following were also recommended:

1. Land mammals: During construction, any open dug trenches must be covered overnight

to prevent any mammals (such as foxes, hedgehogs or domestic pets) from being

trapped. If this was not possible, suitable mammal ladders, in the form of simple wooden

planks with a maximum gradient of 1:2 must be provided. In addition, any piping with

the potential to entrap badgers or other mammals will be capped at the end of each

working day. The contractor shall implement an auditing system, documenting mammal

ladder installation or the capping of pipes. Details should be made available to an

ecologist on request, although monitoring during or post construction was not

proposed; and

2. Birds: Should any suitable breeding bird habitat require removal during the bird breeding

season of 1st March – 31st August inclusive, a suitably qualified individual would need to

undertake an inspection for breeding birds within 48 hours prior to any clearance. This

must involve a survey of each loft, but also a survey of any flat roof area (chimneystack

for example) to identify nesting gulls. If breeding birds were identified, these must

remain in place until breeding has ceased and dependent young have fledged, with a

suitable exclusion zone implemented where necessary. The advising ecologist will

periodically monitor any occupied nest, until young have fledged. No inspection or

supervised clearance would be required for removal of breeding birds habitat between

1st September – 28th February (or 29th in any leap year).

Colmer Ecology ltd


5.3 General Site Mitigation Measures

5.3.1 In order to avoid any adverse impacts to habitats on and in the vicinity of the Site, the

following ecological avoidance measures/mitigation were made at the Site level:

1. Contractors must work in accordance with the Environment Agency pollution

prevention for businesses guidance (Defra and Environment Agency, 2016) and follow

guidelines for preventing adverse dust levels, minimising run off and using bunded

storage, for example when refuelling vehicles and storing oil and fuel. Contractors shall

be made aware of the potential that pollution incidents may occur, with spills kits to

remain on Site for the duration of the development and where necessary, tool box talks

to be given. It is the responsibility of the applicant and their contractors to supply

appropriate information and monitoring for the LPA to review; and

2. In order to prevent any ground works exposing tree roots of retained trees/hedgerows,

where required, a tree root protection zone will be implemented in accordance with

BS5837:2012 Trees in Relation to Design, Demolition and Construction. The tree root

protection zone(s) will be monitored throughout the construction phase and with

appropriate signage in place. In addition, any trees that require pruning to facilitate the

delivery of materials should be carried out following good silvicultural practices,

following consultation with a qualified arboriculturist where appropriate and only where

the lack of any Tree Preservation Order has been confirmed.

5.4 Ecological Enhancements

5.4.1 In accordance with the NPPF (revised 2021), consideration should be sought to creating

new habitats or features of biodiversity gain within a sustainable development, or managing

existing features for ecological and biodiversity gain. Although this may be restricted with

the small-scale development proposal, one of the following enhancements were proposed

for swift:

1. Swifts (external OR retrofitted boxes): As it is not possible to integrate swift boxes into

the new outpatients building (Pers. comm. Stride Treglown to Colmer Ecology, 24th

September 2021), four external OR retrofitted swift boxes will be fitted at the south-

eastern wall of the existing hospital building (Figure 7). External boxes to be installed at

eaves height, at least 5 m high, away from windows in an uncluttered environment and

in clusters (1 m apart) due to the colonial nesting of this species. Swift box installation

must be overseen and signed off by an ecologist with a ‘tool-box’ talk to contractors

(Day et al., 2019). External or retro fitted swift boxes will comprise either:

External

• John Stimpson external swift box model 30 with internal nest chamber; or

• John Stimpson external swift box model 31 with internal nest chamber; or

• WoodStone swift nest box.

Colmer Ecology ltd


Retrofitted

• Ibstock Eco-habitat for swift brick; or

• Habibat 003 or Habibat swift box; or

• Manthorpe swift nesting ‘brick’.

5.5 Residual effects

5.5.1 The residual effects following implementation of mitigation and compensation were

summarised in Table 2 for each ecological feature following CIEEM (2018).

