Written evidence submitted by Dave Bentley (INS0029)

1.1              I wish to provide evidence on the decline of insects and other invertebrates through wilful and neglectful ignoring of existing English laws which are on the statute to attempt to protect declining species and their habitats. I will focus mainly on Priority Species and Priority Habitats which are listed by the Natural Environment and Rural Communities Act of 2006. This Act places a duty on public bodies including local authorities to conserve the species and habitats listed. This is most definitely not happening in Greater Manchester, the county where I live and most often work, and the failure to conserve these species and habitats is almost entirely due to the failure Greater Manchester Ecology Unit (GMEU), administered by Tameside Borough on behalf of the 10 districts of Greater Manchester, to correctly and adequately advise the local (planning) authorities (LPA) of the law. The GMEU is telling LPAs they can ignore the law, is not informing LPA what the law says, and is not at most in any meaningful way seeking the conservation of Priority Habitats and Priority Species under threat from developments and from land allocations in the Places for Everyone spatial plan. This plan is currently with the Planning Inspectorate.

1.2              My name is Dave Bentley. I have been in conservation for 40 years, and have been an ecological consultant since 1993, 30 years. Initially I specialised in wetland conservation with particular regard to aquatic invertebrate communities. Since 2014 I have taken on a wider and yet wider group of insects and invertebrates and habitats and am now considered in North West England to be the entomologist who tackles the widest range of species groups and habitats. In addition to being an entomologist I am also a botanist and also cover a wide range of fauna such as amphibians and mammals.

2.1              Natural Environment and Rural Communities Act of 2006 requires of public bodies the conservation of a wide range of fauna species, including some insects and other invertebrates. These are termed Section 41 species, Species of Principal Importance, but are best known as Priority Species. Formulating the lists began in 1992 “The United Kingdom Biodiversity Action Plan or (UK BAP) was the UK government's response to the Convention on Biological Diversity, opened for signature at the Rio Earth Summit in 1992. The UK was the first country to produce a national Biodiversity Action Plan. It was published in 1994 and created action plans for priority species and habitats in the UK that were most under threat so as to support their recovery (Wikipedia). Reference: https://en.wikipedia.org/wiki/United_Kingdom_Biodiversity_Action_Plan

Note whilst I am including Wikipedia pages for ease you can find this information on the UK JNCC webpages or HM Gov.

2.2              This Wikipedia page introduces Priority Species and Priority Habitats as defined in law by the NERC Act 2006: https://en.wikipedia.org/wiki/List_of_species_and_habitats_of_principal_importance_in_England

“Legal obligations - Section 40 of The Natural Environment and Rural Communities (NERC) Act 2006 places a legal obligation on public bodies in England to have regard to particular living organisms and types of habitat which are of the greatest conservation importance whilst carrying out their functions, whilst also having a general regard for protecting all biodiversity. Section 41 of that same Act of Parliament requires the Secretary of State to maintain and publish statutory lists of these features - a function carried out on his/her behalf by Defra and Natural England. The lists given here are sometimes known as the 'Section 41 lists', or 'priority habitats' and 'priority species' lists. They replace an earlier list which was required under Section 74 of the CRoW Act of 2000, and which was published by Defra two years later, though their contents were at that time identical to the UK BAP priority habitats and species lists.”

2.3              The current governments stated position can be found on HM Gov website at https://www.gov.uk/government/publications/habitats-and-species-of-principal-importance-in-england

It states “List of Priority Habitats and Species in England (‘Section 41 habitats and species’) for public bodies, landowners and funders to use for biodiversity conservation.

Details - The list of habitats and species of principal importance in England includes 56 habitats and 943 species first identified as priority habitats and species in the UK Biodiversity Action Plan (UK BAP).

