6. Discussion

6.1 Nature Conservation Designations

6.1.1           Assessment

6.1.1.1     Statutory nature conservation designations – SPAs

Given the potential for connectivity between the Proposed Development and the SPAs of which one is also a Ramsar site, there is a potential for activities associated with the Proposed Development’s construction and operation to result in adverse effects on the qualifying interests and conservation objectives of specific qualifying features. Consequently, a Habitat Regulations Appraisal (HRA) screening exercise was undertaken in September and October 2021 which, upon consultation with NatureScot and East Lothian Council, determined that an HRA was necessary to identify the nature, extent and significance of any adverse effects on a number of specific SPA qualifying and assemblage species and, if confirmed, whether these are likely to impact the integrity of the designation.

Following the HRA screening exercise a Report to Inform Appropriate Assessment (RIAA) was undertaken in relation to specific receptors due to the Site’s proximity to the following SPAs:

       Firth of Forth SPA/Ramsar;

       Outer Firth of Forth and St Andrews Bay Complex SPA;

       St. Abb’s Head to Fast Castle SPA; and

       Forth Islands SPA.

The RIAA (ITPEnergised, 2022b) included within Volume 1, Chapter 8 and standalone document, details the results of this assessment and must be read in conjunction with this document.

6.1.1.2     Statutory nature conservation designations – SSSIs

Barns Ness Coast SSSI overlaps with the Site at the landfall location. This SSSI is designated for its coastland habitats. Working methods will need to be adopted during the construction phase, in consultation with NatureScot, to avoid potential negative impacts.

The remaining SSSIs of Pease Bay Coast; Pease Bridge Glen; Woodhall Dean; and Lammermuir Deans lie between 1.15 km and 3.3 km from the Site boundary. Due to the separation distance and the nature of the proposed works these SSSIs are unlikely to be affected by the Proposed Development.

6.1.1.3     Non-statutory nature conservation designations

One SWT and four LNCS were identified during the desk study. Thurston Burn Valley LNCS and Dunglass Burn LNCS lie within the Site and Thornton Glen SWT and Dryburn Valley LNCS lie directly adjacent to the Site. The remaining site, Bilsdean Coast LNCS, lies 135 m east of the Site.  The footprint of the Proposed Development will not directly impact these sites however working methods will need to be adopted during the construction phase to avoid potential indirect negative impacts.

Twenty-nine areas of ancient woodland were identified within 2 km of the Site. Of these, two lie within the Site and three directly adjacent to the Site. The footprint of the Proposed Development will not directly impact these areas of woodland however working methods will need to be adopted during the construction phase to avoid potential indirect negative impacts.

6.2 Habitats

6.2.1           Assessment

A large majority of the Site (c. 70%) is improved grassland or arable fields. Other habitats recorded within the Site included semi-improved neutral grassland, mature coniferous and broadleaved woodland, standing and running water, dense and scattered scrub, species-poor hedgerows and coastal habitats. Plant species diversity within the areas of improved grassland and arable fields was low, with higher species diversity recorded in less managed areas of the Site including field margins, mature woodland, dense scrub, semi-improved neutral grassland and coastal habitats. The plant species recorded within the Site and 100 m buffer were considered to consist of common and widespread species commonly found within sites of this nature in this part of Scotland.

As described in Section 3.2, scrub, veteran trees, burns and rivers, neutral grasslands, hedgerows, cereal field margins, sand dunes and intertidal habitats are priority habitats within the LBAP. There is scope to increase biodiversity within the Site by incorporating the measures and recommendations outlined in the LBAP.

6.2.2           Protection of Existing Habitats

In order to reduce potential negative impacts, the following measures are recommended:

       To protect scrub and woodland habitats within and adjacent to the Site working methods should proceed in line ‘BS 5837 (2012) – Trees in relation to Design, Demolition and Construction’.

       There should be no storage of material within 10m of any watercourse in line with SEPA requirements to reduce risk of runoff (SEPA, 2009).

       A biodiversity enhancement plan should be produced for the Site detailing measures to enhance habitats and increase biodiversity within the Site.

       Avoid bryophyte springs and a minimum 250 m buffer.

6.3 Groundwater Dependent Terrestrial Ecosystems

The area of M37 bryophyte spring is likely to be groundwater dependent. If this habitat lies within 250 m of the Proposed Development, mitigation may be needed to reduce impacts.

