Deficiencies in Chisholm Trail planning

Following letter was sent by Chris to council on 26 March 2017, detailing directly contradictory evidence about bat surveys and habitats. None of the issues were ever addressed, including unmentioned limitations to coverage, why at least 11 potential bat roosts were not mentioned nor the presence of an identified maternity colony just north of the river nor inconsistencies in habitat mapping.  Furthermore implementation of an existing management plan for Coldhams Common was claimed as an “offset” for habitat lost i.e. something that would have happened anyway.

Dear Elizabeth

RE : Chisholm Trail application  [C/5007/2016/CC]

Please find attached as an appendix my interim response to the recent ecology information for the Chisholm Trail application [C/5005/2016/CC]. I note that an additional technical note has now appeared and that you are expecting further information.  I will make an additional response when this is available.

The new information presented on ecology, particularly around the extent of the bat surveys, gives serious concerns as to the completeness of the bat surveys presented to accompany the Abbey-Chesterton Bridge application [ C/5005/2016/CC ], which is now the subject of a potential judicial review.

Within this document I point you towards the implications of additional detailed surveys carried out on the Bridge site by Applied Ecology[1]. I do not confirm this represents the only bat survey available for the redline of the Bridge or Trail.

The EcIA as presented has failed to achieve basic accuracy on habitat mapping, despite repeated feedback, and continues to insist that previously identified inconsistencies are correct.  The assessment for bats as presented has data that appears to be at odds with other existing data, and has very significant limitations on coverage that were not previously revealed. I am concerned that this situation is repeated for other species groups, including water voles and birds.

I request that full disclosure is made of all available raw data for all ecology surveys.

I wish to make a formal complaint about the consistency of the ecology information as submitted by the applicant.  Please can you let me know whether this should be to Planning or to the Transport team ?

Best wishes


Chris Smith





Activity surveys

The applicant has indicated that sufficient bat surveys were carried out of key locations to BCT standards.  We have previously pointed out that this is not the case.

However the associated maps now added indicate that there is no coverage whatsover of Barnwell Pits (Section 9), that there are no transects of the area between Newmarket Road and Ditton Meadows ( Section 6 and 7) and that there is no coverage of the woods ( Section 5 ) which are proposed for major thinning works and dumping of spoil.

I also note there is no coverage whatsoever of the northern side of the river as asserted in the EciA accompanying the Abbey-Chesterton Bridge application, which stated that “Bat activity transect surveys were carried out across the Application Site and the wider area including Ditton Meadows to identify levels of activity, key foraging and commuting areas and species present.”

I feel that the omission of this lack of coverage in both cases  is “somewhat alarming”.

Furthermore the two transects on Ditton Meadows include wide areas beyond the red line and appear to have limited fixed point effort on the River Cam or on those other areas which were likely to be most important to bats. We must assume that less than an hour of each transect was spent within or adjacent to the redline.

I note that the transect route claimed along the southern edge of Ditton Meadows is impossible to walk, due to the large transverse ditch and thick scrub in this area, and the walker has to follow the footbridge on the permissive path.

On p15 of the EciA, the applicant concludes that : “The habitats within the Application Site are suitable for foraging for a small number of bats and abundant in the local area.”

Contrary evidence

The activity survey results are directly contradicted by the report by Applied Ecology ( 2015 ) as submitted for 16/0617/FUL, Hayling House Fen Road Cambridge Cambridgeshire CB4 1UN, conducted on 20 May and 10 June 2015.  This report is attached and available at :

I draw your attention to the following extracts.

“Results : Protected species :

 3.10 In May, a total of 18 common pipistrelle bats and two soprano pipistrelle bats commuted past the site from west to east from 21.11 ( 17 minutes after sunset ) until 21.43 ( 49 minutes after sunset).

3.11 In June, 52 common pipistrelle bats commuted past the site from west to east from 21.43 ( 25 minutes after sunset ) until 22.12 ( 54 minutes after sunset ).

3.12 The bats were flying at 1.5m-2m above the ground along, and eiother side ( along the tow path and just inside the site boundary ) of the former trees line that bounds the site in the direction shown by Figure 3.1 )

3.13 The finding confirms the presence of a probable maternity roost of common pipistrelle bats somewhere to the west of the site on the north side of the river and the importance of the southern boundary of the site as a bat flyway/commuting corridor”

I find it unlikely that bats would not cross to the southern side of the river and commute e.g. along the railway line.  We also note that there is at least one roost located within or near to the redline, which contradicts the applicant’s ecologist’s conclusions.

I find it more likely that the applicant’s bat surveys were not sufficient to provide a suitable evidence base and include significant omissions of coverage.


