In Practice Mitigation - CIEEM

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In Practice Mitigation - CIEEM
Number 62 • December 2008

       In Practice
       Bulletin of the Institute of Ecology and Environmental Management

Mitigation
In Practice Mitigation - CIEEM
INFORMATION

  In Practice No. 62, Dec 2008. ISSN 1754-4882                        Institute of Ecology and Environmental Management
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In Practice Mitigation - CIEEM
EDITORIAL AND CONTENTS

Editorial                                                                                             Contents
                                                                                                      Information                                2

B    y the time you read this editorial the Institute will have
     had a thorough discussion about mitigation at its annual
conference in Glasgow. This issue of In Practice concentrates on
                                                                                                      Editorial and Contents
                                                                                                      Mitigation Banking: Securing No Net
                                                                                                      Loss for Biodiversity?
                                                                                                                                                  3
                                                                                                                                                  4-6

the subject, which should be at the heart of our work as ecologists                                   William Latimer CEnv MIEEM and David
and environmental managers. The conference will have had the                                          Hill CEnv FIEEM
benefit of reviewing a number of case studies, and discussing their                                   Large Scale Mitigation: A Case Study        7 - 10
outcomes. I have to anticipate what the outcomes may be, as I write                                   Using Water Voles
                                                                                                      Helen Markwell CEnv MIEEM
this editorial, the day before the Conference starts.
                                                                                                      Site Mitigation for Invertebrates           11 - 12
I think we may hear calls for change in the way we go about mitigation and the way that               Alex Ramsay MIEEM
decision makers and project managers alike rely on mitigation. I use ‘mitigation’ here in
                                                                                                      Mitigating Urban Pressures on Natura        13 - 16
the broader sense, commonly used in environmental assessment, to cover avoidance,                     2000 Heathlands in Dorset
cancellation and reduction measures, rather than the narrower meaning of ‘mitigation’, only           Heather Tidball MIEEM and Phil Sterling
as the action of reducing the severity or seriousness of something. I argue that we should
take these measures into account at every stage of the decision making process. However,              Can Non-Intrusive Geo-Physical              17 - 20
                                                                                                      Techniques Assist in Mapping Setts of
we should distinguish between them and ‘compensatory measures’, which should be                       the Eurasian Badger
considered only after the decision in principle has been taken to proceed with a damaging             P O’Donoghue CEnv MIEEM, L Dolan, P D
change.                                                                                               Dansie MIEEM and I Sharkey
I am advocating a more structured approach to mitigation and compensatory actions,                    Understanding the Habitats Directive:       21 - 23
following a sequence, down a ladder of counter-acting measures; where we give priority                Appropriate Assessment - What is it and
to avoidance, then cancellation, then reduction measures, before considering seven types              what is ‘appropriate’?
                                                                                                      Roger Morris CEnv FIEEM
of compensatory measures. These are, again in the order I suggest they should normally
be prioritised: in situ repair; like-for-like habitat or species restoration; like-for-like habitat   Survey Guidance for Assessing Bat           24 - 27
creation; alternative habitat or species restoration; alternative habitat creation; new               Activity at Proposed On-Shore Wind
protection measures and translocation. All of the measures are not, of course, available in           Farms
                                                                                                      James Cook MIEEM, Andrew McCarthy
every case, and are not mutually exclusive. They should be used individually or in various            CEnv MIEEM, Stephen Holloway CEnv
permutations to deliver the most reliable and most complete recompense for the adverse                MIEEM and Gary Oliver CEnv MIEEM
effects in the longest term.
                                                                                                      Neglected Biodiversity: Mosses,             28 - 31
Requiring mitigation is routine, but compensatory measures are more difficult to secure               Liverworts and Ecological Impact
in most regulatory regimes. Furthermore, although government policy (e.g. PPS9) urges                 Assessment
the spatial planning system to conserve and enhance biodiversity resources, development               Des A Callaghan MIEEM
management and other regulatory processes are not well designed to deliver net benefits.              Restoration Network Ireland                 32
There is scope for a bigger contribution, through regional and local spatial planning, to the         Catherine A Farell MIEEM
planning and delivery of both compensatory measures and net benefits, at greater-than-
                                                                                                      Autumn Conference Report                    33
project- level scale. I also think that there is a positive role for ‘habitat banking’ as a form of
mitigation, or more often, a compensatory measure, when done with care and integrity and              The IEEM Medal: Citation for Professor      34
when properly accounted for.                                                                          Charles Gimingham
                                                                                                      Pat Rae CEnv MIEEM and Una Urquhart
I think we should also place more weight on the need for, and value of, monitoring. All too           CEnv FIEEM
often projects offer mitigation or compensation measures, decision makers accept them, or             Best Practice Awards 2008                   35 - 36
impose alternative measures, the project is implemented and we all assume the measures
were properly applied and fully effective. There are some good examples of diligent                   Ecological Skills Gap Project               37 - 38
monitoring and adjustment of measures in response to actual, as opposed to predicted,                 IUCN World Conservation Congress            39
effects. These should become the norm not the exception. A monitoring and review
procedure should be imposed as a requirement (by way of enforceable conditions) in every              New Fellows                                 40
case where EIA has been undertaken, and potential harm identified.                                    Tony Bradshaw Obituary                      41
                                                                                                      David Parker CEnv MIEEM
David Tyldesley MIEEM                                                                                 Institute News                              42
Principal, David Tyldesley and Associates
                                                                                                      Geographic Section News                     43 - 45
                                                                                                      Partnership News                            46
  Correction                                                                                          In the Journals                             47 - 50
  In the EcIA Questions and Answers article, in In Practice 61, the third last                        Recent Publications                         51
  paragragh on page 27 should make reference to the ‘NERC Act Section 41 list’                        News in Brief                               52 - 53
  rather than to the ‘CRoW Act Section 74 list’. This correction was made by the
  author, but unfortunately was not included in the final print version. IEEM would like              Tauro-Scatology                             54
  to apologise for any inconvenience caused.                                                          New and Prospective Members                 55
                                                                                                      Diary                                       56

                                                                                                      Cover image: Professor Charles Gimingham
   Merry Christmas and Happy New Year!                                                                (right) receives the IEEM Medal from Mr Michael
                                                                                                      Russell MSP, Environment Minister, Scottish
      Everyone here at IEEM would like to wish you a                                                  Government
     wonderful Christmas and a prosperous New Year!
                                                                                                      Artwork on the cover will normally illustrate an
                                                                                                      article in, or the theme of, the current issue. The
                                                                                                      Editor would be pleased to consider any such
                                                                                                      material from authors.
In Practice Mitigation - CIEEM
MITIGATION BANKING

