Item7Appendix3RepresentationObjection20240005DET6HousesKingussie

CAIRNGORMS NATION­AL PARK AUTHOR­ITY Plan­ning Com­mit­tee Agenda Item 7 Appendix 3 09/08/2024

Agenda Item 7

Appendix 3

2024/0005/DET

Rep­res­ent­a­tions – objection

30.01.2024

To whom it may concern,

RE: Plan­ning objec­tion to 2024/0005/DET | Erec­tion of 6no. houses (3 blocks of semi­de­tached) | Land 65M South Of 22 Ker­row Drive Kin­gussie (eplan​ningcnpa​.co​.uk) (Rel­ev­ant also to: 2020/0013/DET | Erec­tion of 22 apart­ments, form­a­tion of access road, SUDS, land­scap­ing | Land 65M South Of 22 Ker­row Drive Kin­gussie (eplan​ningcnpa​.co​.uk))

I am one of the own­ers of imme­di­ately adja­cent to the pro­posed devel­op­ment. My back­ground is in envir­on­ment­al sci­ence and infra­struc­ture devel­op­ment. I am writ­ing to object to the above plan­ning application/​amendment as it stands.

Objec­tion themes • Chal­lenge to EIA screen­ing opin­ion • Sur­face water, drain­age, sub­sid­ence • Design­ing streets guid­ance, hous­ing dens­ity, access­ib­il­ity • Eco­lo­gic­al impact

Sum­mary

The dens­ity of hous­ing pro­posed in a small area would have neg­at­ive impacts in terms of drain­age, flood risk, increased risk of sub­sid­ence, environmental/​ecological impacts, and com­munity cohe­sion and well­being. I do not believe that all the fea­tures of the field or impact on the sur­round­ing houses have been adequately sur­veyed. New hous­ing should main­tain exist­ing land­scape fea­tures, max­im­ise nat­ur­al drain­age oppor­tun­it­ies, provide plenty of nat­ur­al green­space, and be access­ible to res­id­ents with diverse require­ments. At present, it appears the developer is try­ing to max­im­ise the return on invest­ment by fit­ting as many prop­er­ties as is allow­able with­in a very con­fined space. Know­ing the field well, it does not appear prac­tic­ally achiev­able to fit 6 houses into the lower third alone (where fur­ther houses and a block of flats are pro­posed with­in the same field) without caus­ing sig­ni­fic­ant dam­age. Spe­cif­ic requests for con­sid­er­a­tion are lis­ted at the end of this document.

In gen­er­al com­ment, while I am not opposed to new hous­ing, I feel that to achieve the goals of the nation­al park in pre­serving the nat­ur­al and cul­tur­al envir­on­ment, developers should be dis­suaded from devel­op­ing on green­field sites, which are cur­rently treated like a blank can­vas, while brown­field sites, areas of under­u­til­ised amen­ity and derel­ic­tion are over­looked. While I acknow­ledge land sur­round­ing Camp­bell Cres­cent, Ker­row Drive, and Dun­barry Ter­race is zoned for hous­ing devel­op­ment with­in the loc­al devel­op­ment plan (from which author­it­ies can choose to depart), this should not encour­age developers to pack new hous­ing densely into very small areas, as in the above application.

To sup­port my objec­tion, I have attached the below map (Fig. 1) indic­at­ing with­in blue poly­gons (1) boggy area with wet­land veget­a­tion, white poly­gon (2) dry­stone wall and exist­ing fence line, red poly­gon (3) scrub and exist­ing path,

and exist­ing trees which have not already been marked on site lay­out plans.

Fig­ure 1: Site features

Chal­lenge to EIA Screen­ing opin­ion There are sev­er­al ​“No” responses indic­ated by the developer on the EIA screen­ing opin­ion form which I would chal­lenge. • 5.1 Are there any water resources includ­ing sur­face waters, e.g. rivers, lakes/​ponds, coastal or under­ground waters on or around the loc­a­tion which could be affected by the pro­ject, par­tic­u­larly in terms of their volume and flood risk?

Sur­face and ground water col­lects in the boggy areas indic­ated in Fig 1., no.1. The veget­a­tion mit­ig­ates the impact, but they are rel­at­ively deep (~30 – 50cm) and have over­flowed into sur­round­ing gar­dens. The increased hard­stand­ing and remov­al of veget­a­tion would worsen this. • 6.2 Could any pro­tec­ted, import­ant or sens­it­ive spe­cies of flora or fauna which use areas on or around the site, e.g. for breed­ing, nest­ing, for­aging, rest­ing, over-win­ter­ing, or migra­tion, be affected by the project?

