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Gun Hill Infant School

Ecology Survey and BREEAM
Assessment Recommendations
BLANK PAGE
Issuing office
Worton Park | Worton | Oxfordshire | OX29 4SX
T: 01865 883833 | W: www.bsg-ecology.com | E: info@bsg-ecology.com

Client Willmott Dixon

Job Gun Hill Infant School

Report title Ecology Survey and BREEAM Assessment Recommendations

Draft version/final FINAL

File reference 5317.06_R_eahe_290612.docx

Name Position Date

Originated Ed Austin Senior Ecologist 14 June 2012

Reviewed Helen Evriviades Principal Ecologist 15 June 2012

Approved for
Helen Evriviades Principal Ecologist 22 June 2012
issue to client

Issued to client Ed Austin Senior Ecologist 29 June 2012

Disclaimer

This report is issued to the client for their sole use and for the intended purpose as stated in the agreement between the
client and BSG Ecology under which this work was completed, or else as set out within this report. This report may not
be relied upon by any other party without the express written agreement of BSG Ecology. The use of this report by
unauthorised third parties is at their own risk and BSG Ecology accepts no duty of care to any such third party.

BSG Ecology has exercised due care in preparing this report. It has not, unless specifically stated, independently verified
information provided by others. No other warranty, express of implied, is made in relation to the content of this report and
BSG Ecology assumes no liability for any loss resulting from errors, omissions or misrepresentation made by others.

Any recommendation, opinion or finding stated in this report is based on circumstances and facts as they existed at the
time that BSG Ecology performed the work.

Nothing in this report constitutes legal opinion. If legal opinion is required the advice of a qualified legal professional
should be secured.

Offices: Derbyshire, Oxford, Berwick-upon-Tweed, Monmouth and Swansea | BSG Ecology is a trading name of Baker Shepherd Gillespie LLP
Registered in: England and Wales No. OC328772 | Registered address: Wyastone Business Park, Wyastone Leys, Monmouth, NP25 3SR
 Gun Hill Infant School

Contents
1 Introduction .................................................................................................................................................... 2
2 Methods ......................................................................................................................................................... 4
3 Results and Identification of Potential Impacts. ............................................................................................ 6
4 Recommendations......................................................................................................................................... 9
5 BREEAM Assessment Credits (Land-use and Ecology) ............................................................................. 11
6 References .................................................................................................................................................. 14
Appendix 1: Photographs ................................................................................................................................... 15
Appendix 2: Figures ............................................................................................................................................ 16
Appendix 3: Summaries of Relevant Legislation, Policy and Other Instruments ............................................... 17

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1 Introduction
Background to Commission

1.1 Willmott Dixon Construction Ltd commissioned BSG Ecology to undertake an ecological desk study
and extended Phase 1 Habitat Survey at the Gun Hill Infant School in New Arley, Warwickshire.

Site Description

1.2 Gun Hill Infant School is located on Gun Hill road in New Arley, Warwickshire. It is a small school,
serving just over 100 children (boys and girls) aged between 3 and 7. Although based in New
Arley, the school also serves Old Arley and a wider catchment accessible by bus.

1.3 The existing school buildings are circa 1920’s, mainly single-storey brick construction with a slate
pitched roof. The buildings are located in the north-east corner of a flat rectangular site, with
grassed playing fields to the south and west. A secure fence surrounds the site with housing to the
north, east and west and open farmland to the south.

1.4 Approximately one-third of the site is occupied by the existing buildings and associated hard-
standing (playgrounds, car-park and footways). The remaining two-thirds consist of species-poor
grassland managed for amenity use. This has resulted in a closely mown sward dominated by
grass species typical of re-seeded grasslands and lawns. Some mature or semi-mature trees are
present toward the margins of the site in the east and south.

Proposed Development

1.5 Willmott Dixon Construction prepared a desk-top feasibility and costing exercise on behalf of
Warwickshire County Council (Warwickshire County Council, July 2011). The feasibility exercise
identified that new building facilities for Gun Hill Infant School could be provided under a design
and building solution known as Sunesis. The Sunesis concept involves a fixed building layout
available in several different sizes with various options for the selection of external and internal
materials.

1.6 The outline proposals for Gun Hill Infant School involve the development of new building facilities in
the western part of the school grounds. The footprint of the new building is understood to fall
entirely within an existing area of amenity grassland (playing fields). The new building will be
accompanied with various landscaping including meadow planting, allotments, habitat learning
areas, play areas and other soft landscaping. Final details of the design and layout have not yet
been established. It is understood that the current school buildings will ultimately be demolished.

