Hampshire County Council Environment team

The additional information provides a much better level of detail as would be expected by the size and significant location of this development. however, concerns that relate

primarily to the lack of initial discussions with Natural England and specialist species

groups as well as inherent concerns about the success of restoration remain.

Needless to say, especially in light of Natural England’s further objection, and

information supplied by the reptile species groups, we are in the position where we

still cannot determine this application without further information, or a different

approach to the development. There are elements of the response that do not

adequately address the further information that we have requested. I will undertake

to provide a more detailed response to each of the 16 Ecology items that we

requested, but the following should be used in initial discussions with the applicant.

Habitats – loss and creation through restoration.

This is a fundamental concern that runs through as a thread through the issues

outlined below. There are significant areas of habitats being removed from the site

that support extremely rare plants and animals and form a significant element of the

network of Hampshire and Dorset lowland heathland designated as SPA and

SAC. we have sought compensation for this loss (item 11) and to ensure that we

have a full understanding of the available habitats throughout the progress of mineral

operations (items 7, 9, 11, 12, 15 and 16). The sufficiency of the compensation has

been rightly questioned by NE in their response, especially in terms of promoted

recreation, and and there remains some uncertainty on delivery (quality and timing)

of restored habitats on site, which fundamentally undermines most of the strategies

and assessments submitted. Natural England Argue that wet heathland is not

replaceable, and therefore the conclusions drawn on this issue within the EAI would

need to be modified, and the approach to the design of the proposal reconsidered to

accommodate irreplaceable habitats.

Items 15 and 16 clearly asked for a more detailed strategy for habitat restoration,

including specialist soil management to avoid the usual issues that we have with

restoring soils suitable for establishing lowland heathland. Both the restoration

information and the outline Landscape and Ecology mitigation and management plan

provide insufficient information on the detail of soil preservation, storage, and

replacement. The soil handling strategy does not appear to have been updated, and

includes elements of approach (inclusion of interburden, clays, silts etc) that would

be of concerns with respect to establishing soil profiles suitable for supporting

lowland heathland.The heathland creation relies on inappropriate seed mixes, and not using locallyobtained material, and the levels of woodland on the site do give concern with respect to the principles of ongoing heathland management and the objectives of the East Dorset Forest Design plan.

Uncertainty over the delivery of lowland heathland through restoration, the

conclusions of the ES with respect to the impacts arising from loss of habitat on the

SAC/SPA and the birds, reptiles, invertebrates and rare plant species cannot be

justified.

Reptiles

Significant concerns remain relating to ensuring that the favourable conservation

status populations of Sand lizard and Smooth snake within the Hampshire and

Dorset heaths will not be harmed by the proposals, and as such, the authority cannot

meet the tests required of the Habitats Regulations with respect to European

protected Species. As European protected species mitigation licences would be

required to manage the loss and compensation of their habitats and the translocation

of the individuals, the authority also needs to be confident that such a licence would

be forthcoming from the statutory authority.

These are very rare animals and the populations within the area remain one of the

only (but still shrinking) populations in the country, and therefore normal techniques

to manage reptiles are not appropriate for the development. More care should have

been made to obtain more detailed data on the local and regional population

prior todesigning the scheme, and for this to feed into retaining habitats required for

breeding and movement between populations rather than relying on

translocation. Much has been done retrospectively to look at this issue, which is

appreciated, but it remains a significant constraint that has not been adequately

addressed.

The mitigation strategies, though more detail has been supplied still are inadequate

to be satisfied that sufficient habitats will be available throughout operation for

breeding, feeding and movement. There is much concern about the realignment of

Track F, considered to be a significant importance to the species in these

terms. This also relates to the issue outlined above about adequate mapping of

habitats, including retained and perceived establishment of restored habitats at any

given time during the operation. The reptile mitigation strategy lacks sufficient detail

on the methodology of translocation, including its timings in relation to phasing, and

unclear on the phased location and preparation of receptor sites. The

enhancements for the receptor sites also needs more detail; standard methods for

these species are not suitable, and location of sand scrapes etc would need to be

detailed.

Birds

Our concerns relating to the connection of this site to the SPA was outlined in full in

our previous response, and further information was sought through items 4, 6, 7, 9,

11, 13 of the Reg 25. Natural England retains a strong objection on this issue. Their

comments relate to a lack of information on available habitat throughout the operational phase suitable to replicate the sites current function, especially in terms of moving through the site. Therefore, we will be unable to determine this application

due to insufficient information relating to the impact to the nearby SPA.

Compensation areas [environmental offsets]

Item 11 of the Reg 25 set out the requirement for compensation for the loss of the

onsite habitats during operation and prior to establishment of final restored lowland

heathland. It was not the intention that these areas would be provided to as

increased recreation resource to offset any displacement during the operation of the

site. NE has rightly raised significant concerns about this, primarily with respect to

impacts to existing habitats, and SPA bird and EPS reptiles. These compensation

areas are not supported by baseline data related to these species and we are

therefore unable to determine impacts to conservation status or reptile population, or

the level of impacts to the SAP through the functional connection provided by the

bird populations.

Recreational impacts

Item 14 of the Reg 25 asked for further information on the impacts arising from

recreational impacts. The applicant has provided survey data on this, and has

woven the results of this into the long term mitigation strategies. However, Natural

England has significant experience in undertaking and analysing recreational

surveys for impacts to European sites, and has raised significant concerns on the

adequacy of the data. We therefore cannot determine that the information supplied

is sufficient to draw the conclusions on which the impact assessment and

subsequent mitigation strategy is based. As such, impacts to the SPA and SAC

cannot be ruled out.

Hydrological impacts

Natural England retain an objection on the basis of hydrological impacts to the

nearby SSSI. Further discussions between Natural England and the applicant on the

necessary data that is needed to satisfy this issue is required.