PUBLIC INQUIRY QUESTION - bailey.persona-pi.com

1 M4 Corridor around Newport PUBLIC INQUIRY QUESTION REFERENCE NO. : PIQ /083 RAISED BY: The Inspectors DATE: 20/03/17 RESPONDED BY: Matthew Jones DATE: 03/05/17 SUBJECT: Bats Proof of Evidence Clarification The attached document provides responses to questions of elucidation raised by Mr Wadrup in correspondence dated 20 February 2017. Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 1 Bats Proof of Evidence Clarification Richard Green BSc (Hons) CEnv MCIEEM Contents 1. Introduction .. 2 2. Clarifications .. 2 Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 2 1. Introduction This document provides a response to points of elucidation raised by Mr Wadrup in correspondence dated 20 February 2017. 2. Clarifications Evidence paras QUESTION : It would be helpful to have a map showing where the bats are identified in numbers now (Magor lesser horseshoe and Berry Hill common pippestrelle) and where, now, they fly or commute to eg Wye Valley and Forest of Dean Sites , so the barrier of the proposed road can be put into geographical context relative to current hazards and alternatives to the published line.

2 Evidence paras Response: Lesser horseshoe bats around Magor. The figures below, taken from ES documents and edited for clarity, seek to answer QUESTION 1. The following text explains the current knowledge of bat movement in these areas. Figure 1 of the Statement to Inform Appropriate Assessment (SIAA) show the location of the Wye Valley and Forest of Dean SAC constituent sites in relation to the Scheme and all lesser horseshoe bat survey records. Figure 3e of the Statement to Inform Appropriate Assessment shows where the majority of lesser horseshoe bat activity was recorded around Magor. It must be noted that the number of bat passes does not necessarily equate with number of bats but is simply a measure of activity. We do not know if, how many, and along what route lesser horseshoe bats from the Wye Valley and Forest of Dean Bat Sites SAC travel to the Scheme area. We do know that lesser horseshoe bats fly under the existing M4 using Mill Reen Underpass. No lesser horseshoe bats were recorded during bat activity transects during 2014.

3 Static bat detector surveys in 2014/2015 were located along the Scheme route and it is extremely likely that lesser horseshoe bats also forage in the area away from the Scheme. The existing A4810, Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 3 which is lit from the Magor interchange/Junction 23A to the South Wales Mainline Railway and lies adjacent to the proposed line of the Scheme in this area, provides a potential barrier to bats in this area. If crossing the existing A4810 presently, bats are likely to be using the existing South Wales Mainline Railway underpass on the A4810. There are no known lesser horseshoe bat maternity roosts around Magor. The only known lesser horseshoe bat roost is a low-use day or night roost that was found in February 2017, when internal access to the coach house at Woodland House, Magor was arranged (a report will be provided for the listed building INQUIRY in due course). Approximately 200 mixed age bat droppings were present in the building.

4 Whilst this might sound like a lot of droppings, it is indicative of occasional use over several years by one or a small number of bats. Further survey on this building is planned in summer 2017 to determine levels of use. Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 4 Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 5 Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 6 Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 7 Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 8 Evidence paras Response: Common pipistrelle bats around Berryhill Farm. Figure 2e of ES Appendix (on page 12 of this document) shows relative levels of bat activity around Berryhill Farm from static bat detectors in 2014 and 2015. Most this activity is from pipistrelle bats. Pipistrelle bat activity has been summarised on the Figure for this document.

5 The following italicised text is an extract from ES Appendix at paragraph , summarising bat survey findings for Transect 1 (2014; refer to figures on page 13). Common and soprano pipistrelle were the most frequently recorded species on Transect 1, although Myotis bats were also regularly recorded on the Transect. Occasional passes of noctule (Nyctalus noctula), Leisler s bat (Nyctalus leislerii) and Nathusius pipistrelle (Pipistrellus nathusii) were also recorded. Bats were recorded on all parts of the transect with the main areas of highest bat activity around Berry Hill Farm and the woodlands to the south of the farm and in the fields to the west. Relatively high levels of activity were also recorded along the A48 corridor in May and August although in other months the levels were lower. Given the proximity of a known roost at Berry Hill Farm the relatively high levels of pipistrelle bats is to be expected. It is not possible to know exactly where pipistrelle bats from Berry Hill Farm and The Conifers maternity roosts fly to and along which routes.

