Objection to Shepley Street Development, Old Glossop

Glossop Bat Group have objected to the application to build 44 houses and a car park on land north of Shepley Street Old Glossop, on the grounds that the bat surveys conducted in support of the proposal were inadequate.

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

HPK/2013/0056 - Land North of Shepley Street  Glossop Derbyshire.
I object to this application on the grounds that the bat surveys conducted are unsatisfactory for the following reasons:

1. All except one of the activity surveys was conducted outside the optimum period of June to August (see Hundt 2012 Table 7.2). The report states that the surveys were conducted in the summer, but this is incorrect because May and early June are properly considered spring, with mid June to mid September being summer. The statement in 4.2 of the report that "the surveys were focussed on the time of year when maternity roosts were fully established" is incorrect - Pipistrelle births occur during June and July (see Hundt Box 8.3).

2. The site is larger than 1 hectare and the project has a presumed value in excess of £1 million. Therefore it is classed as a medium-sized site (Hundt 2012, Table 7.2) and the guidelines state that even in low quality habitat one activity survey should be conducted in each season (Spring, Summer and Autumn).
The survey report incorrectly treats the site as low quality because of the quality of buildings. However the habitat is close to a river, contains mature trees and a water body and should be considered medium habitat quality - therefore one visit per months from April to September or May to September is recommended, and at least one survey should comprise dusk and pre dawn surveys (or a dusk to dawn survey) within one 24 hour period.
The survey effort therefore falls woefully short of the recommended effort, contrary to the statement in 4.1 of the report.

3. The bat surveys conducted are unsatisfactory because they were conducted too early in the evening to allow detection Myotis and Plecotus bats. The bat survey states that "surveys commenced approximately 15 minutes before sunset and were terminated when light levels became sufficiently low that additional survey effort would not provide useful information on bat species and flight lines". It is usual for the actual times that surveys start and finish to be included in survey reports, but these are not provided.
Many species of bats do not emerge and commence foraging activity until light levels are very low, and the lack of Plecotus activity and low levels of Myotis activity recorded by the survey may be attributable to the fact that surveys are terminated when light levels prevent the bat surveyors from seeing bats. It is normal for bat researchers to use night vision equipment to overcome this obstacle rather than simply cease surveys when it becomes too dark for people to see properly!
 
4. Applicant has indicated no to all parts of question 13, but this is clearly incorrect because the report provided states that "a common pipistrelle roost site was located in a house on the NW corner of the site".

5. No attempt was made to determine if this roost was used as a maternity site because the surveys were conducted only in spring, before the formation of maternity roosts

6. The desk study is inadequate - see http://glossopbatgroup.mampam.com/index.php/planning-advice/23-a-guide-for-planners-and-bat-surveyors

7. Although the report states that ""a common pipistrelle roost site was located in a house on the NW corner of the site" no attempt appears to have been made to determine how many bats occupied this roost and it is not clear how the roost access points were monitored.

8. The reference section of this report does not make reference to:
Hundt L (2012) Bat Surveys: Good Practice Guidelines, 2nd edition. Bat Conservation Trust. ISBN-13: 9781872745985 but instead refers to obsolete guidelines. Hundt 2012 provides the accepted best practise guidelines for bat surveys.

I see this bat survey as a cynical attempt to make bat presence at this site appear minimal, both in terms of overall activity and species richness. By conducting surveys outside the optimum periods, failing to conduct surveys in darkness or at dawn, providing no data on the numbers of bats using the identified roost and making reference to obsolete guidelines the survey fails to provide the information required by the planning authority to make a decision about the likely impact on bats that would be caused by this development. The application should be refused and proper bat surveys in line with the established guidelines should be conducted before the application can be considered.