Aims of Study

1.7 The overall aim of this study is to present baseline ecological information for the site to support
proposals for redevelopment of the existing school with reference to the requirements of a
BREEAM assessment. This information is used to identify outline ecological implications of the
proposed development (with reference to scheme design, current wildlife legislation and planning
policy) and recommendations for further survey (as necessary), mitigation and enhancement. This
report sets out the following:
• Approach to desk study and survey and presentation of the results of this work;

• Identification of potential ecological impacts associated with the scheme with reference to the
layout contained within WCC Primary Places Feasibility Report (July 2011);

• Provision of outline recommendations for further ecological survey, mitigation and/or

enhancement likely to be required for the scheme with reference to the need for a BREEAM
assessment of the site.

• Outlining the credits that may be available to the project under the ecology section of the
BREEAM scheme.

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Credentials of the Suitably Qualified Ecologist

1.8 Ed Austin is a Senior Ecologist at BSG Ecology with over 10 consecutive years’ experience
working as an environmental and ecological consultant (2002 to 2012 onwards). He is a full
member of the Institute of Ecology and Environmental Management (IEEM). This membership and
his employment within BSG Ecology make him subject to both peer review and a professional code
of conduct. Ed holds an honours degree in Zoology and a Master’s degree in Integrated
Environmental Studies, both granted by Southampton University.

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2 Methods
Desk Study

2.1 Existing information on sites designated for their conservation interest, protected species, priority
species in the UK or local Biodiversity Action Plan (BAP) or species otherwise of note for
conservation from within the site and surrounding area (up to 2km) were requested from the
Warwickshire Biological Records Centre (WBRC).

Field Survey

2.2 An extended Phase 1 habitat survey was completed within the site boundary by Ed Austin MIEEM
of BSG Ecology on 3rd May 2012. This involved mapping the type and extent of habitats within the
site in accordance with standard JNCC definitions (JNCC, 2010). A list of characteristic or
dominant flora was also collected from each habitat type identified. The survey was ‘extended’ to
give consideration to the potential of the site and/or component habitats to support protected
species or notable species1.

2.3 In addition to the extended Phase 1 habitat survey, an initial external assessment was made of the
buildings on site to search for features of potential value to roosting bats and nesting birds. This
included a visual inspection of each building from the ground using binoculars to assist where
necessary. A brief description of each building was made together with notes on any visible
features such as potential access points or cavities that could be used by bats and/or birds. A
search was also made for signs of bat activity on the external parts of the buildings, such as
droppings on the ground beneath or on window ledges or dark staining around potential access
features, or bird nesting activity. No internal or ladder-based surveys were completed.

Limitations to Field Survey

2.4 The field survey was completed within an optimal time of year for Phase 1 habitat survey (May)
when habitat types and many floral species are readily identifiable. There were therefore no
limitations to the survey. The initial external assessment of the buildings does not constitute a full
inspection for evidence of roosting bats, bat roosting potential or bird nesting activity. However, the
aim of the external assessment was to enable recommendations for further survey to be made.
This survey therefore met with this aim.

Land Use and Ecology Criteria for BREEAM Assessment

LE 01 Site selection

2.5 The aim of this credit is to encourage the use of previously developed land and/or contaminated
land while avoiding the use of land which has not previously been disturbed by development. A
maximum of two credits are available under LE 01.

2.6 The criteria for the award of the credits available under the second part of LE 01 relates to
contaminated land issues that are outside our ecological expertise, so are not covered further in
this report.

LE 02 Ecological value of site and protection of ecological features

2.7 The aim of this credit is to encourage development on land that already has limited value to wildlife
and to protect existing ecological features from substantial damage during site preparation and
construction works.

2.8 One credit is available where the construction zone is determined to be of low ecological value
(either by a suitably qualified ecologist (SQE) or using the BREEAM checklist) and any existing

1
Including species of principal importance to the conservation of biodiversity in England as listed in response to section 41 of the
NERC Act 2006 and priority species in the UK or local (Warwickshire) Biodiversity Action Plan.

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features of ecological value surrounding the construction zone will be retained and adequately
protected.

LE 03 Mitigating ecological impact

2.9 The aim of this credit is to minimise the impact of a building development on existing site ecology.

2.10 Change in ecological value is calculated based on the number of floral species per area of habitat
pre- and post-development. One credit is available where this change2 is less than zero but greater
than or equal to -9. One further credit (i.e. two in total) is available if the change is equal to or
greater than zero (i.e. no negative change).

LE 04 Enhancing site ecology

2.11 This credit aims to recognise and encourage actions taken to maintain and enhance the ecological
value of the site as a result of development.

