proposed student accommodation howard gardens cardiff bat ... · a quantum geographic information...

W: www.acerecology.co.uk | E: [email protected] T: 029 2065 0331

16 Wordsworth Avenue, Penarth, Vale of Glamorgan, CF64 2RL

Registered in England and Wales No. 7563601

Proposed Student Accommodation

Howard Gardens

Cardiff

Bat Survey Report

September 2017

http://www.acerecology.co.uk/

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1205: Proposed Student Accommodation, Howard Gardens, Cardiff: Bat Survey Report: September 2017

REPORT CONTENTS

INTRODUCTION ......................................................................................................................... 1

1.1. BRIEF ................................................................................................................................ 1 1.2. SITE DESCRIPTION ............................................................................................................ 1 1.3. PROPOSED WORKS ............................................................................................................ 1 1.4. LEGISLATION AND PLANNING POLICY ................................................................................ 1 1.5. SURVEY SCOPE .................................................................................................................. 2 1.6. REPORTING ....................................................................................................................... 2

METHODS .................................................................................................................................. 3

2.1. DESK STUDY ...................................................................................................................... 3 2.2. FIELD STUDY ..................................................................................................................... 3 2.3. SURVEY FOR NESTING BIRDS ............................................................................................. 4 2.4. CONSTRAINTS ................................................................................................................... 4

RESULTS ................................................................................................................................... 6

3.1. DESK STUDY ...................................................................................................................... 6 3.2. FIELD STUDY ..................................................................................................................... 6

EVALUATION ........................................................................................................................... 13

4.1. SUMMARY OF PRELIMINARY ROOST INSPECTION AND DUSK EMERGENCE SURVEY ............ 13 4.2. POTENTIAL SUMMER ROOSTS (BUILDINGS) ...................................................................... 13 4.3. POTENTIAL SUMMER ROOSTS (TREES) ............................................................................. 13 4.4. POTENTIAL HIBERNATION ROOSTS .................................................................................. 13 4.5. BIRDS – INTERPRETATION OF NESTING BIRD SURVEY ..................................................... 14

POTENTIAL IMPACTS OF DEVELOPMENT ................................................................................... 15

RECOMMENDATIONS ............................................................................................................... 16

6.1. PRECAUTIONARY MEASURES (BUILDINGS) ....................................................................... 16 6.2. PRECAUTIONARY MEASURES (TREES) ............................................................................... 16 6.3. ECOLOGICAL ENHANCEMENT FOR BATS ........................................................................... 17

REFERENCES ........................................................................................................................... 18

PLANS

PLAN 1: LOCATION PLAN

PLAN 2: SITE PLAN

PLAN 3: PROTECTED SITE MAP

PLAN 4: DUSK EMERGENCE SURVEY RESULTS (29/08/2017)

APPENDICES

APPENDIX 1: BAT ECOLOGY AND LEGISLATION PROTECTING BATS AND THEIR ROOSTS

APPENDIX 2: GUIDELINES FOR ASSESSING POTENTIAL SUITABILITY OF BUILDINGS FOR BATS AND

DETERMINING THE NUMBER OF FLIGHT SURVEYS REQUIRED

APPENDIX 3: GUIDELINES FOR ASSESSING BAT SUITABILITY

APPENDIX 4: ASSESSMENT OF SUITABILITY OF BUILDING TO SUPPORT ROOSTING BATS



DOCUMENT CONTROL

Howard Gardens, Cardiff

Bat survey Report

Revision Date Prepared by Checked by Approved by

1.0

25 August 2017 Liam Maries

Assistant Ecologist

Hal Starkie

Ecologist

NRW Licence No: 76251a

Paul Hudson MCIEEM

Principal Ecologist

2.0 11 September

2017

Hal Starkie

Ecologist

NRW Licence No:

76251a

Alastair Krzyzosiak

Ecologist

NRW Licence No: 75630

Paul Hudson MCIEEM

Principal Ecologist

Acer Ecology Ltd accepts no responsibility or liability for the use of this document, other than by the

client for the purpose for which it was originally commissioned and prepared.



Summary

Site Location

This report presents the findings of a bat and nesting bird survey of a site

located at Howard Gardens, Cardiff, CF24 0EF (Ordnance Survey Grid

Reference: ST 19152 76692).

Survey Methodology The survey comprised the following:

• The preliminary bat roost assessment of the buildings and trees, searching for signs of bats and nesting birds;

• A search for nesting birds; and

• One dusk emergence survey of the buildings.

Results of Preliminary Bat Roost Inspection

No signs of bats were found anywhere in or around the buildings or trees during the preliminary roost assessment.

Suitability of the Buildings

to Support Roosting Bats

Determined During Preliminary Roost

Inspection

The buildings are assessed as having low suitability to support roosting

bats.

Potential for Trees to

Support Roosting Bats Determined During

Preliminary Roost Assessment

The trees are assessed as having negligible to low suitability to support

roosting bats.

Results of Dusk Emergence Survey

No bats were observed emerging from or re-entering the buildings during the dusk emergence survey.

Overall bat activity across the site was low.

