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Phase 1 Habitat Survey and Bat Roost Potential Survey of The Former Rossendale Hospital, Rawtenstall, Lancashire on behalf of Taylor Wimpey Manchester October 2011 © James Blake Associates 2011

Phase 1 Habitat Survey and Bat Roost Potential Survey · Phase 1 Habitat Survey 2.4 A Phase 1 Habitat Survey was undertaken by Odette Robson BSc (Hons) PhD MIEEM (great crested newt

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Page 1: Phase 1 Habitat Survey and Bat Roost Potential Survey · Phase 1 Habitat Survey 2.4 A Phase 1 Habitat Survey was undertaken by Odette Robson BSc (Hons) PhD MIEEM (great crested newt

Phase 1 Habitat Survey and Bat

Roost Potential Survey

of

The Former Rossendale Hospital,

Rawtenstall, Lancashire

on behalf of

Taylor Wimpey Manchester

October 2011

© James Blake Associates 2011

Page 2: Phase 1 Habitat Survey and Bat Roost Potential Survey · Phase 1 Habitat Survey 2.4 A Phase 1 Habitat Survey was undertaken by Odette Robson BSc (Hons) PhD MIEEM (great crested newt

Former Rossendale Hospital Phase 1 Habitat Survey

2 JBA 11/263 October 2011

Revision Purpose Originated Checked Authorised Date

AO OR OR/RH 10/2011

Job Number: JBA 11/263

Title: Phase 1 Habitat Survey and Bat Roost

Potential Survey of the former Rossendale

Hospital, Lancashire

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CONTENTS

0 EXECUTIVE SUMMARY ....................................................................................................4

1 INTRODUCTION ................................................................................................................5

2 METHODS ..........................................................................................................................7

Desk study ................................................................................................................................7

Phase 1 Habitat Survey ...........................................................................................................7

3 RESULTS ...........................................................................................................................9

4 KEY RECOMMENDATIONS, FURTHER SURVEYS AND PRECAUTIONARY

METHODS ........................................................................................................................46

5 ENHANCEMENT (ADDITIONAL) RECOMMENDATIONS.............................................46

6 CONCLUSION ..................................................................................................................47

7 REFERENCES .................................................................................................................48

8 APPENDICES...................................................................................................................50

Appendix A: Phase 1 habitat map .........................................................................................50

Appendix B: Site plan showing building Target Note number locations ...............................51

Appendix C: Plant species list................................................................................................52

Appendix D: Relevant protected species legislation .............................................................54

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0 Executive Summary

0.1 A Phase 1 Habitat Survey and Bat Roost Potential Survey were carried out at the

former Rossendale Hospital in Lancashire on the 29th September 2011.

0.2 The site was dominated by derelict hospital buildings, associated infrastructure,

woodland, small areas of coarse (former amenity) grassland, and scattered trees

and shrubs.

0.3 Further survey is recommended to assess bat activity on the site.

0.4 The site had limited potential to support other protected, BAP or rare species. No

further survey is recommended but precautionary measures should be followed

to minimise any potential risk of harm to any such species which may be present

on the site.

0.5 Tree, hedgerow or ground clearance should be carried out outside the main bird

breeding season (March until end of August) or under ecological supervision.

0.6 It was considered that by following the key recommendations outlined in this

report, the development can proceed with minimal risk of harm to protected, BAP

or rare species or to local nature conservation.

0.7 By following some, or all, of the enhancement recommendations, it was

considered that the site could be improved for local wildlife, post development.

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1 Introduction

Background

1.1 James Blake Associates were commissioned by Taylor Wimpey Manchester to

undertake a Phase 1 Habitat Survey, and Bat Roost Potential Inspection at the

former Rossendale Hospital in Lancashire. Grid ref: SD 796 225 (taken from the

centre of the site).

1.2 The survey was required to accompany a planning application to develop the site.

The proposed development includes detached and semi-detached residential houses

with associated infrastructure and landscaping.

1.3 Wildlife, such as nesting birds and bats are protected species. All protected and

Biodiversity Action Plan (BAP) species are material considerations for individual

planning decisions under PPS9 (Planning Policy Statement 9) (ODPM, 1994).

Site Description

1.4 The site was located at the former Rossendale Hospital in Lancashire. The site was

surrounded by existing residential areas to the east and west, the A681 Haslingden

Road to the south (beyond which lay All Saints High School and a small reservoir),

and rough grazing/moorland to the north and west (see Figure 1 below).

1.5 The site itself could broadly be separated into two dominant areas: The former

hospital buildings and infrastructure in the north-western half of the site; and mixed

woodland in the south-eastern half. There were smaller areas of amenity and coarse

grassland, ruderal vegetation, scrub, hedgerows and individual trees and shrubs

which were scattered throughout the site.

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Figure 1. Site location: Former Rossendale Hospital

Reproduced from Ordnance Survey map data by permission of Ordnance Survey, ©

Crown copyright.

Aims and objectives

1.6 The aim of the survey was to:

• Identify the presence or likely presence of any protected or notable species

or habitats on or adjacent to the site;

• Assess the potential impact of the proposed works on any protected or

notable species and/or habitats present including nature conservation sites

on or adjacent to the site;

• Make any recommendations for further surveys and/or mitigation following

the survey (if necessary) and provide suggestions to enhance the wildlife

value of the site post-development;

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2 Methods

Desk study

2.1 A 2km radius search for statutory designated sites, either on the proposed

development site or in the surrounding area, was conducted using “MAGIC”, the

Multi-Agency Geographic Information system for the Countryside.

2.2 The National Biodiversity Network (NBN) website was accessed on the 4th October

2011 to obtain records of protected, BAP or rare species on and around the site.

2.3 The site is covered by the Local Biodiversity Action Plan for Lancashire.

Phase 1 Habitat Survey

2.4 A Phase 1 Habitat Survey was undertaken by Odette Robson BSc (Hons) PhD

MIEEM (great crested newt licence number 20113048; bat licence number

20112704) on the 29th of September 2011. During the survey, the temperature was

14°C; there was a light wind (Beaufort scale 0-1), 60% cloud cover and good

visibility.

2.5 The survey methodology followed JNCC (Joint Nature Conservation Committee)

Guidelines (JNCC, 2007) and included mapping habitat types and identifying all plant

species observed on the site, including Wildlife and Countryside Act Schedule 9

invasive plant species, such as Japanese Knotweed Fallopia japonica and Giant

Hogweed Heracleum mantegazzianum.