The list is for: public bodies – to help them meet their ‘biodiversity duty’ to be aware of biodiversity conservation in their policy or decision making”  etc

2.4              And at https://www.gov.uk/guidance/biodiversity-duty-public-authority-duty-to-have-regard-to-conserving-biodiversity 13 October 2014

Which states:

“Guidance - Biodiversity duty: public authority duty to have regard to conserving biodiversity

As a public authority, understand what the biodiversity duty is and how to meet it when carrying out all your activities.

As a public authority in England you have a duty to have regard to conserving biodiversity as part of your policy or decision making. Conserving biodiversity can include restoring or enhancing a population or habitat.

You should be able to show your duty to have regard for conserving biodiversity if you have identified ways to integrate biodiversity when you:

develop policies and strategies AND put them into practice

manage the planning system

manage:

your land and buildings, woodlands and nature reserves, gardens, parks and public open space

develop infrastructure, such as roads, buildings or flood defences

implement economic, environmental and social programmes.

If you are involved in decisions on planning and development, you should refer to guidance on:

protected species

protected sites

Your duty to protect, conserve and restore European sites

National Planning Policy Framework

planning practice guidance on the natural environment.”

2.5              I would like to explain what conserve means. It means to ensure that the Priority Habitat or Priority Species continues to exist into the future in the same or better state than it was previously. It does Not mean do nothing and decide not to tell the LPA what the law is. It does not mean actively deny the presence / existence of Priority Habitats or Priority Species, deny or downgrade the importance of the species, its populations, or the habitats they depend on, or do the same regarding the range of Priority Habitats which species depend upon. And it does not mean weigh up the importance of one thing such as a development or land allocation versus conservation of Priority Habitats/Species, and decide to proceed with the development whilst doing nothing for conservation. In Greater Manchester we expect such tough decisions to be made by the LPA (whilst including conservation) but the Greater Manchester Ecology Unit is actively doing this balancing themselves when it is not their remit and is actively denying the existence of Priority Habitats or downplaying the population of Priority Species. When insect populations have friends like these they don’t need enemies.

3              Scarce Insects and other Invertebrates

The UK has a range of insect (and other invertebrate) scarcity categories and protection/conservation methods. In law there are British and European Protected Species and NERC Act Priority Species and these must be surveyed for on any development proposal or land allocation proposal. There is also the Red lists system which ranks species from Critically Endangered, Endangered, Vulnerable or Near Threatened, and below this many species are ranked as Nationally Scarce. Additionally assemblages of species are seen as important and these can range from species dependent on declining habitats (e.g. NERC Act Priority Habitats) to habitat mosaics rich in species numbers. Local Record Centres and local ecologists are able to advise on the importance of local rarities and assemblages.

4              Natural England’s roll in identifying and recording Priority Habitats

Natural England have a very accessible team who work on the Priority Habitats Inventory. They have developed a series of Evidence Requirement tests to identify grassland and wetland habitats as Priority Habitats (these natural habitats supporting many of our insect populations). These tests are there to ensure that a competent botany surveyor will identify any Priority Habitat and ensure that it CAN properly be recorded and flagged up for conservation if a development / allocation scheme is proposed or as part of a county or district habitat survey. The ecologist provides the botany survey and tests the results and sets out these tests and a map and then Natural England team examines them and, if in agreement, adds the plot to the Priority Habitats Inventory. These plots are then added to the government’s MAGIC map, which is an easy viewable online mapping system. Sadly all too often it seems some ecologists interpret the MAGIC map as if there are no Priority Habitats shown at a point in time then none exist, and this is of course wrong. Whether or not a Priority Habitat is down to the actual botany etc on site, and is nothing to do with anyone’s opinion on the quality of the site or whether or not the site has been surveyed before and added or not added to the MAGIC map.