    Mitigation Banking: Securing No
    Net Loss for Biodiversity?
    William Latimer CEnv MIEEM and David Hill CEnv FIEEM**
    * Associate Director, Faber Maunsell
    ** Chairman, The Environment Bank Ltd

    Introduction                                  habitat creation and management. Credits
                                                  for land set aside for mitigation banking
                                                                                                  planning authorities in its Planning Policy
                                                                                                  Statement No. 9 takes this principle

    E   nvironmental advisors and                 can increase in value as the ecosystem          further, stating (para. 1.vi) ‘Where a
                                                  develops or populations increase to a           planning decision would result in significant
        planners are frequently
                                                  stable and self-sustaining level. In the USA,   harm to biodiversity and geological
    confronted with uncertainties                 the scheme now encompasses broader              interests which cannot be prevented or
    over ecological mitigation,                   habitat and species banks with around           adequately mitigated against, appropriate
    whether the proposed                          150 institutions administering the banks        compensation measures should be
    compensation is adequate and                  or providing ecological and conservation        sought. If that significant harm cannot be
    how it will function over time.               expertise.                                      prevented, adequately mitigated against, or
    The advantages of acquiring and                                                               compensated for, then planning permission
                                                  Mitigation banks have inverted conservation
                                                                                                  should be refused’.
    retaining land in advance for                 values: where wildlife conservation in
    ecological mitigation required                the development context was formerly            The focus is therefore shifting from
    by subsequent development has                 regarded as a financial drain and a             site-based conservation of habitats and
    been demonstrated primarily in                liability, the mitigation banking system        species, to the maintenance of biodiversity
                                                  has transformed protected species and           and functioning ecosystems as emphasised
    the USA where such Mitigation                 habitats into assets.                           in the Government’s 2005 Sustainable
    Banking (or Biodiversity                                                                      Development Strategy (Ch. 5) which
    Offsets, ten Kate, Bishop and                 The results of mitigation banking from
                                                                                                  recognises the importance of biodiversity
    Bayon 2004), pioneered for the                the US experience appear to be broadly
                                                                                                  to self-maintaining natural systems and
                                                  positive as a large number of successful
    conservation of wetlands over 20              conservation schemes have been achieved.
                                                                                                  “ecosystem services”. While the converging
    years ago (Crooks and Ledoux                                                                  policies on biodiversity and sustainability
                                                  There have been some failures attributed
    2000), is now established in the                                                              might be considered fairly straightforward,
                                                  principally to the lack of regulatory
                                                                                                  there remain considerable risks to
    regulatory framework.                         supervision, highlighting the need for
                                                                                                  sustainable development under the current
                                                  effective enforcement and monitoring.
    Essentially, the mitigation bank is                                                           planning system.
    established by acquiring land for
    the creation, or enhancement and              Mitigation Banking: its                         Section 106 ‘Agreements’ of the 1990
                                                                                                  Town and Country Planning Act allow
    management, of habitats or ecosystems
    for a particular wildlife or environmental
                                                  Application in the UK                           the applicant to enter into legally binding
                                                                                                  agreements to secure mechanisms to
    resource. The asset is valued in terms        The Legislative and Planning                    offset adverse environmental effects.
    of credits and the better the condition
                                                  Framework                                       While this adds power and flexibility to the
    of the land in terms of its environmental
                                                                                                  planning process there are a number of
    objectives, the greater its value. Credits    The Habitats Directive, enacted in the          notable disadvantages:
    may be purchased, held, and traded in a       UK by the 1994 Conservation (Natural
    process analogous to carbon trading.          Habitats, &c.) Regulations (Habitats            •    agreements with the local authority
                                                  Regulations), requires the protection,               usually predicate that the works
    Land may be acquired by financial
                                                  at a ‘favourable conservation status’ of             or mitigation feature operate at a
    institutions, businesses, land-owners or
                                                  habitats and species deemed to be rare               local level, often adjacent to the
    investors and managed to maximise its
                                                  or vulnerable at an international level. This        development, which may not be an
    biodiversity or environmental capital.
                                                  principle of no-net-loss applies certainly to        optimal strategy;
    Credits may then be sold as the land comes
                                                  the network of European protected sites
    into appropriate and stable condition                                                         •    mitigation is often initiated at the same
                                                  but also to qualifying species that may
    for which the asset was purchased. The                                                             time or even after the development
                                                  obtain resources, at least occasionally,
    purchase of credits does not in any way                                                            has taken place leading to a temporal
                                                  outside protected sites. Examples of the
    obviate adherence to existing legislation                                                          loss of ecological resources;
                                                  latter might include birds from a protected
    regarding environmental protection, natural
                                                  estuary or marshland that may also roost        •    timescales for ecological succession
    resource or wildlife conservation, but may
                                                  or graze outside a Special Protection                leading to habitat stability are
    be used where impacts are deemed to be
                                                  Area (SPA) or bats from a Special Area               therefore often too short; and
    unavoidable. Along with the reduction in
                                                  of Conservation (SAC) that forage along
    ecological risk that comes to the developer                                                   •    overarching mitigation for combined
                                                  adjacent hedgerows. Where developments
    with the acquisition of credits also comes                                                         developments, which may be
                                                  outside protected sites may affect the
    a reduction in financial risk: credits for                                                         temporally as well as spatially
                                                  interest within, the statutory regulator will
    species or a functioning ecological system                                                         separated is rarely sought, unless
                                                  require an ‘appropriate assessment’ to be
    can be more accurately costed.                                                                     part of an appropriate assessment
                                                  undertaken and, if needed, mitigation to
                                                  ensure no net loss.                                  under Para. 48(1) of the Habitats
    The monetary value of the credits is
                                                                                                       Regulations.
    related to the costs of land acquisition,
                                                  Recent UK government guidance to

