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Ibstock Bricks 1996 Ltd Knutton Quarry - Method Statement
NL06919/Method Statement 2 June 2009
Method Statement for Avoidance of Harm
Knutton quarry May 2009
This method statement sets out a defined means of continued working at Knutton
quarry. The statement is intended to ensure that individual great crested newts
(GCN) and their habitats are not harmed in the course of current operations under
the EC ‘Habitats and Species Directive’ implemented by the Wildlife and Countryside
Act 1981 (as amended). Avoidance of harm is achieved by setting a pragmatic list of
undertakings which constitute reasonable avoidance measures. These measures
identify the exact type, scope and timing of work, clearly define the working areas
and show commitment to avoidance of harm through awareness and training of staff
engaged in the operations.
Preliminary survey information
Homogenised artificial refugia have been set out since March 2009 and checked on a
weekly basis along the tiled path to be removed (Target Note 1), as well as natural
refugia within the site boundary. Four night time searches of the site were also
undertaken between April and May. Six GCN surveys of the waterbodies were also
carried out. The accompanying plan NL06919/14 identifies the potential area of high
risk of committing an offence with respect to great crested newts in relation to
waterbody 1 (Appendix 2). A habitat suitability assessment was also carried out
(Appendix 2). Appendix 4 details the Natural England rapid risk assessment to
determine the likelihood of an offence being committed. This system works by
assessing the suitable habitat types, measuring the areas, and considers the
distance from known breeding ponds. The calculations for these were done through
autocad software and were calculated with the assumption that waterbody 1 is a
breeding pond, although in reality, it is not considered to be one as discussed below.
The results confirm that even when considering waterbody 1 to be a breeding pond, it
is unlikely for an offence to be committed.
GCN Population Assessment
A small population size was determined within the site confined to waterbody 1. The
Habitat Suitability Index (HSI) score classed this waterbody with average suitability
for GCNs. It is considered that the water body is not used for breeding, and is instead
a transitional migration pond, whereby newts move from a breeding pond into other
ponds repeatedly over the spring and summer. (Langton et al, 2001). Reasons for
this pond not being used for breeding include the following;
Ibstock Bricks 1996 Ltd Knutton Quarry - Method Statement
NL06919/Method Statement 3 June 2009
• Five GCNs only were only found on one occasion out of six surveys, and
were not found in 3 previous years surveying in the well-established pond.
This was also based on a higher than recommended trapping effort in
accordance to Natural Englands GCN mitigation guidelines.
• No eggs were observed during the surveys.
• The waterbody is a late-succession pond dominated by greater reedmace
(Typha latifolia) with little or no open areas for male courtship display. This
thick vegetation also shades the pond significantly.
Monitoring for juvenile and larvae will be undertaken in June-July to confirm the
assumption that Waterbody 1 is a non breeding pond.
Site make-up
• Quarry area- Very low risk.
The quarry area is considered to be a significant barrier to GCN dispersal and low
risk of committing an offence. The area is heavily worked and has little foraging and
refuge potential.
• Area stripped of grassland to be quarried- Low risk.
This area is considered low risk again due to being heavily worked with a lack of
foraging and refuge provision.
• Grassland to be stripped and quarried- Low risk.
This area is considered low risk based on the distance between it, and waterbody 1,
and the lack of suitable foraging habitat in between.
• Tiled path to be removed-Low risk.
This area is considered low risk due to no foraging habitat available in this area. The
path was considered to provide refuge potential, and was therefore subject to hand
searches and homogenous artificial refugia checks since March 2009. However, no
evidence of GCNs were found during the thorough weekly checks.
• Woodland -High risk.
Ibstock Bricks 1996 Ltd Knutton Quarry - Method Statement
NL06919/Method Statement 4 June 2009
This area is considered high risk due to the proximity to waterbody 1. Langton et al,
(2001) state that woodland habitats are particularly valuable due to providing an
abundance of invertebrate prey. It is likely that the adjacent woodland provides the
most important foraging habitat the GCNs from waterbody 1 rely on. This woodland
will not be affected by the workings
Avoidance measures
• The position of the current quarry workings and access has been shown on
the accompanying plan NL06919/14 with accompanying target notes in
Appendix 1. The access route onto the working areas transects the least
sensitive habitat. A further access route/gravel path will be created in the
western area of the site (Target Note 2). This plan will be used to confirm the
current operational area, and to define the high risk area with regards
harming GCNs. An ecological clerk of works will be required everyday during
the course of the operations.
Phase 1
Timing
June
Duration of works
1 week
The first phase will be worked in the area shown in drawing NL06919/14. This
will involve the creation of a crushed brick path and fence (Target Note 2).
An ecological clerk is required each day to check the new path route area
prior to creation and will then be declared clear. This area will then be worked
to eliminate the chance of GCN foraging and refuge in these areas.
