Great Crested Newt Surveys Land at Gonerby Moor, Grantham, Lincolnshire

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Great Crested Newt Surveys Land at Gonerby Moor, Grantham, Lincolnshire
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                        Great Crested Newt Surveys
     Land at Gonerby Moor, Grantham, Lincolnshire
                                           April 2021
                                        Report no: WOR 1335.3

                                              A report by

                      Colin Hicks BSc (Hons) MCIEEM, Principal Ecologist

Western Ecology, 1 Geffery Close, Landrake, Cornwall PL12 5HA   Telephone: 0800 622 6828
email: office@westernecology.co.uk
Great Crested Newt Surveys Land at Gonerby Moor, Grantham, Lincolnshire
Report details

Site name:             Land at Gonerby Moor
Site address:          Gonerby Moor, Grantham, Lincolnshire
Grid reference:        SK 891 406
Survey date:           28th April 2020
Report date:           12th April 2021
Report author:         Colin Hicks BSc (Hons), MCIEEM

Report no:             WOR 1335.3

Declaration of compliance

BS 42020:2013
This study has been undertaken in accordance with British Standard 42020:2013
Biodiversity, Code of Practice for Planning and Development.

Code of Professional Conduct
The information which we have prepared is true, and has been prepared and provided in
accordance with the Chartered Institute of Ecology and Environmental Management’s Code
of Professional Conduct. We confirm that the opinions expressed are our true and
professional bona fide opinions.

Validity of survey data and report
The findings of this report are valid for 24 months from the date of survey. If work has not
commenced within this period, an updated survey by a suitably qualified ecologist will be
required.

Revisions
       Date         Report no:   Approved by:      Comment
       22/05/2020   WOR-1335     CDH               Original report
       25/11/2020   WOR-1335.2   CDH               Report aligned with UK_Gonerby Moor_LP2-PDL_04
                                                   no: GON_01
       12/04/2021   WOR-1335.3   CDH               Report aligned with UK_Gonerby Moor_LP2-PDL_09
                                                   no: GON_01

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Great Crested Newt Surveys Land at Gonerby Moor, Grantham, Lincolnshire
Table of contents
1. Introduction .................................................................................................................... 4
   1.1.    Survey aims ........................................................................................................ 4
   1.2.    Site location......................................................................................................... 4
2. Survey Methodology ...................................................................................................... 5
   2.1.    Biological records search .................................................................................... 5
   2.2.    Habitat suitability Index (HSI) .............................................................................. 5
   2.3.    eDNA surveys ..................................................................................................... 5
3. Results ........................................................................................................................... 6
   3.1.    Biological records search .................................................................................... 6
   3.2.    Habitat Suitability Index (HSI) .............................................................................. 6
   3.3.    eDNA surveys ..................................................................................................... 7
   3.4.    Survey constraints ............................................................................................... 7
   Map 1. Waterbodies surveyed for Great Crested Newts HSI and eDNA ......................... 8
4. Legislation...................................................................................................................... 9
5. Habitat assessment ..................................................................................................... 10
6. Assessment of potential impacts associated with development .................................... 12
7. Reasonable avoidance measures ................................................................................ 13
   7.1.    Limit of the RAMs .............................................................................................. 13
   7.2.    Toolbox talk ....................................................................................................... 13
   7.3.    Timing of works ................................................................................................. 13
   7.4.    Limit of construction works ................................................................................ 14
   7.5.    Storage of materials .......................................................................................... 14
   7.6.    Traffic movements ............................................................................................. 14
   7.7.    Cable route........................................................................................................ 14
   7.8.    Unexpected GCN within site .............................................................................. 14
   7.9.    Enhancement for GCN ...................................................................................... 14
8. Conclusion ................................................................................................................... 16
   Map 2. Great Crested Newt Mitigation .......................................................................... 18
9. Appendix 1 ................................................................................................................... 19
   SureScreen Scientifics Technical Reports .................................................................... 19

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Great Crested Newt Surveys Land at Gonerby Moor, Grantham, Lincolnshire
1. Introduction
Western Ecology has been commissioned to complete a Great Crested Newt Environmental
DNA surveys of seven ponds associated with an area of agricultural land to the north of
Gonerby Moor, Grantham, Lincolnshire. Installation and operation of a Solar Farm together
with all associated works, equipment and necessary infrastructure is proposed.

1.1. Survey aims
The survey aim is to determine presence of Great Crested Newt (GCN) within 500 metres of
the proposed development. This will allow an assessment of likely impact, and where
appropriate, recommendations will be made for impact avoidance, mitigation and post-
development enhancement to ensure compliance with wildlife legislation and relevant
planning policy.