4 In Practice December 2008
In Practice Mitigation - CIEEM
MITIGATION BANKING

In addition, there can be a substantial gap     Location                                        habitats undergo the correct development
between what is promised by developers                                                          period are therefore:
                                                It is often appropriate to re-create
through planning obligations and what
                                                habitats in the same ecological area            •    the longer the period of development,
is delivered, due to the inadequacy of
                                                (e.g. English Nature’s Natural Areas or              the greater the likelihood that some
subsequent monitoring and enforcement.
                                                Joint Character Areas) to obtain the                 measure of habitat stability is
Statutory Requirements and                      best like-for-like replacement. It may               achieved, though this is often reliant
Ecological Principles                           also be necessary to make even finer                 on the correct management regime;
                                                discriminations based on microclimatic
Like-for-Like Mitigation                                                                        •    with appropriate monitoring, and
                                                factors or soil types. Adjacent
                                                                                                     remedial action where needed, the risk
The no-net-loss principle dictates that         compensation for housing or employment
                                                                                                     of failure declines over time;
where mitigation is obtained by means of        developments provides a visible
credits, these should have parity with the      and accessible amenity and a public             •    the habitat is therefore better able to
losses due to development, both in keeping      perception of replacement of valued                  fulfil its intended biodiversity function;
with the scale of loss and the nature of the    natural resources.                                   and
loss. The financial analogy would be that       However, in some cases, the success             •    the value of the credits for the habitat
the credits are of the appropriate currency     of mitigation may be compromised by                  increase over time, in keeping with
and monetary value. Thus a pond with            siting the area in close proximity to                greater stability, habitat quality and
protected great crested newts necessarily       the development. These would include                 the assurance that the habitat will fulfil
lost to development would require               mitigation areas for species that are                its objectives.
replacement habitats for that species,          sensitive to anthropogenic disturbances
chalk grassland re-created in mitigation        such as visual disturbance from walkers,        The ability to produce mature and stable
for losses to development should be of a        noise, fires, disturbance or predation          habitats is perhaps the key advantage of
similar plant community.                        from domestic pets. The degradation             the mitigation banking system, as long
                                                of lowland heaths as an apparent result         as the bank is correctly regulated and
Critical Natural Capital or Non-                                                                monitored.
Replaceable Habitats                            of proximate housing developments is
                                                well documented (Liley and Clarke 2002,         Mitigation for Habitats and
Mitigation banks are limited to those           Underhill-Day 2005) and has led to the
habitats that can be created or manipulated
                                                                                                Species without Statutory
                                                development of local spatial planning
to increase their conservation value in         policies (English Nature 2005). On-site
                                                                                                Protection
terms of their ecological function, habitats,   or adjacent mitigation may also not be          For habitats and species without direct
or species. The system cannot deal with         appropriate for busy transport corridors        statutory protection, there is an increasing
losses to habitats that are deemed, in          with high levels of noise, collision risk, or   emphasis on similar compensation being
realistic timescales, to be irreplaceable.      poor air quality. In such cases it would be     provided for any losses of biodiversity
Such critical natural capital (e.g. ancient     necessary to seek alternative sites well        due to development (PPS9). Species and
woodlands and raised mires) cannot be           beyond the range of expected impact.            habitats requiring conservation action are
traded, along with other habitats that may      Climate change adds a challenging new           listed under Section 74 of the 2000 CRoW
be very difficult to replicate because of       dimension to this debate. The value             Act (reinforced by Section 40 of the NERC
environmental complexity (e.g. habitat          of habitat banking is that it provides          Act) and are generally subjects of the UK
mosaics on complex geology) or intricate        a mechanism for the delivery of this            Biodiversity Action Plans (BAP). In addition
relationships between physical and              resource and this principle can be              to BAP and Section 74 habitats and
biological factors (e.g. hibernation caves      extended to the provision of the core           species, the Red and Amber lists of bird
for bats).                                      sites and green corridors comprising            species (JNCC 2002) and Red Data books
Spatial Relationships between                   ecological networks.                            point to additional species for conservation
Development Areas and Mitigation                                                                action.
                                                Timescales for Habitat Development
Sites                                           and Ecological Succession                       While mitigation banks could be developed
Size                                                                                            to permit compensation for BAP species
                                                Where the mitigation bank can be created
                                                                                                and habitats lost to development, it would
The creation of large reserve areas             well in advance of its requirement in
                                                                                                clearly be inappropriate for gains within the
for wildlife is often more successful in        compensation for losses to development,
                                                                                                banks to be counted as progress towards
producing stable and self sustaining            the uncertainty as to the success of
                                                                                                BAP targets for key habitats or species
populations of the target species and           mitigation is reduced as the process of
                                                                                                and the development of mitigation banks
habitats than small isolated sites,             ecological succession, and management
                                                                                                should not, in any way, reduce the effort
vulnerable to random catastrophic factors       as needed, render the habitat better
                                                                                                to promote the favourable conservation
or the deleterious effects of inbreeding.       suited for its purpose. Timescales for
                                                                                                status of these species. Nevertheless,
Small sites can require a disproportionate      habitat creation vary according to the
                                                                                                in some cases the presence of core
effort of management in order to maintain       type of habitat. Ponds may be available
                                                                                                populations within the banks, developed
their ecological interest, e.g. the control     for colonisation by protected amphibian
                                                                                                to compensate for losses elsewhere, may
of invasive species on small heathland          or aquatic insect populations within one
                                                                                                make a temporal, local contribution to
patches, and mitigation costs for separate      or two years; species-rich grasslands
                                                                                                species recovery outside the banks where
developments can also be higher where           may take 4-5 years, with appropriate
                                                                                                favourable habitats exist.
administration and management are               management, to stabilise, while woodlands
replicated both spatially and over time for     will clearly take many decades to mature.       Development in Farmland, a Case in
the same target habitat or species.             The principle that newly created habitats       Point
                                                should be in place in appropriate condition
There is therefore now considerable             for their compensatory purpose is noted         With increasing development on greenfield
interest in developing large ‘reserves’ at a    in Paragraph 30 of the UK Government’s          sites, pressures continue on communities
landscape scale, e.g. the various initiatives   Circular on Biodiversity and Geological         of the mosaic of farmland habitats,
for the restoration of extensive reedbeds       Conservation, but this can be difficult to      already much depleted by intensive
in the Fens, habitats or biotopes sized to      achieve under the current planning regime.      farming. The concern over the loss of
support sustainable populations of key,                                                         species characteristic of arable farmland
‘flagship’ species.                             The important advantages in ensuring that       is highlighted in plans within the UK BAPs

