© RSK ADAS 2017

1 Summary .................................................................................................................................. 1

2 Protected species and important habitats on or near the site ..................................................... 1

2.1 Bats .....................................................................................................................................................1

2.2 Reptiles ................................................................................................................................................1

2.3 Nesting birds .......................................................................................................................................1

2.4 Trees and hedgerows ..........................................................................................................................1

2.5 Grassland ............................................................................................................................................2

3 Risk Assessment of Potentially Damaging Construction Activities ............................................... 2

3.1 Site Clearance ......................................................................................................................................2

3.2 Site Set-up ...........................................................................................................................................2

3.3 Groundworks .......................................................................................................................................2

3.4 Construction ........................................................................................................................................2

3.5 Final Site Clearance and Landscaping .................................................................................................3

3.6 Environmental incidents ......................................................................................................................3

4 Method Statement .................................................................................................................... 3

4.1 Ecological Method Statement .............................................................................................................3

4.2 Tree protection ....................................................................................................................................5

4.3 Environmental protection ...................................................................................................................5

4.4 Final Site Clearance and Landscaping .................................................................................................6

4.5 Lighting ...............................................................................................................................................6

5 Timing of mitigation works ........................................................................................................ 6

6 Responsible Persons and Lines of Communication ...................................................................... 8

7 The Use of Protective Fences, Exclusion Barriers and Warning Signs ........................................... 9

8 References .............................................................................................................................. 10

© RSK ADAS 2017

Appendix 1: Relevant Legislation ....................................................................................................... 1

1 Statutory Sites of Nature Conservation Importance .................................................................... 1

1.1 European Sites (SAC/SPA) ...............................................................................................................1

1.2 Site of Special Scientific Interest (SSSI)............................................................................................1

2 Natural Environment & Rural Communities Act 2006 ................................................................. 1

3 Other Relevant Legislation ......................................................................................................... 1

3.1 Non-native Species ..............................................................................................................................1

3.2 Injurious Weeds ...................................................................................................................................2

3.3 Hedgerows ..........................................................................................................................................2

3.4 Reptiles ................................................................................................................................................2

3.5 Birds ....................................................................................................................................................2

3.6 Bats .....................................................................................................................................................2

Appendix 2: Tool box talk/induction .................................................................................................. 1

Appendix 3: Construction mitigation plan .......................................................................................... 1

© RSK ADAS 2017

Author Checked Approved

Francesca Lemon BSc(Hons)

MSc MCIEEM

James Packer BSc(Hons)

MCIEEM

Francesca Lemon BSc(Hons)

MSc MCIEEM

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This report has been commissioned for the exclusive use of the commissioning party unless otherwise agreed in

writing by RSK ADAS Ltd; no other party may use, make use of or rely on the contents of the report. No liability is

accepted by RSK ADAS Ltd for any of this report, other than for the purposes for which it was originally prepared and

provided.

Opinions and information provided in this report are on basis of RSK ADAS Ltd using due skill, care and diligence in

the preparation of this report and no explicit warranty is provided as to its accuracy. It should be noted that no

independent verification of any of the documents supplied to RSK ADAS Ltd has been made.

Revision Date Amendment

© RSK ADAS 2017 1

This ‘Construction and Environment Management Plan’ details the method of works that will be

adopted to avoid ecological impact during construction works of a new car park extension proposed

at Dorothy House Hospice, Winsley, Wiltshire (National Grid Reference ST797607). It has been

prepared by RSK ADAS Ltd to support a planning application for the new car park extension.

A plan showing the location of ecological mitigation on site is found in Appendix 2.

Relevant legislation is shown in Appendix 1.

The site is next to ‘Winsley Mines’ Site of Special Scientific Interest (SSSI), which is part of ‘Bath

and Bradford on Avon Bats’ Special Area of Conservation (SAC). This is an important

hibernation site for the nationally scarce Greater Horseshoe Bat (supports up to 5% of Greater

Horseshoe Bats in the UK) as well as nationally scarce Lesser Horseshoe Bats.

Horseshoe bats avoid artificial lighting as they are especially sensitive to light.

The site supports a small population of Slow-worm. Hedgerow, woodland boundaries and

species-rich grassland provide suitable habitat.

Hedgerows, scrub and trees on site provide suitable bird nesting habitat in the bird nesting

season. The grassland, being grazed, was considered unsuitable for nesting birds however it

may become suitable if grazing ceases. The main nesting season is generally considered

between March and August inclusive (although birds can sometimes nest outside these

times).