2.12 One credit is available where an SQE is appointed to provide recommendations for enhancing and
protecting site ecology.

2.13 Up to two further credits (i.e. three in total) are available if the ecological value of the site will be
increased, again based on floral species per area of habitat type. This change is defined as greater
than zero up to equal to or less than 6 (1 credit) or greater than 6 (2 credits).

LE 05 Long term impact on biodiversity

2.14 The aim of this credit is to minimise the long-term impact of development on the biodiversity of the
site and surrounding area.

2.15 For a school development, up to 2 credits are available here. To achieve these, a series of
mandatory criteria must be met plus up to 4 additional criteria. One credit may be awarded if only 2
additional criteria (and all mandatory criteria) are met.

2.16 Mandatory criteria include:

• The appointment of an SQE prior to commencement of activities on site

• Confirmation (by the SQE) that all relevant UK and EU ecological legislation has been
complied with during design and construction

• A landscape and habitat management plan appropriate to the site has been produced
covering at least the first 5 years post project completion

2.17 A variety of additional criteria are available, each broadly recognising steps that may be taken to
protect or enhance site ecology or, for educational development only, to set-up partnerships with
local wildlife groups.

2
Note this refers to the calculated index of change – not an exact number of species

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3 Results and Identification of Potential Impacts.

3.1 In this section the results of the desk study and fieldwork are brought together. Their implications
are then considered in the light of the proposed development.

Desk Study

3.2 Data on local site designations, protected species and species of conservation note (due to
inclusion on various lists or schedules) were returned by WBRC.

Designated Sites

3.3 No statutory designated sites occur within the 2km search area.

3.4 A total of 24 non-statutory sites occur within 2km of the site. In Warwickshire, these sites are
termed ‘Ecosites’ to reflect their conservation importance. Some of these sites are also designated
as Local Wildlife Sites (LWS) or potential Local Wildlife Sites (pLWS) reflecting their County
importance to nature conservation.

3.5 None of the Ecosites fall within or immediately adjacent to the site boundary. The three Ecosites
closest (<350m) to the Gun Hill Infant School boundary are summarised below:
• Gorsy Spinney and Pastures – This site is identified as a pLWS and is located
approximately 245m north-east of Gun Hill Infant School at its closest point. It consists of
horse-grazed pasture with some florally diverse grassland present.

• Daffern’s Wood – This site is designated as a LWS and is located approximately 345m to the
west of Gun Hill Infant School at its closest point. It consists of an area of broadleaved
woodland with some ancient woodland indicator species in the ground-flora. The woodland is
noted to be subject to intensive public use.

• Headwaters & Tributaries of the River Bourne – The northern-most extent of the River
Bourne headwaters/tributaries lie approximately 270m south of the Gun Hill Infant School
boundary. At this point, the watercourse is a small channel running along an arable field
boundary. The Ecosite description notes that vegetation is richest further west, where areas of
woodland occur.

3.6 Given the distance between the proposed development and these sites, the nature of the existing
site and the relatively small scale of the proposed development no impacts on these sites are
anticipated as a result of the proposed development.

Protected and Notable Species

3.7 Records of protected and notable species were returned by WBRC from the 2km search area.
These are summarised below:
• Bats – at least 2 bat species have been recorded from within 2km of the site. Common
pipistrelle Pipistrellus pipistrellus was recorded in 2008 at St Michael’s Church, located
approximately 115m west of Gun Hill Infant School. Brown long-eared bats have also been
recorded at Astley Church, approximately 1.6km to the east; however, these are now old
records (1983). A further bat record (indeterminate species) was returned from Ansley, over
1.9km to the north-east.

• Barn owl – a single record of a barn owl was made in 2008 to the south of Ansley
approximately 1.5km from Gun Hill Infant School. It is not known if this relates to a nest site,
roost site or a foraging individual.

• Butterflies – a total of 4 butterfly species listed as priority species in the UK Biodiversity

Action Plan and/or Warwickshire BAP have been recorded within 2km of Gun Hill Infant

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School. These are the dingy skipper Erynnis tages, small blue Cupido minimus, small heath
Coenonympha pamphilus and the wall butterfly Lasiommata megera. However, the most
recent record is from 1998.

• Rare plants – 7 rare plant species have been recorded from the area within 2km of Gun Hill
Infant School. However, these are all old records with the most recent being from 1996. None
of the records pertain to the school grounds or immediate area.

3.8 Whilst these records do occur in the search area, none of these records pertain to the site itself and
the existing site holds little potential to support the majority species outlined above due to the
nature of the habitats present within the site. This is with the exception of bats. Potential
opportunity for bats within the site is outlined below.