There are sev­er­al pro­tec­ted spe­cies either def­in­itely or poten­tially using the site, and with­in 200m of the site, as indic­ated in the table attached in this doc­u­ment. • 8.1 Are there any areas or fea­tures which are pro­tec­ted for their cul­tur­al her­it­age or archae­olo­gic­al value, or any non-des­ig­nated / clas­si­fied areas and/​or fea­tures of cul­tur­al her­it­age or archae­olo­gic­al import­ance on or around the loc­a­tion which could be affected by the pro­ject (includ­ing poten­tial impacts on set­ting, and views to, from and with­in)? Where des­ig­nated indic­ate level of des­ig­na­tion (inter­na­tion­al, nation­al, region­al or local).

The drys­tane dykes sur­round­ing the site, while not iden­ti­fied on Can­more map­ping, are of loc­al sig­ni­fic­ance. The drys­tane dyke to the south, imme­di­ately adja­cent to my prop­erty, is likely to have been built circa 1892, with more recent walls built by Kin­gussie res­id­ents. They all have addi­tion­al eco­lo­gic­al import­ance due to

being little dis­turbed. • 10.1 Are there exist­ing land uses or com­munity facil­it­ies on or around the loc­a­tion which could be affected by the pro­ject? E.g. hous­ing, densely pop­u­lated areas, industry / com­merce, farm/​agricultural hold­ings, forestry, tour­ism, min­ing, quar­ry­ing, facil­it­ies relat­ing to health, edu­ca­tion, places of wor­ship, leis­ure /​sports/​recre­ation.

There is exist­ing hous­ing on all sides of the site which, while not cur­rently densely packed, would become so fol­low­ing new hous­ing con­struc­tion on the site. The site itself is cur­rently heav­ily used recre­ation­ally, along with Tom Baraidh to the north, as indic­ated by the Strava heat­map­ping below.

Fig­ure 2: Strava heat­map of site

Sur­face water, sub­sid­ence, and drain­age The field is on a sig­ni­fic­ant gradi­ent, vary­ing from 11 – 23% slope between my prop­erty and Tom Baraidh. Sig­ni­fic­ant earth­works will be required to grade this out, which presents an increased risk of sub­sid­ence into sur­round­ing prop­er­ties, as well as poten­tially impact­ing the exist­ing drainage.

The over­land flood ana­lys­is provided does not appear to take full account of this gradi­ent. With the increase in hard stand­ing, sur­face water is highly likely to over­whelm what has been char­ac­ter­ized as an ​“exist­ing field drain” but is a rem­nant dry­stone wall (Fig.1, no.2) with a heav­ily veget­ated boggy area. The sur­face water is also likely to run off via the pro­posed whin dust path through the scrub veget­a­tion (Fig. 1, no.3). The atten­u­ation tank pro­posed is not sited to receive the sur­face water run-off from the 6 houses to the south. It is also unclear into what sys­tem the atten­u­ation tank itself would drain. There appears to be an over­re­li­ance that run-off will dis­charge via exist­ing field, garden, and road drain­age. The French drain­age sys­tems in gar­dens are lim­ited, fre­quently blocked by leaf lit­ter, and reli­ant on retain­ing walls in the gar­dens of 29 and 31 Camp­bell Cres­cent. The pre­vi­ous own­ers of 31 Camp­bell Cres­cent required to install addi­tion­al chan­nel drain­age as a res­ult, under the present cir­cum­stances. Neigh­bours have repor­ted that flood events have occurred which led to sur­face water run off enter­ing their garden and under­min­ing their gar­age because of houses built fur­ther uphill. Over time, these impacts are likely to have been some­what mit­ig­ated by an increase in wetland/​bog veget­a­tion indic­ated in Fig.1, no.1. This nat­ur­al mit­ig­a­tion would be com­prom­ised by the new build­ings and increased hard standing.

The sew­er sys­tem is also very old and nar­row, with us and our neigh­bours hav­ing exper­i­enced mul­tiple block­ages. We exper­i­enced a sew­er block­age which required pres­sure clean­ing on sev­er­al occasions.

