Aggregate Industries’ applications are riddled with inconsistencies. After the great crested newts debacle, it seems SLR had problems with dormice too, another European Protected Species. SLR writes:
Devon Biodiversity Records Centre (DBRC) was contacted in 2011 for archive dormouse records within 2 km of the proposal site, as part of a full ecological desk study... In order to augment this distribution information, publically [sic] available ecological assessment reports from nearby proposed and consented developments were also reviewed during the period between 2000 and 2012 2.1.
Despite all this, "The desk study did not return any records of dormouse within 2km of the site boundary" 3.1 which isn’t all that surprising because dormice are rare, to the point that the species is on the edge of extinction. However, SLR mysteriously asserts in the 'Executive Summary' to the document:
Records indicate that the dormice at Straitgate Farm site are probably part of a large and wide ranging population which extends to the south and east.
Which begs the question, do records indicate or do records not indicate dormice extending beyond the site? Dormice are unlikely to be crossing the busy B3174 to the south of the site. In fact, with roads bounding all sides of the site, the population at Straitgate may not be well connected to a large and wide ranging population; SLR simply has no idea where dormice extend to, or in what numbers.
In 2013, out of 100 survey tubes, SLR ecologists found 25 dormouse nests and eight dormice at Straitgate Farm. AI’s proposal seeks to remove over 2km of hedgerows across the site. In 2008, the UK reported on the implementation of the Habitats Directive for the dormouse. It stated that "the continued loss of hedgerows, particularly species rich ones, is a real problem" and declared that the Overall Assessment of the species was "Unfavourable – Bad and deteriorating. The species is in serious danger of becoming extinct (at least locally)".
In mitigation, AI claims 568m of new hedgerow was planted in 2014, and 2,007m will be planted as part of the restoration scheme, which in total is substantially short of the 5,748m of new hedgerow that Defra suggests should be planted to offset the expected loss. AI contends that such shortfall "must be placed in the context of creating [14,547m2] of new woodland and tree belt habitat" 8.261-8.263.
But as we know, the 10,547m2 has not been planted and the 4,000m2 was planted in the wrong place; in any case, woodland planting does not adequately compensate for the loss of hedgerows and the support they provide to bats and dormice.
Why is all this so important? In the group's submission, Charlie Hopkins makes it clear that:
The ES acknowledges that EPS Licences will be required from Natural England (8.218 and 8.222) in respect of bats and dormice. One of the derogation tests for the grant of a licence is that there be “no satisfactory alternative” (to the destruction/disturbance of habitats of EPS). The ES fails to address the derogation tests, and draws no conclusions as to the likelihood of the tests being satisfied. It is clear that an alternative site where EPS were absent or would not suffer habitat loss or disturbance would be preferable to Straitgate Farm. No such comparison of alternatives has been undertaken by the applicants.
