From: Development Control (DMW)
Subject: FW: LW/799/CM(EIA) Fisher's Wharf
From: Kate Cole
Sent: 11 February 2018 17:38
To: Jeremy Patterson
Subject: LW/799/CM(EIA) Fisher's Wharf
The following comments are based on as assumption that the application now covers phases 1 to 3 only as it is understood that phase 4 has been withdrawn.
· The proposed development lies within and adjacent to the Tide Mills Site of Nature Conservation Importance (SNCI), designated in part for its vegetated shingle habitat and associated communities. Whilst it is recognised that phases 1 to 3 of the proposed development lie within areas that have already been developed, no consideration has been given to the potential impacts on the surrounding SNCI, including but not limited to, disturbance, compaction, and air pollution.
· The reptile surveys reported in the Ecological Impact Assessment (Bioscan, September 2017) were not carried out in accordance with best practice, and as such, may not accurately reflect reptile populations on site. All survey visits were carried out at a sub-optimal time of year and over a compressed period of time, with some visits being conducted during unsuitable conditions, e.g. wet and/or too hot. Despite the limitations to the surveys, a reportedly small population (although without the data, this cannot be verified) of common lizards were recorded. No mitigation for reptiles is proposed.
· It is stated that the proposed development will connect to the Port Access Road once complete, but no consideration is given to the additional impact those connections will have on the SNCI. Cumulative and in combination effects have not been considered.
· No consideration has been given to how the proposed development could enhance biodiversity, as required under the NERC Act and NPPF.
In summary, insufficient information has been provided to assess the potential impacts of the proposed development on biodiversity. Consideration should be given to the impacts of the proposals on the wider SNCI. Reptile surveys should be carried out in accordance with best practice to inform appropriate mitigation. Opportunities should be incorporated to enhance the site for biodiversity.
Dr Kate Cole MCIEEM