I note the response from Scot­tish Water reads: ​“For reas­ons of sus­tain­ab­il­ity and to pro­tect our cus­tom­ers from poten­tial future sew­er flood­ing, Scot­tish Water will not accept any sur­face water con­nec­tions into our com­bined sew­er system.”

Design­ing Streets guid­ance Sev­er­al aspects of Scot­tish Government’s Design­ing Streets guid­ance would not be met by the pro­pos­al. • Block struc­ture – “[…] should be dis­tinct­ive with land­marks and vis­tas which provide good ori­ent­a­tion and nav­ig­a­tion of the area.”

The cur­rent pro­pos­al cre­ates a new, poten­tially dom­in­at­ing, block of hous­ing which would block the exist­ing vis­tas to the north, redu­cing oppor­tun­it­ies for pass­ive sur­veil­lance, and decreas­ing a sense of safety for some res­id­ents. The pro­posed road access is long and con­vo­luted. Due to the gradi­ent, and exist­ing street lay­outs, nav­ig­a­tion to neigh­bour­ing streets would be hid­den from view. The pro­posed design of foot­paths to neigh­bour­ing streets is likely to be dam­aged by sur­face water and veget­a­tion with­in a year. Dis­tinct­ive fea­tures appear to be pro­posed for remov­al. • Ori­ent­a­tion – ​“Ori­ent­a­tion of build­ings, streets and open space should max­im­ise envir­on­ment­al benefits”

The cur­rent ori­ent­a­tion of the build­ings removes the envir­on­ment­al bene­fits of the exist­ing grass­land. This could be mit­ig­ated by redu­cing the num­ber of build­ings pro­posed in the small area. • Drain­age — ​“Streets should use appro­pri­ate SUDS tech­niques as rel­ev­ant to the con­text in order to min­im­ise envir­on­ment­al impacts”

The amount of hard stand­ing cur­rently pro­posed will increase sur­face water run off drastic­ally but removes oppor­tun­it­ies for appro­pri­ate SUDS. The cur­rent grassy/​boggy area func­tions as nat­ur­al drain­age over a gradi­ent, pre­vent­ing sur­face water run off into the houses and gar­dens to the south. Any increase in sur­face water run off is likely to flood our own house, espe­cially with the impact of cli­mate change. • Plant­ing — ​“Street design should aim to integ­rate nat­ur­al land­scape fea­tures and foster pos­it­ive biodiversity”

The cur­rent plans seem to indic­ate plant­ing would occur; how­ever, this would be new plant­ing, rather than integ­rat­ing the exist­ing land­scape. A reduced num­ber of build­ings in this small area could main­tain more of the exist­ing grass and scrub and reduce the impact on the under­ly­ing soil mycor­rhiza which has developed over hun­dreds of years. This should not be turned into ​“amen­ity grass­land” which has little eco­lo­gic­al value, but the exist­ing veget­a­tion clas­si­fic­a­tion should be main­tained. • Street light­ing – ​“Street light­ing should be as dis­creet as pos­sible, but provide adequate illumination”

New street light­ing is likely to impact bats who use the grass­land for feed­ing. I don’t believe any new light­ing spe­cific­a­tions are clear from the plans, and there­fore can­not be assessed for appro­pri­ate­ness for bats. • Con­text and char­ac­ter – ​“Oppor­tun­it­ies should be taken to respond to, and to derive value from, rel­ev­ant ele­ments of the his­tor­ic envir­on­ment in cre­at­ing places of dis­tinct­ive character”

The cur­rent design bound­ary appears to remove the exist­ing dry­stone wall which, from his­tor­ic­al map­ping, may have been present since ~1890. Such fea­tures should be retained. The wall also has substantial

• • • • eco­lo­gic­al value, cla­ri­fied else­where in this doc­u­ment. Backs and fronts – ​“In gen­er­al, it is recom­men­ded that dif­fer­ent treat­ments are employed in the design of the fronts and backs of houses and oth­er build­ings. The basic prin­ciple is ​‘pub­lic fronts and private backs’.”

While the pro­pos­al would cre­ate private garden space at the back of the new build­ings, it would impact the pri­vacy of the exist­ing hous­ing. This would be exacer­bated by the new build­ings being high­er up a gradi­ent, over­look­ing exist­ing hous­ing. New two-storey houses would be dom­in­at­ing, espe­cially coupled with a new block of flats per sep­ar­ate plan­ning applic­a­tion, and dir­ectly over­look into our bed­room which due to the height dif­fer­ence would not be pre­ven­ted by pri­vacy fen­cing. Height — ​“It is there­fore recom­men­ded that the height of build­ings is in pro­por­tion to the width of the inter­ven­ing pub­lic space to achieve the level of enclos­ure appro­pri­ate to the char­ac­ter and func­tion of the street. Where build­ing height is increased, it is import­ant to avoid cre­at­ing spaces with an oppress­ive or claus­tro­phobic nature.”