Co

lmer Eco

log

y ltd

20

21-46

32 R

CH

T –

EcIA R

epo

rt

Tab

le 2: Sum

mary o

f residu

al effects

Eco

log

ical Features

Imp

act Level

Mitig

ation

Measu

res C

om

pen

sation

/En

han

cemen

t Measu

res R

esidu

al E

ffects D

esignated Sites SPA

LP

A to

assess if H

RA

is requ

ired

Intern

ation

al -

- -

SSSI N

o im

pact

Natio

nal

Measu

res to in

clud

e site wid

e mitig

ation

-

- H

abitats on Site (B

ased on JN

CC

Phase 1 Habitat C

lassification)

Scattered trees R

emo

val Site

Co

ntracto

rs to w

ork in

accord

ance w

ith th

e p

ollu

tion

preven

tion

for b

usin

ess gu

idan

ce (D

EFRA

and

EA, 20

19)

Ad

ditio

nal n

ative tree plan

ting

(mo

re th

an p

rop

osed

to b

e remo

ved)

Po

sitive

Am

enity grassland R

emo

val N

eglig

ible

Co

ntracto

rs to w

ork in

accord

ance w

ith th

e p

ollu

tion

preven

tion

for b

usin

ess gu

idan

ce (D

EFRA

and

EA, 20

19)

Existing

amen

ity grasslan

d to

be rep

laced

with

a mix o

f flow

ering

lawn

with

w

ildflo

wer areas, n

ative hed

gero

w sh

rub

p

lantin

g an

d o

rnam

ental p

ollin

ator sh

rub

p

lantin

g

Po

sitive

Introduced shrub

Partial rem

oval

Site C

on

tractors to

wo

rk in acco

rdan

ce with

the

po

llutio

n p

reventio

n fo

r bu

siness g

uid

ance

(DEFR

A an

d EA

, 2019

) T

ree roo

t pro

tection

zon

e imp

lemen

ted in

acco

rdan

ce with

BS58

37:2012 T

rees in R

elation

to

Desig

n, D

emo

lition

and

Co

nstru

ction

New

area of o

rnam

ental p

ollin

ator sh

rub

p

lantin

g w

ith existin

g sh

rub

plan

ting

to

be retain

ed in

places

Neu

tral

Intact species poo

r hedge P

artial remo

val Site

Co

ntracto

rs to w

ork in

accord

ance w

ith th

e p

ollu

tion

preven

tion

for b

usin

ess gu

idan

ce (D

EFRA

and

EA, 20

19)

Tree ro

ot p

rotectio

n zo

ne im

plem

ented

in

accord

ance w

ith B

S5837:20

12 Trees in

Relatio

n

to D

esign

, Dem

olitio

n an

d C

on

structio

n

Som

e area to b

e lost to

the

develo

pm

ents w

ith n

ew n

ative hed

gero

w

shru

b p

lantin

g

Neu

tral

Fences R

emo

val N

eglig

ible

- -

Neu

tral B

uilding R

emo

val Site

See belo

w fo

r bats an

d b

irds

mitig

ation

/com

pen

sation

/enh

ancem

ents

- N

eutral

Other habitat

Partial rem

oval

Neg

ligib

le -

- N

eutral

Habitats o

ff Site (Based o

n JNC

C Phase 1 H

abitat Classificatio

n) Ephem

eral with bare

ground

No

imp

act Site

Co

ntracto

rs to w

ork in

accord

ance w

ith th

e p

ollu

tion

preven

tion

for b

usin

ess gu

idan

ce (D

EFRA

and

EA, 20

19)

- N

eutral

Protected and N

otew

orthy Species

Co

lmer Eco

log

y ltd

20

21-46

33 R

CH

T –

EcIA R

epo

rt

Eco

log

ical Features

Imp

act Level

Mitig

ation

Measu

res C

om

pen

sation

/En

han

cemen

t Measu

res R

esidu

al E

ffects B

adgers P

oten

tial to

beco

me en

trapp

ed

in excavatio

n/

pip

ing

du

ring

co

nstru

ction

p

eriod

Neg

ligib

le T

rench

es to b

e covered

at nig

ht o

r fitting

su

itable m

amm

al ladd

ers, as well as cap

pin

g

pip

es

- N

eutral

Bats

(Foraging/C

om

muting)

No

imp

act Site

No

add

ition

al ligh

ting

on

to ad

jacent h

abitats.

