submission appendix g (lg6) (2)€¦ · comment on site lg6 these documents cite surveys carried...

1. APPENDIX G.

MM305 and supporting documents ED95, ED146B

Comment on Site LG6

These documents cite surveys carried out by the firm Keene but not those conducted by

Maydencroft in Dec ’16, Feb ’17, Sept ’17 and Oct ’17.

Local residents on Baldock Road whose properties back on to the site report bats in large

numbers congregating to forage, particularly at dusk in the Summer months. Neither Keene

nor Maydencroft would have surveyed the site at dusk so would not have been aware of

the extent of this activity. The Maydencroft surveys did not detect bat roosts but did note

“...the presence of trees and houses around Radburn Way Orchard offers suitable bat

roosting and foraging habitat which would increase the likelihood of their presence on site”.

DEFRA guidelines clearly state potential sites fitting favourable criteria for bat roosts should

be protected:

DEFRA – JOINT NATURE CONSERVATION COMMITTEE: BATS (2015)

Orchards and parkland provide additional feeding opportunities for species that feed in semi-open habitats

such as woodland edges and glades. Prioritise protection of suitable habitat in the vicinity of bat roosts If a

roost is known about and the species using it can be determined, then appropriate management can be

undertaken to benefit the bats (see chapter 3 for guidance). Conversely, it is also important to protect

potential roost sites such as old trees, buildings and bridges near suitable foraging habitats.

Activities that can harm bats

• renovating, converting or demolishing a building

• cutting down or removing branches from a mature tree

• repairing or replacing a roof

• repointing brickwork

• insulating or converting a loft

• installing lighting in a roost, or outside if it lights up the entrance to the roost

• removing ‘commuting habitats’ like hedgerows, watercourses or woodland

• changing or removing bats’ foraging areas

• Using hazardous chemicals

NHDC ignored this, cutting down nearly all the fruit trees on the grounds they were in poor

condition. Ancient trees like these develop cavities ideal for bat roosts. A substantial high

hedge, not in poor condition, was also erased. This hedge was habitat for proliferous insect

life of particular interest to the foraging bats.

The clearance of the site included: (1) the destruction of the orchard; (2) the destruction of

the high hedge; (3) the quit-notices to the allotment holders at the eastern end of the site.

These allotments were intended as an important facility for the original local residents of

the Jackmans Estate. In more recent times they had been expanded to accommodate

increased demand. Now the local view is that these three actions amount to a deliberate

desensitisation of the site to make it appear ripe for development.

Save the World’s First Garden City. April 2019