Extended Phase 1 Habitat Survey

3.9 The majority of the site is dominated by amenity grassland in use as playing fields (Photograph 1).
This grassland is characteristic of a seeded mix, managed by regular mowing. Perennial rye-grass
Lolium perenne is the dominant grass species, with meadow grasses (Poa spp.) and red fescue
Festuca rubra abundant throughout the sward. Herb species include frequent daisy Bellis perennis
and ribwort plantain Plantago lanceolata with occasional greater plantain Plantago major, yarrow
Achillea millefolium and dandelion Taraxacum agg. Spear thistle Cirsium vulgare and cock’s-foot
Dactylis glomerata were rarely recorded.

3.10 A series of mature and semi-mature broadleaved trees occur around the north-east and southern
boundaries of the site (Photograph 2). Most notably, a line of pedunculate oak Quercus robur trees
is present along the entire southern boundary with smaller trees and shrubs below forming a
defunct species-poor hedgerow with a metal fence behind (Photograph 2). Holly Ilex aquifolium is
abundant below, with frequent elder Sambucus nigra and occasional hawthorn Crataegus
monogyna.

3.11 Figure 1 shows the layout of habitats within the site.

3.12 The development of the new school buildings as indicated in the Warwickshire County Council
Feasibility Report (July 2011) will result in the loss of the majority of the existing amenity grassland
in the western part of the school grounds. However, this loss is not likely to be ecologically
significant as this is currently considered to be of low intrinsic ecological value. Conversely, the
proposals indicate that ecological enhancement of the remaining area of grassland has been
considered, with a small meadow shown on the current indicative masterplan. Further opportunities
for ecological enhancement (particularly within the landscaping areas) may be possible. If
appropriately designed and managed in the medium to long-term, these features could be of
benefit to local biodiversity. This is discussed further in the Recommendations section.

External Building Assessment

3.13 The buildings on site are all understood to date from the 1920’s and are arranged around a
surfaced (tarmac) play area in the north-east part of the site. The buildings are broadly similar in
appearance, being of red-brick construction with slate tile hipped roofs predominant. The buildings
were all found to be in good repair, with some roofs appearing to have been recently replaced or
re-tiled and wooden soffit/barge boards freshly painted and in good condition. A few more modern
flat-roofed extensions are present (age undetermined) with a small portable cabin also present
within the playground area.

3.14 The results of the external building assessment for bat roost and bird nesting potential are
summarised in Table 2 below with building locations shown in Figure 1.

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Table 2: Results of External Building Assessment

Building Description Features of Potential Value to Roosting

Number Bats or Nesting Birds
1 Single storey classroom block with Few small gaps beneath roof tiles. Possible
brick walls and slate tile hipped roof. roof cavity present. Otherwise in good repair.
Wooden soffit/barge boards.
(Photograph 3)
2 Split level main school building with a Possible small gaps in mortar of chimney but
2-storey northern wing and 1-storey unclear if lead anywhere (Photograph 5). Roof
southern wing. Brick walls with slate cavity likely. Otherwise in good repair.
tile hipped roof. Large chimney
present in use as flue. Wooden
soffit/barge boards. (Photographs 3
and 4)
3 Single storey flat-roofed building Very small air gaps in brick-work over
(classroom) with brick walls and felt windows but unclear if lead to internal
roof. Wooden soffit/barge boards cavities.
present. (Photograph 6)
4 Small single-storey extension to None apparent.
building 2. Description as for building 3
above. (Photograph 4)
5 and 6 Two wings of main classroom block Small gaps in walls on 2-storey section may
(Photographs 4 and 7). Mainly single- lead to cavity (Photograph 8). Roof void likely
storey but with 2-storey section at to be present.
northern end of building 6. Brick walls
and slate tile hipped roof and wooden
soffit/barge boards.
7 Single storey brick building with slate Roof void likely but no other features evident.
tile roof (with roof appearing more
recent than other buildings). Wooden
soffit/barge board present.
(Photograph 9)
8 Small portable building in school None evident
grounds currently in use as a toilet
block. Flat felt roof with reinforced
panel walls. (Photograph 10)

3.15 All UK bat species and their roosts are fully protected under both national and EU legislation (see
Appendix 3 for further details). Wild bird species and their active nests and eggs are also subject to
legal protection, under national law (see Appendix 3).

3.16 The demolition of the existing school buildings could have negative impacts on roosting bats and
nesting birds, if these are present at the time. Impacts on bats could include direct mortality or
injury and the loss or damage to roost sites. This would constitute an offence under both EU and
UK legislation so must be avoided. Impacts on birds are most likely to include damage or
destruction of active eggs and nests if these are present at the time. This would constitute an
offence under UK legislation so must also be avoided.