As dis­cussed above, the gradi­ent will sig­ni­fic­antly increase the appear­ance of build­ing height from below. This will cer­tainly cre­ate an oppress­ive and claus­tro­phobic nature. Squares and spaces – ​“A street and block struc­ture can be enhanced with punc­tu­ations of pub­lic space. This may take the form of parks, green edges or form­al and inform­al squares. The intro­duc­tion of small, inform­al squares in a res­id­en­tial area can sup­port nav­ig­a­tion, provide social areas for people to gath­er and chil­dren to play, slow traffic speed and cre­ate pos­it­ive character.”

Giv­en that plan­ning applic­a­tions already dom­in­ate much of the sur­round­ing area, it would seem appro­pri­ate to retain the acre­age covered by this applic­a­tion for six houses instead as a small, inform­al pub­lic space, main­tain­ing the exist­ing veget­a­tion for its eco­lo­gic­al bene­fits and per­haps upgrad­ing the exist­ing desire line to con­nect into Tom Baraidh. Vari­ety — ​“Char­ac­ter can be enhanced and emphas­ised by vari­ety in the streets­cape. Punc­tu­at­ing key views with land­marks or green edges can provide visu­al cues that aid nav­ig­a­tion as well as help­ing to devel­op areas of indi­vidu­al char­ac­ter with­in the over­all urb­an structure.”

The pro­posed devel­op­ment does not increase vari­ety in the streets­cape. Put simply, the pro­posed hous­ing looks exactly the same as hous­ing which is being rolled out across the High­lands. This increases uni­form­ity and reduces loc­al, indi­vidu­al char­ac­ter. Street pat­terns – ​“Short culs-de sac may occa­sion­ally be required because of topo­graphy, bound­ary or oth­er con­straints. Cau­tion must, how­ever, be exer­cised when plan­ning for culs-de sac, as they con­cen­trate traffic impact on a small num­ber of dwell­ings, require turn­ing heads that are waste­ful in land terms and lead to addi­tion­al vehicle travel and emis­sions, par­tic­u­larly by ser­vice vehicles.”

The excess­ive park­ing pro­posed (2 spaces per house, both on and off-street, in addi­tion to fur­ther spaces in adja­cent devel­op­ments) cre­ates a require­ment for addi­tion­al road space for a turn­ing head and adds addi­tion­al width to the road itself. No pro­vi­sion for cycle park­ing has been made. This would be mit­ig­ated by redu­cing the num­ber of park­ing spaces per house to one (or provid­ing space for two vehicles in one private drive­way), or by redu­cing the num­ber of houses pro­posed, or both. 63% of res­id­ents in the Nation­al Park area have one or few­er cars or vans, accord­ing to the last avail­able census data: No cars or vans: 1,276. One car or van: 4,108. Two or more cars or vans: 3,060 On the top­ic of access­ib­il­ity for people using wheel­chairs or mobil­ity aids, the cur­rent point of egress will be the pro­posed road only. The whindust private access paths via Camp­bell Cres­cent and Acres Road do not meet an adopt­able stand­ard for foot­paths. Whindust paths which take addi­tion­al sur­face water and have not been adopted

for main­ten­ance are highly likely to become dam­aged, uneven, and over­grown very quickly. Some people with dis­ab­il­it­ies, push­chairs or bug­gies, or lim­ited mobil­ity would be lim­ited to access­ing their home via car, assum­ing they are able to drive, or would be oth­er­wise put off by the addi­tion­al 500m route via Ker­row Drive and Dun­barry Ter­race. If this hous­ing is inten­ded to be afford­able, there is a sig­ni­fic­ant risk of increas­ing social isol­a­tion by mak­ing it dif­fi­cult for people to leave their homes. This may con­tra­vene the Equal­ity Act 2010.