5              The roll of private ecological consultancies. They are failing.

Lessons from Elton Reservoir, Bury, Greater Manchester

5.1              Most ecological consultancies have no entomologists. They ignore the topic. Some, when they are required, hire in an entomologist. But mostly ecological assessments almost totally ignore invertebrates, whether Priority Species or some those with some other form of scarcity or assemblage value. In terms of Priority Habitats most ecological consultancies ignore Priority Habitats that are not hedges or ponds or woodlands. At my site at Elton Reservoir environs in Bury I was carrying out entomological surveys to hopefully help protect the site. I found 1043 invertebrate species in my work, with 30 of these being officially Scarce. In one Priority Habitat which is Flood Plain Grazing Marsh Priority Habitat I located 618 invertebrate species including 15 Scarce species.

5.2              I was also able to show for example that an area of meadows with flowery silage (and hence not qualifying a Lowland Meadow Priority Habitat as it was too modified by farming) was also rich in insects with 461 species, including 9 Scarce species. So this shows that areas that do not qualify as Priority Habitats are being written off as silage fields of no interest when they can be very valuable for insects e.g. with a Clover added to the seed mix. The system of Priority Habitats misses many habitats which are habitat mosaics as well, and hence misses these potentially valuable insect habitats.

5.3              Now I was working as a volunteer to defend the site from allocation and development in the Places for Everyone Spatial Plan which went to Public Examination in early 2023. I was up against a large ecological consultancy which did not have my skills as an entomologist. They claimed in their submission to the Examination that they had been carrying out entomological surveys in 2022 but failed to present a single species identification to the Examination. When ecological consultancies withhold entomological evidence from Examinations we can see there is something wrong.

5.4              Aside from surveying for insects and other invertebrates I was carrying out botanical surveys of the grassland plots (these being insect habitats). I located and tested and presented up to 24 botanical etc evaluations for Priority Habitat to Natural England and all were accepted by Natural England (a small number were already on MAGIC map as such) and are now on the Priority Habitat Inventory and will appear on MAGIC map. I presented a further 8 plots which will appear on MAGIC Map as Semi-improved Good (Non-priority), with four of these no doubt qualifying as Priority Habitat for Waxcap fungi when the Waxcap Evidence Requirement is finally completed by Natural England. The first ecological consultancy working for the developer/site promotor concurred with Natural England on just 3 plots. Which means a team of so called ecological consultants missed two dozen Priority Habitat grassland plots, and this may have dire consequences for the insect populations which depend on these Priority Habitats.

5.5              The first ecological consultants were replaced by a larger company in early 2022 and these people resurveyed the plots and presented to Public Examination not one jot of botanical species list which could be tested for Priority Habitat status, and identified a grand total of zero Priority Habitats. They did not do the required work even though I had in my submitted work stated that there were Priority Habitats, and then later I set about testing the survey results and presenting them to Natural England who accepted them, as stated. That is two ecological consultancies failing to do adequate botany surveys to identify Priority Habitats upon which many insect species and communities depend.

Other Lessons from Places for Everyone Spatial Plan Greater Manchester

5.6              Now the Places for Everyone plan is the biggest grab of Green Belt land for developers in decades. Carefully protected Green Belt is now viewed as a land bank. I worked on the Greater Manchester Subject Plan in the early 1980s at County Hall.

5.7              I have examined carefully all of the ecological reports presented to the Public Examination and the only body of entomological work submitted is my own. Developers, their ecologists and the Greater Manchester Ecology Unit have done no work whatsoever on insect populations. The most they have done is asked the GMEU to provide them with records collated for their sites by others, typically volunteers, and then gone through the lists looking for Priority Species. That is not a survey for invertebrates. If you do not look you do not find. One report I read sets out that it concentrates on a list of ecological matters the report considers and one bullet point covers insects. These are never mentioned again it the report.

5.9              As far as Priority Habitats goes all of the ecologists look on MAGIC map for Priority Habitats already recorded, but none or few provide testable botanical records, and none (bar the 3 plots mentioned above) state that they have either tested the results of their surveys for Priority Habitats and found none, or have not found and registered any. Given the number of Priority Habitats at Elton Reservoir this seems odd. There is one site in Rochdale where one of the ecologist companies noted above perfectly describes a Lowland Fen Priority Habitat present on their site but does not say it is such, and then states that the nearest Lowland Fen Priority Habitat is one kilometre away along the river. Insects really do not need such poor level of evaluation from professionals.