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4 Recommendations
Habitats

4.1 As discussed above, the proposed development of the new school buildings will result in the loss of
the majority of the existing amenity grassland in the western part of the school grounds. However,
this loss is not likely to be ecologically significant as this is currently considered to be of low
intrinsic ecological value. The proposals indicate that ecological enhancement of the remaining
area of grassland is included within the design, with a small meadow shown on the current
indicative masterplan. Further opportunities for ecological enhancement (particularly within the
landscaping areas) may also be possible. If appropriately designed and managed in the medium to
long-term, these features could be of benefit to local biodiversity.

4.2 The current indicative masterplan for the site shows that areas of meadow planting, grassed
mounds and habitat learning are being considered. It is recommended that these features are
maximised both in size and in numbers of resulting floral species. Species-rich meadow seed
mixtures are available which could be sown to create new meadow habitat both close to the new
building and around the margins of the retained amenity grassland to increase species diversity.
For example, the Emorsgate general purpose meadow mixture (EM3) contains 26 species.

4.3 Further enhancements that could be given consideration include the use of native species of trees
and shrubs in areas surrounding the new buildings as opposed to non-native ornamental planting
and the provision of new trees/shrubs along the existing site boundaries to provide continuous
hedgerows along the boundary. It is best to source trees and shrubs locally to ensure that they are
suitable for local growing conditions. However, example species already growing on site include
the following:
• Pedunculate oak Quercus robur

• Rowan Sorbus aucuparia

• Silver birch Betula pendula

• English yew Taxus baccata

• Holly Ilex aquifolium

• Elder Sambucus nigra

• Hawthorn Crataegus monogyna

4.4 Other habitat enhancements, if desired, could include the creation of a full or partial green-roof on
the new building. This would provide additional space for landscaping with the aim of enhancing
the ecological value of the site. A number of green-roof designs and options are available, ranging
from simple sedum matting, up to fully planted areas with a diverse range of species. Green-roofs
can have additional benefits, including aiding with temperature control and water-retention.

Birds

4.5 In order to avoid impacts on nesting birds which may be using the existing buildings, demolition of
the existing buildings should be completed outside the main bird nesting period to avoid damage to
active nests and eggs or the killing/injury of young or adult birds. In practice, demolition in the
period September to February inclusive will avoid the time when most UK bird species are nesting.
Should the above timing not be possible, then each area should be checked first for the presence
of nests immediately prior to demolition. Where nests are deemed to be present and in use, these
will need to be left intact until the young have fledged or the nest is otherwise determined to no
longer be in use. A suitable buffer area should be established to minimise disturbance; this may
comprise avoiding works on an entire section of building.

4.6 It is understood that none of the trees on site will need to be felled to facilitate development.
However, should it become necessary to remove or prune any trees, this should also be completed
in line with the recommendations in relation to appropriate timing above.

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Bats

4.7 It is recommended that an internal inspection of the existing school buildings is completed in order
to further inform the likelihood of roosting bats being present. This should include a search of
internal roof spaces (where access is possible) for evidence of current or past use by bats
(including bats themselves, bat droppings, staining or feeding remains). The internal inspection will
also enable further identification of features of potential value to roosting bats that may not be
visible externally. This type of survey can be undertaken at any time of year.

4.8 Following the internal inspection, further activity surveys may be required to gather additional
information on roost types (if evidence of roosting bats is found) or to give increased confidence
that bats are not present where there is any reasonable doubt. Such surveys need to be
undertaken during the bat’s active season, between May and August inclusive.

4.9 It is understood that none of the trees on site will need to be felled to facilitate development.
However, should it become necessary to remove or prune any trees, it is recommended that these
are first checked for features that could support roosting bats. This may comprise an assessment
from the ground, climbing inspections and/or targeted emergence/return to roost surveys as
appropriate.

4.10 Should bat roosts be identified, works affecting the roost can only proceed legally under licence
from Natural England (NE) to permit works affecting them. NE can only grant a licence when a
series of requirements are satisfied (see Appendix 3 for further details). Where an existing roost
site is to be removed under licence, it is usual for replacement roost opportunities to be provided.
The type and scale of these would depend on the species of bat and roost type involved.

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5 BREEAM Assessment Credits (Land-use and Ecology)

5.1 Given the potential impacts identified and the recommendations presented for ecological mitigation
and enhancement, the following section outlines the credits that might be achievable under the
Land Use and Ecology section of the BREEAM Assessment.