Evidence of Nesting Birds No evidence of past or current nesting by birds was noted during the

surveys either within or on the exterior of the buildings or trees.

Predicted Impacts of Development on Bats and

Nesting Birds

Based on the conclusion that bats are unlikely to be using the buildings as a roost site, no negative impacts on bats are anticipated.

Licensing Requirements

for Bats

None Required

Recommendations Precautionary measures and enhancements are detailed in Section 6.


1205: Proposed Student Accommodation, Howard Gardens, Cardiff: Bat Survey Report: September 2017 1

Introduction

1.1. Brief

This report presents the findings of a preliminary bat roost assessment and nesting bird survey of a site

located at Howard Gardens, Cardiff, CF24 0EF (Ordnance Survey Grid Reference: ST 19152 76692). The

buildings and trees proposed for development are referred to as Building 1, Building 2, Building 3 and

trees T1 – T9. The site is situated within the boundary of the City of Cardiff Council.

1.2. Site Description

The site is situated within Cardiff city centre. It consists of an old bowling green currently used as

construction storage with a group of 3 buildings at the north end of the site. The site is currently

bordered by hedgerows on all elevations and interspersed with trees on the northern and southern

boundaries. The location of the site is shown on Plan 1: Location Plan.

1.3. Proposed Works

The buildings are proposed for demolition, to facilitate the redevelopment of the site to provide student

accommodation. It is not currently known if the trees are proposed for felling. Planning permission has

not been sought from the City of Cardiff Council.

1.4. Legislation and Planning Policy

1.4.1. Bats

All UK species of bat are designated as ‘European Protected Species’. Their breeding sites or resting

places1 (roosts) are fully protected under the Wildlife and Countryside Act 1981 (as amended) and the

Conservation of Habitats and Species Regulations 2010.

Works affecting bats are subject to licensing procedures by Natural Resources Wales (NRW). The legal

protection and licensing procedures are summarised in Appendix 1.

1.4.2. Nesting Birds

All wild British birds (whilst building nests, nesting and sitting on eggs) and their nests and eggs (with

certain limited exceptions2) are protected by law under Section 1 of the Wildlife and Countryside Act 1981

(as amended) and the Countryside and Rights of Way Act 2000. Some species, such as barn owls (Tyto

alba), are listed on Schedule 1 and have extra levels of protection including protection from disturbance

whilst nest building and disturbance of dependant young.

1 Resting places are defined ‘as areas that are essential to sustain an animal or group of animals when they are not active’ (Anon

2007). 2 Details of the exceptions is available at http://bit.ly/2tZ40Fk.



1.5. Survey Scope

The survey comprised the following:

• A preliminary bat roost assessment of the tree buildings and trees, which included a survey for

nesting birds;

• One dusk emergence survey of the buildings.

1.6. Reporting

The aims of the report are to:

• Outline the methodology used during the survey;

• Present a summary of the survey methods and results;

• Determine if birds are nesting on site;

• Determine if bats are roosting on site or have potential to roost on site, and if so, identify the

species of bat, roosting location, roost type, numbers of bats present and the location of access

points;

• Determine the need for further targeted surveys on site;

• Provide an interpretation of the findings, in relation to the potential impacts of the development;

• Specify the legal and policy constraints relevant to bats and nesting birds which may affect the

development; and

• Provide an indication of potential licensing requirements and mitigation, compensation and

enhancement measures that may be required.



Methods

2.1. Desk Study

An assessment of the site and surrounding area, including existing habitats from maps and aerial

photographs, was carried out. A Quantum Geographic Information System (QGIS) layer obtained from an

NRW dataset, was used to search for statutory and non-statutory nature conservation designated sites

within 10km (for sites specifically designated for bats) and 2km for other designated sites. A 1km search

was undertaken for Ancient Woodland Sites, together with a data search for relevant pre-existing records

held by South East Wales Biological Records Centre (SEWBReC), the local biological records centre.

2.2. Field Study

2.2.1. Daytime External Inspection (Buildings)

A systematic search was made of the exterior of the buildings, looking for features that bats could use for

entry/exiting and roosting3. In addition, a search was made for the presence of bats or evidence of bat

use, such as their droppings, feeding remains, urine staining, scratch marks and the remains of dead

bats. The survey was undertaken on 17th August 2017 by Hal Starkie4 (NRW Licence No: 76251a, expires

31st July 2019) with the assistance of Liam Maries5/6. A high-powered torch (Clulite), an endoscope,

binoculars and a ladder were used, as appropriate during the survey.

2.2.2. Daytime Ground Level Inspection (Trees)

A preliminary ground-level roost assessment of the trees was undertaken on 17th August 2017 by Hal

Starkie with the assistance of Liam Maries to look for features that bats could use for roosting (Potential

Roost Features (PRF)7) and evidence of bats (i.e. droppings in around or below a PRF; odour emanating

from a PRF; audible squeaking at dusk or in warm weather; or staining below the PRF). The inspection

was carried out systematically around all aspects of the tree (where possible), and from both close to the

trunk and further away.