5.10              Whilst not part of the Spatial Plan for Greater Manchester I can raise another issue where the first listed ecological company failed again to identify a Priority Habitat grassland. The grassland had been cut prior to survey and the ecologists claimed they could evaluate a cut meadow, and listed plants around the field edge that were actually Lowland Meadow Priority Habitat indicator species – to be a Priority Habitat they should not be limited to the field edge. The year following the grass was uncut and these plants were found to grow across the meadow. Ergo another Priority Habitat missed by ecologists and an insect habitat threatened unnecessarily by sloppy work.

6              The roll of council ecology departments. They are failing.

6.1              I can only speak of my experience with the Greater Manchester Ecology Unit. The GMEU now also gives ecological advice to Local Planning Authorities in parts of Lancashire and perhaps Cheshire, given the demise of their internal ecology units.

6.2              At my Elton Reservoir site the GMEU had had several years to conduct adequate botany surveys to identify Priority Habitat grasslands. Their ecologists failed to conduct botany surveys which could be tested for Priority Habitat status. When I did this Natural England agreed they were Priority Habitats. One of the roles of GMEU is to accurately advise the LPAs on the value of the wildlife on a site. They failed in this respect.

6.3              Another of the roles of the GMEU is to question the accuracy and efficacy of surveys done by the private (or indeed voluntary) sector. Given they did nothing of the sort and allowed both sets of ecologists to submit untestable surveys which equally and presumably failed to find the botany indicators species (they are not in their reports) for the plots, and at the same time allowing the LPA to think that nothing was amiss. This is dereliction of duty and harms insect conservation.

6.4              My invertebrate survey was submitted. As with any quality work it is divided into relatable areas/plots, the animals have their abundancies supplied where possible, their habitat needs described, and their national scarcity status given, and indeed a local scarcity status is worked out from a careful perusal of county records from numerous sources. This means the assessment of the importance and the relatability to the habitat is done. Some poor consultant entomologists write an list of scientific names with zero interpretation and are maybe responsible for the loss of the sites the survey for failing to provide their audience with adequate and meaningful interpretation. So what was the result of me showing my site had 1043 species with 30 scarce species? The GMEU told the planning inspectorate they as a unit did not have the skills to interpret insect/invertebrate surveys so would not be doing so. They might have approached Liverpool World Museum where there is an invertebrate unit called the Tanyptera Project and asked them to consider my work…but no. They elected to ignore it, and insect conservation. This is of course contrary to its legal Biodiversity Duty, as set out above.

6.5              I distributed these thoughts to the GMEU before a special meeting of the Public Examination which had been called to consider the issues raised by objectors about the treatment of ecology issues during the Places for Everyone process. Here the objections were raised as more evidence was examined during the Examination, the GMEU then was required to give its defence, and then objectors were invited to respond. The GMEU claimed everything was fine despite the damning evidence.

6.6              In response to my thoughts on Biodiversity Duty failings of the GMEU which arrived after the meeting I had a response from the GMEU which they circulated: Two ecological consultancies and the GMEU had not found Priority Habitats and they did not exist and professionals often disagreed. Of course we know  none carried out adequate botany survey to identify Priority Habitats and the sole party who had adequately surveyed the site had presented the tests to Natural England and had the agreement of Natural England. So it is nothing to do with opinions - the qualifying species and structures are present and opinion has nothing to do with it. So we have poor consultancies passing off inferior work and not seeking to or indeed identifying Priority Habitats and one partial GMEU who cannot identify Priority Habitats and cannot hold ecological consultancies to task for not doing this. The GMEU is not fit for purpose and is dragging standards down to the level of poor consultants. They are doing the balancing job which is the job of planners and planning inspectors when their sole role is to encourage the LPAs to have and use accurate ecological information and to understand and obey the laws and Biodiversity Duty. With a GMEU so failing the future for Priority Habitats and insects and other invertebrates which depend on them is bleak.

