We are posting the first part of our comment on RPS’s Preliminary Ecological Appraisal (PEA) of the Church Lane Site for two reasons: firstly the PEA seems particularly ill-informed about the park, the Lambrok and dismissive of their ecological importance; secondly, so that anybody who might like to comment before the public consultation ends on Dec 21st can use any of our data.
Comment on Preliminary Ecological Report on the Church Lane Site.
3.1, 3.10 The site has only been ploughed once in the memory of the residents of Church Lane; it was not seeded, no crop was take from it.
3.63, 3.65 The boundary hedges are not species-poor. A species-poor hedge contains, on average, less than 5 species in 25 metres. The hedges are old, all of them present on the 1886 map, and they have not been cut for many years. They are made up of ash, oak, hedge maple, hawthorn, blackthorn, goat willow, hazel, crab apple and elm; they contain dog rose and honeysuckle as well as ivy and clematis.
Southwick Country Park
3.17 Table 3 wrongly describes Southwick Country Park as:
“Council owned site comprised of previous agricultural land that is now fields and used for leisure. Network of hedges, scrub and ditches provide a suitable habitat for a variety of wildlife.”
The County is in the final stages of designating Southwick Country Park as a Local Nature Reserve. It is a network of 140 acres of woods, coppice, hedges and meadow bound at one side by Lambrok Stream and crossed by a tributary that flows through three established ponds. Set-aside and thicket are carefully maintained as habitat; the meadows are farmed. Southwick Country Park’s rich species lists can be found here
3.21 Table 4 All of the 15 protected and notable birds on this list, with the addition of skylark and tawny owl, have been identified in Southwick Country Park, considerably less than 2km from Church Lane, and reported to Wiltshire & Swindon Biological Records Centre.
3.30 Table 6 All the protected and notable species on this list of mammals, with the exception of polecat, have either been identified in the park or have left evidence of their presence.
3.38 Table 7 Table 7 reports that there are four species of Herpetofauna within a 2 km radius of the Church Lane site; while we have not identified Great Crested Newts in the park, we do have slow worms, common frogs and common toads as well as grass snakes and adders. All have been reported to W&SBRC.
3.9 Great Crested Newts A spokesperson from Wiltshire Wildlife Trust suggested that it is highly probable that there are Great Crested Newts in Southwick Court’s moat, 400m from the SE corner of the Church Lane site. The Lambrok, which moves slowly, runs through the moat, under Frome Road and into the park; therefore neither the road nor the stream need present a barrier to Great Crested Newts. The rough grass of the Church Lane site is their ideal winter terrain.
Tables 4,6 and 7 The appraisal implies that all the species in Tables 4, 6 and 7 are too distant from the site at Church Lane to be affected by the proposed development. This is not true; almost all of these species have been identified in the park within a distance of no more than 600m.
Separating the Church Lane site from the park, Lambrok Stream supports a complex biota that contains species that are protected and species that are vulnerable:
Water vole (Arvicola amphibius) – protected under the Wildlife and Countryside Act 1981, identified in the banks of the Lambrok at the foot of the Church Lane site.
Scarce Chaser Dragonfly (Libellula fulva) – listed in Category 3 in the British Red Data Book for Invertebrates;
Steve Covey, Wiltshire recorder for Dragonflies and Damselflies, writes about the Scarce Chaser in a mail dated 16.10.2018: “Bradford on Avon and Melksham is the primary site for this species in Wiltshire. I suspect the park is used as a maturation site for L. fulva which then moves back down to the Avon to breed. In any case, development would affect these watercourses and maybe reduce the number of maturation sites this species might have available…”
Eight species of Odonata (dragonfly and damselfly) have been identified in the park:
Scarce Chaser – Libellula fulva
Broad Bodied Chaser – Libellula depressa
Common Darter – Sympetrum striolatum
Southern Hawker – Aeshna cyanea
Banded Demoiselle – Calopteryx splendens
Beautiful Demoiselle – Calopteryx virgo
Common Blue Damsefly – Enallagma cyathigerum
Large red damselfly – Pyrrhosoma nymphula
Opposite-leaved pond weed (Groenlandia densa) – listed as vulnerable in both the IUCN’s Red List and in the British Red Data Book for vascular plants.