Woodland, trees and shrubs to the south of the site and along the western boundaries are

important bat foraging habitat and dispersal corridors (as well as important for reptiles and

nesting birds).

© RSK ADAS 2017 2

Grassland to the south of Dorothy House is mostly semi-improved neutral grassland, with

patches of calcareous grassland on thinner soil, which is moderately species-rich. Species-rich

grassland supports a diversity of invertebrates which are important for foraging bats and

reptiles. Cattle grazed pasture to the west of Dorothy House is also important for foraging

Horseshoe bats which are known to feed on invertebrates associated with manure (especially

cattle manure).

Hazards arising from the clearance of scrub, trees, shrubs and ground vegetation and from removal of

logs or debris if present:

Destruction of birds’ nests during scrub/tree clearance.

Harm to reptiles during grassland clearance.

Accidental physical damage to retained trees and subsequent impact to bat foraging corridors.

Hazards arising from installation of any protective fencing, temporary compounds (including

temporary latrines), site lighting and temporary storage of materials, spoil and waste.

Disturbance of nocturnal species including commuting or foraging bats if artificial lighting is

used.

Harm to reptiles if they are occupying the area at the time of site clearance.

Accidental damage to trees and subsequent impact to bat foraging corridors.

Hazards arising from earthworks and construction works.

Harm to reptiles if they are occupying the area at the time of site clearance.

Accidental damage to retained trees and subsequent impact to bat foraging corridors.

Trapping or injuring of animals (e.g. Badger or Hedgehog) within excavations.

Hazards arising from dust, noise or use of aggregate/cement or tarmac (if used) for car park

construction.

© RSK ADAS 2017 3

No piling works are proposed so there is not expected to be significant vibration/noise

disturbance to hibernating bats (Horseshoe bat hibernation site c.100m west of the site).

Habitat degradation to retained trees and grassland on site via dust deposition or

washings/leaching from car park construction aggregate/surfacing materials.

Hazards arising from the disposal of wastes, final site clearance and landscaping.

Pollution by leaching of fertiliser, herbicides/pesticides or use of potentially hazardous

materials.

Fuel leaks and spillages.

Damage to retained trees and grassland.

The nearest watercourses are the Kennet and Avon Canal (c. 220m south of the site) and the

River Avon (c.250m south of the site, south of the canal). These watercourses are unlikely to

be impacted by works due to distance from the site.

The following are measures to avoid or mitigate effects on species and habitats relevant to the

construction activities:

There will be no outside artificial lighting during main construction works – which will be

undertaken during daylight hours. Artificial lighting will only be used inside temporary

compound areas/welfare facilities for security and health and safety purposes. It will be low

intensity, short duration (i.e. porta-cabin doors will be kept closed), low tilted and will be

directed into the site and away from hedgerows or woodland boundaries to avoid impact to

bats.

All site operatives will be given a ‘Tool Box’ talk on the importance of the site for bats and other

species.

Six boundary trees need to be removed from the western boundary to allow for new car park

spaces. Tree felling (and any clearance of any other vegetation suitable for nesting birds) will

be undertaken between September and February to avoid the bird nesting season (which is

generally March to August inclusive) where possible. If clearance is required during the bird

© RSK ADAS 2017 4

nesting season, then a thorough inspection will be undertaken within a period of up to 24 hours

prior to removal to ensure that no nests are destroyed or disturbed. If any active nests are

found they will remain undisturbed, leaving at least a 5m buffer of vegetation around them, if

possible, until the young have fledged (left the nest).

The six boundary trees, to be removed, were young or semi-mature and had no obvious

features suitable for roosting bats. The larger two trees were considered ‘low potential’ for

roosting bats as although they had no obvious ‘potential roost features’ (PRF’s), they were of

sufficient size and age to potentially have PRF’s which may not be visible from a ground

inspection. These trees should be ‘soft-felled’ as a precautionary measure. ‘Soft felling’ would

involve aerial inspection and sectional felling of trees. Any limbs which are found to have any

cracks and crevices potentially suitable for roosting bats should be carefully lowered to the

ground with ropes and left at the base of the tree for at least 48 hours to allow any bats to

disperse, if present.

Timber from the felled trees will be cut to lengths of approximately 1m-1.5m and used to

construct at least three reptile hibernacula (log piles covered with chippings and soil) which

will be installed along the southern boundary - under supervision of an ecologist or person

experienced in hibernacula creation. If the logs have been stored prior to creation of

hibernacula, they must be moved by hand to a new pile, taking care to avoid harming any

reptiles, amphibians or hedgehogs within the pile. Any animals found will be allowed to move

away unharmed.