LED lu

min

aries, ideally o

f a warm

wh

ite sp

ectrum

(< 2,700

Kelvin

), up

ward

ligh

t ratio o

f 0

% an

d w

ith g

oo

d o

ptical co

ntro

l, with

any

external secu

rity ligh

ting

to b

e set on

mo

tion

-sen

sors an

d sh

ort (1 m

inu

te) timers.

Po

tential fo

r new

plan

ting

of eco

log

ical in

terest N

eutral

Bats (R

oo

sting) R

emo

val of

roo

sting

o

pp

ortu

nities

Site E

PSL req

uired

with

too

lbo

x talk and

soft

dem

olitio

n p

roced

ures u

nd

er ecolo

gical

sup

ervision

Pro

po

sed b

at bo

x installed

N

eutral

Birds

Rem

oval o

f nestin

g

op

po

rtun

ities Site

Tim

ing

restriction

with

insp

ection

with

in 4

8 h

of

start of an

y hab

itat clearance (w

here req

uired

) A

dd

ition

al plan

ting

in th

e form

of

scattered trees, n

ative hed

gero

w sh

rub

p

lantin

g an

d o

rnam

ental p

ollin

ator sh

rub

p

lantin

g

Pro

po

sed b

ird b

oxes fo

r swifts w

ithin

the

new

ou

tpatien

t facilities OR

on

existing

b

uild

ing

Po

sitive

Do

rmice

No

imp

act N

eglig

ible

No

imp

act -

Neu

tral G

reat crested newt

No

imp

act N

eglig

ible

No

great crested

new

t po

tential w

ithin

Site -

Neu

tral Invertebrates

Rem

oval o

f som

e h

abitat

Site -

New

areas of flo

werin

g law

n w

ith

wild

flow

er areas, native h

edg

erow

shru

b

plan

ting

and

orn

amen

tal po

llinato

r shru

b

plan

ting

Po

sitive

Reptiles

No

imp

act N

eglig

ible

No

reptile p

oten

tial with

in Site

- N

eutral

Colmer Ecology ltd

2019-21 34 RCHT, West Cornwall Hospital – EcIA Report

6.0 Biodiversity Offsetting Calculations (Biodiversity Net Gain)

6.1 In order to assess biodiversity offsetting, the Small Sites Metric (SSM) (JP040) (DEFRA 2021)

was used in this instance as the Site met both (highlighted in bold) of the following SSM

criteria:

‘1. Development sites where;

For residential developments the number of dwellings to be provided is between one and

nine inclusive on a site having an area of less than one hectare;

Where the number of dwellings to be provided is not known the site area is less than 0.5

hectares:

For all other development types where the site area is less than 0.5 hectares or less than

5000 metres squared.

2. Where there is no priority habitat present within the development area (excluding

hedgerows and arable margins).

6.2 The SSM is a simplified version of the Biodiversity Metric 3.0, and was reviewed to measure

and account for, biodiversity losses and gains resulting from development or land

management within the Site. The SSM encompasses habitat areas pre and post

development, and also linear features such as hedgerows, tree lines, rivers and

watercourses.

6.3 As highlighted by Natural England and DEFRA advice, it should be noted that the SSM is still

currently in BETA7 format and its use (until agreed) and subsequent calculations/results

should be used with caution. Furthermore, the Biodiversity Metric 3.0 and SSM use the UK

Habitat Classification8 system, as opposed to JNCC, 2010 (updated 2016) phase 1 habitat

survey habitat typologies. As the Site was surveyed following the phase 1 habitat survey

classification, the habitat typologies recorded were therefore converted to UK Habitat

Classification using the DEFRA Biodiversity Metric 3.0 conversion table within the

biodiversity metric ‘Technical Data’.

6.4 The DEFRA biodiversity metric calculations of habitats post development have been based

on the suggested an provided landscaping plans. In addition, the SSM appears to consider

proposed habitat enhancements where the targeted increase in units at baseline were zero.