1.2. Site location
The area of land surveyed is situated at the northern edge of the village of Gonerby Moor,
and 5km to the north-west of the town of Grantham in the South Keverston district of
Lincolnshire.

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Great Crested Newt Surveys Land at Gonerby Moor, Grantham, Lincolnshire
2. Survey Methodology
2.1. Biological records search
The desktop survey from Lincolnshire Environmental Records Centre provided biological
records for GCN within 2 km of the site.1

2.2. Habitat suitability Index (HSI)
All accessible waterbodies within 500 metres of the site were evaluated for their potential to
support Great Crested Newt by calculating a habitat suitability index (HSI) as per ARG UK
Advice Note 5.

2.3. eDNA surveys
Water samples for eDNA analysis to determine presence/absence of Great Crested Newt
were collected from 7 waterbodies within the survey area on 28th April 2020 (Map 1). The
survey visits were carried out within the optimum period of mid April to late June and the
samples were collected by a suitably experienced and licenced ecologist.

The eDNA sampling kits were supplied by SureScreen Scientifics and the survey
methodology followed the Natural England protocol2.

For each water body, 20 samples of 30 ml each were collected from the edge of the
waterbody by a suitably licenced and qualified ecologist. These samples were then mixed
after which15ml was withdrawn and added to each of six tubes containing a preservative.
Six tubes from each waterbody were sent for analysis by SureScreen Scientifics.

1
 Please see Preliminary Ecological Appraisal for additional detail
2
 Biggs J, Ewald N, Valentini A, Gaboriaud C, Griffiths RA, Foster J, Wilkinson J, Arnett A, Williams P and Dunn F 2014.
Analytical and methodological development for improved surveillance of the Great Crested Newt. Defra Project WC1067.
Freshwater Habitats Trust: Oxford.

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Great Crested Newt Surveys Land at Gonerby Moor, Grantham, Lincolnshire
3. Results
3.1.   Biological records search
The biological records search returned 2 records for Great Crested Newt all pre-2003 and
approximately 1.7km to the north east of the site.

There are no statutory or non-statuary nature conservation site selected for Great Crested
Newt within 2km.

3.2.   Habitat Suitability Index (HSI)
HSI was calculated for 9 ponds.

A pond is present in Field B (P7 – Map 1), whilst further ponds are present beyond site
boundaries including fisheries ponds to the north east (P1 & P2), three ponds within the
adjacent motocross track (P3 – P6) and two ponds at the south western site boundary (P8 &
P9).

Great Crested Newt Habitat Suitability Index (HSI) has been calculated for all ponds based
on ARG UK Advice Note 5 either assessed from the field visit (P6 – P9) and from aerial
imagery and local knowledge (P1 – P6):

       P1 = 0.51 (below average)
       P2 = 0.53 (below average)
       P3 = 0.79 (good)
       P4 = 0.72 (good)
       P5 = 0.79 (good)
       P6 = 0.62 (average)
       P7 = 0.50 (below average)
       P8 = 0.76 (good)
       P9 = 0.75 (good)

Pond P7 scored low due to its small size and isolated location within an arable field, whilst
ponds P1 and P2 are part of coarse fishery. The presence of fish make it highly unlikely that
these will support Great Crested Newt, as fish are significant predators on eggs and larval
stages.

Ponds beyond the A1 and Great North Road to the west are not included in this assessment
as these features provide a significant barrier to Great Crested Newt dispersal. No other
suitable ponds are present within 500 metres of the site.

The HSI provides an indication of the likelihood of a pond supporting Great Crested Newt:

       •   Only 3% of ponds with ‘poor’ HSI scores are likely to be occupied by Great
           Crested Newt.
       •   Twenty percent of ponds with ‘below average’ scores are likely to be occupied by
           Great Crested Newt.

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•   More than half of ponds (55%) with ‘average’ scores are likely to be occupied by
           Great Crested Newt.
       •   Seventy-nine percent of ponds with ‘good’ scores are likely to be occupied by
           Great Crested Newt.

3.3.   eDNA surveys
eDNA surveys were completed on Ponds 2 to 9 on 28th April 2020. Samples were received
at the laboratory on 28th April and results reported on 6th May (Appendix 1).

Samples from Ponds P4, P5, P6, P8 and P8 were Negative for GCN eDNA.

Samples from Ponds P3 and P7 were Positive for GCN eDNA.

3.4.   Survey constraints
The surveys were completed in the period within which Natural England will accept DNA
evidence to support a European Protected Species licence application.