7              Lessons from elsewhere

7.1              I have a recent example from West Lancashire on a plot in Skelmersdale which was clearly identified as a housing site when the ring road was built years earlier. Successive environmental reports were written over 25 years and all of them suggested there may be interest for insects and other invertebrates but all of them suggested the work was carried out in the future. I was hired and it  was put to me that I might just walk the site and say if there MIGHT be interest in the site if it were surveyed. On reading the reports I put it to my client that this putting off surveying for invertebrates had been going on for years and we had to stop this. So over two days surveying I located 278 species with one Scarce species. Comparing my finds with the Lancashire County Biological Heritage Site methodology I could tell my client that the site qualified as a BHS on the basis of Butterfly assemblage and on Grasshopper assemblage. I look at Google Earth today and see half the site is half developed so the County Council did not declare a BHS on invertebrate grounds despite having the evidence to do so. I made recommendations to hopefully reduce the impact on insects if they proceeded, but the losses would have been massive with or without my input, and I do not know if my recommendations were followed.

8              The role of the Chartered Institute for Ecology and Environmental Management (CIEEM)

8.1              Some things that are wrong with the CIEEM’s Guidelines for Preliminary Ecological Appraisal (December 2017). A PEA is being used by private ecological consultancies when land is being considered for allocation in plans such as Places for Everyone. It SHOULD BE the point where a site rich in  ecology including Priority Habitats and Priority Species should be thrown out and not considered further for development, but it is not. CIEEM was set up to raise standards in ecology, but they have, alas, set the bar so low:

“Box 2. Example Scope for a PEA Field Survey in the UK and Ireland

The field survey element of a PEA should typically include the following (where relevant):

1) Mapping of the habitat types present following a published and recognised habitat

classification that is appropriate for the site’s location (see Appendix 3).

2) An assessment of the possible presence of protected or priority species, and (where relevant)

an assessment of the likely importance of habitat features present for such species, with

reference to available desk study information. This should include:

• Plants

• Fungi

• Terrestrial and aquatic invertebrates

• Fish (where relevant, based on an assessment of any watercourses and water bodies

present);

• Amphibians (including both breeding and terrestrial habitat)

• Reptiles

• Breeding, wintering and migratory birds

• Bats (including potential roost sites, and foraging and commuting habitats/features)

• Other protected or priority mammal species, as relevant”

An assessment of the POSSIBLE presence of PRIORITY SPECIES.

Plants are mentioned but PRIORITY HABITATS ARE NOT mentioned.

Terrestrial and aquatic insects/invertebrates are mentioned.

It is not even clear what 2) is asking of the surveyor.

Typically a site might be covered in a day with no actual survey work done. This is a look and see. This is the level that CIEEM are asking to be provided. It seems it is being interpreted as POSSIBLE PRESENCE. So in short land is being allocated to potentially harmful development with little known and discovered about the site, thanks to CIEEM. Once an allocation is in an approved plan it is impossible to stop the destructive processes happening. There is in fact no mechanism in the CIEEM PEA for avoiding a site, and avoidance only relates to tinkering. So the CIEEM have encouraged the use of a very basic PEA which has no method of withdrawing a site from the development process.

I will attach some text as a footnote which explores the CIEEM’s methodologies.

Footnote on CIEEM methodologies

Some things that are wrong with Guidelines for Preliminary Ecological Appraisal (December 2017):

Firstly let’s look at CIEEM (2018) Guidelines for Ecological Impact Assessment in the UK and Ireland:

Terrestrial, Freshwater, Coastal and Marine version 1.23

1.16 EcIA benefits from early consultation with the relevant competent authority, Statutory Nature

Conservation Bodies (SNCBs), Environment(al) Protection Agencies (EPA) and Non-Governmental

Organisations (NGOs). Through EcIA the developer/project proposer can be made fully aware of matters such as site designations, protected habitats and protected species, and their implications, before pursuing a project. Engagement with consultees on a regular basis will help refinement of the proposal, smooth progression through the planning process and minimise misunderstanding and controversy.