LE 01 Site selection

5.2 The area proposed for the new school buildings is currently in use as amenity grassland (playing
fields) and does not therefore meet the BREEAM defined criteria for previously developed land.
The first credit under LE 01 is not therefore likely to be available.

5.3 The second credit under LE 01 is concerned with contaminated land which is beyond the scope of
this report.

LE 02 Ecological value of site and protection of ecological features

5.4 The footprint of the proposed new school buildings is understood to fall entirely within an existing
area of amenity grassland which has been identified, through the survey undertaken to inform this
report, as of low ecological value.

5.5 In order to gain the credit under LE 02, all existing features of ecological value surrounding the
construction zone will need to be retained and protected. Features of ecological value include the
mature trees around the edges of the school site. It is understood that these will all be retained.
However, if any of these trees could be affected by works (e.g. ground disturbance) the advice of a
specialist tree surveyor should be sought to advise on appropriate protection measures in line with
the relevant British Standard (BSI, 2012).

5.6 The existing school buildings have been found to offer potential opportunities for roosting bats and
nesting birds and the preceding section recommends that further survey work should be carried out
to determine whether there is any evidence of bat use of the buildings in particular. Should bat
roosting or bird nesting evidence be found within the existing school buildings, it will not be possible
to retain them in-situ as the buildings are to be demolished. Although steps will need to be taken to
comply with relevant UK and EU legislation covering bats and their roosts (see Appendix 3), most
likely including the creation of new roosting opportunities nearby, the loss these features would
prevent the credit under LE 02 from being achieved. However, this would only be the case if:
a. Bird nesting or bat roosting evidence is found within the building complex; and
b. The demolition of the existing buildings is included within the footprint of the site considered as
part of the BREEAM Assessment of the new buildings.

5.7 It is recommended that the advice of the BREEAM assessor is sought to determine whether the
demolition of the existing school buildings will be considered part of the BREEAM assessment
covering the redevelopment of the site.

LE 03 Mitigating ecological impact

5.8 As final detailed and scaled plans for the new school buildings and landscaping have not yet been
finalised, it is not possible to complete an accurate calculation of change in ecological value at this
stage. However, although the amenity grassland is deemed to be of low ecological value, 10 floral
species were identified here. The area of this grassland falling within the construction zone will be
replaced by buildings with no associated floral species. Without compensation in the remaining
area of greenspace surrounding the school, this would therefore result in a reduction in ecological
value. Whether this would still result in 1 credit (i.e. a small negative change) would need to be
confirmed by the calculation under LE 03 once scaled plans have been finalised. Should the
proposed development include habitat enhancements, as suggested in the Recommendations
section above, it may be possible to achieve a total of 2 credits under this section if the
assessment, providing the overall change in ecological value is equal to or greater than zero. Given
the footprint of the proposed new school, this is only likely to be achievable through the inclusion of
significant areas of species-rich grassland creation and perhaps the creation of a full or partial
green roof.

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LE 04 Enhancing site ecology

5.9 As discussed above, the loss of an area of amenity grassland to the new buildings may be possible
to be countered via enhancement of retained grassland or other soft landscaping surrounding, or
on the roof of, the new buildings.

5.10 As the calculations under LE 04 (and LE 03) are area-based, all habitats to be affected by
redevelopment, including the new building footprint and those areas included as part of the
landscaping plans, should be included in the calculation. Maximising the area to be enhanced by
new planting whilst minimising the area falling within the footprint of new buildings (i.e. those areas
that will have no associated pant species) would need to be given consideration in order to gain the
most credits under LE 03 and LE 04.

5.11 At least one credit is available under LE04 as a result of this report, as a single credit is achieved
where an SQE is appointed to provide recommendations for enhancing and protecting site ecology.
Should the proposed development include areas of species-rich meadow and creation of areas of
native-species tree and/or shrub planting, another credit may be achievable. A third credit under
LE04 is only likely to be achievable if the design were to include a green roof on the new building.

LE 05 Long term impact on biodiversity

5.12 As set out in section 2, mandatory criteria that must be complied with in order to gain at least one
credit under LE 05 include:
• The appointment of an SQE prior to commencement of activities on site

• Confirmation (by the SQE) that all relevant UK and EU ecological legislation has been
complied with during design and construction

• A landscape and habitat management plan appropriate to the site has been produced
covering at least the first 5 years post project completion

5.13 As an SQE has already been appointed and no development activities have yet been carried out
on site, it can be confirmed that the first of these criteria has been met. Recommendations for
compliance with relevant UK and EU legislation are provided in section 4. It will also be necessary
to produce the required management plan outlined above. This should be based on the final
landscaping design, as each habitat or feature proposed within the site design should be covered
in the plan. However, it is not envisaged that a complex management plan will be required. Based
on current indicative plans and the recommendations set-out in this report, management will most
likely primarily involve a regime aimed to establish and maintain areas of species-rich grassland.

