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Representation by Chris Smith

Date submitted
19 July 2023
Submitted by
Members of the public/businesses

I am concerned about the information presented within Appendix 8.7:Bat Technical, in particular: 1. The low level of attempted survey effort for the transect surveys as only three repeats, given the development affects the river valley of the Cam and associated floodplain habitats, likely to be used by roosting, foraging and commuting bats, and which appears to be of "medium" or "high" quality; however the required level of effort was not achieved; 2. The duration of the transects as stated, some of which are only 1 hr and 5 mins, although no information is presented on timings that I can find; 4. The anonymisation of the tree survey results; 5. The lack of access to Biggin Abbey, which has large historical buildings with apparent good potential for bats; 6. Additional limitations as highlighted in the report. "2.9.5 Due to the length of two of the transects, one at the existing Cambridge WWTP and one around PRoW 85/6 and adjacent land parcels (Figures 8.45, 8.46 and 8.47, Book of Figures – Biodiversity (App Doc Ref 5.3.8)), activity transects fell short of the recommended duration in the Bat Conservation Trust Good Practice Guidelines (Collins, 2016). 2.9.6 During May 2021 and August 2021 the River Cam static detector (location TL 48410 61610), despite being deployed for at least five nights, only collected three nights’ worth of data from each month. Likewise, during August and September at the Proposed Development static detector location (TL 49846, 61223) only four nights of data were collected from each month. This was due to high instances of bat calls or other noise, filling the memory cards or running the batteries low, leading to power failure." 7. The lack of full information on timings, weather conditions, personnel and raw data sheets[My apologies if I could not find these and they were in an annex] These constraints lead me to have serious concerns about the robustness of the dataset collected and the ability for meaningful conclusions to be drawn by an informed person. I also note that Western barbastelle, which is an Annex 2 species under the European Habitats Directive, is indicated as being present within the development area, but that no attempt has been made to identify how close these bats are roosting to the site, whether commuting routes would be impacted; or whether the extent of their use is underestimated due to the limitations in survey effort identified above and within the report. It would seem unlikely that these bats are arriving from known roosts West of Cambridge at "Eversden and Wimpole Woods Special Area of Conservation (SAC)" and that there may be a nearer undocumented roost.