Agenda item

Craig O’Connor delivered introductory remarks, in which they emphasised MCC’s commitment to the climate and nature emergency, ensuring that development proposals are sustainable and balanced. He clarified that MCC is not removing protections for bats and aims to protect and enhance ecological and wildlife interests. Craig explained that the council's approach to policy wording aims to avoid being too prescriptive, allowing flexibility to request bat surveys and ecological assessments across all development types and areas, not just within core sustenance zones. He assured members that the replacement local development plan is undergoing a detailed consultation process, including addressing concerns raised by Natural Resources Wales regarding the habitat regulations assessment methodology. Craig mentioned that the plan will be reviewed by an independent planning inspector, who will examine the habitat regulations assessment and make an informed decision on the development's acceptability.

Kate Stinchcombe delivered a presentation, outlining MCC’s responses to the concerns that have been raised. Craig O’Connor and Kate Stinchcombe answered the members’ questions:

• A member asked Andy Karran of Gwent Wildlife Trust if they believed that there has been a dilution in protection for horseshoe bats.

Mr Karran stated that he did not believe there had been any dilution in the protection of horseshoe bats. He explained that the wording changes were made to ensure impacts on bats are assessed across all areas within Monmouthshire under different circumstances. He expressed concerns about the significance of the proposed development area within the core sustenance zone, noting that areas closer to the maternity roost may be more valuable. He emphasised the need to look into whether the proposed development area is still of significance despite being a small percentage of the sustenance area.

• A member expressed concerns about the general details of the core sustenance zones for greater and lesser horseshoe bats, specifically mentioning a site in Shirenewton. They questioned whether surveys were being conducted for other sites within these zones.

It was clarified that the Redlands site in Shirenewton is within the two-kilometre zone of a hibernation site, which requires different survey considerations compared to maternity sites. It was explained that the Redlands site had low ecological value, with closely managed hedgerows, and highlighted the importance of case-by-case assessment. The need for flexibility in survey requirements to address site-specific conditions was emphasised.Members were assured that effects on hibernation roosts are being considered in the addendum to the habitat regulations assessment.

• The member argued that removing specific details of bat surveys and mitigation from the policy weakens it. They suggested that local policies should reinforce national policies to emphasise local importance.

It was explained that the replacement local development plan (RLDP) must align with Welsh Government's guidance, which requires avoiding duplication of national policies. They acknowledged the challenge but emphasised that the RLDP is part of a broader planning policy framework, including national and regional policies. They assured that all consultation responses are being reviewed, and amendments may be made to strengthen policies where necessary.

• She noted a general weakening of wording and protections in the proposed replacement local development plan compared to the current LDP, suggesting that development priorities were overriding protections.

The officer responded that the amount of information gathered for the Monmouth site is the highest level of information they have ever seen for a development site, which is appropriate given its proximity to the SAC. It was highlighted that the RLDP aims to enhance policies beyond the existing adopted LDP, incorporating new standards for net zero requirements and renewable energy, which will provide the planning committee with tools to enforce higher standards on development proposals. If significant time passes before the development is taken forward, updated surveys would be required.

• A member asked for clarification on who was involved in signing off the process for the Habitat Regulations Assessment (HRA) and how different views within the ecology team were considered in the final outcome.

It was explained that MCC contracted Aecom to conduct the HRA. The process involved discussions between Aecom and the council's internal ecology team. The council felt that Aecom's policy wording was too prescriptive and needed flexibility to ask for ecological surveys outside the three-kilometre zone. The HRA was signed off by officers and will be reviewed by an independent planning inspector when submitted to Welsh Government.

• Are the measures being taken sufficient to protect bats, and is more survey work needed? There are concerns about the impact of building houses on bat habitats, including noise, light, and disturbance.

The officer explained that while any development will have some impact, the goal is to manage and mitigate these effects. The current level of information for the Monmouth site is extensive and includes measures like dark corridors to minimise light pollution. It was noted that the principle of development is based on the best available information and that further surveys would be required if significant time passes before development begins. The RLDP aims to balance housing needs with ecological protection, ensuring sustainable development. It was mentioned that the plan includes significant ecological surveys for all sites and that the process involves thorough assessment and review by an independent planning inspector. The importance of providing housing and economic opportunities while maintaining ecological interests was highlighted.

• The member asked further if there would be no detriment to bats from building.

The officers responded that it will be detrimental, but the key consideration is whether that detriment is adverse. They explained that the proposed measures, such as the dark skies policy and woodland buffer planting, aim to mitigate the impact on bats. The purpose of the HRA is to make an informed decision based on evidence. They emphasised that the assessment suggests the development will not have a significantly adverse impact on the preservation of the conservation species, and this will be reviewed by NRW and the planning inspector.

• A member asked if there has been a study on the extent of the negative effects of human development beyond development borders, including noise, litter, and damage caused by pets. They enquired about what can be done at the RLDP stage to mitigate these risks, particularly for sensitive sites.

The officer explained that there are many studies showing the impacts of development, including noise, litter, and predation by pets. They mentioned that the RLDP includes measures like green infrastructure, rain gardens with biodiversity planting, and thorny planting to protect species like dormice from cats. The importance of balancing development needs with ecological protection and managing long-term impacts through design and policy measures was emphasised.

• A member expressed reassurance with the mitigation measures proposed by the officers to protect bat habitats while balancing the need for housing development. They emphasised the importance of providing housing for people in Monmouthshire, noting the challenges faced by those in temporary accommodation or homeless. The difficulty of predicting the exact impact of development was acknowledged but they felt confident in the measures outlined to mitigate potential harm. They highlighted the lack of brownfield sites in Monmouthshire, which necessitates developing Greenfield sites, and stressed the need to balance conservation with housing needs.

• A member asked if the five local plan allocations identified in relation to bat sites in the HRA will be publicly available. They sought more information on the surveys done for these sites, as detailed information was provided for the Monmouth site but not for the other four sites.

The officer explained that there is no radio tracking data for the other candidate sites, and the level of information is different. They mentioned that the addendum by Acom will provide a qualitative and quantitative assessment of each site within the core sustenance zones, but there are no associated maps available. They noted that past surveys will be drawn upon for site assessments, and activity bat surveys have been requested for the Redlands site to inform development. It was added that if a planning application is submitted, updated ecology surveys will be requested to ensure the design of the site is influenced by ecological movements and foraging. Officers emphasised that the process is strategic at this stage, but detailed surveys will be required as the years go on.

• Members emphasised that the importance of providing accommodation for those in need is well understood but it is equally important to have a rigorous process before anything is built, as by that time it will be too late. Members need to ensure that what is being put forward enables the right sites to progress.

Chair’s Summary:

The Chair thanked everyone for their attendance and contributions, emphasizing the importance of engaging conversations and challenging questions. They acknowledged the strong feelings about the need for housing and the protection of habitats. The Chair recapped the discussions about the impact of development on bat habitats, including concerns about the dilution of bat protection, the need for more detailed surveys, and the impact of human development on bat habitats. They noted the importance of ensuring sustainable development and the need for thorough assessments.