5.14 To gain 1 or 2 credits under LE 05 at least 2 or 4 of the additional criteria respectively would need
to be achieved. The additional criteria options are summarised as follows:
1) Nomination of a ‘Biodiversity Champion’
2) Training of workforce on how to protect ecology
3) Recording of actions taken to protect biodiversity and monitoring of their effectiveness
4) Creation of a new ecologically valuable habitat
5) Programming works to minimise disturbance to wildlife
6) Setting up a partnership with a local wildlife group

5.15 From the list above, additional criteria 4 and 6 are most relevant to the proposed development as
the current understanding of the proposals indicate that no features of ecological value will require
protection during the construction of the new school buildings, criteria 1, 2, 3 and 5 are not
considered to be applicable. However, these steps may be relevant during demolition of the
existing school buildings should this be covered by the BREEAM assessment. Clarification on this
will be required from the design team/BREEAM assessor. However, if they are applicable, criteria
1, 2, 3, 4 and 5 should all be readily achievable.

5.16 Areas of new meadow habitat discussed under LE 04 above would meet the definition of new
ecologically valuable habitat. Lowland meadows are also a priority habitat in the UK BAP (although

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this tends to refer to well-established areas of grassland). The creation and on-going management
of new meadow grassland and other ecologically valuable features, particularly within the school
environment, could be discussed with a local wildlife group such as Warwickshire Wildlife Trust.
This would be in line with the aims of the wildlife partnerships criteria (number 6 as listed above).
Warwickshire Wildlife Trust runs a series of projects aiming to engage young people with their local
environment. Further details can be found on their website (Warwickshire Wildlife Trust, undated).

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6 References
BSI (2012) BS 5837: 2012 Trees in relation to design, demolition and construction –
recommendations. BSI

JNCC, 2010. Handbook for Phase 1 Habitat Survey, a technique for environmental audit. Revised
reprint 2010. JNCC

Warwickshire County Council, July 2011. Primary Places Decision Making Feasibility Report by
Wilmott Dixon on behalf of WCC.

Warwickshire Wildlife Trust, undated. “Community and Youth” http://www.warwickshire-wildlife-

trust.org.uk/community--youth.aspx

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 Gun Hill Infant School

Appendix 1: Photographs
(overleaf)

15 29/06/2012
Photographs

Photograph 2. Trees along southern Photograph 3. Building 1 (on left) and Building 2 (in
Photograph 1. Amenity grassland in use as playing fields.
boundary. centre). View from southwest.

Photograph 4. Building 2 (on left), building 4 (front Photograph 5. Gaps in mortar in chimney of
Photograph 6. Building 3. View from east.
centre) and building 5 (on right). View from southeast. building 2. (Gaps indicated by arrows).
 Photograph 7. Building 6. View from west. Photograph 8. Gap in the wall of building 6. Photograph 9. Building 7. View from south.

Photograph 10. Building 8. View from northwest.

 Gun Hill Infant School

Appendix 2: Figures
(overleaf)

16 29/06/2012
 LEGEND

Site boundary

A Amenity Grassland

Hardstanding

Fence

1 Building

Scattered Trees

HS

4 HS
6
1
2

HS
HS 3
8
L:\Contracts\Live Contracts\5301-5400\5317.06 Gunhill Primary School Phase 1\Technical Documents\Maps & Plans\02 GIS\01 projects\5317.06G_Fig01_P1.mxd

OFFICE: Oxford
T: 01865 883833 JOB REF: 5317.06

PROJECT TITLE
GUN HILL INFANT SCHOOL

DRAWING TITLE
Figure 01:
Results of Extended Phase 1 Habitat Survey

DATE: 29.06.2012 CHECKED: EA SCALE: 1:1,500

DRAWN: RL APPROVED: XX STATUS: DRAFT

Copyright © BSG Ecology

No dimensions are to be scaled from this drawing.

All dimensions are to be checked on site.
Area measurements for indicative purposes only.

This drawing may contain: Ordnance Survey material by permission of Ordnance Survey on behalf
of the Controller of Her Majesty’s Stationery Office © Crown Copyright 2012. All rights reserved.
Reference number: 10048980
OS Open data © Crown copyright and database right 2012 | Aerial Photography © Bing Maps
Sources:BSG Ecology survey data
 Gun Hill Infant School

Appendix 3: Summaries of Relevant Legislation and Policy

6.1 This section briefly summarises the relevant legislation, policy and related issues that are
mentioned in the main text of the report. The following text does not constitute legal advice.