2.6 The site was also assessed for signs and evidence of protected, BAP and rare

species in accordance with Natural England Guidelines, as follows:

2.7 Bats: Mature trees within the site boundary, and adjacent to the site boundary, were

surveyed externally, from the ground, for their potential to support roosting bats,

under the following criteria:

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Table 1: Bat survey protocol for trees (Potential bat roosting opportunities were identified in order to categorise trees, as below):

Bat Roost Potential Field Signs

Confirmed roost Confirmed bat roost in tree: Field evidence of the

past or current presence of bats, e.g. droppings,

staining.

High roost potential

Splits or cracks in major limbs which develop

upwards, smooth surface around entry point,

dense ivy-covering, woodpecker/rot holes,

significant lifting bark, artificial bird or bat boxes.

Ancient or over mature trees where the canopy

cannot be fully inspected from the ground.

Medium roost potential Splits in branches, dense ivy-covering, small

cavities, dense epicormic growth, flies around

entry point.

Low roost potential

Splits in minor branches, sparse ivy, and limited

loose bark.

Young, healthy tree with good visibility to the top

of the canopy.

No roost potential Trees with a negligible potential to support bat

roosts (not supporting any of the above

features).

2.8 Bat Survey Protocol for buildings: all buildings where access was possible were

inspected externally and internally for signs or evidence of past or present usage by

roosting bats. Some buildings were not accessed due to being boarded up or where

asbestos made access unsafe. Roof voids and cellars – where present - were

accessed in most buildings. Binoculars were used to assess buildings externally for

entry points such as cracks or holes, plus evidence of bat activity such as staining,

droppings, feeding remains (such as butterfly or moth wings) that could indicate past

presence of bats

2.9 Dormice: A visual survey for the presence of suitable habitat (broad leaved or mixed

woodland with good under-storey/shrub layer and a range of food plant species,

such as hazel, bramble and honeysuckle) was carried out, to assess if dormice were

likely to be present.

2.10 Reptiles: A visual survey for the presence of suitable habitat was carried out

according to the criteria given in the Reptile Mitigation Guidelines (Natural England

2011).

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2.11 Invertebrates: The site was scoped for significant rotting deadwood, and high

quality aquatic or other habitats which could be used by significant assemblages of

invertebrates, or by any of the invertebrates highlighted in the data search.

2.12 Badgers: A visual survey for setts, hair, latrines, prints, snuffle marks or other signs

of badgers was undertaken within the site boundary.

2.13 Flora and habitats: All habitats and plant species which were identifiable at the time

of the survey were recorded. Habitats adjacent to the site were identified, using

aerial maps and field observation, so that the ecological impact of the proposed

works on the wider landscape could be assessed.

3 Results

Desk Study

Statutory Nature Conservation Sites

3.1 There were three statutory designated areas within 2km of the site: These were

areas of Moorland Line. The Moorland Line encloses land within England which has

been defined as predominantly semi-natural upland vegetation, or predominantly of

rock outcrops and semi-natural vegetation, used primarily for rough grazing. These

are detailed in Table 1 and shown in Figure 2.

Table 2: Statutory conservation sites within 2km of the site

Site Name Designation Distance from the site

Description

Dearden Moor Moorland Line 1.8km south-

east Predominantly semi-natural upland vegetation, or predominantly of rock outcrops and semi-natural vegetation,

used primarily for rough grazing. N/A Moorland Line 1.5km north

N/A Moorland Line 1km north- east

Non-Statutory Nature Conservation Sites

3.2 There were no known non-statutory designated sites within 2km of the site.

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Figure 2: Statutory conservation sites within 2km of the site

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Habitat types within 2km

3.3 Habitat types within the area included a number of plantation woodlands, areas of

lowland meadow and blanket bog. The nearest woodlands (outside the site

boundary) were located approximately 100m to the south and east of the site. The

nearest lowland meadows were approximately 1.8km to the north-east and the

nearest area of blanket bog was approximately 1.9km to the north.

Figure 3: Habitat types within 2 km

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Protected, BAP and Rare Species

3.4 The Birds of Conservation Concern (BoCC) are split into three criteria. The red list is

the highest conservation priority (species needing urgent action). The amber list is

the next most critical group, followed by green. Red listed species are those that are

globally threatened according to IUCN criteria, species with populations or ranges

that have declined rapidly in recent years, and those that have declined historically

and have not shown a substantial recent recovery.

3.5 A search of species records held by the NBN highlighted numerous records of

protected, BAP and notable flora and fauna within 2km of the site. The site is within

the area covered by the Lancashire local BAP.

3.6 Full lists of UK and Local BAP and protected amphibians, reptiles and mammals are

shown below. A reduced list of UK and Local BAP and protected birds, flora and

invertebrates is shown; these have been selected based on their likelihood of being

recorded at the site given the habitats types present.

Table 3: Mammal records within 2 km of the site

Mammals Protection Approximate

distance from site

Year of

Record

Badger Protection of Badgers Act 10km south 2007

Brown hare UK and local BAP Same 10km square as

the site 2006

Brown long eared bat European protected, UK

and local BAP Same 10km square as

the site 2007

Common pipistrelle European protected, local

BAP

0.4km north west

0.5km north east 2006

Daubenton’s Bat European protected, local

BAP 5km south 2010

Hedgehog UK BAP Same 10km square as

the site 1978

Leisler’s bat European protected, local

BAP 9km south west 2006

Natterer’s bat European protected, local

BAP Same 10km square as

the site 2011

Noctule bat European protected, UK

and local BAP 9km south west 2006

Red squirrel UK and local BAP 6km north west 2008

Soprano pipistrelle European protected, UK

and local BAP 0.4km north 2006

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Water vole UK and local BAP Same 10km square as