All areas were accessible and a full assessment was made. There are no significant
constraints to the survey results at this site.

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Map 1. Waterbodies surveyed for Great Crested Newts HSI and eDNA
4. Legislation
Great Crested Newt and their breeding sites and resting places (during all parts of their
lifecycle), are fully protected under the Wildlife and Countryside Act 1981 (as amended), and
The Conservation of Habitats and Species Regulations 2017. They are identified as
European Protected Species. Under these laws it is an offence to:
        • capture, kill, disturb or injure Great Crested Newts (on purpose or by not taking
             enough care);
        • damage or destroy a breeding or resting place (even accidentally);
        • obstruct access to their resting or sheltering places (on purpose or by not taking
             enough care);
        • possess, sell, control or transport live or dead newts, or parts of them; or
        • take Great Crested Newt eggs.

Great Crested Newt are listed as a species of Principal Importance for the conservation of
biodiversity.

Any development activities which could result in the accidental killing, injury or disturbance of
GCN may constitute an offence under the Habitats Regulations. GCN breed in ponds and
other waterbodies but they occupy terrestrial habitats such as grassland, scrub, woodland
and hedgerows for much of the year, and they may be found at distances of 250m or more
from their breeding ponds. GCN may shelter and hibernate in natural or artificial habitats
including tree roots, mammal holes, earth banks, rubble and wood piles and ground fissures.
They may also be found sheltering under surface debris, plastic sheeting etc. This means
there is the potential for a wide range of development activities to result in an offence under
the Regulations.

Natural England may issue a licence to permit activities that would otherwise give rise to an
offence under the Regulations. A European Protected Species Licence (EPSL) can be
issued for a number of purposes, including “imperative reasons of overriding public interest”
(known as IROPI), which covers development activities affecting GCN. Licences can only
be issued where there is (a) no satisfactory alternative and (b) the action authorised will not
adversely affect the favourable conservation status of the species.

However, in low risk situations Natural England encourages developers and their consultants
to consider whether non-licensed avoidance measures can be implemented to reduce or
avoid the risk of harming newts. Such measures can help to avoid the need for highly
precautionary licence applications in situations where there is a very low risk of harming
newts, or in some cases can mean that only part of a site needs to be subject to a licence.

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5. Habitat assessment
Although no ponds will be lost to the proposed development, there is potential for GCN to
use the habitats within the Site both for foraging and for hibernation purposes.

Typically, GCN use habitats with plentiful cover and a supply of invertebrates for foraging;
these could include, for example, tussocky grassland, scrub and woodland. They may
shelter and hibernate within the root systems of hedgerow shrubs and trees, under fallen
branches/logs, within mammal burrows (including rabbit holes) and in banks, earth bunds
and rubble piles.

The following observations are made on the availability of terrestrial habitats within the
proposed development site:
        • The majority arable habitat comprised stubble from the previous years crop.
           Modern cereal crops are intensively managed with regular dressings of
           herbicides, fungicides and insecticides. Although these habitats could be crossed
           by GCN during nocturnal foraging, there is no cover and the likelihood of daytime
           presence is minimal, whilst it provides no potential for hibernation due to frequent
           cultivation.
        • The narrow species poor grassland margins along field boundaries would provide
           nocturnal foraging habitat but is unlikely to provide sufficient structural complexity
           for regular resting during daytime.
        • Hedgerows and ditch habitat along the majority of field boundaries will provide
           nocturnal foraging opportunities, daytime resting habitat, and connectivity with
           off-site habitats, as will the area of woodland between the northern areas of F1
           and F2, outside the development footprint.
        • Root systems associated with hedgerows and woodland will provide hibernation
           habitat.

The two positive eDNA results were for P3 and P7. Pond P3, associated with the motocross
track, was created about 10 years ago and is located in a habitat which will in part be
regularly disturbed, although rough vegetation associated with track margins and woodland
to its north provide good terrestrial habitat for both foraging and hibernating GCN.

P7, in F2, had an HSI of 0.50 making it ‘below average’ for GCN. This was due in part to its
small size, but largely is a result of its isolation in an arable field with limited adjacent
suitable habitat (Image 1). Previous years’ aerial imagery (Google Earth) indicate this field
has been in arable rotation for at least 20 years. P7 is not considered currently to be optimal
for breeding GCN due to its location. The presence of eDNA is unlikely to be due to a long-
term, viable population of breeding GCN.

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Image 1. Pond P7

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6. Assessment of potential impacts associated with
   development
This assessment of impact considers construction within F1, F2 and F3. Construction in F4
is sufficiently distant from ponds with proven GCN presence for construction to continue with
minimal risk of an offence.

