Our concerns regarding this application are two-fold, firstly in regard to the impact on habitat from the development of the biodigesters and secondly the impact of discharged water on pollution levels in water courses.

The development

The site for the development is currently a nesting habitat for skylarks, a known foraging area for bats and the sites hedgerows are a vital corridor for a variety of species.

Skylarks – breeding habitat

Skylarks are listed under Section 41 of the NERC act (2006) and are identified as a BoCC ‘Red list’ species and as page 37 of the Ecological Impact Assessment notes are of national significance. The EIA notes that the mitigations for this loss would be wildflower meadow creation, woodland and hedge planting and other habitat enhancements. However there is no mention of these, beyond the ponds and the reedbeds on the site plans and unless these are built into the planning application it is unclear whether they will be implemented and how quickly. The level of disturbance of the site and a loss of breeding habitat is likely to result in the loss of skylarks on this site. With increasing loss of grassland sites to development the breeding habitat for these protected birds is being squeezed and the mitigation suggested don’t appear adequate for Herefordshire Council Planning Services PO Box 4 Hereford HR1 2ZB the level of loss. The recommendation of nesting boxes would not compensate for the loss of ground nesting sites and these also haven’t been built into the planning application.

Hedgerows

We note the following contradiction in the submitted documents: Page 31 of the EIA states that: ‘the current development proposals do not include the removal of any trees and hedgerows’. However the Arboricultural Impact Assessment and Method Statement clearly states that 135m of hedgerow is due to be removed as part of the development. Our concern is that the mitigations do not take this loss into account when looking at hedgerows and only note the importance of reducing the impact of lighting for foraging species such as bats.

Onsite pond

There is an onsite pond which the EIA describes as a pond surrounded by scrub habitat but no reference to the impact on this pond is given beyond noting it is not currently home to Great Crested Newts. In the last hundred years huge numbers of farmland ponds have been lost to development and they provide a key habitat for many species that cannot survive elsewhere. The management and enhancement of this pond should be included in the mitigations for the development to help enhance biodiversity on the site.

Wetland filtration system and pollution

The proposal includes a system of lagoons and reedbeds for water filtration but page 1 of the CQA report also states that where necessary treated water may be discharged into a surface water source. As noted in the CQA report Natural England has issued a moratorium to prevent development in Herefordshire due to the high phosphate levels in both the river Wye and river Lugg. The proposed development lies in the catchment for both rivers and therefore discharged water will end up in these watercourses. Whilst we cannot comment on the effectiveness of the reedbed system for filtration of the water we are concerned that even a very low level of phosphate remaining in any discharged water will impact on the already degraded habitats in the rivers. High nutrient levels in the rivers can result in algal blooms, which have already contributed to a large loss of water crowfoot (Ranunculus), and loss of invertebrates and fish within the river. We are concerned that even with additional mitigations the level of nutrient in the discharged water will still be too high and would like to see further reassurance that the nutrient levels will be properly monitored and that there are actions in place to prevent high levels of nutrient entering the waterways.

The importance of Reedbed

Reedbed is one of the most important habitats for birds in the UK and was listed as a priority habitat in the UK Biodiversity Action Plan Habitat under the general grouping of Fen Marsh and Swamp. Many species which are associated with reedbed have become nationally scarce including bittern, reed bunting and marsh harrier, which are on the Birds of Conservation Concern amber list due to declines of 25% - 50%. The proposal doesn’t indicate the density of reedbed plantation, this should be included within the proposal to ensure that the reedbed density is suitable for wildlife.

Digestate

The proposal states that the digestate will be used on agricultural fields and whilst this is a more natural solution than artificial fertilisers if the digestate is washed into the waterways this will still result in an increase in nutrient within the rivers. The production of high levels of digestate may result in a greater use within the catchment of the Wye and Lugg. As noted given the risk of phosphates entering the Wye and Lugg catchment we see this development as potentially in conflict with the moratorium issued by Natural England for development in Herefordshire. We also believe that without the additional mitigations the above application may conflict with LD2 – Biodiversity and Geodiversity.

Further information contact: Sarah King s.king@herefordshirewt.co.uk