the site 2001

Whiskered / Brandt’s bat European protected, local

BAP Same 10km square as

the site 2011

Table 4: Bird records within 2 km of the site

Birds Protection Approximate

distance from site

Year of

Record

Barn Owl WCA Schedule 1 Same 10km square as

the site 1988-1991

Cuckoo BoCC Red list, UK BAP Same 10km square as

the site

Between

1988-1991

Grasshopper warbler BoCC Red list, UK BAP Same 2km square as

the site

Between

2004-2009

Curlew BoCC Amber list, UK BAP Same 2km square as

the site

Between

2002-2007

Dunlin BoCC Red list Same 10 km square

as the site 1988-1991

Starling BoCC Red list 0.9km south

0.3km east

2008

2009

Fieldfare BoCC Red list 5.5km north east 2009

Tree sparrow BoCC Red list, UK BAP 4km north west 1990

Grey Partridge BoCC Red list, UK BAP Same 2km square as

the site

Between

2002-2007

House sparrow BoCC Red list, UK BAP 500m south-east,

0.8km south west 2008

Northern Lapwing BoCC Red list, UK and

local BAP

Same 2km square as

the site 1999

Ring Ouzel BoCC Red list, UK BAP 2km south west 1997

Redwing BoCC Red list Same 10 km square

as the site 1981-1984

Song Thrush BoCC Red list, UK and

local BAP 1.4km south 2009

Skylark BoCC Red list, UK and

local BAP

Same 10 km square

as the site 1988-1991

Barn swallow BoCC Amber list Same 10 km square

as the site 1988-1991

Spotted flycatcher BoCC Red list, UK BAP Same 2km square as

the site

Between

2004-2009

Tree pipit BoCC Red list, UK BAP 2km west Between

2004-2009

Wood warbler BoCC Red list, UK BAP 4km west Between

2004-2009

Yellowhammer BoCC Red list, UK BAP Same 10km square as

the site

Between

1968-1972

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Table 5: Plant records within 2 km of the site

Table 6: Invertebrate records with 2 km of the site

Invertebrates Protection Approximate

distance from site

Year of

Record

Wall butterfly UK BAP Same 2km square as

the site Between 1690-2004

Small heath UK BAP Same 2km square as

the site Between 1690-2004

Cinnabar UK BAP Within 3km south 2007

Table 7: Amphibian records within 2 km of the site

Amphibians Protection Approximate

distance from site

Year of

Record

Toad UK BAP Same 10km square as

the site 2005

Great crested newt European protected, UK

and local BAP;

7.5km south,

same 10km square as the site

1985,

1968

Table 8: Reptile records within 2 km of the site

WCA = Wildlife and Countryside Act 1981 as amended; UK BAP = UK Biodiversity Action Plan; LBAP = Local

Biodiversity Action Plan; NBAP – National BAP; BoCC = Birds of Conservation Concern

Plants British Red Data List

Category

Approximate

distance from site

Year of

Record

Birds nest

(Monotropa hypopitys) Endangered, UK BAP

Same 10km square as

the site

Between

1987-1999

Caraway

(Carum carvi) Endangered, UK BAP

Same 10km square as

the site 1964

Red star thistle

(Centaurea calcitrapa)

Critically endangered, UK

BAP

Same 10km square as

the site

Between

1950-1999

Pennyroyal

(Mentha pulegium) Endangered, UK BAP

Same 10km square as

the site

Between

1950-1999

Stinking goosefoot

(Chenopodium vulvaria) Endangered, UK BAP

Same 10km square as

the site

Between

1950-1999

Reptiles Protection Approximate

distance from site Year of Record

Slow worm Partially protected under the WCA Schedule 5

3.2km east 1968

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Phase 1 Habitat Survey

3.7 Appendix A shows a Phase 1 habitat map of the site, with Target Notes. A list of

plant species identified on the site is included in Appendix C. Appendix B shows a

plan of the site, with Target Notes associated with the buildings and man-made

structures on the site that were assessed for bat roosting potential.

Limitations and Assumptions

3.8 The baseline conditions reported and assessed in this document represent those

identified at the time of the survey. The full plant species list (Appendix C) was based

on the current site visit. The survey was conducted in September, which is an

optimal time for Phase 1 surveys. All areas of the site were accessible on the day of

the survey.

Target Notes (Buildings)

3.9 The following Target Notes are associated with the numerous disused buildings on

the site (see Appendix B for locations). The plan in Appendix B was originally

produced by the East Lancashire Hospitals NHS Trust in 1996. The buildings in the

following Target Note descriptions are numbered and named to correspond with the

plan. It should be noted that not all of the buildings could be accessed internally

during the survey due to access or health and/or safety issues.

Building 1

Brynbella Suite OPD

A two-storey brick building with a flat roof. Externally, the structure was well-sealed

with no gaps recorded in the brickwork or around the window and door frames.

Internally, the roof contained a void created by a suspended ceiling. Some ceiling

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tiles were missing which allowed the void to be inspected for bat roost potential

(BRP). The building was considered to have no BRP.

Building 2

Medical Gas Store

A single-storey storage building constructed of stone. It had a flat, felt roof with

timber fascias which were partially rotten. There were also ventilation grilles in the

side walls which could potentially provide internal access for bats. The building could

not be accessed at the time of the survey, though potential for use by bats was

considered to be low.

Building 3

Wards 1 and 2, Hospice, X-Ray, Pharmacy, Offices

A three-storey stone building with a pitched roof which was finished with slates.

Externally, the building was well-sealed with no gaps recorded in the stonework and

limited slate damage. Lower window frames were boarded which could provide

limited opportunities for small numbers of crevice-roosting species, such as

pipistrelles. The loft space was accessed internally and was totally dark – indicating

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no bat access possibilities into the main void. The length of the roof was sectioned

by internal fire break doors. The roof was lined with sarking boards which could

provide roosting opportunities underneath the external slates.

Building 5

Operating Theatre

A single-storey, brick built structure with a lead covered roof. The building was well-

sealed and no access points that could be used by bats.

Building 6 & 7

Wards 3 and 4 and Medical Records

A three-storey building of similar construction to Building 3. Internally, the roof was

timber lined and lagged. Externally, the structure was well-sealed, although a couple

of access points were recorded under the eaves which could be used by roosting

bats. Boarded windows provided potential for occasional crevice-roosting species,

though no opportunities for more significant roosts were noted.

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Building 10

Physiotherapy and Elderly Day Unit

A more modern, brick built structure with a hipped roof, finished with slates.

Access to the building was not available at the time of the survey, though there

were limited potential but access points noted externally.

Building 11

General and Other Stores

Stone built structures with pitched roofs, finished with slates. Grills to the rear

provided access for bats. Boundary dry-stone walls held gaps suitable for

roosting bats. The emergency generator had a roof void which was partially

damaged. This series of buildings were partially voided, though no access was

available. Felt lining would provide crevice-roosting opportunities, though the

slates were tight-fitting and access was limited.