3 Bats may utilise gaps as small as 8mm by 20mm (Bat Conservation Trust, Cluster flies leaflet). 4 Hal graduated from the Manchester Metropolitan University with a 1st Class Hons. BSc. Wildlife Biology degree and is employed as

an ecologist with Acer Ecology. He has three years’ postgraduate experience of working in ecological consultancy and holds both English (NE Licence No: 2016-24257-CLS-CLS) and Welsh bat licences (NRW Licence No: 72059). He is a member of his local mammal, bat and plant groups and volunteers with the Bat Conservation Trust in his spare time. Further details of his qualifications and experience can be found at https://uk.linkedin.com/in/hal-starkie-b083a4114. 5 Liam is a biological science student and is undertaking his third bat surveying season. He has undertaken training with Acer

Ecology in basic bat ecology, bat survey techniques and bat sound analysis under the tutorship of Daniel Seaward, Rory Jones, Hal Starkie, Alastair Krzyzosiak and Lea Likozar. Further details of his qualifications and experience can be found at http://bit.ly/. 6Liam is listed as a helper on Hal’s license and is allowed to enter roosts to assist in the survey but is not allowed to perform

licensable activities. 7 Potential Roost Features that bats may use include: woodpecker holes; rot holes; hazard beams; other vertical or horizontal

cracks and splits in stems or branches; partially detached flaking bark; knot holes; man-made holes; cankers; other hollows or cavities; double leaders with included bark and potential cavities; gaps between overlapping stems or branches; partially detached ivy with stem diameters greater than 50mm; and bat, bird or dormouse boxes.



The trees were subsequently assessed for their suitability to support roosting and hibernating bats in

accordance with table 4.1 of the Bat Conservation Bat Surreys for Professional Ecologists: Good Practice

Guidelines (Collins, 2016). A high-powered torch (Clulite), binoculars and a ladder were used as

appropriate during the survey

2.2.3. Assessment of Bat Roost Suitability

An assessment of the value of the site for bats (and any potential roost sites therein) was made, in

accordance with Table 4.1 of the Bat Surveys for Professional Ecologists (Collins, 2016) (see Appendix 2).

The assessment was based on the relative abundance and quality of potential roost sites and the habitat

features within both the site and the surrounding landscape suitable for roosting, foraging and

commuting bats.

2.2.4. Dusk Emergence and Dawn Re-entry Surveys

The dusk emergence survey commenced approximately 30 minutes prior to sunset, and continued

approximately 1.5 to 2 hours after sunset.

Surveyors were positioned at viewpoints where they had good sight of all the elevations of the buildings,

so that all potential roosting features could be observed to detect any bat emergence from or re-entry to

the buildings. In addition, bat activity near the buildings was also recorded to help ascertain flight lines.

In accordance with section 2.6.1 of the Bat Conservation Trust’s Bat Surveys for Professional Ecologists

(Collins, 2016) surveys were undertaken during nights with temperatures above 10oC at sunset and

during mornings where the previous sunset temperature was above 10oC. The surveys were also

undertaken in the absence of strong wind (5.4ms and greater which is equivalent to 13mph or Beaufort

4).

2.3. Survey for Nesting Birds

A visual search was undertaken for active bird nests, as well as any signs which might indicate either past

or current nesting, such as guano, singing birds, birds carrying nesting material, food items or faecal sacs

and calling chicks.

2.4. Constraints

General Temporal Constraints

An ecological survey can only identify what was present on site at the time it was conducted, however,

habitat usage by species can change over time.



Restricted Access

Not all parts of the buildings could be inspected during the preliminary roost assessment. All three

buildings were boarded up and locked and therefore only an external inspection was possible on all of the

buildings. However, this was taken into account while making the assessment of the buildings and is not

considered a significant constraint.



Results

3.1. Desk Study

3.1.1. Protected Sites

Statutory Sites Notified for Bats (Sites of Special Scientific Interest (SSSIs) or Special Areas of

Conservation (SACs)) Within 10km

No SACs or SSSIs that have been specially designated for bats lie within 10km of the site.

Other Protected Sites Within 2km

There are no statutory designated sites such as SACs, Sites of Special Scientific Interest (SSSIs), National

Nature Reserves (NNRs) or Local Nature Reserves (LNRs) either within the proposed development site or

within 2km of the proposed development site.

Ancient Woodland Sites

There are no areas of Ancient Semi-Natural Woodland (ASNW), Plantations on Ancient Woodland Sites

(PAWS), Restored Ancient Woodland Sites (RAWS) or Ancient Woodland Site of Unknown Category within

1km of the site.

3.1.2. Bat Records

The data search returned a total of 41 records of bat roosts within 2km of the site. Of the 41 roost

records only six were within 1km of the site. Five of these records from within 1km were recorded within

the last 10 years. The closest roost record is of a pipistrelle bat located approximately 150m from the

site.

In addition to the roost records, SEWBReC returned approximately 300 records of bats foraging or

commuting within 2km of the site.

3.1.3. Roof-nesting Bird Records

The data search returned a total of eight records of roof-nesting birds within 150m of the site. This

included records of four different species; house sparrow (Passer domesticus), starling (Sturnus vulgaris),

swift (Apus apus), lesser black-backed gull (Larus fuscus).