Pond P3 and P7 were positive for GCN eDNA, whilst Ponds P4, P5, P6, P8 and P9 were
negative. All ponds are within 700 metres of each other. Although eDNA analysis is not a
reliable indicator of population size, it can be reasoned from the lack of eDNA in the majority
of ponds at this site, as well as the dominance of suboptimal terrestrial habitat in the
surrounding area, that the local population of Great Crested Newts is likely to be limited in
numbers.

     On that basis it is reasonable to assume the following within F1, F2 and F3:

          •    during their terrestrial phase, March to October inclusive3, GCN may be present
               within suitable habitats (hedgerows, woodland and rough grassland at field
               margins);
          •    at night occasional GCN may move across arable habitats within this area, in
               particular between P7 and nearby field boundaries during the period March to
               October inclusive;
          •    in the period November to January inclusive, GCN may hibernate within
               hedgerows, woodland and mammal holes;

The construction phase of the proposed development will not result in a loss of valued GCN
habitat such as ponds and woodland. All construction works will be limited to arable habitats
and the development will not damage or destroy a breeding or resting place and will not
obstruct access to their resting or sheltering place.

The only risk of an offence in relation to GCN during the construction phase is the potential
to kill or disturb during the following operations:

          •    Tracking vehicles along field margins.
          •    Moving stored materials under which GCN have sought shelter.
          •    Accidental damage/pollution to Pond P7, hedgerows and rough grassland.

If works can be managed through reasonable avoidance measures that avoid the above
impacts, the risk of an offence to GCN is reasonably unlikely.

The operational phase will require site visits for maintenance, repair and habitat
management in winter months (hedgerow and grass cutting). It is extremely unlikely that
these would result in an offence and no mitigation is required.

3
 GCN display seasonal activity patterns. See Langton, T.E.S., Beckett, C.L., and Foster, J.P. (2001), Great Crested Newt
Conservation Handbook, Froglife, Halesworth.

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7. Reasonable avoidance measures
   The purpose of this method statement is to:
      • avoid an offence under regulation 41 of Conservation of Habitats and Species
         Regulations (2017); and
      • maintain the favourable conservation status of GCN associated with this site

If land management moves away from intensive arable farming prior to development, this
method statement may need to be re-visited.

7.1. Limit of the RAMs
Only F1, F2 and F3 are subject to these RAMs (Map 2) and these comprise intensively
managed arable fields with narrow grassland margins and hedgerows.

Prior to the start of works, a suitably experienced and licenced ecologist will be appointed to
act as Ecological Clerk of Works (ECoW).

In addition, a member of the construction staff will be appointed as ‘responsible person’ to
liaise with the ECoW and ensure that the ECoW is present at appropriate times during the
construction phase to ensure these RAMs are adopted in an appropriate manner.

A copy of this method statement will be made available to all site staff and sub-contractors
and will be included as an appendix in any safe systems of work adopted here.

7.2. Toolbox talk
Prior to the start of any works within F1, F2 and F3, a suitable toolbox talk will be provided to
all site staff indicating:
          • the area in which these RAMs will be adopted,
          • working methods to be adopted under the RAMs,
          • the Legal protection provided for GCN,
          • how to identify GCN,
          • what to do if a GCN is unexpectedly encountered during works, and
          • the location and purpose of any buffer zones at field boundaries.

7.3. Timing of works
Although arable habitats could theoretically be traversed by nocturnal GCN, there is little
cover and the likelihood of daytime presence within arable habitats is negligible. There are
no timing constraints to construction works within arable areas.

Occasional GCN could rest within hedgerow vegetation and adjacent species poor grassland
field margins, whilst the hedgerows could provide hibernation habitat.

Field margins and hedgerows will be retained intact behind a 6-metre buffer zone delineated
by a suitable temporary fence. There will be no access, storage of materials, ground
disturbance, vehicle movements, parking, refuelling, burning or contamination within the
fenced areas. The purpose of the fence will be explained to all site staff during site induction.

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7.4. Limit of construction works
Hedgerows and grassland will remain outside the development, protected by the 6 metre
buffer and a suitable fence (Map 2). Signs will be fixed to the fence explaining its purpose. If
any construction works will impact this 6 metre buffer zone, these will need to be done under
a separate method statement whilst under the direct supervision of the ECoW.

No features with potential to shelter GCN will be disturbed, such as log or rock piles, unless
the ECoW has completed a finger-tip search and given clearance.