6.4 Invasive Non-Native Species

Evidence of invasive non-native species was found during the survey, with an area of Japanese knotweed recorded next to the Thornton Burn and Himalayan balsam found in some of the roadside ditches within the Site.

While there is no legal obligation to remove or treat these non-native invasive species, the Wildlife and Natural Environment Act (2011) states that this species must not be planted or caused to grow in the wild. Responsibility for dealing with invasive weeds rests with individual landowners and there is a duty of care with regards to the disposal of any part of the plant that may facilitate establishment in the wild and cause environmental harm. Therefore, waste containing Japanese knotweed and Himalayan balsam is classified as ‘controlled waste,’ under the Environmental Protection Act (1990).

Works should be reviewed and if there is a risk that works are likely to be within 10 m of these stands an Invasive Non-Native Species (INNS) plan must be produced to prevent the spread of these species within and off the Site. The management plan should include suitable precautions to prevent spread of plant fragments/seeds including exclusion zones, biological control, on-site treatment or removal by an approved company that specialises in non-native species disposal.

6.5 Protected or Otherwise Notable Species

5.1.2           Badger

It is considered highly likely that badgers will be present within the study area and may be directly and indirectly impacted by the works.  Following the PEA a badger survey of the Site and a 100 m buffer began in October 2020 and the results of these surveys can be viewed in Volume 4, Appendix 7.2 (ITPEnergised, 2022b).

5.1.3           Otter

Otters are wide-ranging, primarily nocturnal and spend a lot of their time within aquatic environs. They can occupy large home ranges and utilise a wide range of habitats, including rivers, streams, ditches and wetlands.

Evidence of otter presence was found along the Thornton Burn confirming their presence within the Site.  The watercourses that traverse the Site and the coastline, provide high quality foraging and commuting habitat as well as numerous habitat features within banks, rocky substrates and surrounding tree root systems that could be used by otter as resting sites (e.g. holts, couches). Following the PEA an otter survey of all watercourses within the Site and up to 250 m upstream and downstream of the Site boundary was completed to provide full information on otter presence within the Site and to determine potential impacts/licensing and mitigation requirements. The survey also encompassed the area of the coastline that falls within this buffer zone. Otter surveys began in October 2020 and results of these surveys can be viewed in Volume 4, Appendix 7.2 (ITPEnergised, 2022c).

5.1.4           Water Vole

No incidental evidence of water vole as found on the Site during the survey. However, suitable habitat was recorded within the study area including the Thornton Burn, Thurston Mains Burn Dry Burn and Bilsdean Burn.

Further survey for water vole was conducted alongside the otter survey and the results of these surveys can be viewed in Volume 4, Appendix 7.2 (ITPEnergised, 2022c).

5.1.5           Reptiles

In Scotland, reptiles are partly protected under the Wildlife and Countryside Act 1981 (as amended) making it an offence to kill or injure a reptile. Common lizard could potentially be present in parts of the Site, particularly on south-facing slopes of semi-improved grassland where it forms a mosaic with scrub, piles of overgrown rubble etc. This habitat lies along the Dry Burn corridor and as edge habitat adjacent to the Braidwood Burn corridor.  However, areas of improved grassland and arable fields which form the majority of the Site are largely suboptimal, with presence of reptiles likely to be restricted to the field margins.

Where works require removal of suitable terrestrial habitat, such as rough grassland, tall ruderal and scrub, or removal of suitable refugia habitat, such as stone walls or piles of rubble, then pre-construction checks should be carried out by a Suitably Qualified Ecologist.

5.1.6           Great Crested Newt

Two waterbodies within 500 m of the Site were assessed as having potential suitability for use by great crested newt. Further surveys environmental DNA (eDNA) surveys were completed in May 2021 to inform licencing, mitigation and compensation requirements. The results are contained within Volume 4, Appendix 7.2 (ITPEnergised, 2022c).

5.1.7           Other Amphibians

There was no incidental evidence of common frog, common toad, palmate newt (Lissotriton helveticus) and smooth newt (Lissotriton vulgaris) found during the survey, but the habitats identified as suitable for great crested newt are likely to also support these species. These species are offered limited protection under the Wildlife and Countryside Act 1981 (as amended). Common frog, common toad and smooth newt are listed as SBL species, so are considered key species for biodiversity conservation in Scotland. If any amphibians are encountered during the works they should be collected by a member of the Site team or the ECoW and moved a safe distance from the works area within suitable habitat.