3.2. Field Study

3.2.1. Ecological Context of Site

The site is located within an area providing low quality foraging and commuting habitat for bats as a

result of the urban environment including multiple high-rise buildings, residential properties, proximity to



multiple busy roads (including an arterial road (Newport Road)) and presence of multiple street lamps

and significant light spill from surrounding buildings. There are small areas of trees surrounding the site

and a small cemetery to the south. However, these are generally ecologically isolated and do not form a

continuous habitat corridor with the wider landscape.

3.2.2. Site Description

The three buildings are located along the northern boundary of the site: Building 1 is located in the

north-western corner of the site; Building 2 sits between Building 1 and 3 and Building 3 is located in the

north-eastern corner of the site. In addition, the site is surrounded by a hedgerow which is interspersed

with nine trees on the northern and southern border (Plan 2: Site Plan).

3.2.3. Building Description from the Perspective of Bat Habitat

Building 1

Building 1 is a small timber shed with corrugated asbestos roof and timber clad walls (Photos 1-4). The

ridge tiles sit flush on the roof, however the end ridge tiles appear to provide access into the structure.

The roof and walls, although clearly looking old, are generally in good condition. Wooden bargeboards

are present on the eastern and western gables of the building and gaps are present at the lower corners

of the bargeboards (Photo 5) providing access into the structure. There are a couple of small holes in the

wooden cladding of the walls that were large enough for bats to use as access (Photo 6). Internally the

ceiling of the building is vaulted, creating a small void between the roofing sheets and the wooden

vaulted ceiling. The void could be utilised by roosting bats and nesting birds.

Photo 1: Southern and Eastern Elevations of Building 1

Photo 2: Eastern Elevation



Photo 3: North-Eastern Corner of Building 1

Photo 4: South-Western Corner of Building 1

Photo 5: Gap Under Bargeboard at the South-Eastern Corner of Building 1

Photo 6: Hole in Wooden Cladding of Building 1

Building 2

Building 2 is a small brick building with a steep-pitched clay tiled roof (Photos 7-9). There is a small

extension to the north of Building 2 (Photo 10). The roof is in bad condition with lots of missing and

slipped tiles (Photo 11) providing potential roosting features. The building has been boarded up and

therefore the internal areas could not be inspected.

Photo 7: South-Western Corner of Building 2 Photo 8: North-Western Corner of Building 2



Photo 9: South-Eastern Corner of Building 2 Photo 10: Northern Extension of Building 2

Photo 11: Raised Tiles Around the Chimney of

Building 2

Photo 12: Gaps Under End Roof Tiles

Photo 13: Missing Tiles on the Western Pitch of Building 2

Building 3

Building 3 is a timber clad derelict toilet block with a slate roof (Photos 14-16). The walls and roof are in

good condition, however gaps are present under the end ridge tiles (Photo 17) and where the timber

cladding meets the soffit boxes of the gable walls (Photo 18) providing potential roosting features and

access into the structure.



Photo 14: South-Western Corner of Building 3 Photo 15: South-Western Corner of Building 3

Photo 16: Eastern Gable of Building 3 Photo 17: Gap at End Ridge Tile of Building 3

Photo 18: Gaps Where Timber Clad Walls Meet Soffit Box.

3.2.4. Evidence of Bats

No bats or signs of bats were found in any of the buildings during the initial survey, however due to

access restrictions internal inspections of the buildings could not be carried out.



3.2.5. Tree Inspection from the Perspective of Bat Habitat

No. Description Category

T1 Multi-stemmed sycamore (Acer pseudoplatanus). Approximately 10m tall and 20cm diameter at breast height (DBH). Some ivy cover. No visible

PRFs.

Low suitability

T2 Multi-stemmed sycamore. Approximately 15m tall and 25cm DBH. Some ivy cover. No visible PRFs (see Photo 19).

Low suitability

T3 Multi-stemmed Leylandii species. Approximately 8m tall and 15cm DBH.

No ivy cover or visible PRFs.

Negligible suitability

T4 Palm species. Approximately 10m tall and 30cm DBH. Heavy ivy cover. No

visible PRFs.

Low Suitability

T5 Tightly packed group of Ash (Fraxinus excelsior), palm species. and Leylandii species trees. All approximately 10m tall and 15cm DBH. Palm

has some ivy cover. No visible PRFs.

Palm – Low Ash and Leylandii –

Negligible

T6 Ash. Approximately 15m tall and 35cm DBH. Light ivy cover and no visible PRFs.


T7 Unidentified species. Approximately 10m tall and 15cm DBH. No visible

PRFs.


T8 Multi-stemmed sycamore. Approximately 15m tall and 25cm DBH (see

Photo 20).

Low suitability

T9 Multileader of unidentified species. Approximately 6m tall and 20cm DBH. Heavy ivy cover. No visible PRFs.