Bullhead (Cottus Gobio) – a reportable species in Wiltshire; The River Avon Special Area of Conservation requires the monitoring of local populations of Bullheads.
Spined Loach (Cobitis taenia) – this a tentative identification of a very rare species that would be listed under Annex II of the EC Habitats and Species Directive. Photographic evidence has been sent to DEFRA.
A colony of Swan Mussels (Anodonta cygnea) estimated to be at least 60 years old, indicating good water quality.
Bechstein bats (Myotis bechsteinii) listed in Annex II of the EC Habitats Directive, come from the Green Lane Wood roost, using the Lambrok as a green corridor, to feed in the park and the Church Lane site on the insects that breed in the park’s stream and ponds. A Bechstein roost has been identified in one of the park’s oaks.
Nine species of bats have been identified in the park:
Serotine bat – Epteisicus serotinus
Bechstein bat – Myotis Bechsteinii
Daubenton’s bat – Myotis daubentonii
Natterer’s bat – Myotis nattereri
Nathusius bat – Pipistrellus nathusii
Soprano pipistrelle– Pipistrellus pygmaeus
Common pipistrelle – Pipistrellus pipistrellus
Greater horseshoe bat – Rhinolophus ferrenequinum
Brown long eared bat – Plecotus auritus
4.1 This Ecological appraisal has categorised the mature trees in the hedges of the site as of low to medium bat roost potential; the increased bat activity in Church Lane this summer suggests a change in behaviour (yet to be assessed by the Wiltshire Bat Group) that makes it quite likely that tree roosting bats may have established roosts in the site or the park
Thirty nine identified species in the park are directly dependent on Lambrok Stream:
Opposite-leaved pondweed Groenlandia densa
Canadian waterweed Iodea canadensis
Perfoliate pondweed Potamogeton perfoliatus
Curled pondweed Potamogeton crispus
Water starwort Callitriche sp.
Water-crowfoot Ranunculus sp.
Water Plantain Alisma plantago-aquatica
Branched bur-reed Sparga
Bulrush Typha latifolianium erectum
Yellow iris Iris pseudacorus
Lesser water-parsnip Berula erecta
Fool’s watercress Apium nodiflorum
Water-dropwort Oenanthe sp.
Watercress Rorippa nasturtium-aquaticum
Celery-leaved buttercup Ranunculus sceleratus
Thread-leaved water crowfoot Rununculus trichophyllus
Water figwort Scrophularia auriculata
Water vole Arricola amphibious
Otter Lutra lutra
Kingfisher Alcedo atthis
Heron Ardea cinereal
Common Frog Rana temporaria
Common Toad Bufo bufo
Spined Loach Cobitis taenia
Bullhead Cottus gobia
Three-spined Stickleback Gastrerosteus aceleatus
Swan mussel Anodonta cygnea
Great pond snail Limnaea stagnates
Great Rams Horn Planorbus corneus
Fingernail clam Sphaerum corneus
Caddis flies Mystacides sp.
Southern Hawker Aeshna cyanae
Broad-bodies Chaser Libellula depressa
Scarce Chaser Libellula fulva
Common Blue Damselfly Enallagma cyathigerum
Beautiful Damoiselle Calopteryx virgo
Large Red Damselfly Pyrrhosoma nymphula
Banded Damoiselle Calopteryx splendens
1. While this appraisal concedes that the Lambrok must be protected:
4.26 “Measures must be put in place to ensure that the construction of the housing development and its operation does not adversely affect the water quality of the stream and the connecting waterbodies”
it does not appear to recognise that development at this site will endanger the stream and its biota:
4.27 “The development is unlikely to affect the stream...”
The site is steep, in places the gradient more than 5%; run off from the proposed development and from building will reach the stream, habitat will be damaged and protected species will be lost.
2. The appraisal seems to predate this plan in its present form:
4.32 “An area of approximately 3 hectares within the redline boundary is to remain undeveloped and will be used as public open space and an ecological enhancement area. This area is located along the western edge of the site parallel to Lambrok stream.”
These 3 hectares are now excluded from the master plan though they remain in the ownership of Mrs Parry. This means that the sole buffer between the site and the stream will be the drain for surface water running west to east along the access road. into an attentuation pond. This will not suffice.