1.19 The following principles34 underpin EcIA:

Avoidance Seek options that avoid harm to ecological features (for example, by locating on an

alternative site).

Mitigation Negative effects should be avoided or minimised through mitigation measures,

either through the design of the project or subsequent measures that can be

guaranteed – for example, through a condition or planning obligation.

Compensation Where there are significant residual negative ecological effects despite the

mitigation proposed, these should be offset by appropriate compensatory

measures.

Enhancement Seek to provide net benefits for biodiversity over and above requirements for

avoidance, mitigation or compensation.

Box 6: Preliminary Ecological Appraisal

Preliminary Ecological Appraisal38 (PEA) is the term used to describe a rapid assessment of the ecological

features present, or potentially present, within a site or the surrounding area (within the Zone of Influence

for a proposed project). It normally comprises a desk study and a walkover survey.

A PEA can be undertaken in a variety of contexts, often as a preliminary assessment of likely impacts of a

development scheme. It can help the project proposer and planning authority to agree the appropriate

scope of any subsequent impact assessment or determine that ecological issues will not be significant in

determining the application.

The results of the PEA can be provided in a PEA report or simply incorporated into the EcIA report, ecology

component of an EIA, or a scoping report, as needed.

A PEA report does not replace an EcIA, as it normally contains recommendations for further surveys or

general design advice to a developer, rather than a detailed assessment of the effects of a finalised scheme,

with all required ecological surveys completed. For very straightforward projects, where no further ecological

surveys are needed, an EcIA Report can be produced following completion of the PEA.

Avoidance and Mitigation

6.2 Negative impacts should always be avoided where possible, for example by deciding not to locate a

project in a particular area or making a change to scheme layout to ensure no negative impacts. Avoidance

can also be part of mitigation. Mitigation includes measures to avoid or reduce the negative impacts of a

project, for example careful timing of an activity to prevent an impact occurring.

6.3 Avoiding and/or minimising negative impacts is best achieved through consideration of potential impacts

of a project from the earliest stages of scheme design and throughout its development. Many impacts can be

avoided or reduced by consideration of alternatives.

Comment – Many developments come about due to land zoning in local and spatial and joint

development plans made by Local Planning Authorities. Thus someone in a LPA makes a decision

there is need to allocate land for a use, be it housing or employment etc. And then there is a process

inside the LPA which weighs up the various sites that have come forwards in the Call for Sites

Process. At this point there needs to be ecological input to help the LPA sieve the sites to find

appropriate sites free of ecological value and risks to biodiversity. The CIEEM has nothing on this

very important part of planning. The closest would be the PEAR but the CIEEM PEA guidelines make

no mention of this important part of planning and wildlife protection. In Greater Manchester for the

GMSF/PfE plan no ecological consideration was given to this whatsoever and even registered and

designated Local Wildlife Sites were not considered either planning or physical constraints.

Once the sites are selected they are put to public consultation and this brings out ecological

information from objectors. But we see that the LPA has no interest in Avoidance by not choosing

that particular site. They insist on pursuing that site, however ecologically damaging, and eventually

take it to a Public Examination by the Planning Inspectorate (assisted by CIEEM members).

The scheme set out at Public Examination is a Masterplan. In Greater Manchester one page desktop

PEAR have been produced by CIEEM members at the Greater Manchester Ecology Unit citing an

earlier version of the PEA guidelines. Only where the objectors have raised substantial objections has

an additional PEAR with site visit been conducted, and in some few cases ecologists have been hired

by the developer to conduct some sort of EcIA. In some cases for countryside sites there has been

zero ecological information provided, and on two sites planners had a bash at doing a faux-PEA from

maps and unrelated PEARS on the file from other jobs.

