From: Melissa Sullivan <Melissa.Sullivan@tameside.gov.uk>

Sent: 17 June 2025 14:13

To: Development Management

Subject: 25/00353/FUL

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Good afternoon,

Thank you for your consultation on the application at Cope Funeral Services Ltd, Manchester Road, Rochdale (25/00353/FUL).

The application is accompanied by a Preliminary Ecological Appraisal (PEA) report and a Biodiversity Net Gain (BNG) statutory metric (Rachel Hacking Ecology, April 2025). Based on the submitted information, GMEU have the following comments:

Ecological Assessment

As detailed in the PEA report, the site holds relatively low ecological value as it is mostly hardstanding and modified grassland, however there are scattered trees present and buildings which may provide potential for roosting bats and nesting birds. The PEA survey was undertaken in January 2025 which is a sub-optimal time of year for habitat surveys, this has not been considered within the report and not stated as a limitation, but it must be considered as part of the assessment.

Bats

The bat Preliminary Roost Assessment (PRA) undertaken on the existing buildings found them to have ‘negligible’ suitability for roosting bats and I have no reason to doubt the findings of the assessment given the descriptions provided, no further surveys are necessary. However, there appears to be very limited information regarding the trees onsite with no information provided in the results and the ‘Impacts on Species’ section simply stating that the trees offered negligible potential for roosting bats. More details should be provided regarding the trees and if any Potential Roosting Features (PRFs) were found, particularly given that all trees are proposed to be removed.

Invasive Non-Native Species (INNS)

Wall cotoneaster is present onsite, and it is an offence under the terms of Schedule 9 of the Wildlife and Countryside Act 1981 to allow the plant to grow in the wild. We would therefore recommend that a condition be attached to any permission that prior to the commencement of any works on site (including vegetation clearance) a methodology for the control of invasive species be submitted to and agreed by the council. Once agreed the method statement must be implemented in full.

Nesting Birds

As all wild birds, their nest and eggs are protected under the Wildlife and Countryside Act 1981 (as amended), we would recommend that the following condition be attached to any permission, should it be granted:

No removal of or works to any trees, vegetation or buildings shall take place during the main bird breeding season 1^st March and 31^st August inclusive, unless a competent ecologist has undertaken a careful, detailed check of vegetation for active birds' nests immediately before clearance and provided written confirmation that no birds will be harmed and/or that there are appropriate measures in place to protect nesting bird interest on site.

Biodiversity Enhancements

No enhancements appear to have been recommended within the PEA but this would be expected to comply with the NPPF 2024 (Section 15 - paragraph 187) where planning policies and decisions should contribute to and enhance the natural and local environment and should be standard practice. Therefore, GMEU recommended that at least three bat boxes and three bird boxes are incorporated into the development to provide additional opportunities for bats and birds. Integrating the boxes into the buildings or placing them on the buildings is recommended in appropriate locations. We would recommend that a condition to this effect be attached to any permission.

Biodiversity Net Gain (BNG)

There are various discrepancies between the BNG metric and the PEA report (which contains some BNG information). No standalone BNG report has been provided. My below comments must be addressed so that sufficient information has been provided for the BNG:

• The baseline habitat totals within the body text of the report do not match some of the totals (in hectares) within the metric, making it unclear which is correct. The headline results also do not match. This should be consistent between the metric and report documents to ensure accuracy.
• No species lists have been provided for the baseline habitats present, however we would expect this to be provided in the report.
• A small area of ruderal/ephemeral habitat is shown in the baseline tab of the metric and within the baseline map in the report, however this is not stated within the report but should be, along with species present.
• The report states that ‘Multiple individual trees exist on site, ranging in size and condition.’ – this does not provide sufficient information for us to review the BNG. We would expect the report to state how many trees are currently present and the size and condition of each. The Habitat Condition Assessments (HCAs) refer to T1 to T7 which should also be shown in the baseline plan. The report also states that the baseline trees deliver 0.1253 habitat units however this is the size of the trees combined in hectares.
• The ‘Proposed Landscaping’ figure shown in the PEA report (Appendix 4, although there are two Appendix 4’s), shows that there are proposed hedgerows and 7 small sized trees which do not appear to have been captured in the BNG metric or report. I am also struggling to work out where the native mixed scrub is proposed. The BNG should be updated to reflect the correct landscape plans.
• The 7 trees proposed are non-native species. GMEU would recommend that native species are used or justification should be provided as to why this is not feasible.
• The proposed seed mixes/ species for the modified and wildflower grassland does not appear to be provided within the report or the landscape plan but this would be expected.
• The amendments suggested above is likely to alter the BNG scores slightly however the proposal is likely to still be achieving a loss of biodiversity and the trading rules will not be satisfied. The report states that it will be necessary to the applicant to seek offsite compensation, it should be confirmed whether the applicant plans to do this so that GMEU can be confident that 10% BNG can be achieved.

In summary, insufficient information has been provided regarding the BNG assessment and the bat tree assessment and it is advised that the documents are updated based on my comments above. This is required prior to determination of the application.

If you have queries relating to this advice, please do not hesitate to contact me.

Kind regards,

Melissa Sullivan

Ecologist

Greater Manchester Ecology Unit

Tameside MBC, Dukinfield Town Hall

King Street, Dukinfield,

Tameside, SK16 4LA

Tel: 0161 342 2842

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