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Building 13

Garage and General Store

Single-storey building constructed from bricks and stone. The roof was pitched

and tiled with no lining. The northern half of the building had a suspended ceiling

and was partially lined with plaster-board. There were very high levels of bird

activity, mainly from swallows which were likely to have nested this year, within

the structure.

Building 14

Visitors Toilets

Single-storey stone structure with a pitched roof finished with slates. Internally,

the roof was timber lined.

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Building 15

Electrical Sub-Station

Single-storey stone building with a hipped slate roof and vented ridge tiles. The

small, flat-roofed extension (brick with rendering) had a well-sealed flat felt roof

and wooden fascias.

Building 16

Administration

A two-storey, stone built structure with a pitched roof finished with well-sealed

slates. The lower level windows were boarded providing potential roosting

opportunities. Access was available into the underground heating ducts which

were potentially suitable and accessible for hibernating bats: no signs of bats

were found, though the whole network could not be accessed. There were also

access points under the eaves and between a few lifted slates. Internally, the

roof space was mainly unlined and open: Though access for bats was possible

under the eaves, no signs of past or present use by bats were found. One part of

the roof could not be accessed due to a false ceiling.

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Building 17

Bus Shelter – No BRP

Building 18

Doctors House – Staff Accommodation

Two-storey, brick built house with a well-sealed tiled roof. The lower level

windows were boarded. The structure was generally well-sealed. No internal

access was available at the time of the survey. Small gaps at the gable ends may

have provided access to the roof void.

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Building 19

Salt Store

Walled structure with no roof. The store was full of assorted waste and debris

Building 20

Mortuary

Stone built structure with a hipped slate roof. The building was well-sealed with a

small roof void. Access was available through a small loft hatch to the loft space,

which was low, dusty and cluttered. No signs of bats and limited BRP.

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Building 21

Estates Department Store

Brick built structure with a flat roof. No access points for bats.

Building 22

Visitors Toilets

Brick built toilet block with a pitched roof finished with tiles. Internally, the roof

was lined with sarking felt. No signs of bats with a clean, loft space: Fully

accessible during the survey.

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Building 23

Estates Maintenance Workshops

A single-storey, slate roofed building constructed from stone. The doorways to

the front had been bricked-up and the windows boarded. Internally, the slate roof

was unlined and open (no roof void). No BRP. The building was light inside die to

skylights.

Building 24

Linen Services, Joiners Workshop

A single-storey, slate roofed building constructed from stone. The walls were

well-sealed. Slate roof was generally well sealed to the front though there were

some lifted and broken tiles – particularly around the broken skylights to the

back. The roof was lined access for bats was possible between the wooden lining

and the slates. Access to the buildings was not available at the time of the

survey.

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Building 26

Garages

Concrete garages in a poor state of repair. Open-fronted with a partially intact

corrugated asbestos roof. No BRP.

Building 27

Boiler House

Internally, the building was very light due to roof windows. Lined roof offered

limited roosting opportunities between the tiles and internal cladding: No roof

void.

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Building 28

Central Kitchen, Staff Dining Room

Stone-built catering building with limited roof voids and a number of false ceilings

which could not be inspected in detail due to access limitations. Boarding to the

lower windows could provide opportunities for roosting pipistrelles. There was

good potential for bats to be able to enter the buildings due to damaged roof and

slates, stripped lead, and ventilation grills on external walls. No droppings or

signs of bats were found.

Building 29

Walkway

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Building 30

Wards 8, 9, 10 and 11

Suspended ceilings – broken in many places and heavily used by pigeons. Large

gaps in roof and broken slates. Access to the loft space was unsafe.

Building 32

Hospice Accommodation Annexe

Stone built building with many missing slates on the damaged roof. Potential

access for bats. The adjoining ‘pre-fab’ building was fully boarded with a flat roof.

Neither building could be accessed for a detailed inspection at the time of the

survey.

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Building 33

Hospice Accommodation

Stone building with a slate roof containing numerous broken tiles. Boarded lower

level windows and doors. The building was not surveyed internally due to

presence of asbestos. However, the cellars were inspected: these could be

accessed by bats through missing external drainage slabs and ventilation bricks.

The cellars had potential to be used by hibernating bats: stone walled with cracks

and crevices suitable for use by bats, high humidity, extensive underground

heating duct network and a series of storage rooms which could provide a variety

of thermal niches. A thorough examination of all accessible areas was

conducted.

Building 34

Gardeners Store

Brick and stone built structure. No roof left. No BRP.

Building 40

Gas Meter House

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Flat roofed stone building. Low BRP

Building 41

Supplies Holding Store

Building 50

Ward 1 Boiler House:

Access was not available on the day of the survey, but the building had low BRP

due to a well-sealed flat roof and no obvious access for bats.

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Target Notes

3.10 The following Target Notes relate to other features within the site boundary such

as vegetated habitats. The Target Note locations are shown on the Phase 1

Habitat plan in Appendix A.

Target Note 1

An area of rough grassland containing Timothy Phleum pratense, Yorkshire fog

Holcus lanatus, ragwort Senecio jacobaea, broad-leaved dock Rumex

obtusifolius, Crocosmia sp., bramble Rubus fruticosus and creeping buttercup

Ranuculus repens. Mammal tracks and scat (likely fox) noted. To the western

boundary there was a shrub border containing Rhododendron sp. and willow

Salix sp. To the east, a mature beech Fagus sylvatica with low-medium BRP and

semi-mature ash Fraxinus excelsior and holly Ilex aquifolium with no BRP.

Target Note 2

Mature ash tree with medium BRP.

Target Note 3

Stone wall along the western site boundary. Well-sealed.

Target Note 4

Pocket of rough grassland with limited potential to provide foraging habitat for

reptiles and small mammals.

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Target Note 5

Line of Acer sp., ash and Poplar Populus sp. trees with low BRP. Rhododendron

sp. hedge to the north.

Target Note 6

Hedge containing beech and occasional crab apple Malus sylvestris and Prunus

sp. Approximately five metres tall. It had previously been managed but not

recently.

Target Note 7

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Shrub border containing Rhododendron sp., redcurrant Ribes rubrum, Rosa sp.,

laurel Prunus laurocerasus, Holly, Lilac sp. and hawthorn Crataegus monogyna.

Crocosmia sp. was also present. The shrub border was very dense to the south

and was unmaintained.

Target Note 8

Mature Acer sp. – lifting bark. Low to medium BRP due to lifting bark, but no

cracks or crevices suitable for significant bat roosts.

Target Note 9

Himalayan balsam Impatiens glandulifera growing between the road and kerb.