                                                                                                                 In Practice December 2008 5
In Practice Mitigation - CIEEM
MITIGATION BANKING

    and summarized in chapter 4 of the               comprising sustainable rural communities          biodiversity. Journal of Applied Ecology 44:
    Government’s Biodiversity Strategy for           where economic, social and environmental          6-12.
    England (Defra 2002a). In view of this,          issues are all taken into account. Where
                                                                                                       Crooks S and Ledoux L (2000) Mitigation
    the statutory conservation agencies              compensation for the loss of farmland
                                                                                                       banking: potential applications in the UK.
    and planning authorities are likely, in          biodiversity is required, mitigation banking
                                                                                                       Environmental and Waste Management 3(4):
    accordance with the requirements of PPS          could transfer some of this commitment,
                                                                                                       1-8.
    9, to seek appropriate mitigation for such       currently funded from the public purse
    losses due to development. The advance           through piecemeal Environmental                   Defra (2002a) Working with the Grain of
    acquisition of biodiversity credits in species   Stewardships, to the developer.                   Nature: A Biodiversity Strategy for England.
    and habitats characteristic of farmland
                                                     The system would benefit extensive                Defra (2002b) Strategy for Sustainable
    habitats appears to be increasingly tenable
                                                     landscape initiatives where progress and          Farming and Food - Facing the Future.
    given current concerns over landscape
                                                     sustainable management may be limited             www.defra.gov.uk/farm/policy/sustain/
    conservation, intensive agriculture, food
                                                     by the uncertainties and unpredictability         newstrategy/strategy/strategy.pdf
    quality and the rural economy.
                                                     of piecemeal funding (Wall 2006). As
    Whole Landscape Conservation                     noted above, such initiatives could also be       Defra (2004) The Rural Strategy. www.defra.
                                                     spatially designed to deliver the ecological      gov.uk/rural/strategy/default.htm
    By supporting a farming system geared
                                                     networks needed to enable the dispersion          Ecosystem Marketplace. See:
    towards conserving declining animal
                                                     of species across the wider landscape,            ecosystemmarketplace.com/index.php
    and plant species of increasingly rare
                                                     from local, through regional, even to
    farming landscapes, other gains, in                                                                English Nature. Natural Areas. www.english-
                                                     national dimensions, providing one of the
    addition to enhanced biodiversity, may                                                             nature.org.uk/science/natural/NA_search.
                                                     pre-requisites for mitigating the effects of
    arise. There is some evidence that                                                                 asp
                                                     climate change.
    extensive and organic farming methods
    not only produce increasingly sought-                                                              English Nature (2005) Thames Basin Heaths.
                                                     Delivery of the Mitigation Banking
    after products with a high market value                                                            Pulling together for access, conservation and
                                                     System                                            development. A new approach to housing
    but also support a landscape that offers
    sustainable production (Bullock et al.           With no formal system in place for a              allocations and nature conservation (see:
    2007) with a higher biodiversity than            nationwide approach to mitigation banking,        www.english-nature.org.uk/about/teams/
    modern conventional intensive farming            the approach at present would rely on             team_photo/Thames1.pdf). English Nature
    (New Scientist 2004). Organic farming            partnerships between financial institutions       Thames and Chilterns Team.
    is now seen as a viable sector of the UK         and land management or conservation               Liley D and Clarke R T (2002) Urban
    agriculture industry with acknowledged           agencies. There is, however, nothing              development adjacent to heathland sites
    benefits for sustainability, biodiversity and    to prevent developers from acquiring              in Dorset: the effect on the density and
    the rural economy (Defra 2002b, 2004)            additional land and managing this in order        settlement patterns of Annex I bird species.
    though without farm diversification, the         to provide for future mitigation needs.           English Nature Research Report No. 463.
    economics can, at present, be borderline.        However, we believe such acquisition, or          Natural England, Peterborough, UK.
                                                     establishment of land is more appropriately
    Payments for biodiversity credits held by        done through a third party working                New Scientist (2004) Organic Farming
    landowners who conserved ecological              independently of the developer and                boosts Biodiversity. 11 October. www.
    assets upon their land could assist in           relieving him from the specialist work of         newscientist.com/article.ns?id=dn6496
    keeping land-owners or tenant farmers            ecological mitigation design, construction
    and their employees working on the land,                                                           ten Kate K, Bishop J and Bayon R (2004)
                                                     and management.
    thereby assisting the rural economy.                                                               Biodiversity offsets: Views, experience and
    Management for sustainable food                  Regulatory supervision, as with the               the business case. IUCN, Gland, Switzerland
    production and biodiversity often requires       carbon trading scheme administered by             and Cambridge, UK and Insight Investment,
    a higher level of skilled application whether    the Environment Agency, would be most             London, UK. www.iucn.org/themes/
    applied to the management of rotational          properly undertaken by the appropriate            business/Biodiversity%20Offsets/ten%20ka
    farming, sound and sympathetic animal            statutory conservation agencies, though           te%20et%20al%20paper.pdf
    husbandry, or the management of habitats         it is highly likely, and clearly desirable both
                                                                                                       Underhill-Day J C (2005) A literature review
    and ecosystems.                                  for the regulators and the development
                                                                                                       of urban effects on lowland heaths and their
                                                     industry, that these agencies would require
    Landscapes farmed in part for biodiversity                                                         wildlife. English Nature Research Report No.
                                                     that managers of mitigation banks and
    objectives have a higher visual appeal                                                             623. Natural England, Peterborough, UK.
                                                     developer seeking credits should obtain the
    than those under intensive agriculture           assistance of professional ecologists.            The UK Government (2005) Sustainable
    which often result in rather forbidding and                                                        Development Strategy; Securing the Future.
    constrained environments for ready public        There is a real opportunity to obtain
                                                                                                       Defra (see: www.sustainable-development.
    access. Bio-diverse landscapes would             much greater gains for biodiversity and
                                                                                                       gov.uk/publications/uk-strategy/index.htm)
    have an enhanced high value for public           ecosystem function, at varying landscape
    enjoyment and, linked to public goods and        scales through the implementation of a            Wall T (2006) Inching towards conservation
    services, enhancements of ecological             mechanism based on mitigation banking.            at the landscape scale. Conservation Land
    patches and networks on farmland,                The required investment in land and skills        Management 4: 2, 4-7. English Nature.
    delivered through mitigation banking, could      should find favour in the current economic
    also provide more areas for people to visit,     climate and the re-visiting of Keynesian
    alleviating pressure on vulnerable protected     economics. We propose that such a                 This article is based on Mitigation Banking:
    sites, assisting in progress towards             mechanism is enshrined within the planning        Securing No Net Loss to Biodiversity? A UK
    government targets for restoring the Sites       process in the UK.                                Perspective by William Latimer and David
    of Special Scientific Interest (SSSI) network                                                      Hill in Planning, Practice & Research, Vol.
    to favourable condition.                         References                                        22, No. 2, pp. 155–175, May 2007.
    The Rural Strategy (Defra 2004) presents         Bullock J M, Pywell R F and Walker K              Correspondence:
    a government vision of a living, working,        J (2007) Long-term enhancement of                 william.latimer@fabermaunsell.com
    protected and vibrant countryside                agricultural production by restoration of         dhill@davidhillecology.com

6 In Practice December 2008
In Practice Mitigation - CIEEM
WATER VOLE MITIGATION

Large Scale Mitigation: A Case
Study Using Water Voles
Helen Markwell CEnv MIEEM
Senior Environmental Scientist, Halcrow Group Ltd