7.5. Storage of materials
No materials will be stored within arable habitat areas overnight as this may provide resting
habitat suitable for newts and encourage them into the site. If this is unavoidable, materials
will be stored on a pallet, off the ground.

7.6. Traffic movements
Construction vehicles will not move within the RAMS area unless necessary.

Travel will be along dedicated tracks outside the hedgerow buffer zone. Where practicable,
these tracks will be signposted onsite and a plan provided to all relevant construction staff
showing their location.

No vehicles will be parked within the RAMs area overnight.

7.7.    Cable route
The cable route will pass through existing gaps in hedgerows.

There is potential for animals to become trapped within any trenches left open overnight.
Where possible, all trenches will be in-filled on the day of excavation. If this is not
practicable, an escape ramp, with a slope of 45 degrees or less, will be left allowing any
animal trapped within it to escape.

Any trench left open overnight will be checked prior to continuation of works.

7.8. Unexpected GCN within site
If GCN are encountered at any time during construction, the animal must be left undisturbed
and all works must stop that may impact it. The ECoW or ‘responsible person’ will be notified
immediately and advice sought from Natural England on how best to proceed.

7.9. Enhancement for GCN
There is good potential to provide a significant gain for GCN at this site by simple changes in
land management from arable to pastoral.

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Buffer habitats
The 6 metre buffer habitat to the hedgerows could be managed to create a tussocky
grassland for the benefit of GCN. Existing grassland could be retained, and bare areas sown
with a suitable grass seed mix, such as Emorsgate EG10.

Area beneath panels
The area beneath the solar panels could be sown with a suitable grass mix to provide low
impact grazing for livestock. This will create suitable habitat for GCN, especially where solar
PV supports create structural diversity for resting animals, whilst livestock dung will improve
invertebrate numbers for foraging GCN.

Pond P7
A 10 metre fenced buffer sown with a tussocky grassland mix could be created around P7
(Map 2). To prevent poaching and damage to this small pond, it should not be used as a
water source for livestock during the operational phase of the development.

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8. Conclusion
Natural England has produced guidance for developers and their consultants to help decide
whether an EPS licence is required4. This includes the following advice:

“If the consultant ecologist, on the basis of survey information and specialist knowledge of
the species concerned, considers that on balance the proposed activity is reasonably
unlikely to result in an offence under Regulation 41 or 45 then no licence is required.”

In addition, within Great Crested Newt Method Statement for EPS licence application5
Natural England state:

“Natural England is concerned about the trend for increasingly risk-averse mitigation for
several reasons. Primarily, there is no legal need, and little benefit to great crested newt
conservation, in undertaking mitigation where there are no offences through development.
Even where there technically is an offence, such as the destruction of a small, distant area of
resting place habitat, it is arguable that impacts beyond the core area often have little or no
tangible impact on the viability of populations. Mitigation in such circumstances is of
questionable value in conservation terms. There are, however, substantial costs: developers
delay projects and spend large sums on mitigation. Sometimes the mitigation project itself
has environmental costs, especially when it entails substantial lengths of newt fencing. In
some cases long newt fences are employed with no justification. Natural England wishes to
see newt fencing used more appropriately, i.e. only where there is a reasonable risk of
capturing, containing and/or excluding newts.”

Taking into account the reasonable avoidance measures in Chapter 7, the actual risk of the
development adversely affecting GCN is considered to be very low. There will be no
impacts on breeding sites, and it is considered reasonably unlikely that the works will result
in deliberate capture, injury or killing of GCN; damage or destruction of resting places; or
deliberate disturbance to GCN in such a way as to impair their ability to survive, breed,
reproduce, rear or nurture their young, hibernate or migrate, or to significantly affect the local
distribution or abundance of the species.

There is a small risk that individual GCN could be encountered during preparatory or
construction work, for example if a GCN entered the working area during construction. If this
happened and GCN were disturbed as a result it would constitute an offence. For this
reason, the precautionary measures in Section 7.8 include the actions to be taken in the
event that GCN are discovered during the preparatory or construction works.

On the basis of the information given above, it is the conclusion of the author that, on
balance, the proposed preparatory and construction work is reasonably unlikely to result in
an offence under Regulation 41 of the Conservation of Habitats and Species Regulations
2010 (as amended).

4
    WML-G12 – EPS Mitigation Licensing – How to get a licence – Version December 2013
5
    See: https://www.gov.uk/government/publications/great-crested-newts-apply-for-a-mitigation-licence

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Provided these RAMs are adopted, no European Protected Species Licence is required for
construction of this development.

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Map 2. Great Crested Newt Mitigation

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9. Appendix 1
SureScreen Scientifics Technical Reports

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