Target Note 10

Block of woodland – mainly Scots pine Pinus sylvestris and sycamore Acer

pseudoplatanus with some holly, ash, rowan Sorbus aucuparia, elder Sambucus

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nigra and Rhododendron sp. Ground cover was mainly pine needles with some

male fern Dryopteris filix-mas, nettle Urtica dioica and Ribes sp.

Target Note 11

Railed walkway with concrete steps.

Target Note 12

Stand of Japanese knotweed Fallopia japonica.

Target Note 13

Tarmac area and scattered rubble piles with high ruderal colonisation. Dominated

by Himalayan balsam. Other species include; common knapweed Centaurea

nigra, red bartsia Odontites vernus, mosses, Willowherb Epilobium sp., ribwort

plantain Plantago lanceolata, broad-leaved dock, Yorkshire fog, spear thistle

Cirsium vulgare, daisy, annual meadow grass Poa annua, ragwort, bramble,

cleavers Galium aparine, Fuschia sp., grey willow Salix cinerea, creeping

buttercup and hogweed Heracleum sphondylium.

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Target Note 14

Wet woodland (very damp in places towards the north) – mainly ash, willow salix

sp., hawthorn, birch Betula sp., hazel Corylus avellana, oak Quercus robur, larch

Larix decidua, sycamore, horse chestnut Aesculus hippocastanum, alder Alnus

glutinosa and poplar. Ground flora included creeping buttercup Ranuculus

repens, nettles, mosses, Himalayan balsam, Ribes sp. and enchanters

nightshade Circaea lutetiana. No trees with BRP were recorded.

Target Note 15

Horse chestnut and sycamore dominant to the far eastern boundary. One horse

chestnut had a split trunk creating a cavity which had low potential to be used by

bats (open to the elements).

Target Note 16

Mature sycamore/maples – medium BRP for individual roosting bats due to lifting

bark.

Target Note 17

Horse chestnut and ash with medium BRP.

Target Note 18

Steep slope with some mature trees, mainly sycamore, horse chestnut, ash and

maple. Dense laurel to the west with Rhododendron sp., raspberry Rubus

idaeus, Ribes sp. nettles and ash.

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Target Note 19

Small stand (5m x 5m) of Japanese knotweed on made-up ground.

Target Note 20

Access track – lined with mature ash, sycamore and lime Tillia sp. Some

contained cavities, rot holes and other features which could support roosting

bats. Medium to high BRP.

Target Note 21

Raised garden – heavily choked with bramble.

Target Note 22

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Disused holes – potentially badger due to significant earth movement and size of

D-shaped holes. All of the holes had collapsed, were overgrown and had clearly

not been used over the past 12 months.

Target Note 23

Previous amenity grassland lawn area. Main grass species were Yorkshire fog

and bents Agrostis sp. Also present in lower quantities: birds foot trefoil Lotus

corniculatus, selfheal Prunella vulgaris, forget-me-not Myositis arvensis, creeping

buttercup, common chickweed Stellaria media and compact rush Juncus

conglomerates.

Target Note 24

Amenity grassland – now unmanaged and overgrown, with ornamental shrubs

including lilac and Rhododendron sp., a mature poplar and declining ash (no

BRP).

Target Note 25

Boundary wall (approximately 2m high). large stand of Rhododendron sp. and

two multi-stemmed ash trees by wall.

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Target Note 26

Rough grass area (previously amenity). Trees to the eastern boundary: laurel,

Salix sp., holly, beech, Rhododendron sp., sycamore, lime, horse chestnut, ash.

Low to medium BRP in mature specimens. To the west, scrub and semi-mature

ash trees (no BRP).

Target Note 27

A former terraced garden – now overgrown and unmanaged, becoming rough

grassland. Species present included creeping buttercup, Yorkshire fog, bramble,

mosses, yew Taxus baccata, heather Calluna vulgaris, tufted vetch Vicia cracca,

Crocosmia sp., compact rush, and lady’s mantle Alchemilla mollis. Boundary

shrubs and trees included beech, Prunus sp., laurel, Rhododendron sp. and

dogwood Cornus sanguinea.

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Target Note 28

Grass and ruderal boundary – ruderal species have encroached this now

unmanaged area, including creeping thistle Circium arvense, rosebay willowherb

Epilobium angustifolium and nettles. Mature trees included cypress Cupressus

sp., sycamore and poplar (all Low BRP).

Target Note 29

Rough grass with a privet Ligustrum ovalifolium hedge to the west.

Target Note 30

Steep bank between two car parks. Sycamore, ash, Salix sp., bramble, rosebay

willowherb and Himalayan balsam. A line of mature Scots pine were present

adjacent to the road boundary with the lower car park.

Target Note 31

Belt of Laylandii and Scots pine along road boundary.

Target Note 32

Vegetated boundary with union road. Mature sycamore, ash, Scots pine (low

BRP).

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Target Note 33

Tarmaced access road. Walled to the north and railed to the south with hedges

beyond the site boundary.

Target Note 34

Semi-mature cherry trees on a grass verge between the hedge and the road. No

BRP.

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Target Note 35

Missing stones covering surface water drains and service ducts: since vandalism,

this now provided access into underground voids where there could be

opportunities for hibernating bats.

Protected Species – Results and Evaluation

Flora and habitats

3.11 The single largest habitat on the site was the area of wet woodland in the south

eastern half. The woodland was mainly broadleaved, dominated by ash and also

including oak, larch, sycamore, horse chestnut, birch, willow, hawthorn, Scots pine

and hazel. The northern areas of the woodland were very damp in places and stands

of alder were present. Under the current proposals, the woodland will not be directly

impacted by the development. However, it was considered that it could be enhanced

for wildlife and amenity value by implementing a woodland management plan which

could include enhancements for birds and bats.

3.12 The hedgerow within the site boundary (see Target Notes 6) had been planted for

amenity value and was species poor (dominated by beech with occasional crab

apple and blackthorn). It will not be classified as ‘important’ under the Hedgerow

Regulations 1997, but could provide habitat for nesting birds and small mammals.

Potential for use as a linear landscape feature, enhancing movement of wildlife

through the site, is limited due to the short length of the hedge and the lack of habitat

at either end.

3.13 A number of small grassland and ruderal habitats were located amongst the former

hospital buildings. These had previously been areas amenity grassland which had

become dominated by coarse grasses and ruderal species once mowing

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management had ceased. These areas were not floristically diverse and did not

support any rare species. There was an abundance of coarse grassland habitats in

the surrounding landscape and therefore, it was considered that the loss of these

habitats would not have a significant impact in the local landscape context.