Summary                                                              the protection
                                                                     afforded by        Map of rivers in the BFAP project area

L   arge scale development projects can pose                         the Project’s
                                                                     flood
    significant challenges when implementing
                                                                     defences.
protected species mitigation, but also provide
opportunities for developing novel solutions and                     In order to
best practice methodologies. A prime example                         deliver the
                                                                     works, a large
is the issue of water vole mitigation required                       team of civil
for the Broadland Flood Alleviation Project                          engineers,
(BFAP). Achievements to date have included the                       environmental
development of an effective mitigation technique,                    scientists,
using water draw down as a displacement tool,                        and project
and a rapid assessment survey methodology.                           managers
Post works monitoring indicates mitigation is a                      are employed
                                                                     by the client,
success and Broadland continues to provide a UK                      design
stronghold for the species.                                          consultant
                                                                     and works
Project Background                                                   contractor,
                                                                     operating from
The BFAP is a long-term project providing a range of flood           a single main
defence improvements, maintenance and emergency response             office base.
services within the tidal areas of the Rivers Yare, Bure, Waveney    An extensive
and their tributaries. The contract for the Public Private           network of
Partnership Programme was awarded in 2001, and the 20                site personnel
year programme of works is being delivered on behalf of, and         implement the construction works. All baseline ecological
in partnership with, the Environment Agency (EA). The project        surveys are either undertaken in-house or are sub-contracted
is the first of its kind to provide flood defences on this scale;    to relevant specialists. Impact assessments, mitigation
more than 240 km of floodbanks protect in excess of 21,000           prescription, on-site environmental (clerk of works) supervision
hectares of Broadland.                                               and strategic post-works monitoring are all undertaken by
Situated in East Anglia, Broadland is one of the finest areas        members of the Project’s Environment Team.
of wetland in Britain. It includes open water, the Broads
themselves, and the low-lying marshland surrounding the tidal        Nature of Works
river reaches. The rivers reach the sea at Great Yarmouth, and
together with the Broads comprise a major inland navigation.         Under the BFAP contract the main flood defence improvement
                                                                     works are to be completed by 2012. As a result many tens of
The Broads, a unique and environmentally sensitive area, has         kilometres of floodbanks may be worked each year. The works
a status equivalent to a National Park, and is home to plants        are based on the use of sustainable techniques, and utilise
and animals found in few other places in Britain, many of which      locally sourced material for building new and strengthening/
are protected under UK and European law. The Project area            crest raising existing floodbanks wherever possible.
contains 28 Sites of Special Scientific Interest (SSSI), amounting
to more than 7,000 hectares in total, the majority of which          The zones and habitats directly affected within the works
benefit from protection under European law either as Special         corridor comprise the rond (area of reed/saltmarsh located
Protection Areas (SPAs) or Special Areas of Conservation             between the main river and the floodbank); the floodbank itself;
(SACs). Two Ramsar sites are also located within the Project         the folding (area of land between the floodbank and the soke
boundary. Conservation bodies own or manage some of                  dyke); and the soke dyke. The soke dyke runs parallel to the
the sites, but most of Broadland is productive farmland and          floodbank and is the traditional source of local material for
much of the land is now used for traditional summer livestock        building and maintaining the flood embankments.
grazing. Many of the biodiversity features of the area rely on       The construction works involve removal of vegetation and large-

                  Habitats schematic of works corridor

                                                                                                            In Practice December 2008 7
In Practice Mitigation - CIEEM
WATER VOLE MITIGATION

                                                 scale earthworks,             of displacement techniques, whereby habitat in the working
                                                 including the need            corridor is rendered ‘unsuitable’ for water voles, to encourage
                                                 to in-fill sections           them to move to nearby alternatives. Prior to 2007, vegetation
                                                 of redundant dyke.            cutting comprised the main method of habitat manipulation
                                                 Furthermore the               used. Because of concerns about the effectiveness of
                                                 timing of works (April        vegetation cutting alone as a displacement technique (e.g. Dean
                                                 to October to benefit         2003), trapping was used as an additional method to ensure
                                                 from suitable ground          animals had left the area subject to mitigation, whether fresh
                                                 conditions) means that        field signs were recorded in the area or not.
Example of pre works soke dyke habitat           impacts on habitat
                                                                               Due to the scale of the mitigation required, certain aspects of
                                                 and associated plant
                                                                               recommended ‘best practice’ (Strachan and Moorhouse 2006)
                                                 and animal life can
                                                                               are not routinely implemented as part of the BFAP:
       be considerable, indeed unacceptable, without appropriate
       mitigation being taken to avoid or reduce them.                         •   Individual burrow entrances are not marked. Capture of
                                                                                   animals post cutting indicates burrow entrances are not
        Water Voles                                                                generally blocked.
                                                                               •   Vegetation is neither strimmed off to bare earth nor raked
        The catastrophic decline of the UK water vole Arvicola terrestris
                                                                                   and removed, but mainly cut using excavator mounted
        population during the 1980s and 1990s is well documented
                                                                                   flails.
        (e.g. Strachan and Moorhouse 2006). Populations have suffered
        primarily as a result of habitat loss and fragmentation, and           •   ‘Soft release’ methods are not used for relocated animals.
        predation by feral American mink Mustela vison. Measures
        to address this decline culminated in April 2008 when the              •   Fencing is not used due to cost, maintenance and waste
        species was afforded full legal protection under the Wildlife              issues.
        and Countryside Act, 1981 (as amended). One of the main                •   Mitigation is undertaken from spring through to early
        consequences for development works resulting from the update               autumn.
        to the legislation is that trapping of animals as part of mitigation
        now requires a license from Natural England.                           In 2006, the first year when large scale mitigation was required
                                                                               as part of the BFAP, more than 470 animals were captured
        Within the UK East Anglia is considered a stronghold for water         from more than 13 km of soke dyke habitat despite vegetation
        vole, and increased recording effort since 1999 indicates that         cutting being implemented and maintained. Animals were
        they remain widespread in Norfolk, with density in the Broadland       relocated to alternative suitable nearby dyke habitats.
        area being the highest or one of the highest in Britain (Henson
        2001). Habitats in Broadland which support large, apparently           The significant number of animals caught during 2006
        robust populations include reedbeds, the extensive grazing             prompted an internal review of mitigation. Concerns included
        marsh dyke systems, and in the upper stretches of tidal rivers         the effectiveness of vegetation removal alone in achieving
        reeded ronds. As part of the wider grazing marsh dyke system           displacement as part of large scale mitigation, and potential
        soke dykes often provide important water vole habitat.                 welfare implications for the high numbers of animals caught.
                                                                               The review resulted in a modification of the approach to
                                                                               mitigation, most notably a concerted effort was applied to
        Mitigation of Impacts                                                  achieve maintained water draw down in combination with
        Whilst the improvement works require major earthworks,                 vegetation removal. Draw down is achieved by bunding discrete
        including the in-filling of lengths of soke dyke used by water         sections of dyke and using diesel pumps to remove the water.
        voles, they are fundamentally important for the protection             This technique was applied to more than 16 km of dyke in 2007.
        of the wildlife value of the wider marshes from inundation by          During 2007 an undergraduate research project used radio
        river water that is brackish and/or eutrophic. The floodbank           collars and Passive Integrated Transponder (PIT) tracking to
        corridor habitat (including the soke dyke) is always re-instated       monitor the reaction of individual water voles to mitigation
        as part of the works, and scheme implementation provides               implementation. Mitigation comprised vegetation cutting,
        the opportunity to improve habitats otherwise undergoing               repeated on an as required basis, and at least two weeks
        succession.                                                            maintained water draw down. The project was undertaken by
        As one of many protected species present within the Project            Ben Raybould, a student from the University of East Anglia, with
        area, water voles are a material consideration for design and          assistance in the use of PIT tags and radio collars provided by
        construction. Whilst they have always been present within the          Merryl Gelling, a WildCRU researcher from the University of
        BFAP since its commencement in 2001, the numbers found                 Oxford. The research was funded by the Project and the EA,
        within the working corridor in 2006 and 2007 were exceptional,         and was based on a SSSI owned and managed by the Royal
        with more than 30 km of soke dyke subject to mitigation for            Society for the Protection of Birds (RSPB) adjacent to the River
        water voles in those two years alone. Baseline surveys indicate        Yare. The marshes of the site are subject to moderate intensity
        this will continue to be the case for the remaining works.             grazing, and have an extensive water vole population present
                                                                               across parts of the site. As such the site provides a comparable
        The large scale and longevity of the Project, together with a          standard for much of the BFAP project area.
        Project dedicated Environment Team, affords opportunities with
        regard to research and development of survey and mitigation            Although based on a small sample size, the research
        techniques. The main outcomes related to water voles are               demonstrated that
        summarised below.                                                      a proportion of
                                                                                                      Water vole mitigation: vegetation removal
                                                                               the resident water
                                                                                                      and dewatering of soke dyke
                                                                               vole population
        Displacement: Vegetation Cutting                                       was displaced to
        and Water Draw Down                                                    nearby alternative
                                                                               habitat (Raybould
        Because of the extensive dyke system adjacent to the works             2008). Of the 30
        corridor, mitigation for water voles mainly comprises the use          PIT tagged animals