6 However, it is reasonable to assume that bats will fan out from the roost along hedgerows/tree-lined field boundaries and woodland, with bat numbers diverging as distance from the roosts increases. The main corridors and foraging areas are considered likely to be the woodland and tree-lines to the south and east of Berryhill Farm, along with the tree-lined A48 to the west. Similar behaviour is expected from brown long-eared bats breeding at Berryhill Farm, although this species is more associated with woodland and trees and tends to range over Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 9 less distance from a maternity roost (most foraging activity observed within 2 km of maternity roosts). No bats were observed flying over the existing M4 using Pound Hill Bridge during three surveys in September 2015. However, there is an underpass under the existing M4 at Grid Reference ST 27233 84620 that has not been surveyed (refer to aerial photograph and Google Street View below).

7 The height marker on the underpass reads 14-0 , so it is estimated that the underpass is approx. 5m w x h. This could be used by bats, including pipistrelles and brown long-eared bats from Berryhill Farm to access woodland foraging habitat to the north of the existing M4. Bat survey at the culvert could be undertaken this season (from April 2017) to confirm bat use. Location of underpass (Point B) under existing M4 in relation to Berryhill Farm Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 10 View of underpass from the south Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 11 Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 12 Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 13 Para QUESTION : What evidence substantiates your claim of over evaluation ? Para Response: As stated in & of my proof, Wray et al. state that their approach should be used as a framework rather than a rulebook.

8 Their approach was the first attempt in the UK to assign values for bat in EcIA, and although not strictly a recognised standard, it has been adopted by ecologists, as published in the CIEEM journal In Practice (December 2010), in the absence of any alternative. The method of evaluation relies heavily on knowing the approximate number of bats (individuals, small number or large number) using a commuting route or foraging area. Unfortunately, without direct observation, it is impossible to determine the number of bats foraging in an area. Even with direct observation, if an individual bat flies out of sight and then returns, it is not possible to be certain if this is one or two bats. It is also impossible to observe bats effectively after dusk and before dawn, when it is too dark to see them. Static bat detectors are therefore a suitable alternative for measuring bat activity. However, activity level is all that can be deduced from their recordings. They cannot count individual bats.

9 Where high levels of bat activity are recorded, it is impossible to say whether this is due to a high number of bats flying past or one bat foraging for a prolonged period in the same area, repeatedly flying past the bat detector, which records each pass. Pipistrelle bats have relatively loud calls and are readily recorded by bat detectors. They also have a habit of foraging in the same location for prolonged periods, particularly along the edge of tree canopies and tall hedges, and around street lights, as they feed on the insects attracted to them. In my experience of undertaking an extensive amount of bat activity survey, other species that forage for prolonged periods in an area include Myotis and serotine bats and to a lesser extent, barbastelle, noctule and Leisler s bats, particularly when foraging along hedgerows. In my experience, long-eared and horseshoe bats tend to be more wandering species, not repeatedly flying up and down the same hedgerow for extensive periods. Some bat species, , long-eared, have very quiet calls and therefore may be under-recorded.

10 Welsh Government M4 Corridor around NewportBats POE Clarification May 2017 Page 14 Therefore, it is very difficult to determine even an approximate number of bats commuting or foraging, , along a hedgerow/reen. The following activity levels were used to assign number of bats in the valuation for bats in the ES. Over, on average, 100 passes per night = large number; on average, between 10 and 100 passes per night = small number; and on average, less than 10 passes per night = individuals. This is a reasonable conversion but as there is no way of confirming numbers, the valuation could be grossly affected by an over (or under) estimation. It would not take long for one bat to generate 100 bat passes when foraging up and down the same hedge repeatedly. One pass does not even equate to one actual pass of the detector, as it is possible for the detector to record two or more passes as the bat approaches and passes the detector. Therefore, the assessment based on bat activity alone could be misleading and the landscape is an important consideration in valuing the area for bats.