The plant and equipment involved in carrying out this work will include 1x 40
tonne tracked excavators, 1x compacter, and post pushers.
Phase 2
Timing
July
Duration of works
Ibstock Bricks 1996 Ltd Knutton Quarry - Method Statement
NL06919/Method Statement 5 June 2009
1 week
The second phase involves the removal of the current tiled footpath (Target
Note 1). Please note that the areas to the east and west of the tiled path have
already been worked and do not provide foraging potential for GCNs. The
area between the new path (from phase 1) and the existing worked quarry
area will then be stripped of grassland prior to starting the quarry workings in
the western area of the site (Target Note 3). The grassland will be stripped to
approximately 10-15cm in length and left for 24 hours so that potential GCNs
disperse. The area will then be worked to eliminate foraging potential.
An ecological clerk is required each day to check the area during the removal
of the tiled footpath. A series of hibernacula will be created (overseen by an
ecologist) as shown in drawing NL06919/14 to mitigate any potential loss of
refugia that the tiled path provided. See Appendix 3 for hibernaculum design.
This phase will require 1x 40 tonne tracked excavator, 2x dumper trucks, a
dozer, tractor and grass cutter.
Phase 3
Timing
July/August
Duration of works
2 days
The third phase involves drainage of water bodies 2, 3, 4 and 5. Water will be
taken down over a period of time to allow amphibians safe exit. Vegetation
will also be searched. If GCNs are found, the operation will be stopped and
appropriate action taken in agreement with Natural England. It is proposed
that these ponds be drained over a period of 2 days with a pump and
mechanical filter with an appropriate mesh size that will avoid harm to all
amphibians. Following this operation these areas will be infilled and levelled
to avoid accumulating any further water.
This phase will require a digger and water pump with mechanical filter.
• On site staff will likely include a 4 man operating team for the duration of the
works including the Quarry Manager and Assistant Quarry Manager.
Ibstock Bricks 1996 Ltd Knutton Quarry - Method Statement
NL06919/Method Statement 6 June 2009
• The daily timing of the works will be between 07:30 and 16:30.
• No workings will be undertaken during the night. Newt migration is known to
take place at night. Presently using Natural England guidance it is known that
newts will not migrate in temperatures below 5oc. Because of the lack of
natural refugia on the existing working areas, even when the temperatures
rise consistently above 5oc any migration is likely to occur from one vegetated
area to either a waterbody or to another vegetated area. Once an area is
checked and worked, it will be declared clear as detailed in the 3 phases
above. Any newts found as a result of these hand searches will be reported to
the Quarry manager, recorded and works will not proceed until consultation
and agreement has been made with Natural England.
• All the works will be undertaken in accordance with these written instructions.
The whole works within the mapped disturbed area will not go beyond six
months of this date, and the next phase of workings will not commence
without a new method statement being produced and agreed with Natural
England.
• Wardell Armstrong will undertake a “tool box” talk for the works team
regarding newts at the start of the works. This will involve GCN identification
sheets and a briefing on wildlife legislation and practical mitigation issues.
A summary of potential risks and mitigation measure is summarised in the table
below.
Risk Mitigation
Disturbance/destruction of habitat by site
access
Access transects least sensitive habitat
area
Disturbance/destruction of habitat in
working area
Working confined to sub-optimal habitat
area, daily visual inspection
Encroachment of workings into suitable
habitat/refugia
Works as per defined area, movement
into suitable areas only in agreement
with Natural England
Disruption of nocturnal newt migration on
site
No night working
Disturbance/destruction of habitat by site
development, new working areas.
Habitat surveys and consultation with
Natural England as required
Lack of awareness of wildlife legislation
and site mitigation issues
Toolbox talks for operators
Ibstock Bricks 1996 Ltd Knutton Quarry - Method Statement
NL06919/Method Statement 7 June 2009
This method statement for the avoidance of harm is deemed appropriate protection
for the population around the site. Under these measures the nature conservation
status of any population within the area is not compromised and no offence is being
committed. Under regulation 44 of the Conservation (Natural Habitats&c.)
Regulations 1994 (as amended), a license is required to damage or destroy a
breeding site or resting place or deliberately disturb and affect an animal in such a
way as to affect its ability to survive, breed or reproduce, rear its young and affect its
local distribution. This method of working ensures that no breeding site or resting
place is destroyed and the operation will not affect the ability of a population around
the site to maintain its viability.