5.1.8           Breeding birds

Habitats within the Site and study area are suitable for a range of farmland and lowland bird species. In order to ensure compliance with the Wildlife and Countryside Act 1981 (as amended), which affords protection to all birds (whilst actively nesting), their nests and eggs, it is recommended that all construction works should be completed outside of the bird breeding season (March to August, inclusive).

Should this not be possible, a suitably qualified ecologist should search the Site of evidence of nesting birds immediately prior to any works commencing in areas that have been highlighted as having the potential to support bird species, with a re-check undertaken for any works delayed longer than 48 hours. Should a nest be recorded, a suitable working buffer would be put in place until the young have successfully fledged the nest.

5.1.9           Use of Appropriate Lighting

Artificial lighting can often impact the foraging and commuting behaviour of nocturnal mammals such as badger, otter and bats. As a consequence, it is advised that construction phase lighting be directed to where it is needed and light spillage (whether direct/or in-direct) should be avoided, particularly within the vicinity of edge habitat, riparian corridors and other linear features such as pathways, tree lines and hedgerows. The times during which the lighting is on should be limited to provide some dark periods. Roads, track ways and hedgerows in areas likely to contain foraging bats should contain stretches left unlit to avoid isolation of bat colonies. These unlit stretches should be ten metres in length either side of a commuting route (ILP, 2018). 

6.6 Compliance with Legislation and Policy

The baseline survey data is considered to be valid for 18 months (e.g. up to the end January 2023). If construction works commence after this time, it is recommended that an updated survey, as per the methods section of this report, is undertaken to ensure there has been no significant change to the baseline outlined within this report.

Fulfilment of the recommendations outlined above will ensure compliance with the relevant nature conservation legislation and planning policy outlined in Section 2.1 (Legislation) and 2.2 (Policy Framework), respectively.

7. References

Averis AM, Averis B, Birks HJB, Horsfield D, Thompson DBA and Yeo MJM (2014). An illustrated guide to British upland vegetation, 2014 re-print. Joint Nature Conservation Committee.

British Standards Institute. (2012). BS5837: 2012 Trees in Relation to Design, Demolition and Construction: Recommendations.

Chanin P (2003). Monitoring the Otter Lutra lutra. Conserving Natura 2000 Rivers Monitoring Series No. 10. English Nature, Peterborough.

CIEEM (2017). Guidelines for Preliminary Ecological Appraisal. 2nd Edition. Chartered Institute of Ecology and Environmental Management. Available online at: https://cieem.net/resource/guidance-on-preliminary-ecological-appraisal-gpea/ (accessed April 2019).

CIEEM (2018). Guidelines for Ecological Impact Assessment in the UK and Ireland. Chartered Institute of Ecology and Environmental Management. Available online at: http://www.cieem.net/data/files/Publications/EcIA_Guidelines_Terrestrial_Freshwater_and_Coastal_Jan_2016.pdf (accessed May 2020).

CIEEM (2013a). Competencies for Species Survey: Eurasian Otter. Available online at: https://cieem.net/wp-content/uploads/2019/02/CSS-EURASIAN-OTTER-April-2013.pdf (accessed May 2020).

CIEEM (2013b). Competencies for Species Survey: Water Vole. Available online at: https://cieem.net/wp-content/uploads/2019/02/CSS-WATER-VOLE-April-2013.pdf (accessed May 2020).

CIEEM (2013c). Competencies for Species Survey: Badger. Available online at: https://cieem.net/wp-content/uploads/2019/02/CSS-BADGER-April-2013.pdf (accessed May 2020).

CIEEM (2013d). Competencies for Species Survey: Great Crested Newt. Available online at: https://cieem.net/wp-content/uploads/2019/02/CSS-GREAT-CRESTED-NEWT-April-2013.pdf (accessed May 2020).

Dean, M, Strachan, R, Gow, D and Andrews, R (2016). The Water Vole Mitigation Handbook (Mammal Society Mitigation Guidance Series). Matthews, F and Chanin, P Eds, Mammal Society, London.

East Lothian Council (2017). East Lothian Biodiversity Report. Available at: https://www.eastlothian.gov.uk/downloads/file/23321/biodiversity_report_2017

East Lothian Biodiversity Partnership (2008). East Lothian Biodiversity Action Plan 2008-13. August 2008.