Eco­lo­gic­al Impact

As there appeared to be few doc­u­ments relat­ing to eco­lo­gic­al impacts attached to the applic­a­tion 2024/0005/DET, I also looked at 2020/0193/DET and 2020/0013/DET for any addi­tion­al inform­a­tion. Between these three, a full Pre­lim­in­ary Eco­lo­gic­al Apprais­al or study of sim­il­ar depth does not appear to have been car­ried out, res­ult­ing in over­sight of sev­er­al pro­tec­ted spe­cies using the area. The Phase 1 hab­it­at sur­vey avail­able on the plan­ning portal does not cov­er the site pro­posed in this plan­ning amend­ment, and addi­tion­al sur­veys do not all cov­er the area con­cerned in 2024/0005/DET, except for a rep­tile sur­vey, see Table 1 below. Myself and my part­ner have observed rep­tiles on site which coun­ters the find­ings of the survey.

Myself, my part­ner, and my neigh­bours have all dir­ectly observed mul­tiple oth­er pro­tec­ted spe­cies on or dir­ectly adja­cent to the site, in addi­tion to rep­tiles, and there are dif­fer­ent hab­it­ats avail­able on the site as com­pared to the high­er fields covered by 2020/0193/DET. Table 2 con­tains a list of dir­ect obser­va­tions of pro­tec­ted spe­cies occur­ring since June 2023, and an assess­ment of wheth­er the site may provide suit­able hab­it­at for others.

In Fig.1, poly­gon no. 2, is indic­ated an area of dry­stone rem­nants, trees and scrub which clearly provide import­ant hab­it­at for mul­tiple pro­tec­ted spe­cies, as we have dir­ectly observed. This area of the field should be removed from the site extents entirely.

Sev­er­al of the pro­tec­ted bird spe­cies are ground feed­ers, rely­ing on scrub and grass­land veget­a­tion, such as that found on the site, espe­cially at the fringes which act as an edge hab­it­at. We have observed pro­tec­ted bird spe­cies act­ively using these with 100+ birds of 16+ spe­cies vis­ible daily. We have also observed spe­cies hunt­ing and using the site for dust bathing includ­ing kestrels, owls, and buz­zards. The dry­stone walls provide suit­able ​“com­mut­ing” for mam­mals and reptiles.

I would urge the Author­ity to fully enact the pre­cau­tion­ary prin­ciple out­lined in the Loc­al Devel­op­ment Plan 2021 (4.69).

Table 1: Eco­lo­gic­al sur­vey­ing extents

Pub­licly avail­able doc­u­ment related to eco­lo­gic­al impact	Does it cov­er the area mapped in 2024/0005/DET?
2020 0193 DET- DUN­BARRY TER­RACE PHASE 1 HAB­IT­AT SUR­VEY- 100165719.pdf (eplan​ningcnpa​.co​.uk)	No
2020 0193 DET-TREE SUR­VEY REPORT-100165812.pdf (eplan​ningcnpa​.co​.uk)	No
2020 0193 DET- REP­TILE PRO­TEC­TION METHODOLOGY-100167360.pdf (eplan​ningcnpa​.co​.uk)	No, and a full rep­tile sur­vey has not occurred, as writ­ten in the doc­u­ment itself
2020 0193 DET-CON­DI­TION 5 — GREAT­ER BUT­TER­FLY-ORCH­ID SUR­VEY REPORT- 100175096.pdf (eplan​ningcnpa​.co​.uk)	No
2020 0193 DET- PRO­TEC­TED TER­RESTRI­AL MAM­MAL SUR­VEY REPORT- 100165717.pdf (eplan​ningcnpa​.co​.uk)	No
2020 0013 DET-CON­DI­TION 2 REP­TILE SUR­VEY- 100177413.pdf (eplan​ningcnpa​.co​.uk)	Yes, but find­ings countered by dir­ect observations

Table 2: Pro­tec­ted spe­cies and hab­it­ats on/​near 2024/0005/DET The table is provided to high­light the unknowns and evid­ence the need for the pre­cau­tion­ary prin­ciple. It includes dir­ect sight­ings of pro­tec­ted spe­cies since June 2023, as well as a high-level assess­ment of wheth­er the field includ­ing peri­phery could poten­tially provide suit­able hab­it­at for oth­ers. Due to the time avail­able for response (31^st Janu­ary from neigh­bour noti­fic­a­tion by post) I have not covered lichens, mosses, or liv­er­worts in the hab­it­at assess­ment. Hab­it­at assess­ments are informed by mul­tiple resources and data­sets includ­ing NatureScot, BSBI, But­ter­fly Con­ser­va­tion, Bat Con­ser­va­tion Trust, Wild­life Trusts, High­land Bio­lo­gic­al Record­ing Group, NBN Atlas, Froglife, iNat­ur­al­ist, and others.