Brash can be used to form small ‘habitat piles’ or chipped into small piles located within the

tree boundaries. Chippings will not be deposited on grassland.

During the reptile active season (April to October) any tall grassland vegetation within the

proposed development area will be reduced to a height of approximately 10-15cm c.7-10 days

prior to site clearance (to avoid harm to reptiles and to make the area less suitable for them).

A hand search for reptiles will be undertaken by an ecologist immediately before site clearance.

The area will then be stripped using an excavator under supervision of the ecologist.

Any deep excavations will be covered overnight or ramps installed to prevent Badgers and

other animals from falling in and becoming trapped. Any open pipework over 1500mm

diameter will be capped overnight. Daily inspections will be carried out to ensure mammals

are not trapped in excavations.

© RSK ADAS 2017 5

In order to avoid compaction, there should be no vehicle or plant access or storage of vehicles

or equipment within tree root protection areas. There will be no excavations within 1m of tree

trunks (‘prohibited zone’). If any excavation works need to be undertaken within the

‘precautionary tree root zone’ (4 x trunk circumference) then this will need to be undertaken

carefully by hand avoiding damaging any ‘structurally important’ roots (>25mm) which should

be protected. Care should be taken when planning site operations to ensure that wide or tall

loads, or plant with booms, jibs and counterweights can operate without coming into contact

with retained trees.

Where required, trees and their root zones along site boundaries will be protected from works

by temporary tree protection fencing as per British Standard BS5837. This will be done prior to

any heavy machinery or materials being brought onto site to commence construction.

The main contractor will supply environmental method statements which will detail how dust and air

pollution, pollution from fuel use and storage and other potentially hazardous materials will be

controlled. Good housekeeping procedures will be employed to prevent the build-up of waste

materials in uncontrolled locations.

The contractor will be responsible for pollution prevention for the duration of the contract and until

such time as permanent measures, such as permanent drainage, are deemed to be adequate and

appropriately constructed. This responsibility will include the actions of any third party who is sub-

contracted or otherwise involved in the project.

The contractor will also be responsible for obtaining all necessary consents, licenses and permissions

for activities as required by current legislation governing the protection of the environment.

Measures to protect the environment will include:

Material which will contaminate the soil, e.g. diesel oil and vehicle washings, will not be

discharged on the site. Precautions will be put in place to avoid/mitigate against potential run-

off and discharge of any chemicals, pollutants if these are used or temporarily stored on site

(e.g. bunds, use of spill kits, regular checks of plant and equipment, not leaving plant running

idle, re-fuelling off-site where possible, or storing fuel in lockable, bunded tanks).

If top soil or other materials (e.g. aggregate) are imported onto the site this will be free of any

non-native invasive plants/or seeds or harmful chemicals/substances.

No herbicide or pesticide will be used nor stored on site unless specifically authorised.

© RSK ADAS 2017 6

Defined work areas will be clearly delineated using appropriate fencing around the car park

development area – which will not extend into surrounding grassland or woodland areas. No

unauthorised construction works, machinery, workers or storage of materials will be allowed

outside of these areas or in the surrounding grassland or woodland.

Landscape planting will be undertaken in the first season after completion of the development.

Detailed specifications for planting are provided in the Landscape and Ecological Management Plan

(ADAS, 2016) and planting will be in strict accordance with the Planting Plan. All tree planting is to be

in accordance with BS8545:2014.

The lighting of the new and existing car park will be as per agreed lighting layout plans: drawing

numbers 0468-DFL-1301_K [2m Above Ground Level] and 0468-DFL-1301_K [Ground Level] (to avoid

impact to bats and their hedgerow foraging corridors). These plans show indicative lighting column

locations. There may need to be minor adjustment required (e.g. to the locations of 1 or 2 lighting

columns) due to potential for buried services or other construction difficulties however the final

lighting layout will be in accordance with the agreed lighting strategy.

A light test will be undertaken once the lighting is installed to ensure it meets the mitigation

requirements. This will be a horizontal illuminance survey by a competent professional to ensure the

levels of spill light are equal to or less than that originally calculated at ground level. Ensuring the light

meter has a valid calibration certificate.

A competent ecologist will oversee the construction of the reptile hibernacula and site clearance

works.

The table below shows the proposed times that works will be undertaken to ensure that construction

works do not adversely affect biodiversity.