ITPEnergised (2022a). Berwick Bank EIA, Ecology Chapter, Technical Appendix 7.3, Bat ITPEnergised (2022c). Berwick Bank EIA, Ecology Chapter, Technical Appendix 7.2, Protected Species Report.

ITPEnergised (2022b). Berwick Bank Onshore RIAA.

ITPEnergised (2022c). Berwick Bank EIA, Ecology Chapter, Technical Appendix 7.2, Protected Species Report.

ILP (2018). Guidance Note 08/18 Bats and artificial lighting in the UK Bats and the Built Environment series. Institution of Lighting Professionals. Document download available online at: https://www.theilp.org.uk/documents/guidance-note-8-bats-and-artificial-lighting/

JNCC (2010). Handbook for Phase 1 Habitat Survey – a technique for environmental audit, revised re-print. Joint Nature Conservation Committee, Peterborough, UK.

NatureScot (2022). Sitelink. Available online at: https://sitelink.nature.scot/home (accessed January 2021).

NBN Atlas (2022). Explore Your Area. Available online at: https://nbnatlas.org/ (accessed January 2021).

Rodwell JS (ed.) (1991). British Plant Communities, Volume 2: Mires and heaths. Cambridge University Press, Cambridge.

Rodwell JS (2006). National Vegetation Classification: Users’ Handbook. JNCC, Peterborough.

Scottish Badgers (2018). Surveying for Badgers Good Practice Guidelines Version 1: 2018. Available online at:  https://www.scottishbadgers.org.uk/userfiles/file/planning_guidelines/Surveying-for-Badgers-Good-Practice-Guidelines_V1.pdf (accessed February 2022).

Scottish Government (2000). Planning for Natural Heritage: Planning Advice Note 60. Available online at: https://www2.gov.scot/Publications/2000/08/pan60-root/pan60 (accessed February 2022).

Scottish Government (2013). Scottish Biodiversity List. Available online at:  https://www2.gov.scot/Topics/Environment/Wildlife-Habitats/16118/Biodiversitylist/SBL (accessed February 2022).

Scottish Government (2014a). National Planning Framework 3. Available online at: https://www.gov.scot/publications/national-planning-framework-3/  (accessed February 2023).

Scottish Government (2014b). Scottish Planning Policy. Available online at: https://www.gov.scot/publications/scottish-planning-policy/ (accessed February 2023).

Scottish Government (2023). National Planning Framework 4. Available online at:  https://www.gov.scot/publications/national-planning-framework-4/ (accessed February 2023).

SEPA (2009) Temporary Construction Methods. Engineering in the Water Environment Good Practice Guide. https://www.sepa.org.uk/media/150997/wat_sg_29.pdf

SEPA (2015) Scotland’s Environment Web. Available at:   https://www.environment.gov.scot/maps/scotlands-environment-map/ (accessed March 2022).

SEPA (2017). Guidance on Assessing the Impacts of Development Proposals on Groundwater Abstractions and Groundwater Dependent Terrestrial Ecosystems. Version 3. Land Use Planning System SEPA Guidance Note 31.

SNH (2018). A guide to understanding the Scottish Ancient Woodland Inventory (AWI). Scottish Natural Heritage, November 2018. Available online at: https://www.nature.scot/sites/default/files/2018-11/A%20guide%20to%20understanding%20the%20Scottish%20Ancient%20Woodland%20Inventory%20%28AWI%29.pdf (accessed March 2022).

Stace, C (2010). New Flora of the British Isles Third Edition. C&M Floristics

Stanbury A, Eaton M, Aebischer N, Balmer D, Brown A, Douse A, Lindley P, McCulloch N, Noble D, and Win I (2021). The status of our bird populations: the fifth Birds of Conservation Concern in the United Kingdom, Channel Islands and the Isle of Man and the second IUCN Red List assessment of extinction risk for Great Britain. British Birds 114, December 2021, 723-747. Available online at https://britishbirds. Co.uk/wp-content/uploads/2014/07/BoCC4.pdf (accessed March 2022).

TWIC (2021). Protected and Notable Species Records, Data Request January 2021.

