JFA take a look at look at two sites and what may be possible using the proposed non-licensed approach.
Site 1 is a large development site circa 80ha, bisected by a line of ponds of geological origin following an east-west spring line through semi-natural woodland habitat. Mixed development is proposed both north and south of the ponds in agricultural fields. Baseline data on species and habitats has been collected as the result of an EIA. This has shown the ponds to contain a medium population of GCN, although the population fluctuates, as would be expected. The ponds are within a matrix of mature mixed wood and scrub, and surveys have found few (less than 10 in total) GCN outside of the immediate vicinity of the ponds. The development will include additional areas of open space and balancing ponds will be created. At the master planning stage, JFA would promote the use of the open space as additional habitat for GCN, with balancing ponds designed to allow co-use as key habitat for GCN. The new habitat would be clearly and effectively linked with extant habitat. GCN friendly features (gully pots, culvert ledges) would be incorporated into the design, and movement barriers would be identified and minimised before final design was agreed. Planning JFA would approach Natural England for an advisory meeting to agree the approach. Given that development would not harm the conservation status of GCN in the vicinity and additional habitat would be developed, the loss of a few individuals would effectively be licenced. The need for GCN exclusion fencing temporary or permanent would be ruled out by this strategy. JFA would set out the entire strategy to the Agency and get agreement in principle prior to the grant of planning permission. Licensing A licence would then be prepared, based on advice and agreement, which would allow the site to be developed without being cleared of GCN, based on the use-patterns and earlier survey results. Mitigation would assume an average/medium population persists, and would provide habitat to increase the total habitat/population for GCN in the vicinity of the existing ponds and proposals. No permanent exclusion fencing would be put in leaving the site permeable to wildlife. It is accepted that there might remain some mortality of individuals, but the conservation status would be maintained, thereby meeting legislative objectives. The licence would be based on the data already available for the species, and on the habitat creation approach outlined above. Fencing such as Heras would be placed around key habitat to prevent harm to the habitat, stopping vehicles from disturbing it and prevent it being used for materials storage, a common problem on development sites. There would be no GCN temporary fencing, no drift fencing and no pitfall traps. GCN would continue to use the key habitat and peripheral areas. The licence would permit the inadvertent loss of individual GCN who strayed into the development site, whilst protecting the extant habitat from damage, and would mandate the provision of new habitat, using a planning obligation. Construction Phase During construction, the GCN populations would be periodically monitored, and the developer would be obliged to maintain protective fencing in good order. Remedial measures will have been agreed as part of the license to address damage during construction or any significant decline in species population size. The Finished Development Site. This would now comprise a mixed use development with a maintained and enhanced natural setting providing habitat for GCN (and other wildlife). GCN (and other wildlife) would be able to move freely through the site. In comparison to the current system, the proposed change in the licensing regime would have the following benefits:
The above four points would save a great deal of money (probably in excess of £50,000 if not more). Points 1 and 2 would reduce time constraints greatly, as work could be undertaken irrespective of the seasonal cycle of GCN. Certain activities might require the same or more input as under the current regime;
It is clear, however, that the benefits and cost-saving clearly outweigh the new focus on habitat creation. Site 2 is a small site of 10ha, the majority of which is formed of amenity grassland, this is surrounded by a species rich hedge line which connects to many small woodland areas in the vicinity. There are a number of ponds present in the local area, with a single shallow shaded pond in a small area of woodland on site. The development is proposed within the amenity grassland area, with the SUDs scheme utilising the small pond in adjacent woodland before draining to a watercourse locally. Surveys for great crested newts for a previous development in the vicinity have established that a medium population of GCN are present in off-site ponds, with a single GCN found in the on-site pond. Planning Under the new licencing proposals JFA would design a scheme that benefits the GCN population through provision of new aquatic and hibernation habitat and enhancements to the existing pond to increase suitability for GCN. These would be licenced by Natural England and the management of these would be secured through planning conditions or S106 agreement. Construction Phase During construction to maintain the conservation status of GCN in the area a temporary exclusion fence will be placed along the linking boundary with the known breeding ponds. The amenity grassland will be maintained at a very short sward to ensure it remains suboptimal until construction begins. The SUDs scheme would be completed providing new breeding and hibernation habitat of benefit to GCN. No trapping of the amenity grassland habitat or small woodland pond would be required and, should it occur, the loss of a few individual GCN are in effect licensed. No additional pond would be required for the SUDs scheme. The Finished Development Site. This would now comprise a residential development with mixed use SUDs and wildlife area. In comparison to the current system, the proposed change in the licensing regime would have the following benefits:
The above four points would save a great deal of money (probably in excess of £150,000 if not more) and reduce time constraints greatly, as work could be undertaken irrespective of the seasonal cycle of GCN. Certain activities might require the same or more input as under the current regime;
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