© RSK ADAS 2017 7

Table 5.1: Timings of works to be undertaken to ensure construction works do not adversely affect

biodiversity.

Period Action When Rationale Ecological

Clerk of

Works

Pre-

construction

The six boundary trees to be

removed will be cut to

ground level. The two larger

trees will be ‘soft-felled’.

Ideally

between

September

and February

inclusive

To avoid harm to

nesting birds (main

nesting bird season is

March to August

inclusive).

Soft-felling is a

precautionary

measure to avoid

harm to bats.

Yes if

required in

nesting

bird season

Pre-

construction

Use logs from the felled trees

to create reptile hibernacula.

After tree

felling (above)

To create habitat for

reptiles, small

mammals and

invertebrates

Yes

Pre-

construction

Any tall grassland vegetation

within the proposed

development area will be

reduced to a height of

approximately 10-15cm c.7-

10 days prior to site

clearance

During the

reptile active

season (April

to October)

To avoid harm to

reptiles and to make

the works area less

suitable for them.

No

Pre-

construction

Installation of temporary tree

protection fencing if required

Before

construction

works

To protect trees and

their root zones during

works

No

Construction A hand search for reptiles will

be undertaken by an

ecologist immediately before

site clearance. The area will

then be stripped using an

excavator with a toothed

bucket under supervision of

the ecologist.

During the

reptile active

season (April

to October) –

immediately

before site

clearance

To avoid harm to

reptiles and small

mammals.

Yes

© RSK ADAS 2017 8

Construction Landscape planting (as per

Landscape and Ecological

Management Plan)

November to

March

Optimal to ensure

survival of trees and

shrubs

No

Post-

construction

A light test (horizontal

illuminance survey) will be

undertaken once the lighting

is installed to measure lux

levels to ensure it meets the

mitigation requirements. The

council will be notified of

compliance.

After

installation of

car park

lighting

To ensure bats and

their foraging

corridors are not

impacted.

No

Post-

construction

Tree and shrub landscaping

aftercare

(see details in Landscape and

Ecological Management Plan)

5 years post

construction

To ensure survival or

replacement of trees

and shrubs

No

Post-

construction

Bat monitoring

(see details in Landscape and

Ecological Management Plan)

At least in

years 1 and 2

after

construction.

If there is a

change in bats

usage of the

site further

survey and

remedial

action would

be required.

To determine any

change in bat usage of

the site once the car

park is in operation.

Yes

This CEMP is intended to be supplied to and agreed by the Site Manager prior to commencement of

any works on site. Copies of the CEMP will be available for inspection on site.

The Site Manager will be responsible for ensuring that the CEMP and associated method statements

are adhered to during day to day works.

© RSK ADAS 2017 9

In the event of a protected species being found, an unforeseen incident threatening the ecology of

the site or if ecological advice is required ecological advice will be sought from:

Francesca lemon

Senior Ecology Consultant

ADAS

Bristol

Tel: 0117 2444003

Mobile: 07791 381161

E-mail: Francesca.lemon@adas.co.uk

Tree protection fencing will be installed prior to ground works. Fencing will consist of 2 metre tall

welded mesh panels on rubber feet joined with a minimum of 2 anti-tamper couplers so that they can

only be removed from the inside of the fence and be at least 1 metre apart in accordance with BS5837:

2012 6.2.2.3.

© RSK ADAS 2017 10

ADAS (2016). Ecological Impact Assessment: Dorothy House, Winsley. ADAS, Bristol.

ADAS (2016). Landscape and Ecological Management Plan: Dorothy House, Winsley. ADAS, Bristol.

BS 42020:2013. Biodiversity – Code of Practice for Planning and Development. BSI Standards

Publication.

© RSK ADAS 2017 i

Habitats of European-wide importance (other than for birds) are listed under Annex I of the Council

Directive 92/43/EEC on the conservation of natural habitats and of wild fauna and flora (EC Habitats

Directive). Habitats designated under this Directive are Special Areas of Conservation (SACs).

Habitats of European-wide importance for birds are listed under the EC Wild Birds Directive

(EC/79/409/EEC). Habitats designated under this Directive are Special Protection Areas (SPAs).

The Conservation of Habitats and Species Regulations 2010 (as amended) requires the competent

authority to carry out an ‘appropriate assessment’ where a plan or a project, either alone or in

combination with other plans or projects, is likely to have a significant effect on Natura (European) site,

i.e. SAC or SPA.