Figures

Figure 7.1.1 Location Plan

Figure 7.1.1 Location Plan

Figure 7.1.1 Location Plan

Figure 7.1.2 Statutory Nature Conservation Designations

Figure 7.1.2 Statutory Nature Conservation Designations

Figure 7.1.2 Statutory Nature Conservation Designations

Figure 7.1.3 Non-Statutory Nature Conservation Designations

Figure 7.1.3 Non-Statutory Nature Conservation Designations

Figure 7.1.3 Non-Statutory Nature Conservation Designations

Figure 7.1.4 Extended Phase 1 Habitat Survey Results (north)

Figure 7.1.4 Extended Phase 1 Habitat Survey Results (north)

Figure 7.1.4 Extended Phase 1 Habitat Survey Results (north)

Figure 7.1.5 Extended Phase 1 Habitat Survey Results (south)

Figure 7.1.5 Extended Phase 1 Habitat Survey Results (south)

Figure 7.1.5 Extended Phase 1 Habitat Survey Results (south)

Annexes

Annex A: Species Specific Legislation

Badger

Badgers and their setts are protected under the Protection of Badgers Act 1992, as amended by the Wildlife and Natural Environment (Scotland) Act 2011. Under this legislation it is an offence to intentionally or recklessly:

       Kill, injure, take, possess or cruelly ill-treat a badger or attempt to do so;

       Interfere with a sett by damaging or destroying it;

       Obstruct access to a badger sett;

       Disturb a badger whilst it is occupying a sett;

       Cause or allow a dog to enter a sett;

       Sell a live badger, or offer one for sale, or possess a live badger; and

       Be in the possession, or control of, a dead badger or anything derived from a dead badger.

Under the Protection of Badgers Act 1992, a badger sett is defined as ‘any structure or place which displays signs indicating current use by a badger’. Following NatureScot guidance, in the absence of any case law to define current use, the presence of field signs such as bedding, fresh spoil heaps, signs of recent digging, hair, latrines, or footprints in or around the potential sett or evidence of badgers entering or exiting the structure or place in question would indicate current use of the structure / place by a badger (SNH, 2018). Where a possible sett has no immediate evidence of current use, and is to be impacted by works, the structure should be actively monitored for a minimum of two weeks.

This legislation means that badgers are fully protected in Scotland, and that any planned activity, which may affect them, requires prior consultation with the appropriate statutory nature conservation organisation (i.e. NatureScot). Under Section 10 (1) of The Protection of Badgers Act 1992, licences may be granted by NatureScot for certain purposes that would otherwise be illegal.

Otter

Otters are a European Protected Species (EPS), protected under the Conservation (Natural Habitats, &c.) Regulations 1994. As such, in Scotland it is an offence to deliberately or recklessly:

       Capture, injure or kill an otter;

       Harass an otter or group of otters;

       Disturb an otter in a den or any other structure or place it uses for shelter or protection;

       Disturb an otter while it is rearing or otherwise caring for its young;

       Obstruct access to a den or other structure or place otters use for shelter or protection, or otherwise deny the animal use of that place;

       Disturb an otter in a manner or in circumstances likely to significantly affect the local distribution or abundance of the species; and

       Disturb an otter in a manner or in circumstances likely to impair its ability to survive, breed or reproduce, or rear or otherwise care for its young.

It is also an offence to:

       Damage or destroy a breeding site or resting place of such an animal (whether deliberately or recklessly); and

       Keep, transport, sell or exchange, or offer for sale or exchange any wild otter (or any part or derivative of one) obtained after 10 June 1994.

It should be noted that otter shelters are always legally protected, whether an otter is present or not.

Otter is also included on the Scottish Biodiversity List (SBL), where it is listed for avoidance of negative impacts (The Scottish Government, 2013).

Water Vole

Water vole receives partial protection through its listing on Schedule 5 of The Wildlife and Countryside Act 1981 (as amended). In Scotland, this legal protection is currently restricted only to the water vole places of shelter or protection; it does not extend to the animal itself. It is an offence to intentionally or recklessly:

       Damage, destroy or obstruct access to any structure or place that water voles use for shelter or protection; or

       Disturb a water vole while it is using any such place of shelter or protection.

Water vole is a Priority Species on the Scottish Biodiversity List (SBL) (Scottish Government, 2013), where it is listed for both conservation action and for avoidance of negative impacts. This species has suffered significant declines in recent decades, mainly due to habitat loss and degradation, population fragmentation and predation by American mink (Mustela vison).

