Via OCR

June 7th 2016

Dear Mr Bainbridge,

Re. PA16/03519 Erection of retail development (Class A1), including all associated
access, servicing and infrastructure works, car parking, public realm improvements
and landscaping together with enhancement works including footpaths, bird hide and
landscaping to the nature reserve and surrounding land Hayle Retail Park And Marsh
Lane Nature Reserve Marsh Lane Hayle Cornwall

Cornwall Wildlife Trust has reviewed the Updated Ecological Report prepared by Betts Ecology
for this application. We have repeatedly lodged objections to proposals on this site due to the
habitat loss that will occur. For many years we have asked for more evidence to back up the
claims in the Ecological reports, namely a habitat loss and gain table and detailed information on
compensation for habitat loss but still none is provided. These requirements have since become
part of the British Standard for Biodiversity BS42020 as they are recognised as being an important
part of assessing the impacts of developments. Betts Ecology state on the title page of the report
that the project will have ‘no or only minor impacts on ecology and some gains’, yet no evidence is
given to support this. Another requirement of BS42020 is a constraints and opportunities plan.
We have asked for many years for this information where the development footprint is overlain
on the habitat map, but it has never been provided.

We note that the emerging Neighbourhood Development Plan for Hayle does not have this area
allocated for employment space due to its designation as a County Wildlife Site and the fact that
other sites are available. The emerging Cornwall Local Plan also has ever-stronger wording to
protect County Wildlife Sites. At a time when we are advised through the John Lawton report to
create bigger, better, joined spaces for wildlife, and when alternative sites for development are
available we feel this is the wrong site for development. This development results in a loss of
habitat, despite the clearance work that happens every few years to clear vegetation. The
proposals include limited information about managing retained habitats, but we are never given any
quantitative information that demonstrates the true contribution of this ‘compensation’. In the
absence of more detailed information we conclude that the compensation will be fairly minor
tweaks to the pre-existing retained habitats.

Cornwall Wildlife Trust objects to this proposal due to a lack of evidence to
demonstrate that it is in-line with section 118 of the NPPF, the emerging Policy 23 in
the Cornwall Local Plan and the emerging Hayle NDP. More detail is given below in note
form.

1- The repeat survey was carried out in February after vegetation management. This is a suboptimal time for vegetation surveys which makes us concerned about the bold claims that are
made in the Ecological report with respect to marshy grassland. The photo below shows the site
on 7th June 2016 and shows a mix of ruderal and marshy grassland species.

2-Comments on bracken on page 8 appear contradictory.

3- The comment that ‘surrounding fields are now drying out’ comes after a single site visit and is
anecdotal.

4- The conclusions drawn on page 10 are not substantiated.

5- The fields are repeatedly cleared and this is used in the Ecological report to suggest they are
less valuable than previously. This has happened several times and the site regenerates.

6- It is not clear if the bats and lighting issues has been fully addressed.

7- There still does not appear to be a detailed Ecological Management Plan included.

8- Page 18 names Cornwall Wildlife Trust as if we are in agreement with the ‘generous mitigation
and enhancement’ which we are not. We have had various meetings with Cranford and Betts
Ecology but our requests for additional information have not yet been met.

9- The ditch deepening work appears to be carried out without advice from the applicant’s
ecologists and could be damaging.
Yours sincerely,

Cheryl Marriott
Conservation Manager- Cornwall Wildlife Trust