   8 In Practice December 2008
In Practice Mitigation - CIEEM
WATER VOLE MITIGATION

Water vole awaiting radio-
collaring                                                                                          Example of soke dyke habitat one year after
                                    monitored along a 1700 m length        Monitoring              works completion
                                    of soke dyke, 10 of which were         indicates that,
                                    radio collared, nine animals were      in order to be
                                    confirmed to have dispersed to         considered
                                    nearby dykes through radio tracking    successful, the
                                    and recaptures. Two animals were       mitigation methods
                                    trapped and actively relocated to      must include:
                                    alternative nearby habitat within
                                                                           •   thorough
                                    the marshes, one of which was
                                                                               vegetation
                                    subsequently recaptured at the
                                                                               cutting,
                                    release site a few months later. Two
                                                                               repeated on
                                    animals were known to have died
                                                                               an as required
                                    prior to mitigation commencing,
                                                                               basis;
      found by their radio collars. The fate of the remaining animals
      was unknown, although at least one radio collar was presumed         •   maintained water draw down, in conjunction with vegetation
      to have been removed from the site by a predator, as its signal          removal, for a period of at least two weeks; and
      was lost entirely during the monitoring.
                                                                           •   the presence/provision of suitable alternative habitat for
      Animals recorded as dispersing generally moved only relatively           animals within proximity of the works corridor.
      short distances to nearby marsh dykes i.e. up to 300 m
      but mainly less than 150 m. More males than females were             Tool Box Talks, Mitigation Practice Notes, Environmental Issue
      displaced, possibly reflecting population demographics,              Posters and the regular presence of environmental staff on site
      territoriality and/or seasonality factors. Males generally moved     to monitor works are all approaches used to ensure mitigation
      greater distances than females. Monitoring indicated that            is successfully implemented. As it is believed that the methods
      animals largely remained in situ when vegetation cutting alone       developed are the best available techniques suitable for use
      was implemented and, only when subsequent water draw down,           on the BFAP, trapping is no longer used as a routine method of
      commenced and was maintained, did animals respond through            water vole mitigation.
      permanent relocation.
      At other sites worked during 2007, more than 14 km of soke
                                                                           Water Vole Habitat Suitability
      dyke was subject to mitigation which included trapping as a final    Assessments
      measure, after vegetation cutting and water draw down were
      maintained for at least two weeks. The exception was one small       A Water Vole Habitat Suitability (WVHS) assessment was
      length of 330 m where asbestos removal resulted in the cutting       developed for use as a survey tool for the BFAP during 2007.
      short of water draw down. In total, 33 animals were caught.          The assessment is based on a method developed by Jane Harris
      Seventeen of these were from the 330 m length where water            of Kepwick Ecological Services, a local sub-consultant regularly
      draw down was not maintained for the full two week period.           employed by the Project. It is designed to enable a rapid
                                                                           assessment of habitat suitability over extensive lengths, which
      Field observations indicated the density of animals present          can then be validated using searches for field signs at a number
      in 2007 was comparable to 2006. This allows comparison               of sub-locations.
      between years of the effectiveness of displacement based on
      vegetation cutting alone vs. vegetation cutting and water draw       The assessment considers eight separate site characteristics,
      down, using the number of animals trapped as a measure of            based on cover, food source, burrow and nesting opportunities,
      animal persistence:                                                  and freedom from disturbance. Sites receive a score of 1 to 8,
                                                                           which relate to ‘unsuitable’, ‘sub-optimal’ and ‘optimal’ habitat
      Comparison of trapping numbers from water vole                       types.
      mitigation undertaken in 2006 and 2007
                                                                           The main benefit of
       Year     Length of      No. of animals     Animals per              the use of habitat
                mitigation (m) caught             km equivalent            assessments relates        Example of works corridor one year after
       2006     17,280           476              27.55                    to the recognition         completion (new double soke dyke to left
                                                                           that baseline surveys      of photo)
       2007     14,075           33               2.34
                                                                           for field signs only
       2007*    13,743           16               1.16                     provide a snapshot
                                                                           evaluation of animal
      (*excluding data from 330 m length where water draw down not
                                                                           presence at any one
      maintained)
                                                                           time, and can quickly
      The data indicate the number of animals caught is reduced by         (within a breeding
      an order of magnitude when water drawn down is implemented           season) become out
      in addition to vegetation cutting alone. When the 330 m              of date. However,
      length where water draw down was not fully implemented is            if a habitat is
      removed from the assessment, a greater than 95% reduction            considered suitable
      in the number of animals caught over standardised lengths is         for supporting
      apparent.                                                            water voles, it will generally remain suitable from one season to
                                                                           another i.e. a precautionary approach can be taken. Validation
      Whilst predation pressure will almost certainly be a factor          checks can then be used to confirm the presence of field signs.
      affecting displaced voles, the data gained using the radio           Where habitats are assessed as unsuitable, thorough checks
      tracking study and results from animal trapping in 2007 indicate     for field signs are required prior to works commencement to
      a proportion of resident water voles are successfully displaced      confirm animals are absent. The method can also be used to
      from habitats subject to development works, to establish             assess habitat suitability of adjacent marsh dykes for displaced
      territories nearby. Such operations are likely to be considerably    animals, and in post-works surveys to assess the success of
      less stressful for animals than trapping and forced relocation.      habitat re-instatement.