Tax­on	Tax­on name	Com­mon name	Obser­va­tion on or with­in 200m of site (dir­ect, indir­ect) with­in past 8 months	Pos­sible suitable/​supporting hab­it­at (on site, with­in 20m, with­in 200m)
Amphi­bi­an	Rana tem­por­ar­ia	Com­mon frog	Yes — dir­ect observation	On site
Amphi­bi­an	Bufo bufo	Com­mon toad	Yes — dir­ect observation	On site
Amphi­bi­an	Trit­ur­us cristatus	Great cres­ted newt	Unknown	On site
Amphi­bi­an	Trit­ur­us helveticus	Pal­mate newt	Unknown	On site
Amphi­bi­an	Trit­ur­us vulgaris	Smooth newt	Unknown	On site
Bird	Turdus mer­ula	Black­bird	Yes — dir­ect observation	With­in 20m of site
Bird	Fringilla mon­ti­fringilla	Brambling	Yes — dir­ect observation	With­in 20m of site
Bird	Pyrrhula pyrrhula	Bull­finch	Yes — dir­ect observation	With­in 20m of site
Bird	Fringilla coelebs	Chaffinch	Yes — dir­ect observation	With­in 20m of site
Bird	Gal­lin­ago gallinago	Com­mon snipe	Unknown	On site
Bird	Parus cristatus	Cres­ted tit	Unknown	With­in 200m of site
Bird	Lox­ia spp	Cross­bills (all species)	Unknown	With­in 200m of site
Bird	Prunella mod­u­lar­is	Dun­nock	Yes — dir­ect observation	With­in 20m of site
Bird	Turdus pil­ar­is	Field­fare	Unknown	On site
Bird	Plu­vial­is apricaria	Golden plover	Unknown	On site
Bird	Car­du­el­is carduelis	Gold­finch	Yes — dir­ect observation	On site
Bird	Accipiter gen­til­is	Gos­hawk	Unknown	With­in 200m of site
Bird	Car­du­el­is chloris	Green­finch	Yes — dir­ect observation	With­in 20m of site
Bird	Anser anser	Greylag goose	Unknown	On site
Bird	Per­nis apivorus	Honey buz­zard	Unknown	On site
Bird	Cor­vus monedula	Jack­daw	Yes — dir­ect observation	On site
Bird	Gar­rulus glandarius	Jay	Yes — dir­ect observation	With­in 200m
Bird	Car­du­el­is cannabina	Lin­net	Yes — dir­ect observation	With­in 20m
Bird	Anas platyryn­chos	Mal­lard	Unknown	On site
Bird	Falco colum­bari­us	Mer­lin	Unknown	On site
Bird	Falco peri­grinus	Per­eg­rine falcon	Unknown	With­in 20m of site
Bird	Coturnix coturnix	Quail	Unknown	On site
Bird	Mil­vus milvus	Red kite	Unknown	With­in 200m of site
Bird	Car­du­el­is flammea	Red­poll	Unknown	With­in 200m of site
Bird	Turdus ili­acus	Red­wing	Unknown	On site
Bird	Car­du­el­is spinus	Sis­kin	Yes — dir­ect observation	With­in 20m of site
Bird	Turdus philomelos	Song thrush	Yes — dir­ect observation	On site
Bird	Sturnus vul­gar­is	Starling	Yes — dir­ect observation	On site
Bird	Car­du­el­is flavirostris	Twite	Unknown	On site
Bird	Columba palum­bus	Wood­pi­geon	Yes — dir­ect observation	With­in 20m of site
But­ter­fly	Coen­onympha tullia	Large heath	Unknown	On site
But­ter­fly	Cupido min­im­us	Small blue	Unknown	On site
Mam­mal	Meles meles	Badger	Indir­ect obser­va­tion — calls, tracks and signs	With­in 20m
Mam­mal	Ple­cotus auritus	Bat — Brown long-eared		On site

