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From: Denzil Williams Sent: Tue, 7 Jan 2025 16:27:38 +0000 To: Gatt, Charlotte Cc: Jonathan Hayter;Katie Brewer Subject: 23/00488/B. conditions 6 and 8
Dear Charlotte Thank you for your emails showing the notes from Dr Richard Selman, please see our responses in red below: I have CC’d The Ecologists at Collington Winter to keep them fully informed and to ask them make additions to their method statement where indicated. Thank you Beverley Beverley Williams
Condition 6. Prior to the installation of external lighting within the site, a Lighting Plan shall be submitted to and approved in writing by the Department. The lighting of the site will be designed utilising inward directed led lighting columns to provide required site illumination without creating undue light pollution. The development shall not be carried out other than in accordance with the approved plan, and shall be retained as such thereafter. Reason: To provide adequate safeguards for the ecological species existing on the site.
In lieau of a lighting plan, a Lighting Mitigation Scheme (11 Nov 2024) has been provided, with objectives and guidelines. It notes that there is already a manual switch external light on the adjacent building and internal lighting, and lighting is proposed during works, for the roof and wall works, which will be minimised and directed away from areas of bat interest and switched off at night, and they note that ‘The proposals do not include the introduction of any external lighting post development’. They have referenced the BCT guidance on Bats and Artificial Lighting at Night (2023). Luminaire specifications have been provided to guide any lighting that may be introduced. On page 4 it is stated that ‘There is to be no further external lighting introduced into the site other than security lighting.’ They also state that, ‘Lighting is not to be introduced to the front of the proposed cottages’. There is no other reference to security lighting, or a plan of the lighting that will be introduced, though the specification details what they should and should not do in relation to lighting
and bat conservation on the site. There is therefore clearly an intention to have lighting for the works, but to avoid lighting areas of interest to bats, though it is not clear what security lighting may be introduced during works and remain in situ afterwards. Conclusion: we recommend that the applicants clarify their requirement for security lighting, post-construction, where this is to be located and how this will comply with the BCT guidance.
Condition 8. Prior to the commencement of any works on the barn, a Methodology for bat protection during works and covering the bat mitigation provisions with notes to clarify intentions and a method statement, shall be submitted to and approved in writing by the Department. The development shall not be carried out other than in accordance with the submitted Bat Protection Methodology. Reason: To provide adequate safeguards for the ecological species existing on the site.
A Precautionary Working Method Statement for Bats (8th Nov 2024) has been provided, but we don’t as yet know the results of the hibernation survey, as noted within the statement. This information is relevant to the contents of the method statement. We therefore recommend that the method statement is only signed off once the hibernation survey has been completed and a timing schedule, taking this into account, has been provided.
The statement includes a reference to licensing: ‘A licence to allow the works to commence lawfully is to be completed once the required hibernation surveys are completed (these are on-going at the time of writing).’ Note, a Wildlife Act licence is not applicable to
developments, as they take place under the defence of Wildlife Act section 9(3)(c), however, the DEFA Ecosystem Policy Team must be notified of works affecting a bat roost, under section 10(5) of the Wildlife Act, and statutory advice will then be provided to the applicant, prior to works commencing, and it can be based on this discussion.
Roosts 6, 7, and 8 are to be retained, in the masonry. Will these be marked in some way to avoid them being filled in during works?
Sign off by an ecologist has been included for the initial site checks, briefing and provision of the bat house. This should include the provision of the bat boxes that are to be placed in the woodland prior to works commencing.
We also recommend sign off by an ecologist at the end of the development, to ensure that the contracted works have been completed correctly in relation to the plans for bat protection. This should include checking for the retention of external roosts 6, 7 and 8 and whether the mitigation bat house has been adopted successfully by the bats. A statement on the post-construction monitoring is therefore recommended as an addition to this method statement, to show whether the works have been successful and the bat roosts have been retained on site, whether in situ or in the new bat house, following the completion of works.
We haven’t yet been given clarity on whether Roost 2 will be retained or not. DEFA should be notified of the status and intentions with regard to this roost. It should be retained in situ if possible.
The timing of works has not been covered. In our advice of 10/11/23, we noted, ‘If works are planned for over winter, then it will be necessary (temporarily during the active season, and for the duration of works) for a bat worker to provide exclusion devices to prevent bats from hibernating deep within the walls. The method statement must address how works are planned in a manner so as prevent any damage to bats and to retain the roost spaces, including the timing of the works.’ We await, of course the results of a hibernation survey. Similarly, we noted ‘As the proposal is to exclude bats from some summer roosts, this must be given detailed consideration in the method statement to determine what is possible and when that must be scheduled.’ It is inadvisable to move bats from a maternity roost. We therefore expect a comment on the timing of works in relation to bat work and consideration within the statement, of whether exclusion devices may be required (at an active season of the year for bats). The statement includes removal of remaining bats but not when or how. Bats might be in very difficult to reach places and there are is a season of inactivity when exclusion is not an option and disturbance threatens their survival to the spring. They will also need to prevent bats from reinhabitating excluded sites, prior to works.
We also recommend that the statement include a comment on the kind of roof membranes that will be used, to ensure that any used in areas that bats have access to, will be bat-safe, as standard breathable roof membranes can be deadly to bats.
We hope this helps to improve the plans and ensure a successful development. Kind regards, Richard
Dr RG Selman, (he/him), Ecosystem Policy Manager Department of Environment, Food & Agriculture, Thie Slieau Whallian, Foxdale Road, St John's, Isle of Man, IM4 3AS Tel (direct) +44 (0)1624 695740 Tel. DEFA +44 (0)1624 685835 Fax +44 (0)1624 685851 Email [email protected] Website: www.gov.im/defa
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