Finally, the metric does not consider biodiversity enhancements such as bat or bird boxes

incorporated into/onto a development, or physical enhancements for other terrestrial

animals.

7 The ‘beta’ label means the first version of a new service or web page. The beta label is displayed on a new service to show it is being tested – DEFRA website, 2021. 8 http://ecountability.co.uk/ukhabworkinggroup-ukhab/

Colmer Ecology ltd


6.5 Based on the landscape plans provided and reviewed (Stride Treglown, Landscape GA,

154345-STL-XX-ZZ-DR-L-XXXX-90000) each habitat type was accurately measured pre

and post development using AuotCAD software with the habitat distinctiveness and

condition assessed and habitat units lost evaluated. The mitigation hierarchy was used

throughout. Table 3 outlines the SSM biodiversity offset calculations.

Table 3: Biodiversity Offset Calculations (Small Sites Metric JP040, based on Site area of 2,098 sq m)

Headline BNG Targets Met Trading Rules Trading Rules Satisfied

Detailed Results

Baseline value Habitat units 0.2745 Hedgerow units Zero Units Baseline River units Zero Units Baseline

Post development value Habitat Units 0.3025

Hedgerow Units 0.5791 River Units 0.0000

Net gain targets Habitat Units 0.3019


Total net unit change Habitat Units 0.0280


Total net % change: Including all on-site and off-site habitat creation and retained habitats

Habitat Units 10.22 % Hedgerow Units % target not appropriate River Units % target not appropriate

6.6 From the information gathered and landscape plans provided, a 10.22 % total net change in

habitat units will occur, which is greater than the suggested 10 %. Provided the proposed

mitigation, compensation and enhancement measures are followed within this report, there

will be some net positive benefit for wildlife in the form of creation of valuable habitats

within a relatively sub-urban location.

Colmer Ecology ltd


7.0 Conclusion

7.1 An EcIA comprising two main elements (Stage 1 and Stage 2) was carried out of land and

buildings at RCHT, West Cornwall Hospital, Penzance, Cornwall, to assess impacts from the

proposed development. Stage 1 was a PEA including a biological desk study, a phase 1

habitat survey with a protected species habitat assessment, a preliminary ground level bat

tree roost assessment and a protected species building assessment. Stage 2 comprised a bat

roost characterisation survey undertaken due to the evidence of, and potential for,

protected species noted during the Stage 1 PEA. In addition, a Biodiversity Net Gain (BNG)

calculation was completed, following the DEFRA Small Sites Metric (SSM) (JP040).

7.2 All habitat types have been mapped, with the Site dominated by hardstanding and buildings,

with the addition of amenity grassland, introduced shrub, intact species poor hedge and

scattered trees. An assessment of site valuation and impact to habitats was undertaken with

suitable mitigation and compensation measures suggested as required.

7.3 In the absence of mitigation measures, the proposed development was considered likely to

have, at worst, long-term, adverse effect at the ‘Site’ level. However, by following the

proposed mitigation and precautionary measure, the development was not considered to

have any significant residual effect to important ecological features within or adjacent to

the Site. Provided the proposed mitigation, compensation and enhancement measures are

followed, the development was considered to be consistent to relevant conservation

legislation, NPPF (2021) and local policies. In addition, an increase above 10 % biodiversity

net gain was calculated.

7.4 The Stage 2 bat roost characterisation survey was conducted between July and August

2021, with no bats observed emerging/re-entering the structure. Due to the number of bats

(a single bat observed roosting in situ during Stage 1), and no subsequent bat emergence/re-

entry during Stage 2, the Site was considered to be an infrequent day, non-breeding roost

for singleton/low numbers of common pipistrelle bats. The development works will result

in the loss/alteration/blocking access of the roosts, the potential to kill/injure bats during

some of the works as well as disturbance, and therefore, an EPSL was considered

necessary.