                                                                                                                  In Practice December 2008 9
In Practice Mitigation - CIEEM
WATER VOLE MITIGATION

                                                                             to develop best practice, and a pro-active workforce who
                                                                             enabled the mitigation to be implemented successfully over a
                                                                             huge scale on the ground.
                                                                             It is believed that the methods developed are the best available
                                                                             for implementation on the BFAP. The data indicate water draw
                                                                             down is an
                                                                             effective
                                                                             displacement
                                                                             tool and
                                                                             post works
                                                                             monitoring
                                                                             demonstrates
                                                                             no long term
                                                                             negative
                                                                             impacts upon
                                                                             water vole
                                                                             distribution at
Example of pre and post works monitoring data (Strumpshaw and                the Broadland
Buckenham Marshes, River Yare)                                               scale. Indeed
                                                                             an increase
       Experience gained using the WVHS method in 2007 and 2008
                                                                             in distribution
       indicates habitat assessed with a score 5 or better is routinely
                                                                             is apparent in
       found to support water voles, based on validation checks for
                                                                             recent years.
       field signs. Furthermore, the method was applied to 423 sample
                                                                             The works
       points during the undergraduate research project (Raybould
                                                                             to date have
       2008). Logistic regression analysis demonstrated a significant
                                                                             generated a
       positive relationship between habitat suitability scores and the
                                                                             huge dataset
       probability of the presence of water vole (P
INVERTEBRATE MITIGATION

      Site Mitigation for Invertebrates
      Alex Ramsay MIEEM
      Senior Invertebrate Ecologist, RSK Carter Ecological

      Which Invertebrates                       on a series of habitat patches
                                                which can extend over several
      are Likely to Require                     kilometres, and if the core
                                                habitat area is lost to a
      Mitigation?                               proposed development, this

      O
                                                will have a significant bearing
           ver 30, 000 invertebrate             on whether the development
           species have been                    actually goes ahead.
      recorded from the UK and it is
      clear that not all species can            UK BAP Species
      be mitigated for during site
                                                The recent review of BAP
      development. Mitigation plans
                                                species (Anon 2007) led to
      usually focus on species with             the inclusion of 411 species.        Floral diversity is key to retaining good bee faunas on
      statutory protection, currently           Some of these are well-known         mitigation sites
      71 species. Biodiversity Action           and include charismatic              Photo: Alex Ramsay
      Plan (BAP) species are also now           species such as the stag
      a material consideration in the           beetle and a third of all British
                                                butterflies, to more obscure species            of scarce and threatened species are
      planning process, currently                                                               an invaluable resource for the ecology
                                                such as the lacebug Physatocheila
      411 species (Anon 2007). Rare                                                             and distribution of rare invertebrate
                                                smreczynskii, which is found only in old
      species identified in the Red             orchards. Generally speaking, good              species and can provide a useful
      Data Books (Shirt 1987, Bratton           invertebrate sites will include a number        starting point for developing a mitigation
      1991) may also be considered              of BAP species and in such cases rare           scheme. Kirby (2001) and Fry and
      (some of which are likely to also         species are also likely to be present.          Lonsdale (1991) provide habitat-based
                                                                                                management principles which can be
      be protected or BAP species),
                                                                                                used in conjunction with specific ecology
      particularly on sites where               Rare Species                                    for target species.
      there is an assemblage of rare
                                                Defined as species which occur in less        A decision needs to be taken regarding
      species that could be nationally          than fifteen 10 km squares in Great           best practice - ideally mitigation areas
      significant.                              Britain (Shirt 1987), the criteria for such   are retained within the development,
                                                species are gradually being upgraded          but if this is not possible then suitable
      Protected Species                         to IUCN threat categories which are           sites for translocation will need to
                                                based on level of threat to the species in    be identified. However, it should be
      Most protected invertebrates only         Britain rather than simply on rarity. The     stressed that retention of habitat within
      occur at one or two sites and hence       advantage of this system is that it allows    the development is usually the best
      are rarely likely to feature in the       status to be assessed internationally.        option. Mitigation for mammals and
      planning process or be affected by        Recent status assessments of                  many other groups can require large
      development. However, a few species       invertebrates which use the IUCN criteria     areas, but for invertebrates small areas
      are extremely widespread but very         include Foster (in press) for the water       of habitat can support populations for
      rare and could occur wherever the         beetles and Falk and Chandler (2005) for      many years, although the likelihood of
      habitat is suitable. This includes the    Nematoceran flies.                            success can be enhanced by connecting
      fairy shrimp, mole cricket and marsh                                                    areas of suitable habitat within the site.
      fritillary The former two species are
      found in flood plains, where a number
                                                What Form is the                              For more mobile species, maintaining a
                                                                                              series of habitat patches within the site
      of housing developments have been         Mitigation Likely to                          may be a minimum requirement.
      sited in recent years. For more mobile
      invertebrate species such as the marsh    Take?                                         Mitigation Timing
      fritillary, mitigation needs to cover a
      larger area as the species is dependent   This is largely dependent upon what
                                                is known about the ecology of the             Creation of new habitat for invertebrates
                                                species or assemblage present. In             is not an instant process, and ideally
The mole cricket can potentially occur in                                                     a mitigation site should be set up at
floodplain development areas                    some cases the ecology is extremely
                                                well-known, but in others very little         least a year before animals are moved
Photo: Alex Ramsay                                                                            to maximise natural colonisation.
                                                is known. Where notable species are
                                                found, repeat site surveys to study the       Careful consideration should be given
                                                ecology of poorly-known species will          to the location of mitigation areas,
                                                certainly add to the known information.       particularly as aspect and levels of
                                                Background literature including British       shading are crucial - there is little point
                                                Red Data Books for Insects (Shirt 1987)       in moving insect species from flower-rich
                                                and Invertebrates other than Insects          grassland on a sunny, south-facing bank
                                                (Bratton 1991), and the JNCC reviews          to a shaded north-facing bank because