3.14 The desk study highlighted records of five grassland and woodland species, though

several of these were potentially historic records (i.e. recorded between 1950 and

1999) and none were recorded during the survey which was conducted at a time of

year when these species would have been visible.

3.15 Four Wildlife and Countryside Act Schedule 9 species, Japanese knotweed,

Crocosmia sp., Rhododendron sp. and Himalayan balsam, were recorded growing in

scattered locations around the site (see Target Notes 9, 12, 13 and 19). These

should be treated and disposed of appropriately prior to the commencement of any

ground works to avoid infringing legislation regarding spread of Schedule 9 species.

Bats

3.16 There were several mature oak, ash, horse chestnut, sycamore, poplar and lime

trees around the site which had mostly low to medium, and occasionally high bat

roost potential. They exhibited features such as lifting bark which could potentially be

used by individual, transient roosting bats; and cracks, crevices and rot holes which

could be used by a more significant roost, such as hibernation or maternity roosts.

Trees within the woodland were limited in terms of features suitable for use by

roosting bats. Many of the numerous buildings in the north-western half of the site

provided bat access opportunities due to their poor state of repair. Most of the roof

voids were accessed, though health and safety issues limited this in some buildings,

and all of the buildings were inspected externally. No positive evidence of past or

present use by roosting bats was found.

3.17 The site was dominated by woodland and buildings, with areas of grassland, ruderals

and tree and shrub planting, which provided moderate quality foraging habitat for

bats.

3.18 There are recent records of seven bat species within 10km of the site: Soprano and

common pipistrelles have been recorded within half a kilometre of the site boundary.

It was considered that species such as pipistrelle Pipistrellus sp. and noctule

Nyctalus noctula, which were identified in the desk study, could be using habitats

around the site for foraging and commuting. Much of the site is well lit with security

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lights, which make the area less suitable for some species, such as brown long-eared

bats, though other species, such as pipistrelles and noctules are often feed on the

insects attracted to lights. Leisler’s, Natterer’s, Daubentons and whiskered / Brandt’s

bats were also identified within 10km of the site. Leisler’s bats are a predominantly

woodland species roosting mainly within trees, so are more likely to be found

foraging and roosting within the woodlands in the surrounding area due to a lack of

features on the trees in the woodland on the site. Natterer’s and whiskered / Brandt’s

bats are known for using roosts in buildings, and the buildings on site would be

suitable for individual roosting bats of these species. Daubenton’s bats tend to be

associated with water and as such are unlikely to be found roosting or foraging on the

site.

3.19 Further activity survey is recommended (a dusk and dawn) to assess bat activity

levels at the site: though this will now be late in the season, it should pick up any late

season mating or pre-hibernation swarming activity and provide a general indication

of the level of bat activity on the site.

3.20 A tree-climbing survey is recommended to assess some of the potential roosting

features which could not be inspected fully from the ground. The climber should hold

a Natural England bat licence and suitably NPTC qualified.

Reptiles

3.21 The site generally had low potential to support a population of reptiles, dominated by

buildings and woodland, with only small, isolated areas of grassland and ruderal

habitat suitable for foraging reptiles. Areas of shorter vegetation and bare ground

associated with the buildings, which had been used for vehicle and pedestrian

access, provided potential basking opportunities for species such as common lizard.

3.22 There are historical records of slow worms within 4km of the site. Due to past

management of the site, it was considered that the rough grassland areas provided

low potential to support reptiles, and further survey is not necessary. However due to

the low possibility that the rough grassland areas could be used by occasional slow

worms, these should be cleared under ecological supervision to minimise any

potential harm to any reptiles which might be present. This will involve reduction in

the quality of the habitat through strimming prior to clearance.

Birds

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3.23 A visual survey of bird activity and suitable nesting habitat was carried out, in order

to determine if any areas would be suitable for WCA Schedule 1 birds, Birds of

Conservation Concern or other common and widespread nesting birds. The

woodland, trees, shrubs and hedgerows on the site provided potential nesting and

foraging opportunities for birds. The areas of coarse grassland provided potential

shelter and nesting opportunities for ground nesting birds such as skylark. Habitats

within the site such as coarse grassland and trees are abundant locally, and the area

of woodland will not be directly impacted by the proposed development. Therefore, it

was considered unlikely that protected, BAP or rare birds would be significantly

impacted by the proposed development.

3.24 Bird species observed during the field survey included goldfinch Carduelis carduelis,

magpie Pica pica and swallow Hirundo rustica. Swallows were recorded nesting in

Building 13 and 11.

3.25 The site provided potential habitat for a range of nesting widespread and common

species. BAP and red-listed species such as tree sparrow, yellowhammer, wood and

warbler, which were identified in the desk study, could use habitats such as those

within the site boundary. Other species identified in the desk study such as ring ouzel

Turdus torquatus are moorland and upland specialists unlikely to be found on the

site.

3.26 Trees proposed for retention, should be suitably protected from harm during the

construction works following British Standard: BS5837.

3.27 Site clearance and works proposed to any buildings, trees or hedges should be

conducted outside the main bird breeding season (which is March until the end of

August). If vegetation removal is necessary between these dates, an ecologist

should survey the site for active bird nests immediately prior to works. If nests are

identified, there may be a delay in the clearance of some vegetation until all young

birds have fledged.

Amphibians

3.28 There were no ponds or waterbodies on the site. There was a small reservoir

approximately 150m south of the site which is unlikely to provide suitable habitat for

protected breeding great crested newts.

3.29 The woodland and areas of coarse grassland provided moderate quality habitat for

amphibians such as great crested newts and toads in their terrestrial phase.

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3.30 There are records of great crested newts within 7.5 km of the site in 1985 and toads

within the same 10km grid square in 2005.

3.31 Although there was a reservoir within 500m of the site to the south, there were no

ponds on, or to the north of the site. This reduced the likelihood of amphibians

dispersing across the site in search of water bodies to breed, or woodland for

hibernation. There is potential for amphibians to use the woodland in the south-east

of the site during their terrestrial phase. However, the woodland is not being directly

impacted by the proposed development and therefore any amphibians using it would

not be significantly impacted. The Haslingden Road also forms an ecological barrier

which further reduces the likelihood of amphibians dispersing onto the site from the

south. The grassland habitats on the site were of low suitability for amphibians –

limited cracks and rabbit holes which could be used for hibernation, and fragmented

from other potential foraging areas and breeding habitat by buildings and hard-

standing. Therefore, further survey is not necessary.