Great Crested Newt

Great crested newts are a European Protected Species (EPS), protected under the Conservation (Natural Habitats, &c.) Regulations 1994. As such, in Scotland it is an offence to deliberately or recklessly:

       Capture, injure or kill a great crested newt;

       Harass a great crested newt or group of great crested newts;

       Disturb a great crested newt in a structure or place it uses for shelter or protection;

       Disturb a great crested newt while it is rearing or otherwise caring for its young;

       Obstruct access to a structure or place great crested newt use for shelter or protection, or otherwise deny the animal use of that place;

       Disturb a great crested newt in a manner or in circumstances likely to significantly affect the local distribution or abundance of the species;

       Disturb a great crested newt in a manner or in circumstances likely to impair its ability to survive, breed or reproduce, or rear or otherwise care for its young;

       Disturb a great crested newt while it is migrating or hibernating; and

       Take or destroy the eggs of a great crested newt.

It is also an offence of strict liability to:

       Damage or destroy a breeding site or resting place of such an animal (whether deliberately or recklessly). These sites and places are protected even when the animal isn’t present. For example, great crested newt ponds are protected all of the time as long as it can be shown that the newts use the ponds some of the time; and

       Keep, transport, sell or exchange, or offer for sale or exchange any wild great crested newt (or any part or derivative of one) obtained after 10 June 1994.

Great crested newt is also included on the Scottish Biodiversity List (SBL), where it is listed for avoidance of negative impacts (The Scottish Government, 2013).

Annex B: Policy Framework

National Planning Framework 4 (NPF4)

National Planning Framework 4 (NPF4) (Scottish Government, 2023) replaces National Planning Framework 3 (Scottish Government, 2014a) and Scottish Planning Policy (Scottish Government, 2014b). NPF4 outlines the duty of planning authorities to further the conservation of biodiversity as defined in the Nature Conservation (Scotland) Act 2004.

The planning system has an important role to play in improving the environment, for example by strengthening green and blue infrastructure, safeguarding, and enhancing urban and rural biodiversity, and contributing to the improvement of water, air and soil quality. Development plans should also seek to achieve a net enhancement of landscape quality and biodiversity. Policies relevant to nature conservation include:

       Policy 1: Tackling the climate and nature crises;

       Policy 3: Biodiversity;

       Policy 4: Natural places;

       Policy 5: Soils;

       Policy 6: Forestry, woodland and trees;

       Policy 8: Green belts;

       Policy 11: Energy; and

       Policy 20: Blue and green infrastructure.

Planning Advice Note (PAN) 60

National planning policy on landscape and natural heritage is supported by Planning Advice Note (PAN) 60 Planning for Natural Heritage, the key elements include:

       Taking a broader approach to landscape and natural heritage than just conserving designated or protected sites and species, taking into account ecosystems and natural processes.

       Facilitating positive landscape change whilst maintaining and enhancing distinctive character.

       Seeking benefits for species and habitats from new development including the restoration of degraded habitats.

       Siting and design of development should be informed by local landscape character.

       Encouraging connectivity between habitats, through green networks.

       Protecting internationally and nationally designated habitats and species.

       Protecting and enhancing woodland and trees of high nature conservation value.

Local Development Plan

The East Lothian Council Local Development Plan’s (ELC, 2018) Sustainable Natural and Environment policies relevant to nature conservation are as follows:

         Natural Heritage:

• Policy NH1: Internationally Designated Sites (RAMSAR);
• Policy NH2: Protection of Sites of Special Scientific Interest and Geological Conservation Review Sites;
• Policy NH3: Protection of Local Sites and Areas;
• Policy NH4: European Protected Species;
• Policy NH5: Biodiversity and Geodiversity Interests, including Nationally Protected Species;
• Policy NH7: Protecting Soils;
• Policy NH8: Trees and Development;
• Policy NH9: Water Environment;
• Policy NH10: Sustainable Urban Drainage Systems;
• Policy NH11: Flood Risk;
• Policy NH12: Air Quality; and
• Policy NH13: Noise.

         Infrastructure and Resources:

• Policy T4: Active Travel Routes and Core Paths as part of the Green Network Strategy;
• PROP T5: Cycle Route Network; and
• PROP T20: Transport Related Air Quality Measures: Relocation of Bus Stops.

         Energy Generation, Distribution and Transmission:

• Policy SEH1: Sustainable Energy and Heat; and
• Policy SEH2: Low and Zero Carbon Generating Technologies.

         Countryside and Coastal Areas:

• Policy DC10: The Green Network.

Annex C: Full bird records

Table C1: Bird species recorded within 5 km of the Site