7.5 Mitigation and compensation measures for the loss/alteration of the bat roost was

proposed, which, if followed would ensure that the favourable conservation status is

maintained for this bat species and the continued ecological functionality of its roost. An

EPSL will be necessary, which is applied for and granted by Natural England, once

planning permission has been approved. Construction work must proceed in accordance

with terms and details outlined in any EPSL method statement submitted to Natural England,

Colmer Ecology ltd


and any deviation from a granted EPSL would constitute a breach of licence terms and

conditions. No works to the Site/areas where bats were roosting can commence until an

EPSL is in place.

7.6 As evidence of breeding birds was noted on Site, suitable mitigation, compensation

measures and enhancements were recommended and will be adopted during the

development works.

7.7 Additional ecological mitigation and enhancements at the Site level were proposed where

necessary.

7.8 This report is valid for a period of 12 months from the date of the last survey.

Colmer Ecology ltd


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Andrews, H. et al., 2016. Bat Tree Habitat Key (3rd Edition). AEcol, Bridgwater. Available from:

http://battreehabitatkey.co.uk/?page_id=43

Andrews, H. and Pearson, L., 2017. A review of empirical data in respect of emergence and return

times reported for the UK’s 17 native bat species. Unpublished report.

Barataud, M., 2012. Écologie acoustique des chiroptères d’Europe. Identification des espèces, étude

de leurs habitats et comportements de chasse. Biotope Éditions – Publications Scientifiques du

Muséum. 344pp.

Bat Conservation Trust (BCT), 2006. Bat Call Library.

British Standards Institution (BSI), 2012. Trees in Relation to Design, Demolition and Construction.

London, UK.

British Standards Institution (BSI) BS42020:2013, 2013. Biodiversity – Code of Practice for Planning

and Development. London, UK.

Chartered Institute of Ecology and Environmental Management, 2017a. Guidelines for Ecological

Report Writing (2nd edn). Chartered Institute of Ecology and Environmental Management,

Winchester.

Chartered Institute of Ecology and Environmental Management, 2017b. Guidelines for Preliminary

Ecological Appraisal (2nd edn). Chartered Institute of Ecology and Environmental Management,

Winchester.

Chartered Institute of Ecology and Environmental Management (2018) Guidelines for Ecological

Impact Assessment in the UK and Ireland, 2018 (version 1.1 updated in 2019).

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

The Bat Conservation Trust, London.

Cornwall Local Development Framework. 2012. St Austell, St Blazey and China Clay Area

Regeneration Plan.

Day, J., Mayer, E. and Newell, D. 2019. The swift – a bird you need to help. In Practice, June 2019,

Issue 104. CIEEM.

Colmer Ecology ltd


Defra and Environment Agency, 2016. Pollution prevention for businesses. Available at:

https://www.gov.uk/guidance/pollution-prevention-for-businesses#construction-inspection-

and-maintenance.

Eaton, M. A., Aebischer. N.J., Brown, A. F., Hearn. R. D., Lock, L., Musgrove, A. J., Noble, D. G., Stroud,

D. A. and Gregory, R.D. (2015) Birds of Conservation Concern 4: the population status of birds in

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Edwards, J., Knight, M., Taylor, S. and Crosher, I., E., 2020. Habitat Networks Maps, Use Guidance

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Gilbert, G., Gibbons, D. and Evans, J., 1998. Bird Monitoring Method. A manual of techniques for

key UK species. The Royal Society for the Protection of Birds.464 pp.

Gunnell, K., Murphy, B., and Williams, C., 2013. Designing for biodiversity: A technical guide for new

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Institution of Lighting Professionals and Bat Conservation Trust, 2018. Guidance note 08/18 Bats

and Artificial Lighting in the UK.

Joint Nature Conservation Committee. (JNCC). 2010. Handbook for Phase 1 Habitat Survey. A

technique for Environmental Audit. JNCC, Peterborough, UK.

Middleton, N., Froud, A. & French, K., 2014. Social Calls of the Bats of Britain and Ireland. Exeter:

Pelagic Publishing. 176pp.

Natural England, 2017. Natural England Standard – Habitat Regulations Assessment (HRA) Standard.

ODPM Circular 06/2005, 2005. Biodiversity and geological conservation - statutory obligations and

their impact within the planning system.