3.32 Precautionary clearance of the grassland habitats, which is already recommended to

minimise any potential harm to reptiles, will serve the same purpose for any

amphibians which might be present.

Invertebrates

3.33 The areas of grassland, amenity shrub and tree planting, hedgerows and woodland

provided potential habitat for common invertebrates.

3.34 The data search highlighted records of the wall Lasiommata megera and small heath

Coenonympha pamphilus butterflies, and cinnabar Tyria jacobaeae moth (all UK

BAP species) within 3km of the site. Food plant grasses (meadow grasses) and

ragwort were present, as were basking and nectaring opportunities. However, due to

the abundance of similar habitats within the surrounding area, it was not considered

that the local conservation status of invertebrates would be significantly affected by

the proposed development.

3.35 Habitats within the site were not considered of suitable structure or diversity to

support a significant assemblage of BAP, rare or protected invertebrates. No further

survey is necessary.

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Hedgehogs, hares and badgers

3.36 There were signs of past badger activity on the site in the form of several disused

holes (see Target Note 22). However, these holes had collapsed and were

overgrown, indicating that had not been used for some years. No snuffle holes,

latrines or other field signs indicating the presence of badgers were recorded.

3.37 There are records of brown hares and hedgehogs within 10km of the site from 2006

and 1978 respectively. There was limited suitable habitat for brown hares on the site

and it was considered unlikely that they would be significantly impacted by the

development. There was suitable habitat for hedgehogs on the site. However, the

woodland area will remain undeveloped providing a safe refuge for any which may

be present within the construction zone. It was also considered that sensitive

landscape plans could enhance the site for hedgehogs post development.

3.38 There are records of red squirrel within 6km from 2008. However, the woodland area

is unlikely to support this species due to being small and relatively isolated from

other woodland habitats in the surrounding landscape. Again, the woodland will not

be directly impacted by the development and it was therefore considered unlikely

that the local conservation status of red squirrels would be impacted either.

3.39 Prior to the commencement of any ground works, it is recommended that a

precautionary badger survey is undertaken to confirm the status of the disused sett

and to ensure that badgers have not colonised the site in the interim.

Dormice

3.40 The woodland on the site provided low quality potential habitat for dormice. The

woodland structure was poor, with limited shrub layer providing access to the canopy

and limited variety and quantity of dormouse food resources. There are no records

of dormice within 10km of the site and connectivity to further suitable habitat within

the local area is poor.

3.41 No further survey is recommended.

Other Protected, BAP or Rare Species

3.42 There were no significant water courses within the site or within 50m of the site

boundary. It was considered unlikely that species such as otter and/or water vole

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would be impacted by the proposed development. The site was not considered

suitable to support any other protected, BAP or rare species.

4 Key Recommendations, Further Surveys and Precautionary Methods

4.1 Precautionary clearance of grassland habitats to be undertaken to minimise the risk

of potentially harming reptiles or amphibians.

4.2 Schedule 9 species Japanese knotweed, Crocosmia sp., Rhododendron sp. and

Himalayan balsam should be removed and disposed of appropriately prior to the

commencement of works on the site.

4.3 Badger survey to be undertaken prior to ground works to ensure the status of inactive

sett has not changed in the interim.

4.4 Precautionary clearance of the site, buildings, hedgerows and trees will be

necessary, as detailed in Section 3, to avoid infringing legislation which protects all

nesting birds.

4.5 Further survey of trees with bat roost potential, which could be impacted by the

development – either indirectly (lighting) or through felling, should be carried out by a

NE bat licenced and qualified tree climber.

4.6 Further bat surveys within the active bat season should be carried out prior to

demolition, to ensure that bats are not using the buildings. A further bat survey in

September (dusk and dawn) will identify any late season swarming, pre-hibernation

activity within cellars, and general foraging activity levels on the site.

5 Enhancement Recommendations

5.1 The following are suggestions that the client may wish to consider to enhance the

value of the site for wildlife. However, it should be noted that these suggestions are

not legally required for compensation of habitats or mitigation and may be revised

depending on the outcome of the further surveys.

5.2 The addition of four house sparrow terraces on the new buildings on site will provide

additional nesting opportunities for this BoCC red listed species which has been

recorded in the surrounding landscape. A further six standard bird boxes with a

variety of shaped and different sized entrance holes should be located within the

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woodland to attract a greater diversity of birds to nest. Boxes should be located

appropriately, out of direct sunlight, prevailing wind direction and close to vegetation.

Swallow boxes should be located under eaves of new builds, particularly those to the

north western boundary, to offset the loss of these nesting opportunities.

5.3 Connectivity in a landscape context should be considered at all stages of the design

process. Native tree and hedgerow planting around the site should be considered, to

create dispersal corridors, biodiversity linkages and enhance the existing connections

associated with the site.

5.4 A woodland management plan could be implimented to ecologically enhance the

woodland area.

5.5 Bat boxes or bricks could be installed in/on the new houses. Bat boxes need to be at

least 4m from the ground, out of direct sunlight and close to vegetation.

5.6 The inclusion of wildflower rich swards could enhance the area for invertebrates

including butterflies and bumble bees. These areas could also enhance the site for

birds and bats post development.

5.7 Native and/or wildlife attracting tree and shrub planting should be included in the

landscape design. This would enhance the area for birds, invertebrates and other

wildlife in the long-term. Trees and shrubs should be planted to encourage movement

through the site as well as providing habitat.

6 Conclusion

6.1 The site was considered to be of moderate ecological value, predominantly

consisting of woodland, derelict buildings, small areas of grassland and individual

trees and shrubs.

6.2 If key recommendations, as detailed in this report are undertaken – and any

subsequent recommendations followed, it was considered that the development

could proceed with minimal impact on the local conservation status of any protected,

BAP or rare species within the area.

6.3 It is also considered that by including some, or all, of the enhancement

recommendations, the site could be improved for local wildlife, post development.

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7 References

Bat Surveys: Good Practice Guidelines 2007. Bat Conservation Trust, London.

Cheffings, C.M. & Farrell, L. (Eds), Dines, T.D., Jones, R.A., Leach, S.J., McKean,

D.R., Pearman, D.A., Preston, C.D., Rumsey, F.J., Taylor, I. 2005. The Vascular Plant

Red Data List for Great Britain. Species Status 7: 1-116. Joint Nature Conservation

Committee, Peterborough.