                                                                                                            In Practice December 2008 11
INVERTEBRATE MITIGATION

                                                               kill subterranean insect larvae).    and donating it to a conservation body
                                                               Ideally, such areas should be        to preserve a similar assemblage off
                                                               monitored post-construction          site. Ideally this should include a sum for
                                                               to assess the species                future upkeep of the site.
                                                               present. If compensatory
                                                               habitat is created, then it
                                                               can be prepared at this
                                                                                                    Monitoring
                                                               stage which would maximise           Almost always regarded as an
                                                               the chances of colonisation          afterthought, the post-construction
                                                               before existing habitat is           monitoring of any invertebrate mitigation
                                                               lost. This is most likely to be      is crucial to determining the success of
                                                               successful if mitigation areas       the mitigation technique used, be that
                                                               are immediately adjacent to the      retention of key breeding areas for rare
                                                               proposed development area so         invertebrates or colonisation success of
Mitigation for stag beetles could require provision of         that species loss is minimised.      re-created habitat. There is unfortunately
partially buried logs for larvae                               If this is not possible then steps   very little published or readily accessible
Photo: Alex Ramsay                                             should be taken to ensure that       material on success (or otherwise) of
                                                               plants and soil present on the       invertebrate mitigation schemes due
         inevitably they are unlikely to survive.              proposed development site are        to lack of adequate post-mitigation
         Consideration should also be given to       carefully removed to the mitigation site       monitoring. This is a situation that needs
         when the translocation is carried out       prior to construction.                         to be urgently addressed so that future
         and to the life-stage of the species being                                                 schemes can be improved or refined. At
         moved - in some cases eggs or larvae          Medium-Term                                  the very least a post-construction survey
         may be appropriate, in other cases                                                         would enable the target species to be
         the adult stages of the target species        Mitigation                                   identified as still present, and allow for
         will be more appropriate. If adults are                                                    slight changes in management if these
                                                     It is crucial that appropriate                 are required to boost populations.
         moved, this should ideally be early in
                                                     management is implemented for
         their emergence period to ensure that
                                                     the mitigation site to ensure the
         eggs are laid in the mitigation site,
                                                     translocated species continue to thrive.
                                                                                                    References
         although there are always exceptions
                                                     Such measures could include phased             Anon (2007) New UK BAP Species 2007.
         - female stag beetles lay a single batch
                                                     planting of host plants for plant-feeding      www.ukbap.org.uk/newprioritylist.aspx
         of eggs towards the end of the breeding
                                                     species, or nectar plants for bees and
         season and so a later translocation may
                                                     wasps. Soil disturbance in some areas          Bratton J H (ed) (1991) British Red
         be more appropriate for this species.
                                                     would provide basking and hunting sites        Data Books 3: Invertebrates other than
         For certain species a mid-successional
                                                     for a variety of species and ensures that      insects. Joint Nature Conservation
         habitat is crucial and mitigation might
                                                     parts of the sward are open to provide         Committee, Peterborough.
         involve creation of several habitat
                                                     potential future breeding habitat through      Falk S J and Chandler P (2005) A review
         patches which will vegetate at different
                                                     natural succession. The implementation         of the scarce and threatened flies of
         rates, thereby providing a continuity of
                                                     of appropriate management is necessary         Great Britain. Part 2: Nematocera and
         future habitat.
                                                     to maintain and enhance invertebrate           Achiza not dealt with by Falk (1991).
                                                     populations on the mitigation site. Early
        Moving Entire                                successional habitats such as grassland
                                                                                                    JNCC Species Status Report, No.2.
                                                                                                    Joint Nature Conservation Committee,
        Assemblages                                  may benefit from occasional surface soil
                                                     disturbance to maintain optimum habitat
                                                                                                    Peterborough.

         This will usually involve a more broad-     conditions. Late successional habitats         Fry R and Lonsdale D (1991) Habitat
         brush approach so that any newly-           such as woodland may benefit from              Conservation for Invertebrates
         created habitat will be suitable for        enhancement of the dead-wood resource          - a neglected green issue. Amateur
         the widest range of species possible.       by provision of log piles.                     Entomologist’s Society, Middlesex.
         Specific host plants may be selectively                                                    Foster G N (in press) A review of the
         planted, and if swards can be moved           Long-Term Mitigation                         scarce and threatened Coleoptera of
         then careful removal and replacement                                                       Great Britain, part 3. Aquatic Coleoptera.
         will provide a seed bank of hostplants      Veteran parkland trees retained
                                                                                                    JNCC Species Status Report, No.1.
         and may contain eggs and larvae of          in a development are of particular
                                                                                                    Joint Nature Conservation Committee,
         invertebrates. Particular care should be    importance for saproxylic beetles
                                                                                                    Peterborough.
         taken to ensure that the sward is not       and flies. Long-term mitigation for
         inverted during removal and replacement     these species is crucial to maintaining        Kirby P (2001) Habitat Management for
         on the mitigation site, as this would bury  the fauna, and this will involve an            Invertebrates: a practical handbook (2nd
         eggs and prevent development.               assessment of the local age structure          edition). RSPB, Sandy.
                                                     of trees present and identifying gaps in
                                                                                                    Shirt D B (ed) (1987) British Red
        Short-Term Mitigation                        recruitment ages of the trees. Where
                                                     these are identified then further planting
                                                                                                    Data Books 2: Insects. Joint Nature
                                                                                                    Conservation Committee, Peterborough.
         This usually involves careful selection of  of trees to fill identified gaps will help
         key areas for invertebrates which can       to ensure long term survival of the
         be retained during development. They        saproxylic fauna present.
                                                                                                    Correspondence:
         must be adequately protected from           A potential mitigation mechanism which         ARamsay@rskcarterecological.co.uk
         construction processes including night      has been only rarely applied in the UK
         lighting (a particular problem for moths),  context (although in widespread use
         excessive dust (which can kill insect host  in the USA) is the concept of buying
         plants) and soil compaction (which can      areas of pristine invertebrate habitat

   12 In Practice December 2008
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