| Mam­mal | Pip­istrel­lus pip­istrel­lus | Bat — Com­mon pip­istrelle | | On site | | Mam­mal | Myot­is daubentonii | Bat — Daubenton’s | | On site | | Mam­mal | Myot­is nat­ter­eri | Bat — Natterer’s | Yes — dir­ect obser­va­tion — how­ever, without the cor­rect equip­ment it is hard to dis­tin­guish spe­cies. | On site | | Mam­mal | Pip­istrel­lus pyg­maeus | Bat — Sop­rano pip­istrelle | | On site | | Mam­mal | Erin­aceus euro­paeus | Hedge­hog | Yes — dir­ect obser­va­tion | On site | | Mam­mal | Martes martes | Pine marten | Unknown | With­in 200m of site | | Mam­mal | Sciur­us vul­gar­is | Red squir­rel | Yes — dir­ect obser­va­tion | With­in 20m of site | | Mam­mal | Arvic­ola ter­restris | Water vole | Unknown | On site | | Rep­tile | Vipera ber­us | Adder | Unknown | On site | | Rep­tile | Anguis fra­gil­is | Slow worm | Unknown | On site | | Rep­tile | Zootoca vivi­para | Vivi­par­ous liz­ard | Yes — dir­ect obser­va­tion | On site | | Vas­cu­lar Plant | Hyacinthoides non-scripta | Blue­bell | Unknown | With­in 200m | | Vas­cu­lar Plant | Wood­sia ilven­sis | Oblong wood­sia | Unknown | On site | | Vas­cu­lar Plant | Saxi­fraga hir­cu­lus | Yel­low marsh saxi­frage | Unknown | On site |

Requests for con­sid­er­a­tion • Amend the site bound­ary to exist­ing fence line (see Fig. 1, dot­ted line). • Sig­ni­fic­antly reduce the num­ber of houses pro­posed in this very small area, and design as to reduce their uni­form­ity. This will enhance per­meab­il­ity, eco­lo­gic­al oppor­tun­it­ies, and com­munity well­being. • Altern­at­ively, remove the pro­posed houses and flats to the south from the devel­op­ment plans, and retain much or all of the field as a nat­ur­al amen­ity. • Employ the pre­cau­tion­ary prin­ciple in terms of eco­lo­gic­al impact. Under­take more extens­ive and spe­cial­ised eco­lo­gic­al sur­vey­ing, at the appro­pri­ate times of year per CIEEM guid­ance, and use con­struc­tion meth­ods which assume grass­land and scrub spe­cies are present regard­less of sur­vey find­ings. • Retain all young trees and scrub veget­a­tion on the field peri­pher­ies, as indic­ated in Fig. 1. • Retain her­it­age fea­tures such as dry­stone walls, includ­ing rem­nants as indic­ated in Fig 1, no.2. • As far as prac­tic­al, rein­state exist­ing grass­land spe­cies with­in new garden areas, as opposed to repla­cing with amen­ity grass/​turf or grass spe­cies not nat­ive to the area. • Ensure appro­pri­ate drain­age, informed by hydro­geo­lo­gic­al sur­vey­ing, for run-off and ground­wa­ter mit­ig­a­tion to pre­vent impact­ing sur­round­ing gar­dens, house found­a­tions, roads, or foot­paths, and as far as pos­sible retain or improve exist­ing wet­land veget­a­tion. • Under­take any sur­vey­ing required to ensure the sew­er sys­tem will not become com­prom­ised by increased wastewa­ter from new houses. • Under­take ground invest­ig­a­tions and pro­pose mit­ig­a­tions against the risk of sub­sid­ence. • Foot­paths should be designed to adopt­able stand­ards, as well as to access­ible stand­ards in terms of gradi­ents, per Inclus­ive Mobil­ity or Roads for All guid­ance. • The foot­path (Fig. 1, no.3) between 31 Camp­bell Cres­cent and 33 Camp­bell Cres­cent should use a low/no-dig meth­od and avoid or min­im­ise scrub remov­al as this cur­rently provides pri­vacy for houses, and hab­it­at for birds and small mam­mals. • Non-mater­i­al request to developer re: con­struc­tion noise — there are people who work from home and who work night shifts in the imme­di­ate area, and the con­struc­tion meth­od must take this into account – no gen­er­at­ors overnight, no con­stant beep­ing from heavy plants, no radi­os, etc. • Non-mater­i­al request to developer: Bey­ond the usu­al defects peri­od, the developer as prin­cip­al design­er should be liable for mak­ing good any dam­age to the sur­round­ing houses arising from the design, such as from flood­ing, dam­age to drains, sub­sid­ence, etc.

Many thanks for your con­sid­er­a­tion of the above.