English Nature (2004). Guidelines for Developers. English Nature, Peterborough

English Nature (2001) Great Crested Newt Mitigation Guidelines. English Nature

Froglife. 1999. Reptile Survey. An Introduction to Planning, Conduction and Interpreting

Surveys for Snake and Lizard Conservation. Froglife Advice Sheet 10. Froglife.

Gent, A.H. and Gibson, S.D., eds. 1998 Herpetofauna Workers’ Manual. Peterborough,

Joint Nature Conservation Committee.

Gregory, R. D. Wilkinson, N. I. Noble, D. G. Robinson, J. A. Brown A. F. Hughes, J.

Proctor, D .A. Gibbons, D. W. & Galbraith, C.A. (2007). The population status of birds

in the United Kingdom and Isle of Man: an analysis of conservation concern 2002-

2007. British Birds 95: 410-450.

JNCC (2010). Handbook for Phase 1 habitat survey: a technique for environmental

audit (revised reprint). JNCC: Peterborough.

Natural England (2011) Reptile Mitigation Guildines. NE 2011.

Office of the Deputy Prime Minister (ODPM), (1994). Planning Policy Statement 9. The

Stationery Office (TSO), London.

Stace, S. (1991). New Flora of the British Isles. Cambridge University Press,

Cambridge. 2nd ed. (1997).

Web references

MAGIC: Designated area data downloaded from URL http://www.magic.gov.uk.html

(Accessed 4th October 2011).

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National Biodiversity Network: Protected species data downloaded from URL

http://data.nbn.org/interactive/map (Accessed 4th October 2011).

UK BAP www.ukbap.org.uk

Lancashire Local BAP http://www.lancspartners.org/lbap/biodiversity_action_plans.asp

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8 Appendices

Appendix A: Phase 1 habitat map

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Appendix B: Site plan showing building Target Note number locations

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Appendix C: Plant species list

Forbs

Common Name Scientific Name

Black knapweed Centaurea nigra

Broad leaved dock Rumex obtusifolius

Cleavers Galium aparine

Common bird’s-foot-trefoil Lotus corniculatus

Common ragwort Senecio jacobaea

Creeping buttercup Ranunculus repens

Daisy Bellis perennis

Enchanter’s nightshade Circaea lutetiana

Field forget-me-not Myosotis arvensis

Himalayan Balsam Impatiens glandulifera

Hogweed Heraclium sphondylium

Japanese knotweed Fallopia japonica

Lesser stitchwort Stellaria graminea

Montbretia Crocosmia x crocosmiiflora

Nettle Urtica dioica

Perennial sow-thistle Sonchus arvensis

Red bartsia Odontites vernus

Ribwort plantain Plantago lanceolata

Rosebay willowherb Chamerion angustifolium

Selfheal Prunella vulgaris

Spear thistle Cirsium vulgare

Tufted vetch Vicia cracca

Trees and shrubs

Common Name Scientific Name

Alder Alnus glustinosa

Apple Malus sp.

Ash Fraxinus excelsior

Beech Fagus sylvatica

Blackthorn Prunus spinosa

Bramble Rubus fruticosa

Buddleja Buddleja sp.

Cherry Prunus sp.

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Common lime Tilia x europaea

Common lilac Syringa vulgaris

Crab apple Malus sylvestris

Cypress Cupressus sp.

Dogwood Cornus sanguinea

Elder Sambucus nigra

Fuschia Fuschia sp.

Goat willow Salix caprea

Grey willow Salix cinerea

Hawthorn Crataegus monogyna

Hazel Corylus avellana

Heather Calluna vulgaris

Holly Ilex aquifolium

Horse chestnut Aesculus hippocastanum

Ivy Hedera helix

Larch Larix decidua

Laurel Prunus laurocerasus

Maple Acer sp.

Oak Quercus robur

Poplar Populus sp.

Privet Ligustrum Ovalifolium

Raspberry Rubus idaeus

Redcurrant Ribes rubrum

Rhododendron Rhododendron spp

Rose Rosa sp.

Rowan Sorbus aucuparia

Scots pine Pinus sylvestris

Silver birch Betula pendula

Sycamore Acer pseudoplatanus

Yew Taxus baccata

Grasses, sedges, rushes and ferns

Common Name Scientific Name

Annual meadow grass Poa annua

Cocksfoot Dactylus glomerata

Common male fern Dryopteris filix-mas

Compact rush Juncus conglomeratus

Creeping bent Agrostis stolonifera

False oat grass Arrhenatherum elatius

Timothy Phleum pratense

Tufted hairgrass Deschampsia cespitosa

Yorkshire fog Holcus lanatus

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Appendix D: Relevant protected species legislation

Species Relevant Legislation Level of Protection

Badgers

o Protection of Badgers Act 1992 o Badgers are also protected by the Wild

Mammals (Protection) Act 1996

The Protection of Badgers Act (1992) makes it an

offence to intentionally or recklessly:

• Damage a badger sett or any part of it

• Destroy a badger sett

• Obstruct access to, or any entrance of a badger sett

• Disturb a badger whilst it is occupying a badger sett

Bats

o Full protection under the Wildlife and Countryside Act (WCA) (1981) (Listed on Schedule 5) - as amended

o Classified as European protected species under Conservation of Habitats and Species Regulations 2010

o Also protected by the Wild Mammals (Protection) Act 1996

The WCA (1981) makes it an offence to:

• intentionally kill, injure, or take any species of bat

• intentionally or recklessly disturb bats

• intentionally or recklessly damage destroy or obstruct access to bat roosts

Birds

o Protection under the Wildlife and Countryside Act (1981) as amended with the exception of some species listed in Schedule 2 of the Act

The WCA (1981) makes it an offence to (with

exceptions for certain species):

• Intentionally kill, injure or take any wild bird • Intentionally take, damage or destroy nests

in use or being built (including ground nesting birds)

• Intentionally take, damage or destroy eggs

Species listed on Schedule 1 of the WCA or their

dependant young are afforded additional protection

from disturbance whilst they are at their nests

Reptiles

o Partially protected by the Wildlife and Countryside Act

The WCA (1981) makes it an offence to:

• intentionally kill or injure these animals

• sell, offer for sale, advertise for sale, possess or transport for the purposes of selling any live or dead animals or part of these animals