From the PEA Guidelines

1.9 A PEA can also be used to inform, for example:

• scoping for an Environmental Impact Assessment (EIA18);

• an assessment as to whether a particular site should be included as an allocated site in a development plan;

CIEEM appear to have caused this mess with their faulty guidance which allows PEARS to be

presented at Public Examination for up to 45 land allocation greenbelt removal sites in Greater

Manchester. So in essence once (if) the allocation is confirmed via the Public Examination and

subsequent ratification, there is nothing in the way of an ecologically harmful development

happening, bar tinkering with the mitigation hierarchy, with the first part AVOIDANCE, dead in the

water, as the decision to site the development here is already made relying on a PEAR.

I have some other comments:

Data sources also include iRecord and recording schemes for many invertebrate biological recording

groups e.g. BWARS. I have not read a PEAR that referenced NBN Atlas at all.

MAGIC map. The priority habitats shown on MAGIC map do not appear there by magic. An ecologist

has to do field surveys and botany to DAFOR to work out if a site contains a Priority Habitat and then

make a case to the PHI team at Natural England using the Natural England PHI Evidence

Requirements (attached). That is Priority Habitat Inventory. If you do the survey you find the Priority

Habitats and if you tell people that all they need to do is a desktop and a walkover then they don’t

find them. CIEEM is setting the bar so low and is clearly allowing unsuitable sites (for ecology

reasons) to be allocated to major developments in development plans. A site I have been protecting

at Public Examination had 8 Priority Habitats before I started and now has 27 (rough figures) – had I

been using CIEEM standards I would have found nothing. Many of these are grassland habitats.

Generally I see CIEEM members’ PEARs avoiding discussing potentially valuable grasslands, as they

have not properly surveyed them, and just list hedges, ponds, woods as Priority Habitats. How can

CIEEM justify not surveying for valuable grasslands at PEAR stage?

I find this Box below rather odd. Not one PEAR I have read suggests potential for Waxcap Fungus

Grasslands (I have 13 on my site). And they all ignore invertebrates as the ecologists know nothing

about them (I am, amongst other things, an invertebrate ecologist).

Box 2. Example Scope for a PEA Field Survey in the UK and Ireland

The field survey element of a PEA should typically include the following (where relevant):

1) Mapping of the habitat types present following a published and recognised habitat

classification that is appropriate for the site’s location (see Appendix 3).

2) An assessment of the possible presence of protected or priority species, and (where relevant)

an assessment of the likely importance of habitat features present for such species, with

reference to available desk study information. This should include:

• Plants

• Fungi

• Terrestrial and aquatic invertebrates

• Fish (where relevant, based on an assessment of any watercourses and water bodies

present);

• Amphibians (including both breeding and terrestrial habitat)

• Reptiles

• Breeding, wintering and migratory birds

• Bats (including potential roost sites, and foraging and commuting habitats/features)

• Other protected or priority mammal species, as relevant

In the PEA flowchart there is the only reference to avoidance in the whole report (via wordsearch),

whilst other references relate to tinkering, and not finding to an alternative site. The flowchart

moves swiftly from avoidance to submission of a scheme to planning, as if the word avoidance has

no meaning. There is no mechanism in PEAR for telling a developer or LPA they have selected the

wrong site/allocation.

The final row of flowchart boxes refers twice to EcIA and 3 times to a “planning submission”. What is

a planning submission in this respect? A planning application? A land allocation in a development

plan? CIEEM seem to fundamentally misunderstand the harm a wrongly made allocation can do.

I will tell you something about my site:

27 Priority Habitats inc floodplain grazing marsh, rush pasture, lowland meadow, lowland fen,

7 diverse Local Wildlife Sites

A birding hotspot and motorway services for migratory birds, being the only area of countryside

grassland, hedges, marsh and water in the middle of the county. 198 bird species on the site list. 31

S41 species, 49 red list, 72 amber list BOCC etc

Lapwing and Brown Hare in every field. Recognised County Importance for Lapwing.