European and National Legislation

European protected species

6.1 European protected species relevant to this report include all species of bat. European protected
species (EPS) are those which are present on Schedule 2 of the Conservation of Habitats and
Species Regulations 2010. They are subject to the provisions of Regulation 41 of those
Regulations. All EPS are also protected under the Wildlife and Countryside Act 1981 (as
amended). Taken together, these pieces of legislation make it an offence to:
a. Intentionally or deliberately capture, injure or kill any wild animal included amongst these
species
b. Possess or control any live or dead specimens or any part of, or anything derived from a these
species
c. deliberately disturb wild animals of any such species
d. deliberately take or destroy the eggs of such an animal, or
e. intentionally, deliberately or recklessly damage or destroy a breeding site or resting place of
such an animal, or obstruct access to such a place

6.2 For the purposes of paragraph (c), disturbance of animals includes in particular any disturbance
which is likely—
a. to impair their ability—
i. to survive, to breed or reproduce, or to rear or nurture their young, or
ii. in the case of animals of a hibernating or migratory species, to hibernate or migrate; or
b. to affect significantly the local distribution or abundance of the species to which they belong.

6.3 Although the law provides strict protection to these species, it also allows this protection to be set
aside (derogation) through the issuing of licences. The licences in England are currently
determined by Natural England (NE) for development works. In accordance with the requirements
of the Regulations (2010), a licence can only be issued where the following requirements are
satisfied:
a. The proposal is necessary ‘to preserve public health or public safety or other imperative
reasons of overriding public interest including those of a social or economic nature and
beneficial consequences of Primary importance for the environment’
b. ‘There is no satisfactory alternative’
c. The proposals ‘will not be detrimental to the maintenance of the population of the species
concerned at a favourable conservation status in their natural range.

Breeding birds

6.4 All nesting birds are protected under the Wildlife and Countryside Act 1981 (as amended) which
makes it an offence to intentionally kill, injure or take any wild bird or take, damage or destroy its
nest whilst in use or being built, or take or destroy its eggs.

National Planning Policy Framework

6.5 The government published the National Planning Policy Framework (NPPF) on 27th March 2012.
The NPPF states that, “the planning system should contribute to and enhance the natural and local
environment by:
a. Protecting and enhancing valued landscapes, geological conservation interests and soils;

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b. Recognising the wider benefits of ecosystem services;

c. Minimising impacts on biodiversity and providing net gains in biodiversity, where possible
contributing to the Government’s commitment to halt the overall decline in biodiversity,
including by establishing coherent ecological networks that are more resilient to current and
future pressures;
d. Preventing both new and existing development from contributing to or being put at
unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or
noise pollution or land instability; and
e. Remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land,
where appropriate.”

Planning applications and biodiversity

6.6 “When determining planning applications, local planning authorities should aim to conserve and
enhance biodiversity by applying the following principles:
a. If significant harm resulting from a development cannot be avoided (through locating on an
alternative site with less harmful impacts), adequately mitigated, or, as a last resort,
compensated for, then planning permission should be refused;
b. Proposed development on land within or outside a Site of Special Scientific Interest likely to
have an adverse effect on a Site of Special Scientific Interest (either individually or in
combination with other developments) should not normally be permitted. Where an adverse
effect on the site’s notified special interest features is likely, an exception should only be made
where the benefits of the development, at this site clearly outweigh both the impacts that it is
likely to have on the features of the site that make it of special scientific interest and any
broader impacts on the national network of Sites of Special Scientific Interest;
c. Development proposals where the Primary objective is to conserve or enhance biodiversity
should be permitted;
d. Opportunities to incorporate biodiversity in and around developments should be encouraged;
e. Planning permission should be refused for development resulting in the loss or deterioration of
irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found
outside ancient woodland, unless the need for, and benefits of, the development in that
location clearly outweigh the loss; and
f. The following wildlife sites should be given the same protection as European sites:
i. potential Special Protection Areas and possible Special Areas of Conservation
ii. listed or proposed Ramsar sites; and
iii. sites identified, or required, as compensatory measures for adverse effects on European
sites, potential Special Protection Areas, possible Special Areas of Conservation, and
listed or proposed Ramsar sites.”

6.7 In paragraph 125 the NPPF stipulates that ‘by encouraging good design, planning policies and
decisions should limit the impact of light pollution from artificial light on local amenity, intrinsically
dark landscapes and nature conservation.’

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