Russ, J., 2012. British Bat Calls: A guide to Species Identification. Exeter: Pelagic Publishing. 192pp.

Stace, C., 1997. New Flora of the British Isles. 2nd Edition. Cambridge University Press.

Sterry, P., 2006. Collins Complete Guide to British Wildflowers. Harper Collins Publishers Ltd.

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Sterry, P., 2007. Collins Complete British Trees. Harper Collins Publishers Ltd.

Websites:

Actin for Swifts. http://actionforswifts.blogspot.com

Cornwall Council Interactive map: https://map.cornwall.gov.uk/website/ccmap/

MagicMap. www.magic.defra.gov.uk

Natural England. https://designatedsites.naturalengland.org.uk

Natural England, 2015. https://www.gov.uk/guidance/hazel-or-common-dormice-surveys-and-

mitigation-for-development-projects

NPPF, 2021.

https://www.gov.uk/government/publications/national-planning-policy-framework--2

Swift Conservation. https://www.swift-conservation.org

The Small Sites Metric (JP040): http://nepubprod.appspot.com/publication/6047259574927360

Figures

Figu

re 2: An

no

tated p

ho

tog

raph

s –in

ternal an

d extern

al (18th

May 20

21)

Fron

t elevation

of th

e cottag

es –n

ote b

ord

ered

win

do

ws w

ith co

mm

on

pip

istrelle roo

sting

beh

ind

h

igh

ligh

ted w

ind

ow

Rear view

of co

ttages, taken

from

main

ho

spital carp

ark

Terrace co

ttage lo

ft interio

r, with

intern

al chim

neystack

divid

ing

adjacen

t cottag

esExam

ple o

f derelict co

ttage in

terior –

no

te, no

evid

ence o

f bats w

as no

tedC

om

mo

n p

ipistrelle fo

un

d in

situ, ro

ostin

g in

the cavity

beh

ind

bo

arded

win

do

ws

Examp

le of am

enity g

rassland

and

scattered tree h

abitats

X

Figu

re 3: Eviden

ce of b

ats and

bird

s no

ted in

ternally an

d extern

ally

No

rth

Co

mm

on

pip

istrelle fou

nd

in situ

(beh

ind

win

do

w)

Leg

en

dCh

imn

eystacks

X

XA

ctive herrin

g g

ull n

est

X

Figu

re 4: Em

ergen

ce survey –

1stJu

ly 2021

No

rth

Leg

en

dSurveyo

r locatio

n

Ch

imn

eystack

Figu

re 5: Emerg

ence su

rvey –1stA

ug

ust 20

21

No

rth

Leg

en

dSurveyo

r locatio

n

Ch

imn

eystack

Figu

re 6: Em

ergen

ce survey –

19th

Au

gu

st 2021

No

rth

Leg

en

dSurveyo

r locatio

n

Ch

imn

eystack

Figu

re 7: Mitig

ation

, com

pen

sation

and

enh

ancem

ents –

bat an

d sw

ift

Bat m

itigatio

n/co

mp

ensatio

n:Sch

weg

ler 1FQ (o

r similar) b

at b

ox fitted

externally, at th

e sou

thern

elevation

of th

e existing

h

osp

ital, away fro

m w

ind

ow

s. Th

is is mitig

ation

/com

pen

sation

fo

r the lo

ss of th

e bat ro

ost w

ithin

the co

ttages.

Swift b

oxes:Lo

cation

of extern

al OR

retrofitted

swift b

ox

enh

ancem

ents.