The applicant’s EcIA report indicates on p17 Table 4.1

Although bats are known to commute large distances between roosts and foraging habitat, direct construction impacts are only likely to occur on roosting habitat within 30 m of the Scheme boundary. However, due to the potential for indirect impacts on known roosts in the local area, the EZoI was extended to 100 m.”

This would imply an area of search of the redline plus at least 30m and upto 100m.

The applicant indicates that these have been searched for and there are no such roosts.

Contrary evidence

The Aspect Ecology report indicates a maternity roost of common pipistrelle bats somewhere to the west of the site on the north side of the river, which would be within the 100m buffer and possibly the 30m buffer.

The following potential roosts are easily identifiable from even a brief walkover of the site :

  • Pill box north of river
  • Willow pollards on north bank of the river, including those to be felled for the Bridge. All of these trees possess considerable cavities and would be rated of moderate potential for bats. They may support the maternity roost indicated in the Aspect Ecology report.
  • Large oak adjacent to footbridge over railway line, Ditton Meadows
  • Ashes along southern edge of Ditton Meadows
  • Culvert of Coldhams Brook under Mildenhall Railway Line
  • The Round House, Newmarket Road
  • The Leper Chapel, Newmarket Road
  • Paper Mills, Ditton Walk
  • Culvert of Coldhams Brook under Newmarket Road, which is of substantial height
  • Mature sycamores adjacent to football ground

Furthermore there are additional large numbers of trees and buildings present within either 30m or 100m of the redline.

No evidence is produced as to which potential roosts have been assessed.


The Aspect Ecology report makes the following recommendations :

“4.3 The following recommendations are made with respect to the proposed re-development of the site to minimise short and long-term adverse biodiversity impacts and to enhance the biodiversity value of the site :

– the southern boundary of the site should be strengthened by new native tree planting appropriate to the locality and the existing native tree resource along the north bank of the River Cam City Wildlife Site

– the southern boundary of the site should not be illuminated ( temporarily or permanently ) with security of other floodlighting during or after construction and should not be blocked by construction related infrastucture or temporary or permanent built structures.”

This would indicate that the removal of linear commuting features and installing structures e.g. such as a bridge with lit underpasses, would have a deleterious effect on the colony.  Furthermore, if bats were present e.g. within the pollards on the north of the river, then this roost would be lost.


The report continues to have habitat mapping errors. The following are from the applicant’s ecology sections  :

  1. North of the river : this is recently felled woodland, not ruderals. Confirmed by Aspect Ecology – Results : Habitats “3.3 The land to the immediate west of the red line boundary …. had been very cleared very recently of surface vegetation and a relatively large number of trees had been felled”
  2. Section 1 : The western boundary is incorrect and the railway fence is much further east. Section 1 includes scattered scrub and tall fen vegetation ( F1) . This is clearly visible on Google. The river’s edge has fringing vegetation ( F2).  There is no blob of dense scrub as indicated at the south of the section.
  3. Section 2 : Coldhams Brook, which is a chalk stream is omitted.
  4. Section 3 : This is not dense scrub as pointed out on multiple occasions, but includes blocks of unsurveyed grassland, which are clearly visible on Google Maps. It also includes part of the operational compound of the oil depot, which appears to be open ground with low bramble cover.
  5. Section 4 : This contains scattered scrub and trees and a tree belt along its western and northern edge.
  6. Section 5 : This is broad-leaved woodland and is mapped as such by Natural England’s MAGIC mapping system. There are already “clearings and rides” within it. The locality is known to contain meadow saxifrage on the southern boundary.
  7. Section 8 : The mapping of dense scrub in the south of this area is erroneous. There is a smaller narrow belt along the road edge. The site consists of Local Wildlife Site grassland that was recently excavated by the applicant for archaeological investigations.
  8. Section 9/10 : There is unmapped scrub on the eastern bank of the stream.
  9. Section 10 : There is a contention that this entire section is species-poor, but there is no data to support this and this contention is contradicted by the WTs data. The area is known to contain a number of scarce species such as spiny restharrow and meadow barley.

Habitat measurements

The total application area is 51,443.00m2 ( application form 8/12/17) of which only 43,600 is accounted for in the Technical Note Revision 2.

There is no such habitat as “Species-rich grassland” either under Phase 1 or under Section 41.

Furthermore it is disingenuous to classify as being a gain “improving” “scrub” to “broadleaved woodland”, when the classification as “scrub” is under contention [ it is patently broadleaved woodland ] and the “gain” seems to involve felling the existing scrub.  These habitats are key for bat populations within the site.

The applicant asserts that “the remainder of the site will be enhanced and will be subject to a 25 year management plan”.  This ignores those existing management plans in place e.g. Coldhams Common and Ditton Meadows, and that other areas e.g. 141 Ditton Walk are already subject to planning obligations.  The Notes omit the concept of Cumulative Impact.


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