References
Langton, T.E.S, Beckett, C.L, Foster, J.P. (2001), Great Crested Newt Conservation
Handbook, Froglife, Halesworth
APPENDIX 1
TARGET NOTES
APPENDIX 1 – TARGET NOTES
TARGET
NOTE
(TN)
FEATURE PHOTOGRAPH OF FEATURE
1
Tiled pathway to be removed
2 Proposed access route and fence
area
3 Proposed grassland area to be
stripped and quarried
APPENDIX 2
WATERBODIES
APPENDIX 2 – WATERBODIES AND HABITAT SUITABILITY AS SESSMENT
Waterbody FEATURE PHOTOGRAPH OF FEATURE
1
A well vegetated reeded pond.
HSI score = 0.65 categorised as
average
2 A shallow pond with suitable
aquatic and emergent
vegetation.
HSI score = 0.68 categorised as
average
3 A shallow pond with suitable
aquatic and emergent
vegetation.
HSI score = 0.68 categorised as
average
4 Shallow recently established
pond.
HSI score = 0.52 categorised as
below average
5 Shallow recently established
pond.
HSI score = 0.52 categorised as
below average
6 Shallow waterbody.
HSI score = 0.52 categorised as
below average
APPENDIX 3
HIBERNACULUM DESIGN
APPENDIX 3- HIBERNACULUM DESIGN
Basic hibernaculum design courtesy of the Great Crested Newt Mitigation Guidelines (2001)
APPENDIX 4
RAPID RISK ASSESSMENT
APPENDIX 4-RAPID RISK ASSESSMENT Instructions for completion of Method Statement template Application tools: (1) "Do I need a licence?" - rapid risk assessment Caveats and limitations This risk assessment tool has been developed as a general guide only, and it is inevitably rather simplistic. It has been generated by examining where impacts occurred in past mitigation projects, alongside recent research on newt ecology. It is not a substitute for a site-specific risk assessment informed by survey. In particular, the following factors are not included for sake of simplicity, though they will often have an important role in determining whether an offence would occur: population size, terrestrial habitat quality, presence of dispersal barriers, timing and duration of works, detailed layout of development in relation to newt resting and dispersal. The following factors could increase the risk of committing an offence: large population size, high pond density, good terrestrial habitat, low pre-existing habitat fragmentation, large development footprint, long construction period. The following factors could decrease the risk: small population size, low pond density, poor terrestrial habitat, substantial pre-existing dispersal barriers, small development footprint, short construction period. You should bear these mitigating and aggravating factors in mind when considering risk.
It is critical that, even if you decide not to apply for a licence, you ensure that any development takes account of potential newt dispersal. Where great crested newts are present, landuse in that area must ensure there is adequate connectivity. Retaining and improving connectivity will often involve no licensable activities.
Component Likely effect (select one for each
component; select the most harmful option if more than one is likely; lists are in order of harm, top to bottom)
Notional offence probability score
Great crested newt breeding pond(s) No effect 0
Land within 100m of any breeding pond(s)
No effect 0
Land 100-250m from any breeding pond(s)
0.1 - 0.5 ha lost or damaged 0.1
Land >250m from any breeding pond(s) 1 - 5 ha lost or damaged 0.04
Individual great crested newts No effect 0 Maximum: 0.1
Rapid risk assessment result: GREEN: OFFENCE HIGHLY UNLIKELY
Guidance on risk assessment result categories "Green: offence highly unlikely" indicates that the development activities are of such a type, scale and location that it is highly unlikely any offence would be committed should the development proceed. Therefore, no licence would be required. However, bearing in mind that this is a generic assessment, you should carefully examine your specific plans to ensure this is a sound conclusion, and take precautions (see Non-licensed avoidance measures tool) to avoid offences if appropriate. It is likely that any residual offences would have negligible impact on conservation status, and enforcement of such breaches is unlikely to be in the public interest.
"Amber: offence likely" indicates that the development activities are of such a type, scale and location that an offence is likely. In this case, the best option is to redesign the development (location, layout, methods, duration or timing; see Non-licensed avoidance measures tool) so that the effects are minimised. You can do this and then re-run the risk assessment to test whether the result changes, or preferably run your own detailed site-specific assessment. Bear in mind that this generic risk assessment will over- or under-estimate some risks because it cannot take into account site-specific details, as mentioned in caveats above. In particular, the exact location of the development in relation to resting places, dispersal areas and barriers
should be critically examined. Once you have amended the scheme you will need to decide if a licence is required; this should be done if on balance you believe an offence is reasonably likely.
"Red: offence highly likely" indicates that the development activities are of such a type, scale and location that an offence is highly likely. In this case, you should attempt to re-design the development location, layout, timing, methods or duration in order to avoid impacts (see Non-licensed avoidance measures tool), and re-run the risk assessment. You may also wish to run a site-specific risk assessment to check that this is a valid conclusion. If you cannot avoid the offences, then a licence should be applied for.
APPENDIX 5
GCN SURVEY RESULTS 2009
DRAWINGS