From:                                                       David Dutton <david.dutton@tameside.gov.uk>

Sent:                                                         28 January 2025 13:20

To:                                                            Development Management

Cc:                                                             Ryan Killeen (He/Him)

Subject:                                                   Planning application 23/00650/HYBR Land at Stakehill

 

 

Hi Ryan

 

Thank you for consulting the GMEU

 

Summary

The updated species surveys identified no material changes on the site. A number of my original questions from December 2023 remain unanswered.

 

Validity of the Preliminary Ecological Appraisal

Whilst updates of various protected and invasive species reports have been provided, it is now nearly 3 years since the last baseline survey of the habitats present. I recommend a review of the baseline habitats prior to determination.

 

Lack of any New documentation on the Planning Portal

My comments are based on the assumption that no new phasing, landscape proposals or masterplans have been provided as no new documentation is shown on-line. If layouts have changed, I recommend these are provided so that I can reassess my recommendations.

 

Statutory Protected Sites

No additional information has been supplied. My recommendations for further information from the 20th December 2023 therefore still applies.


Sites of Biological Importance (SBI) (excluding Rochdale Canal)

No additional information has been supplied. My previous recommendations of the 20th December 2023 therefore still apply.


Bats

Updated bat activity surves were carried out in 2024. Similarly low levels of bat activity to the surveys in 2022 were recorded. Building 1 was also assessed for bat roosting potential, omitted from the 2022 survey as assumed retained. The building was assessed as having negligible bat roosting potential. I have no reason to doubt the findings of the report. My previous recommendations therefore no longer apply. The consultant has recommended further updates beyond September 2025. Given the bat activity season would however not commence until April 2026 and the consistent low levels of bat activity I recommend a revised condition along the following lines is applied to any full permisison.


If development and or demolition does not commence prior to April 2026 an updated bat activity survey for the site and bat assessment of any building still to be demolished will be provided to and agreed in writing by the LPA

 

My previous recommendation for bat activity surveys re. the outline parts of the site still applies.

 

No additional information has been provided on the bat roosting potential of trees on the site. Previously I recommended more information dependent on whether or not trees with low or higher risk levels ofbat roosting potential were to be lost. I therefore recommend:

 

Prior to determination clarification on whether any trees with bat roosting potential will be lost as part of the full application.

 

My previous recommendations re. the outline parts of the application still apply

 

My previous recommendations re. external lighting also still apply.

 

Badger

An updated badger survey has been provided. This identified no material changes regarding the risk to badger, with no main setts recorded on the site, but probable outlier and badger activity detected. The survey occurred in March 2024 and is therefore no longer valid.

 

No significant activity was however recorded again with all setts on-site regarded as inactive (less active than 2022) and only one of the potential outliers likely to be permanently lost. I am therefore satisfied that additional surveys at this time are not required.

 

My previous concerns and recommendations however still apply, with a lack of understanding regarding where the badgers are coming from and whether the local population would suffer signficant harm as a result of loss of what is likely foraging habitat.

 

I am still satisfied that the full application is unlikely to have a significant effect on the local badger populaiton. I therefore recommend a conditon along the following lines.

 

Prior to any development, earthworks or vegetation clearance and updated badger survey and badger mitigation strategy will be provided to and agreed in writing by the LPA.

 

With regards the outline application, I still have concerns that the loss of foraging habitat could be significant, given the lack of understanding regarding where the badgers are coming from and the size of the population. There is however good connectivity proposed through the site from north to south, my previous recommended condition for the outline phase is therefore on reflection more than is reasonably required. More information is however required on the population dynamics and idealy the location of the main sett located (assuming one is present somewhere nearby) in order to ensure the layout takes in to account badger foraging and commuting routes and provide sufficient cover along these routes and replacement foraging habitat eg fruit trees to ensure year round supply of food. I therefore now recommend a condition along the following lines is applied to any permission.

 

As part of first reserved matters a badger mitigatiion strategy will be provided to and agreed in writing by the LPA. This will be based on additoinal survey including camera trapping over one whole season of potential foraging and commuting routes and outlier setts. It will also include survey for main and annexe setts within 50m of the development footprint, where accessible.

 

Great Crested Newts (gcn)

No additional information has been specifically supplied though there appears to be an indication that additional correspondence on district licensing may have occurred. My recommendations for further information from the 20th December 2023 however still apply.


Water Vole

An updated survey has occurred. As for the previous survey possible evidence of water vole in ditch 1 was recorded. No evidence was found in any of the other ditches. Disturbance of ditch 1 will occur as part of the full application, with the access road cutting across the northern end of the dtich. Further survey and a water vole mitigation strategy has been recommended. I am satisfied that these measure are adequate. I therfore recommend a condition along the following lines is applied to the full permission.

 

Prior to any earthworks or vegetation clearance within phases 1 or 2 a water vole mitigation strategy including an updated water vole survey will be provided to and agreed in writing by the LPA.

 

White-Clawed Crayfish

The PEA notes that ditch 1 was assessed for white-clawed crayfish in March 2024 and assessed as having negligible suitability. It also notes the ditch is not hydrologically linked to the canal. I was unable to locate the details of this survey but have no reason to doubt the summary provided. The habitat from the photographs clearly unsuitable. No further information or measures are required.

 

Other Protected Species

Casual records of barn owl were reported as part of the bat activity surveys in 2022 and 2024. No updated survey for breeding sites has however been provided. No barn owl were recorded during the breeding bird survey in 2023, which are still valid. Given the low number of suitable breeding or roosting opportunities on the site, I am satisfied that no further surveys are required at this time. I recommend however precautionary surveys prior to the demolition of any remaining buildings on the site or any mature trees.

 

If development and or demolition does not commence prior to April 2025 an updated barn owl assessment of any building still to be demolished and mature trees will be provided to and agreed in writing by the LPA

 

Nesting Birds

No additional information has been supplied. My previous recommendations of the 20th December 2023 therefore still apply.

 

Brown Hare

No new information has been provided, though the PEA acknowledges the issues in its recommendations. My previous recommendations of the 20th December 2023 therefore still apply.

 

Other Mammals and Amphibians

No new information has been provided, though the PEA acknowledges the issues in its recommendations and indicates that a reasonable avoidance measures method statement has been provided. I was however unable to locate such a document. (Report P.1172.19 Small Mammal and Amphibian Reasonable Avoidance Measures (RAMS).) Prior to determination please provided a copy of this document.

 

Invasive Species

An update has been provided. This indicates that himalyan balsam has spread since the previous survey as anticipated. Materially however my previous recommendations still apply.

 

Protection of Watercourses

No additional information has been supplied. My previous recommendations of the 20th December 2023 therefore still apply.

 

Contributing to and Enhancing the Natural Environment & Biodiversity Net Gain (BNG)

Section 180 of the NPPF 2023 states that the planning policies and decisions should contribute to and enhance the natural and local environment. 10% BNG is mandatory under Schedule 7A of the Town & Country Planning Act 1990 (as inserted by schedule 14 of the Environment Act 2021). No new information has been provided, though I note the PEA’s recommendation is generally in agreement with my recommendations.

 

Prior to determination, I recommend a response to the issues I raised on BNG and the landscape proposals.



David Dutton

Ecologist

Planning and Transportation

Planning and Transportation

Place

Dukinfield Town Hall | King Street | Dukinfield | Tameside | SK16 4LA

 

Tel. 0161 342 2895

Mobile. 07583961784

 

This email was sent at a time & date convenient to the sender; please do not feel under any pressure to respond immediately if this is outside your normal working hours.


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