Appendices

Appendix 1

Ap

pen

dix 1 - List o

f Ind

ictive Faun

a and

Flora Latin

Nam

es

Faun

aFlo

ra

Ad

der

Vip

era berus

Bin

dw

eedC

alystegia sepium

Go

ose g

rassG

alium ap

arine

Bad

ger

Meles m

elesB

ird's-fo

ot-trefo

ilLo

tus corn

iculatusG

reater bird

s-foo

t trefoil

Lotus p

edun

cuulatusB

arbastelle

Barb

astella barb

astellusB

lacktho

rnP

runus sp

ino

saG

reater bu

rdo

ckA

rctium lap

pa

Bech

steinM

yotis b

echstein

iB

lueb

ellH

yacinth

oid

es no

n-scrip

taG

rou

nd

ivyG

lecho

ma h

ederacea

Bran

dt

Myo

tis bran

dtii

Bo

rage

Bo

rago o

fficinalis

Gu

ilder ro

seV

iburn

um o

pulus

Bro

wn

lon

g-eared

Pleco

tus auritusB

rackenP

teridium

aquilin

umH

art's ton

gu

e fernA

splen

ium sco

lop

end

riumC

om

mo

n fro

gR

ana tem

po

rariaB

ramb

leR

ubus frutico

sus sp. agg.

Haw

kbit

Leon

tod

on

sp.

Co

mm

on

lizardZ

oo

toca vivip

araB

ug

leA

juga reptan

sH

awth

orn

Crataegus m

on

ogyn

aC

om

mo

n p

ipistrelle

Pip

istrellus pip

istrellusB

uttercu

pR

anun

culus spH

azelC

orylus avellan

aC

om

mo

n to

adB

ufo b

ufoB

utterfly b

ush

Bud

dleja d

avidii

Hem

lock w

ater-dro

pw

ort

Oen

anth

e crocata

Dau

ben

ton

Myo

tis daub

ento

nii

Cam

om

ileM

atricaria cham

om

illaH

emp

-agrim

on

yEup

atorium

cann

abin

umD

orm

ou

seM

uscardin

us avellanarius

Can

adian

po

nd

weed

Elod

ea canad

ensis

Herb

Ro

bert

Geran

ium ro

bertian

umG

rass snake

Nartix n

atrixC

hickw

eedStellaria m

edia

Him

alayan b

alsamIm

patien

s gland

uliferaG

reat crested n

ewt

Triturus cristatusC

leaversG

alium ap

arine

Ho

gw

eedH

eracleum sp

ho

nd

yliumG

reater ho

rsesho

eR

hin

olo

ph

us ferrumeq

uinum

Clo

ver species

Trifolium

H

olly

Ilex aquifo

liumG

rey lon

g-eared

Pleco

tu austriacusC

ob

nu

tC

orylus sp

eciesH

on

eysuckle

Lon

icera periclym

enum

LeislerN

yctalus leisleriC

ock's-fo

ot

Dactylis glo

merata

Ho

rse chestn

ut

Aesculus x carn

eaLesser h

orsesh

oe

Rh

ino

lop

hus h

ipp

osid

eros

Co

mfrey

Symp

hytum

officin

aleIvy

Hed

era helix

Nath

usiu

s pip

istrelleP

ipistrellus n

athusii

Co

mm

on

chickw

eedStellaria m

edia

Japan

ese kno

tweed

Fallop

ia japo

nica

Natterer

Myo

tis nattereri

Co

mm

on

marsh

-bed

strawG

alium p

alustreLau

rel Lauraceae

No

ctule

Nyctalus n

octula

Co

mm

on

nettle

Urtica d

ioica

Lavend

erLavan

dula o

fficinalis

Otter

Lutra lutraC

om

mo

n so

rrelR

umex aceto

saLesser b

ulru

shTyp

ha an

gustifolia

Palm

ate new

tTriturus h

elveticusC

om

mo

n vio

letV

iola rivin

iana

Leyland

cypress

Leyland

ii spSero

tine

Eptesin

us serotin

usC

oto

neaster

Co

ton

easter spLim

e Tilia sp

.Slo

w w

orm

An

guis fragilisC

otto

ng

rassErio

ph

orum

angustifo

liumM

arch m

arigo

ldC

altha p

alustrisSm

oo

th n

ewt

Triturus vulgarisC

ow

parsley

An

thriscus sylvestris

Mead

ow

bu

ttercup

Ran

unculus acris

Sop

rano

pip

strelleP

ipistrelly p

ygmaeus

Creep

ing

ben

tA

grostis sto

lon

iferaM

eado

w fescu

eFestuca p

ratensis

Water vo

leA

rvicola am

ph

ibius

Creep

ing

bu

ttercup

Ran

unculus rep

ens

Mead

ow

foxtail

Alo

pecurus p

ratensis

Wh

iskeredM

yotis m

ystacinus

Crested

Do

gstail

Cyn

osurus cristatus

Mead

ow

sweet

Filipen

dula ulm

ariaD

aisyB

ellis peren

nis

Navelw

ort

Um

bilicus rup

estrisFlo

raD

and

elion

Taraxacum o

fficinale agg.