Low suitability

Photo 19: T2 Sycamore Photo 20: T8 Sycamore



3.2.6. Dusk Emergence and Dawn Re-entry Surveys

The dusk emergence survey of the buildings was undertaken on the 29th August 2017. During the survey,

there were five surveyors: Hal Starkie8, Emily Panter9, Jess Ware10, Matthew Collins11 and Alan

Bateman12. All of the surveyors were equipped with an Elekon Batlogger, or an Anabat Express coupled

with a heterodyne detector (Elekon Batscanner). The results of the survey are summarised in the table

below and Plan 4:

Survey Number 1 Date: 29th August 2017

Sunset time: 20:06 Start time: 20:50

Finish time: 21:36 Cloud cover: 6/8 oktas

Precipitation: None

Wind13: 2 Sunset temp.: 16oC

Surveyors: 5

Dusk Emergence: No bats were recorded

emerging from or interacting closely with any of the

buildings surveyed.

Bat Activity: Low levels of common and

soprano pipistrelle activity was recorded during the survey.

3.2.7. Nesting Bird Survey

No signs of birds having recently nested in any of the buildings or trees were found during the initial

survey. However, the buildings, hedges and trees on site all have the potential to be utilised by nesting

birds.

8 Hal graduated from the Manchester Metropolitan University with a 1st Class Hons. BSc. Wildlife Biology degree and is employed as

an ecologist with Acer Ecology. He has three years’ postgraduate experience of working in ecological consultancy and holds both English (NE Licence No: 2016-24257-CLS-CLS) and Welsh bat licences (NRW Licence No: 72059). He is a member of his local mammal, bat and plant groups and volunteers with the bat conservation trust in his spare time. Further details of his qualifications and experience can be found at https://uk.linkedin.com/in/hal-starkie-b083a4114. 9 Emily graduated from the University of the West of England with a 2:1 BSc. in Integrated Wildlife Conservation degree and is

employed as a graduate ecologist with Acer Ecology. Prior to this she worked at Natural England gaining a year’s experience within this field. Further details of her qualifications and experience can be found at http://bit.ly/2pYFYfa. 10 Jess graduated with 1st Class Hons. in BSc. Environmental Science from Manchester University and a distinction in MSc

Environmental Biology: Conservation and Resource Management from Swansea University. During her studies she undertook several protected species surveys and worked at Acer Ecology for a year gaining 160 hours of bat surveying experience. Currently Jess is studying a PhD at Swansea University where she continues to gain additional surveying skills for coastal birds, fish and marine invertebrates. 11 Matthew is currently studying Biological Sciences at Cardiff University. 12 Alan graduated from Aberystwyth University with an 2.1 Hons in Geography. He is currently studying for a University Certificate

in Biological recording with Manchester Metropolitan University and has achieved a FISC level 4 with the Botanical Society of the British Isles. He has previously completed Protected Species legislation training with Swansea University Bioscience Department 2014 and has undertaken National Plant Monitoring Scheme and Atlas 2020 recording as a volunteer. He has experience of undertaking practical nature conservation work as self-employed contractor for over 15 years. 13 Estimated on site using the Beaufort scale.



Evaluation

4.1. Summary of Preliminary Roost Inspection and Dusk Emergence Survey

The preliminary roost asessment found no evidence of bats roosting within the buildings or trees on site.

However, a full inspection of the buildings was not possible due to access restrictions.

During the dusk emergence survey, no bats were recorded emerging from or re-entering the buildings.

Bat activity around the site during the survey was low, with low numbers of pipistrelles occasionally

commuting and foraging onthe site.

4.2. Potential Summer Roosts (Buildings)

The building was assessed as having low suitability for use by crevice-dwelling bats; low suitability for

use by roof-void dwelling bats; and negligible suitability for use by direct access species (horseshoe

species). Full justification of the assessment can be found in the Appendix 2C. This assessment was used

to determine the number of dawn re-entry and dusk emergence surveys required (see Appendix 2B).

4.3. Potential Summer Roosts (Trees)

No signs of roosting bats were found on site. The potential for trees surveyed to support roosting bats

was assessed as negligible or low.

4.4. Potential Hibernation Roosts

It is possible that the buildings on site could be used by crevice-dwelling hibernating bats, but this is

considered highly unlikely14, due to the following factors:

• The lack of direct evidence of bats found using the buildings during the preliminary roost

inspection15 and during the dusk emergence survey;

• The lack of underground or subterranean features;

• Much of the buildings fabric is exposed to the elements, and is likely to be subject to sub-

zero conditions in winter;

• The roof of Building B1 is of corrugated metal;

• The walls of the buildings are generally well-mortared lacking deep penetrating crevices

suitable for entry by bats; and

• The site is likely to be subject to disturbance and environmental variations.

14 Pipistrelle bats are sometimes found hibernating adjacent to their breeding roosts in secure locations such as cavity walls that

have relatively stable temperatures. Other individuals disperse to roost in small numbers in more exposed locations such as around window frames. Often there are often no obvious external signs of their presence (JNCC, 2004). Because of the highly-exposed location of hibernation sites used by some individuals, it is very difficult to completely rule out hibernation use by this species in almost any building that has some very shallow crevices, openings or gaps. 15 Due to the low levels of activity of bats in hibernation sites relatively few droppings are produced.



