TORBAY LOCAL PLAN
A landscape for success
The Plan for Torbay – 2012 to 2032 and beyond
DRAFT HABITATS REGULATIONS
ASSESSMENT ADDENDUM
EXCLUDED SITES (PINK CATEGORY – COUNCIL
DOCUMENT TC/4)
Torbay Council - December 2014
December 2014
Contents
1.
Background ..................................................................................................................... 3
2.
Land South of White Rock, Brixham ................................................................................ 3
2.1 Likely significant effects ................................................................................................ 4
2.2 Mitigation recommendations ......................................................................................... 4
3.
Sladnor Park, Torquay..................................................................................................... 5
3.1 Likely significant effects ................................................................................................ 5
3.2 Mitigation recommendations ......................................................................................... 5
4.
References ...................................................................................................................... 6
December 2014
1. Background
Excluded’ sites do not feature in the new Local Plan for a reason. All of them have significant
environmental constraints and/or have proven themselves to be difficult to deliver. This might be
because of a national policy presumption against development (e.g. sites in AONB), impact
mitigation is difficult to achieve (e.g. because the level of acceptable development isn’t viable),
because the land owner is not willing to develop or, quite simply, because the site - in its
existing state - forms such a valuable contribution to the Bay and the sustainability of its
communities that it should not be developed.
This Draft Habitats Regulations Assessment, subject to consultation with Natural England,
refers specifically to the 'pink category' sites described in the Torbay Local Plan: 'Excluded'
Sites, document submitted to the Local Plan Examination. These were the sites considered to
have the least environmental impacts of all the sites identified. These include:
1. Land South of White Rock, Brixham
2. Sladnor Park, Torquay
3. Victoria car park, Paignton
4. Station Lane/Great Western car park, Paignton
5. The Terrace car park, Torquay
6. Lower Union Lane car park, Torquay
7. Paignton Harbour car park, Paignton
8. Churchward Road car park, Paignton
The first two sites are within the greater horseshoe bat sustenance zone and/or flyway and
consequently they will require HRA. The rest of the sites are not within the greater horseshoe
bat sustenance zone or flyway (see Figures1-3) and therefore development of these sites will
not have likely significant effects on the South Hams SAC and will not require HRA.
2. Land South of White Rock, Brixham
The site comprises a mix of intensively managed arable fields with semi-improved cattle grazed
pasture fields divided by managed hedgerows/Devon hedgebanks with occasional trees within
these hedgerows.
December 2014
An ecological survey conducted by Ecosulis in 2014 has identified that greater horseshoe bats
have been recorded using the site for commuting and foraging. Activity was concentrated along
hedgerows; the activity levels were low considering the size of the site and suitable habitat
present. The site contains numerous large mature trees and buildings that may offer suitable
roost sites.
2.1 Likely significant effects
The site provides good habitats for the greater horseshoe bat population, with well-established
hedgerows providing good foraging and commuting routes, pasture and woodland providing
foraging habitat, numerous large mature trees and buildings that may offer suitable roost sites.
Greater horseshoe bat activity surveys should be undertaken on site to identify any important
foraging areas and commuting routes. The survey should be undertaken in accordance with
Natural England South Hams SAC guidance 2010.
2.2 Mitigation recommendations
 An updated dawn swarming survey of the buildings should be undertaken prior to
demolition to reassess their suitability for bats;

Daytime and emergence surveys of trees should be undertaken to identify roost sites.
These surveys can only be undertaken when bats are active between May and August;

A habitat suitability assessment of any trees proposed for removal should be undertaken
to fully assess their suitability to support bat roosts prior to felling;

Lighting during construction should be avoided where possible. Where unavoidable,
consultation with an ecologist should be undertaken and directional lighting should be
used wherever practicable during construction work, particularly near to features such as
hedgerows, mature trees and woodland edges to avoid disturbance to foraging and
commuting bats;

Suitable alternative habitats for greater horseshoe bats within the local area with
consideration of offsite mitigations including enhancements to hedgerows or new
hedgerows creation is recommended;

New roosting opportunities should be provided throughout the development such as
bricks and tiles within buildings and bat boxes on mature trees within the woodlands;
and

The detailed mitigation proposal should be agreed with Natural England, prior to
commencement of any work on the site.
December 2014
3. Sladnor Park, Torquay
The extensive area of grassland to the east of the site offers a potential feeding area for greater
horseshoe bats. The bat survey conducted by Ambios Environmental Consultants in 2006 has
identified a narrow tunnel in the northwestern corner of the site. The tunnel entrance was found
approximately 2 metres above ground level, adjacent to a number of sheds at this location. The
tunnel runs in a westerly direction into the sandstone cliff for a distance of approximately 15
metres, and a smaller side tunnel runs north for approximately 8 metres. At the time of the
survey a number of greater horseshoe bat droppings were found in the main tunnel for various
ages, which indicates that the tunnel is likely to be used by small number of bats throughout the
year.
3.1 Likely significant effects
Development of the site could cause obstruction of the entrance to the tunnel, which would
prevent access by greater horseshoe bats. Significant removal of vegetation and/or buildings
around the entrance may disrupt the existing flight path to and from the tunnel, thus reducing
level of tunnel use by bats. In the long-term, open access to the tunnel may lead to human
disruption that causes the bats to stop using this roost. Reduction of habitats quality may lead to
a loss of bat foraging area.
The high level of protection afforded to greater horseshoe bats makes it imperative that a
detailed bat survey of the site is undertaken prior to any work commencing. The survey should
be undertaken in accordance with Natural England South Hams SAC Guidance 2010
3.2 Mitigation recommendations
 The tunnel identified on site should be protected during and following development;

Work to remove existing buildings and vegetation around the tunnel entrance should
only take place with advice from a suitably qualified bat worker;

The pasture and woodland surrounding the development should be managed to
conserve bat foraging habitat;

It is important to design lighting in the new development to avoid illuminating the hedge.
Security lights if fitted should point away from the hedge and be of short period; and

The detailed mitigation proposal should be agreed with Natural England, prior to
commencement of any work on the site.
December 2014
4. References
1. Ambios Environmental Consultants (2006), Baseline Ecological Assessment, Sladnor
Park.
2. Nigel Wood Ecology Services (2014), Preliminary Ecology Appraisal, Pine Lodge,
Sladnor Park.
3. Stride Treglown (2014), White Rock 2 Urban Extension, Draft Land Promotion Study.
December 2014
Figure 1: Torquay excluded sites
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Figure 2: Paignton excluded sites
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Page 8
Figure 3: Brixham excluded sites
December 2014
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