New

Zealan

d p

igm

y weed

Crassula h

elmsii

Do

ck spR

umex sp

Oxeye d

aisyLeucan

them

um vulgare

Ag

rimo

ny

Agrim

on

ia spD

og

rose

Ro

sa canin

aP

edu

ncu

late oak

Quercus ro

bur

Ald

erA

lnus glutin

osa

Do

g's m

ercury

Mercurialis p

erenn

isP

erenn

ial rye-grass

Lolium

peren

ne

An

nu

al mead

ow

-grass

Po

a ann

uaEld

erSam

bucus n

igraP

eriwin

kleV

inca sp

.A

pp

leM

alus do

mestica

ElmU

lmus m

ino

r var. vulgarisP

ine

Pin

us species

Ash

Fraxinus excelsio

rField

bin

dw

eedC

on

volvulus arven

sisP

on

d w

eedP

otam

ogeto

nA

spen

Po

pulus trem

ulaField

map

leA

cer camp

estreP

op

lar speceis

Po

pulus sp

Bay lau

relLaurel n

ob

ilisFo

rget-m

e-no

tM

yoso

tis scorp

ioid

esP

op

py

Pap

aver species

Beech

Fagus sylvaticaFo

xglo

veD

igitalis purp

ureaP

rivetLigustrum

spB

ell heath

erErica cin

ereaG

erman

der sp

eedw

ellV

eron

ica cham

aedrys

Pu

rple lo

osestrife

Lythrum

salicaria

Rag

wo

rtSen

ecio jaco

bae

Red

camp

ion

Silene d

ioica

Red

clover

Trifolium

praten

seR

eed can

ary grass

Ph

alaris arund

inacea

Reed

sweet g

rassG

lyceria maxim

aR

ibw

ort p

lantain

Plan

tago lan

ceolata

Ro

semary

Ro

smarin

us officin

alisR

ou

gh

haw

kbit

Leon

tod

on

hisp

idus

Ro

ug

h m

eado

wg

rassP

oa trivialis

Ru

ssian vin

eFallo

pia b

auldsch

uanica

Silver birch

Betula p

end

ulaSilverw

eedP

oten

tilla anserin

aSo

ft rush

Juncus effusus

Stinkin

g iris

Iris foetid

issima

Spin

dle

Euon

ymus euro

paeus

Sum

acR

hus sp

.Sycam

ore

Acer p

seudo

platan

usT

easel spD

ipsacus sp

Th

istle spC

irsium sp

Tim

oth

yP

hleum

praten

seW

alnu

tJuglan

s regiaW

ater crow

foo

tR

anun

culus aquatilis

Water fo

rget-m

e-no

tM

yoso

tis scorp

iod

esW

ater min

tM

enta aq

uaticaW

ater plan

tainA

lisma p

lantago

-aquatica

Wayfarin

g-tree

Vib

urnum

lantan

a W

hite cam

pio

nSilen

e latifolia

Wh

ite clover

Trifolium

repen

sW

hite d

eadn

ettleLam

ium alb

umW

hite m

elilot

Melilo

tus albus

Wild

geran

ium

sG

eranium

maculatum

Willo

w h

erbEp

ilob

ium sp

eciesW

illow

species

Salix species

Wo

od

sorrel

Oxalis aceto

sellaW

oo

d sp

urg

eEup

ho

rbia am

ygdalo

ides

Wo

od

mellick

Melica un

iflora

Wo

un

dw

orts

Stachys sp

eciesW

ych elm

Ulm

us glabra

Yarro

wA

chillea m

illefolium

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Kier Construction Limited October 2021