4.5. Birds – Interpretation of Nesting Bird Survey

No signs of birds having recently nested in any of the buildings or trees were found.



Potential Impacts of Development

Potential Direct Impacts

Based on the conclusion that bats are unlikely to be using the buildings or trees as roost sites, no

negative impacts on bats are anticipated.

Potential Indirect Impacts

No regularly used bat commuting routes/ or highly used foraging areas were observed and no bat species

that are particularly light-sensitive (horseshoe bats, Natterer's bat (Myotis nattereri), long-eared bats

(Plecotus species) etc. were recorded on site. The development may result in the loss of foraging habitat

for low numbers of pipistrelle bats.



Recommendations

6.1. Precautionary Measures (Buildings)

Given the lack of any evidence of any use by bats, it is highly unlikely that the development proposals will

have any impact on bats or their roosts. No precautionary timing restrictions on works are necessary.

However, it is not possible to rule out bat use entirely, and there is also a risk of an offence being

committed if active birds’ nests are present. The following recommendations are made to minimise risks

to bats and birds:

• It will be clearly understood that in the event of any bats (or occupied birds’ nests) being found,

the contractor must halt works (if bats are encountered, the bat will be carefully covered over

again), and appropriate advice will be obtained from a suitably qualified bat and bird consultant

or Natural Resources Wales and, if necessary, a bat development licence obtained before work

can resume;

• Contractors will check for the possible presence of bats on the undersides of roofing tiles/ sheets,

ridge tiles, fascias, soffits and barge boards etc. as they are lifted off. This is especially important

at the outset of the works, since once the works have started, the disturbance is likely to drive

any bats which are present away voluntarily; and

• The services of an appropriately qualified and licensed ecological consultant will be available on

an ‘on-call’ basis at all stages of the works to deal with any unexpected encounters with bats or

nesting birds. Contact details of such will be held on site. Acer Ecology Ltd. will be happy to

provide this support.

6.2. Precautionary Measures (Trees)

Due to the negligible/ low assessment of the trees surveyed no further surveys are required to confirm

presence/ absence of bat roosts (Table 7.1 BCT, Bat Surveys for Professional Ecologists, Good Practice

Guidelines 2016). However, the following precautionary recommendations are made to help ensure no

negative impacts occur directly to bats or their roosts:

• If possible, felling the trees should take place between October and February to coincide with the

period of lowest bat activity and likelihood of bats being absent. This timescale would also

eliminate the risk of causing accidental harm to nesting birds;

• Tree surgeons undertaking felling works should be warned of the possible presence of roosting

bats (and/or nesting birds), and of their protected status. It should be clearly understood that in

the event of any bats (or occupied birds’ nests) being found the contractor must halt works in the

area surrounding the roost (at least 15m from the identified roost) and advice sought from the

bat consultant or Natural Resources Wales;



• If any hollow sections, limbs with cavities, PRFs etc are observed by the contractors working on

the trees then work will stop and an appropriately qualified ecologist (licensed bat worker who is

qualified to use endoscopes) will be called to site to thoroughly inspect the PRF before work

continues. If the ecologist assesses the feature as having moderate or high suitability for roosting

bats then further survey work will be required before work can continue;

• Particular care should be taken when cutting into any obvious cavities, splits or hollows, with

frequent checking to make sure that no bats (or birds) are concealed within; and

• The services of an appropriately qualified and licensed bat consultant should be available on an

‘on-call’ basis at all stages of the works to deal with any unexpected encounters with bats or

nesting birds.

6.3. Ecological Enhancement for Bats

The Environment (Wales) Act 2016, Planning Policy Wales (Edition 8, January 2016), TAN 5 Nature

Conservation and Planning (2009) and Biodiversity supplementary planning guidance stipulate that

development projects minimise ecological damage and contain elements of ecological enhancement.

Ecological enhancements measures could be provided within the proposal and could include purpose-built

bat roosting boxes being installed, either on the exterior of the buildings or incorporated directly into the

structure of the walls.

In addition, consideration could be given to using landscaping to provide habitat suitable for bats by

encouraging night flying invertebrates. Plant species that provide a rich source of nectar should be used.

Suitable species include flowering herbs such as lavender (Lavendula spp.), violets (Viola spp.); or shrubs

such as flowering currant (Ribes sanguineum), privet (Ligustrum vulgare), forsythia (Forsythia spp),

dogwood (Cornus sanguinea), berberis (Berberis spp), pyracantha (Pyracantha sp) and ceanothus

(Ceanothus sp).



References

Anonymous (2007) Guidance document on the strict protection of animal species of Community

interest under the Habitats Directive 92/43/EEC. Final version, February 2007.

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

Bat Conservation Trust, London.

Southern E (1986) Glamorgan: Inventory of Ancient Woodlands (Provisional). Nature Conservancy

Council, Peterborough.