1043 taxa of invertebrates to date with 30 scarce taxa, accepted as County Important.

Even the silage fields support scarce invertebrates, hares and lapwings

12 Great Crested Newt ponds and several 5 species breeding ponds. Plenty of Common Toad.

Two Red listed plants and one nationally scarce plant and several county rarities.

30+ veteran field boundary or singleton trees of English Oak and Ash some possibly ancient.

Small Bluebell woods.

Hedgehog, badger, breeding Otter etc.

Elements of pre 1766 field boundaries plus a Hengiform monument, roman road and possible

barrow.

Meanwhile CIEEM members are providing woeful surveys and claiming all this wildlife, and the

people pressure of 1000 more houses can be shunted onto land the developer does not control -

mitigation and recreation on other people’s land. But it’s OK. They do own land off site somewhere

(with other uses). And as allocations take no account of ownership and the CIEEM members have

made no attempt to identify or discuss this other land at the same time as backing the project. These

are CIEEM members. We even had a CIEEM member from the GM Ecology Unit saying to the

inspectors it was all fine that the Lapwings and Hares would become extinct here. Nothing to see

here, and nowhere to mitigate.

Yours faithfully, Dave Bentley

Habitats of 'principal importance' in England (as found on the cited Wikipedia page)

The latest update to the list of Section 41 habitats of principal importance (priority habitats) was published by Natural England in August 2010. ((Note that there is a proposal to add another category for Waxcap fungi Grasslands))((All of these habitats support a range of insects/invertebrates typical of the habitat in its region))

The list shows the broad habitat group, followed by name of the habitat of principal importance (as used by original source).

Arable and horticulture: Arable field margins

Arable and horticulture: Traditional orchards

Boundary: Hedgerows

Coastal: Coastal saltmarsh

Coastal: Coastal sand dunes

Coastal: Coastal vegetated shingle

Coastal: Intertidal mudflats

Coastal: Maritime cliff and slopes

Coastal: Saline lagoons

Freshwater: Aquifer-fed naturally fluctuating water bodies

Freshwater: Eutrophic standing waters

Freshwater: Mesotrophic lakes

Freshwater: Oligotrophic and dystrophic lakes

Freshwater: Ponds

Freshwater: Rivers

Grassland: Lowland calcareous grassland

Grassland: Lowland dry acid grassland

Grassland: Lowland meadows

Grassland: Purple moor-grass and rush pastures

Grassland: Upland calcareous grassland

Grassland: Upland hay meadows

Heathland: Lowland heathland

Heathland: Mountain heaths and willow scrub

Heathland: Upland heathland

Inland rock: Calaminarian grasslands

Inland rock: Inland rock outcrop and scree habitats

Inland rock: Limestone pavements

Inland rock: Open mosaic habitats on previously developed land

Marine: Blue mussel beds

Marine: Estuarine rocky habitats

Marine: Fragile sponge and anthozoan communities on subtidal rocky habitats

Marine: Horse mussel beds

Marine: Intertidal boulder communities

Marine: Intertidal chalk

Marine: Maërl beds

Marine: Mud habitats in deep water

Marine: Peat and clay exposures

Marine: Sabellaria alveolata reefs

Marine: Sabellaria spinulosa reefs

Marine: Seagrass beds

Marine: Sheltered muddy gravels

Marine: Subtidal chalk

Marine: Subtidal sands and gravels

Marine: Tide-swept channels

Wetland: Blanket bog

Wetland: Coastal and floodplain grazing marsh

Wetland: Lowland fens

Wetland: Lowland raised bog

Wetland: Reedbeds

Wetland: Upland flushes, fens and swamps

Woodland: Lowland beech and yew woodland

Woodland: Lowland mixed deciduous woodland

Woodland: Upland mixed ashwoods

Woodland: Upland oakwood

Woodland: Wet woodland

Woodland: Wood-pasture and parkland

Species of 'principal importance' in England (as found on the cited Wikipedia page)

28 April 2023