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Tue 3rd March 2009 08:37 by Peter Harvey
You need to try and (rapidly!) stir your local wildlife trust, Natural England, maybe Buglife, etc into action to respond to this planning application. I note that table 4.9 which purports to give an assessment of Potential for regional and local extinction looks distinctly dodgy to me for several species, based on the other text in that table, and the risks are probably much higher than indicated (not surprisingly, since the consultancy is working for the developer).

Paragraph 5.1 notes that "a full and detailed impact assessment will be undertaken as part of the Environmental Statement of the EIA. At this stage we do not wish to pre-empt the potential impacts until all of the environmental surveys have been completed."

Hence until this has been done it SHOULD be impossible for planning officers and planning committee members to properly assess the information and determine the application, and if they do so they may be open to subsequent legal challenge. Always worth pointing out.

With Ceratina cyanea listed as a priority species in the local BAP, you need to find out what the local authority policy is to these BAPs - presumably they will state something about trying to ensure their survival (!) etc. At the very least there should be mitigation and probably also compensation sought as part of the planning approval - 5.2 Potential mitigation measures states that "Once the impact assessment for the Bath Transport Package scheme has been completed, a detailed mitigation plan will be formulated to ensure that the scheme is developed to ensure the minimum possible impact on the ecological value and conservation importance of the features within the impact areas." Once again this appears to be 'later'. There is also a very great need for mitigation proposals specifically relating to invertebrates such as Ceratina - the sorts of things proposed by consultancies are usually hopeless and need specialist input from people that actually know what they are talking about - promote the idea for example that the developer should be talkling to and getting advice from Buglife etc. This needs to be pinned down now, as part of the planning application, otherwise it will never happen. Also I advise strongly against any reliance on Section 106 agreements, in my experience they are a total waste of time and usually not adequately followed up or monitored, with no-one interested in their detail later.

Your strongest line may well be that there us currently insufficient information and detail for this application to be adequately considered - but you need help from regional wildlife groups.



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