Areas notified under the Wildlife and Countryside Act, 1981 by Natural England as being of special interest

for nature conservation. Statutory Undertakers are required to seek Natural England assent before any

listed, potentially damaging operations, development or change in land use etc. can be carried out.

Section 40 of the NERC Act 2006 places a duty upon all local authorities in England to promote and

enhance biodiversity in all of their functions. Section 41 lists habitats and species of principal importance

to the conservation of biodiversity. Fifty-six habitats and 943 species of Principal Importance for

Conservation are included on the Section 41 list.

These are all the habitats and species in England that have been identified as requiring action in the UK

Biodiversity Action Plan (UK BAP) and are a material consideration in the planning process.

Section 14 of the Wildlife and Countryside Act 1981 (as amended) prohibits the introduction into the wild

of any species of animal or plant that is not ordinarily resident in, and is not a regular visitor to, Great

Britain in a wild state, or any species of animal or plant listed on Schedule 9 of the Act. Commonly

occurring non-native species in the countryside include Japanese Knotweed, Himalayan Balsam and Giant

© RSK ADAS 2017 ii

Hogweed. The Schedule also includes commonly occurring garden species such as Cotoneaster spp.,

Montbretia and Rhododendron.

Five weeds are classified under the Weeds Act 1959: Common Ragwort, Spear Thistle, Creeping Thistle,

Broad-leaved Dock and Curled Dock. It is not illegal to allow these weeds to grow on one’s land, however

they must not be allowed to spread to agricultural land, particularly grazing areas or land which is used to

produce conserved forage.

Hedgerows are protected by the Hedgerows Regulations 1997, under which it is an offence to remove or

destroy certain hedgerows without permission from the Local Planning Authority.

These regulations do not apply to any hedgerow within the curtilage of, or marking the boundary of the

curtilage of, a dwelling house.

Common reptiles: Slow-worm, Adder, Grass Snake and Common Lizard are protected under the Wildlife

and Countryside Act 1981 (as amended). It is illegal to kill or injure them.

It is not illegal to capture, disturb or to damage their habitats. However, the reptiles themselves are

protected so any works to damage their habitat could risk causing harm to reptiles and hence could be

illegal.

Wild birds are protected under the Wildlife and Countryside Act 1981 (as amended). It is illegal to take or

harm them, their nests (whilst in use or being built) or their eggs.

Additionally for some species listed in Schedule 1 of the Act it is an offence to intentionally or recklessly

disturb the adults while they are in and around their nest or intentionally or recklessly disturb their

dependent young.

Bats are protected under the Wildlife and Countryside Act 1981 (as amended) and the Conservation of

Habitats and Species Regulations 2010 (as amended). It is illegal to kill or injure bats, cause disturbance

at their resting places or to block access to, damage or destroy their roost sites.

© RSK ADAS 2017 i

The following measures need to be communicated to site staff within the tool box talk / site

induction.

Protected species wildlife species are present on site that are protected by UK and European

legislation.

There must be no use of artificial lighting except if required for security or health and safety

reasons. If artificial lighting is needed it must be low intensity, short duration, low tilted and

facing into the site i.e. directed away from hedgerows or surrounding trees.

Excavations must be stepped or ramped to allow Badgers and other animals which may

become trapped to escape. Any open pipework over 1500mm should be capped overnight.

If any vegetation needs to be removed between March and August inclusive, an ecologist

needs to be consulted to check that there will be no impacts to nesting birds.

Standard good site practice should be observed (i.e. no littering, drip trays etc.).

Reptiles have the potential to be in habitats adjacent to the site. If reptiles are observed, they

should be allowed to move away unharmed. If reptiles are observed within the site, a Suitably

Qualified Ecologist must be contacted.

An ecologist needs to be present during site ground clearance works.

An ecologist will supervise construction of reptile hibernacula.

© RSK ADAS 2017 i

See following page

During April-Oct grassland will be

cut to 10cm high c.7 days before site

clearance. It will then be soil stripped

under ecological supervision – to

avoid harm to reptiles

Six young trees to be felled outside

the nesting bird season or checked

for nesting birds prior to works.

The largest two of these trees will

be soft-felled as a precautionary

measure (to avoid impact to bats)

Three reptile ‘hibernacula’

to be created along

southern boundary using

logs from felled trees.

Protect tree

root zones

along

boundaries

The works area will

not extend beyond

the development

footprint

Artificial lighting will be

mitigated during main

construction works to

avoid impact to bats

Pollution mitigation

measures will be put in

place to prevent noise, air,

water, soil, light pollution

Construction

Ecological

Mitigation Plan