Objection to new library plan

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Glossop Bat Group have objected to the application to demolish the old St Luke's school and construct a new library on the grounds that attempts to ascertain if the building was used by hibernating bats was wholly inadequate.

Full text of the objection is given below, the application is here

Re: CD1/1212/128

Glossop Bat Group object to this proposal on the following grounds:
The bat surveys submitted are inadequate to allow the planning authority to determine if this site is used by bats for hibernation. The surveys state that the building is used by bats in the summer, that the cellar has a host of features suitable for roosting bats and that it should be considered as a potential hibernation site. However no serious attempt was made to assess the cellar as a bat hibernation site, and the evidence submitted in support of the application is unsatisfactory for two reasons: 1) the work was conducted outside the hibernation season, and 2) the  work was carried out with unsuitable equipment.

The area around the site was used by Pipistrellus, Myotis and Plecotus bats and Pipistrellus bats were found to roost in the building in August and September. The cellar of the building was correctly recognised as having potential to be a bat hibernaculum, and on 8th February 2013 Natural England told DCC (ref 77767) that the application required a “winter months scoping survey of the building’s basement/cellar” in accordance with Hundt 2012 (referred to as “the guidelines hereafter), which sets out best practice for bat surveys. A search of the building was carried out immediately (8th and 9th November) and the supplementary bat survey submitted in support of the application details the methodology used. On 12 February 2013 Natural England’s confirmed that the new survey satisfied their standing advice sheet process. However the NE standing advice sheet assumes that all bat survey work is conducted in accordance with the guidelines. In this case the surveys submitted are not in accordance with those guidelines and therefore do not provide the planning authority with sufficient information to determine the likely effect on local bat populations and the levels of mitigation that would be required if the application was granted.

i) No endoscope was used in the scoping survey. An endoscope is necessary to examine crevices in buildings because many species of bats (particularly Pipistrelle species) shelter in small crevices and are rarely found roosting in open space. Table 6.1 of the guidelines lists the basic equipment required for bat surveys: lamps. bat detectors, binoculars, night vision scopes, endoscopes, thermometer and camera. Page 55-56 of the guidelines state: ’When assessing a site’s potential as a hibernaculum surveyors should be aware that bats may hibernate in places that cannot be seen or accessed; this may lower the confidence in a negative survey result. It also means that inspections for winter roosts can be time consuming, as endoscopes and mirrors are often required in order to search for individual bats or small numbers of bats hidden in crevices.  The bat report submitted states that the surveyors used torches and binoculars to conduct scoping surveys. Therefore if bats were not in open view of the surveyor he would have had no way of seeing or hearing them.  The reason endoscopes and bat detectors are required for scoping surveys is to allow species of bats that shelter in crevices to be detected. In this case, although the surveyors have been able to see bats flying into the building, they have been unable to trace the animals inside the building; for the simple reason that the equipment they have used is not suitable for finding crevice dwelling bats. The submitted bat survey states that there are multiple potential entry points into the cellar for bats, includes a long list of features in the cellar of the building that are suitable for roosting bats, identifying gaps between lintels and timbers that provided “ideal potential bat roosting areas”.  Despite this, only binoculars were used for the scoping surveys, and so there was no possibility that crevice dwelling bats would be encountered. An absence of bats is inferred by the surveyors because no bats were seen and no droppings encountered. This is unjustified given the methodology used, and the survey should be conducted with equipment capable of detecting the presence of crevice dwelling species such as Pipistrellus. The application cannot be considered without this information and the suggested mitigation would be wholly inadequate in the event that the building was used by hibernating bats.

ii. The survey was not conducted at the correct time of year. Table 4.5 of the guidelines gives the recommended times of year for surveys and clearly states that December to March are suitable for hibernacula surveys, and that the optimum time is December to February. The “winter scoping survey“ submitted in support of this application was carried out early November; much too early for a hibernaculum survey, especially in mild weather at the end of a particularly wet summer.  Prior to entering hibernation bats spend late autumn accumulating fat and will not retire to hibernation shelters until they have sufficient fat to survive the winter. No justification was provided for conducting a survey for hibernacula outside the approved time periods. In order to find bats at a hibernaculum you must look when they are hibernating, and inspections in early November are unsuitable for this and do not provide suitable information to allow the planning authority to determine whether this site is a hibernaculum or not. The application cannot be considered without this information and the suggested mitigation would be wholly inadequate in the event that the building was used by hibernating bats.

We also have the following comments:
It is disappointing that these very serious deficiencies in the bat surveys were not noted by DCC Environmental Services in their consultation response. It is also disappointing that DCC did not consult Glossop Bat Group and that they commissioned bat surveys only over a over a short space of time in very late summer, greatly reducing the possibility that a maternity roost, if present, could be detected. Despite having been made aware that several parts of the building were used by bats in August and September, only a very poor effort was made to to determine if the building was used by bats at other times of the year. DCC are aware that Glossop Bat Group has campaigned vigourously to ensure that bats receive the protection they are entitled to under law, and that local authorities are vigilant in ensuring that they have sufficient information on which to base planning decisions. This application is noteworthy because we believe that it is the first time that a bat roost has ever been identified by a commissioned survey at a site proposed for development in Glossop. However it should be obvious to anybody that hibernating bats in crevices can only be found by looking inside crevices when bats are hibernating, and for that reason we have been obliged to object to the development.