Plan 1: Location Plan



Plan 2: Site Plan



Plan 3: Protected Site Map



Plan 4: Dusk Emergence Survey Results (29/08/2017)



Appendix 1: Bat Ecology and Legislation Protecting Bats and Their Roosts

Bat Ecology

There are 17 known breeding species of bat found in the UK, with additional species recorded as

migrants or vagrants. All of them are small, nocturnal, flying, insectivorous mammals that are under

conservation threat and many having undergone massive population declines over the last century. Some

species, such as pipistrelle bats are relatively common and widespread in the UK, while others, such as

greater horseshoe (Rhinolophus ferrumequinum) bats, have an extremely restricted distribution.

Most bats will use a variety of roosts of different types throughout the year. The winter hibernation sites

typically have cool, humid conditions with a stable microclimate and low levels of disturbance. Most

British bats hibernate in caves or artificial structures that fulfil these requirements such as mines, tunnels

and cellars. Bats emerge from hibernation around late March or early April and move into transition or

intermediary roosts. Around early May, female bats gather in colonies to form summer or maternity

roosts, and it is here where they will give birth between late May and early July. A colony may consist of

many individuals (sometimes hundreds of bats) of mixed age and sex. Roosts may be in a variety of

habitat types including tree-holes, caves, buildings and other secure crevices or internal spaces with

appropriate stable temperatures and humidity. Bats may change roost locations many times during a year

and colonies may split up and reform during this period. Males occupy solitary roosts in autumn, to which

they attract females for mating.

Legislation

All British bat species and any place used for shelter or protection, or a breeding site or resting place

(their roosts) are fully protected under the amended Wildlife and Countryside Act 1981 through inclusion in

Schedule 5. The roosts are protected irrespective of whether bats are present at the time. All bats are

‘European Protected Species’ and fully protected under the Wildlife and Countryside Act 1981 (as

amended) and the Conservation (Natural Habitats etc.) Regulations 1994, updated and consolidated by

the Conservation of Habitats and Species Regulations 2010.

These pieces of legislation make it illegal to deliberately or recklessly:

• kill, injure or capture bats;

• disturb bats;

• damage, destroy, or obstruct access to bat roosts (including sites that are currently unoccupied);

• possess or transport a bat or any part of a bat unless acquired legally; or

• sell, barter or exchange bats or parts of bats.

Disturbance is defined as that which is likely to impair bats ability:

• to survive, to breed or reproduce, or to rear or nurture their young;

• to hibernate or migrate; or



• to affect significantly the local distribution or abundance of the species to which they belong.



Habitats Regulations Licensing

If a European Protected Species will be affected by a development, Natural Resources Wales (NRW) can

issue licences under the Habitats Regulations to permit otherwise prohibited acts. Licences for certain

activities can be granted providing “3 tests” are satisfied, that is:

1. the purposes of “preserving public health or safety, or for reasons of overriding public interest,

including those of a social or economic nature and beneficial consequences of primary importance

for the environment”;

2. there must be “no satisfactory alternative”; and,

3. the derogation is “not detrimental to the maintenance of the population of the species concerned at

a favourable conservation status in their natural range”.

Licences are issued by NRW, with NRW assessing Test 3, and the Local Planning Authority assessing tests

1 & 2 (where proposals are not subject to planning, then NRW alone will assess all three tests). Where

Planning regulations apply, NRW will only issue a licence after determination of the planning application.

The licence application will require the production of a detailed method statement, which sets out the

activities to be carried out under the licence to minimise the risk of bats being harmed during

construction works, and to ensure that bats will be conserved during the development of the site. This

will need to detail the mitigation proposed (such as the replacement or compensation roost), the

timescale and schedule of works, the number, size and locations of bat access points to be provided, the

type of materials to be used (roofing material, roof lining, fascias, soffits and bargeboards etc.), lighting

proposals, action to be taken in the event bats are found during works and a post-development

monitoring programme. The method statement will need to be accompanied by scaled plans and maps

detailing the bat mitigation features. A cross-section of the access points and roost space is often

required. The method statement must ensure that provision is made for new or continued roosting

opportunities after the completion of development works. In some instances, a method statement is

requested by the Local Planning Authority or Natural Resources Wales before the planning application is

determined.

Environment (Wales) Act 2016

The Environment (Wales) Act 2016 dictates that Local authorities have a duty to have regard to the

conservation of biodiversity in exercising their functions. The duty affects all public authorities and aims

to raise the profile and visibility of biodiversity, to clarify existing commitments relating to biodiversity,

and to make it a natural and integral part of policy and decision making. Part 1 Section 7 of the Act

provides a list of the ‘living organisms of principal importance for maintaining and enhancing biodiversity

in relation to Wales’. This includes seven bat species (soprano pipistrelle, barbastelle, Bechstein’s,

noctule, brown long-eared, lesser horseshoe and greater horseshoe bats).



Appendix 2: Guidelines for Assessing Potential Suitability of Buildings for

Bats and Determining the Number of Flight Surveys Required

Suitability Description of Roosting Habitat Minimum Number of Flight Surveys

Required (Collins 2016)16

Negligible Negligible habitat features on site likely to

be used by roosting bats.

None.

Low A structure with one or more potential

roost sites that could be used by individual bats opportunistically. However,

these potential roost sites do not provide enough space, shelter, protection

appropriate conditions17 and/or suitable surrounding habitat to be used on a

regular basis or by larger numbers of bats

(i.e. unlikely to be suitable for maternity) or hibernation18.

One survey visit. One dusk emergence or

dawn re-entry survey (Survey period from May to August).

Moderate A structure with one or more potential

roost sites that could be used by bats due to their size, shelter, protection,

conditions and surrounding habitat but

unlikely to support a roost of high conservation status19 (with respect to

roost type only) the assessments in this table are made irrespective of

conservation status, which is established

after presence is confirmed.

Two separate survey visits. One dusk

emergence and a separate dawn re-entry survey20. Surveys should be undertaken

from May to September with at least one of

the survey between May and August.

High A structure with one or more potential

roost sites that are obviously suitable for use by larger numbers of bats on a more

regular basis and potentially for longer

periods of time due to their size, shelter, protection, conditions and surrounding

habitat.

Three separate survey visits. At least one

dusk emergence and a separate dawn re-entry survey. The third visit could be either

dusk or dawn. Surveys should be

undertaken from May to September with at least two of the surveys from May to

August.

Confirmed Roost

Evidence of bats or use of bats found. Minimum of two required to characterise the roost21.

16 Adapted from tables 7.1 and 7.3 of the Bat Surveys for Professional Ecologists: Good Practice Guidelines (Collins, 2016). 17 For example, in terms of temperature, humidity, height above ground levels, light levels or levels of disturbance. 18 Evidence from the Netherlands, shows mass swarming events of common pipistrelle bats in the autumn followed by mass

hibernation in a diverse range of building types in urban environments (Korsten et al., 2015). This phenomenon requires some research in the UK but ecologists should be aware of the potential for large numbers of this species to be present during the autumn and winter in large buildings in highly urbanized environments. 19 ‘High roost status’ is not defined within Collins, 2016. Acer Ecology Ltd. interpret maternity, hibernation, swarming sites, mating

sites, and satellite roosts as being of ‘high roost status’ and exclude day roosts, night roosts, feeding roosts, transitional/occasional roosts from this definition. Pre-maternity/collecting roosts are not included within Collins, 2016 and will be assessed on an individual basis. 20 Multiple surveys should be spread out to sample as much of the survey period as possible. It is recommended that surveys are

spaced at least two weeks apart, preferably more. A dawn survey immediately after a dusk survey is considered only one visit. 21 If it is is not possible to characterise the roost on the basis of two surveys, additional surveys may be required.



Appendix 3: Guidelines for Assessing Bat Suitability

Suitability Commuting and Foraging Habitat

Negligible Negligible habitat features on-site likely to be used by commuting and foraging bats.

Low Commuting Habitat Habitat that could be used by small numbers of commuting bats such as a gappy

hedgerow or un-vegetated stream, but isolated, i.e. not very well connected to the surrounding landscape by other habitat.

Foraging Habitat

Suitable but isolated habitat that could be used by small numbers of foraging bats such as a lone tree (not in a parkland situation) or a patch of scrub.

Moderate Commuting Habitat

Continuous habitat connected to the wider landscape that could be used by bats for

commuting such as lines of trees and scrub or linked back gardens.

Foraging Habitat

Habitat that is connected to the wider landscape that could be used by bats for foraging such as trees, scrub, grassland or water.

High Commuting Habitat

Continuous high-quality habitat that is well connected to the wider landscape that is likely to be used regularly by commuting bats such as river valleys, streams, hedgerows,

lines of trees and woodland edge.

Foraging Habitat High-quality habitat that is well connected to the wider landscape that is likely to be

used regularly by foraging bats such as broadleaved woodland, tree-lined watercourses and grazed parkland.

Proximity to Known Bat Roosts

Site is close to and connected to known roosts.



Appendix 4: Assessment of Suitability of Building to Support Roosting Bats

The buildings have been assessed as having:

• Low suitability for use by crevice-dwelling bats (Pipistrellus species and smaller Myotis species

such as Brandt’s (Myotis brandtii) and whiskered bats (Myotis mystacinus)) due to the presence

of potential Access and roosting features such as raised, slipped or missing roof tiles, gaps under

bargeboards, fascias and soffits and the space between the vaulted ceiling and asbestos sheeting

on Building 1. However, the site lies in an area of low quality foraging and commuting habitat

which reduces the buildings suitability to support roosting bats;

• Low suitability for use by roof void-dwelling bats (long-eared species22 (Plecotus species), large

Myotis species such as Natterer’s bat (Myotis nattereri)) due to the presence of potential access

points such as gaps under bargeboards, fascias and soffits, holes in wooden cladding and raised,

slipped or missing roof tiles; and

• Negligible suitability for use by direct access species requiring a large access point and large

roost space (lesser (Rhinolophus hipposideros) and greater horseshoe (Rhinolophus

ferrumequinum)) due to the lack of direct access to any of the buildings.

The building has been assessed as having low suitability for crevice-dwelling and roof-void dwelling. This

assessment will be used to guide the level of further survey effort required (see section 5 and Appendix

2).

22 It should be noted that in non-maternity roosts long-eared bats can make use of crevice features without gaining access into a

roof void.

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