Stoke Park SNCI; Parkland Restoration Works September 2018 to March 2019 Non-licensable Method Statement - Great Crested Newt, Reptiles and ...
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Stoke Park SNCI; Parkland
Restoration Works September 2018
to March 2019
Non-licensable Method Statement –
Great Crested Newt, Reptiles and
Nesting Birds
On behalf of Bristol City Council
August 2018
Date: November 2018
Our ref: AE194.1
Avalon Ecology Ltd
Pendine House
6 Bridge Street
Chepstow
Monmouthshire
NP16 5EY
Tel: 07733097922
Email: craigstenson@avalonecology.org.uk
Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018 Disclaimer This report has been prepared by Avalon Ecology Ltd, with all reasonable skill, care and diligence within the terms of the Contract with the client and taking account of the resources devoted to Avalon Ecology Ltd by agreement with the client. Avalon Ecology Ltd disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and Avalon Ecology Ltd accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at its own risk.
Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Document Number:
AE194.1
Date of Issue:
27th November 2018
Amendment Record:
Revision No. Date Reason for Change Authors Signature
Section 2 Summary of
1 27th November 2018
Survey Results revision
Revisions to methodology
required to take into
1 27th November 2018 account negative 2018
eDNA result for Barn
Wood Pond
Main Contributor:
Craig Stenson
Issued by:
Craig Stenson
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Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Contents
Summary
1. Background 5
2. Summary of Survey Results 10
3. Legislation and European Protected Species Licenses 13
4. Risk Avoidance Measures (RAMs) 18
5. Additional Recommendations – Great Crested Newt 30
References 31
Figures
Figure 1: Stoke Park Parkland Restoration Works September 2018 to March 2019
Figure 2: Proposed Artificial Hibernacula Locations
Figure 3: Ecological Supervision Requirements
Figure 4: Clearance of Dense Bramble and Thorn Scrub – proposed Long Reach Flail Use
Figure 5: Retention of 6m Wide Vegetated Scrub Corridors for GCN
Figure 6: Site Waterbodies Locations
Plates
Plate 1.1: Dew Pond
Plate 1.2: Dew Pond
Plate 1.3: Duchess Pond
Plate 1.4: Barn Wood Pond
Plate 2.1: GCN egg found at Dew Pond
Plates 4.1 to 4.2: Existing access routes across Stoke Park
Plate 4.3: Existing access route leading to Dew Pond area in photo background
Plates 4.4 to 4.6: Dense bramble and thorn scrub within vicinity of Dew Pond
Plates 4.7 to 4.8: Woodland subject to ash and hawthorn thinning
Plates 4.9 to 4.10: Historic hedgrows
Plates 4.11 to 4.13: Over mature hedgerows
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Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
1. Background
1.1. This non-licensable method statement sets out a defined means of continued parkland restoration
works (See Figure 1) at Stoke Park Site of Nature Conservation Interest (SNCI). This report is
intended to ensure that great crested newts (GCN) Triturus cristatus are not harmed and no offence
committed under the Conservation of Habitats and species regulations 2010 (as amended) and the
Wildlife and Countryside Act 1981 (as amended).
1.2. Avoidance of harm is achieved by setting a pragmatic list of undertakings which constitute reasonable
avoidance measures (RAMs). 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 contractors and supervision staff engaged in the operations.
1.3. In addition to not harming GCNs, the RAMs outlined within the document will equally avoid harm to
reptiles, other amphibians and nesting birds known to be present within the Stoke Park restoration
works area.
1.4. The evaluation was undertaken by Craig Stenson, a highly experienced field ecologist of over 28
years, including extensive experience in GCN survey, evaluation, licensing and mitigation on large
scale development sites. For thirteen years he has held a Natural England Class Licence WML-CL09.
1.5. The methods and mitigation applied at the site are based on the known presence of GCN at the Stoke
Park site, and a site visit to confirm features and formulate a method of ensuring GCN will not be
adversely affected by the proposed works.
1.6. The non-licensable method statement applies to the restoration works as shown on Figure 1.
1.7. The Stoke Park parkland restoration works to be carried out between September 2018 and March
2019 shall be implemented in full under the direct supervision and advice of retained suitably qualified
ecologists.
Site Location and Context
1.8. Stoke Park SNCI covers approximately 101 hectares in the north east of Bristol. It is a broadly linear
site partly occupying the eastern flank of the Pur Down – Stoke Park ridge which lies on the western
side of the Frome Valley. The site covers a number of landforms from plateau through scarp face to
dry valley, it runs south west to north east for a distance of 2.7km and is 800m wide at its broadest
point. There are many aspects but the south-easterly aspect is predominant, and the site is generally
well-drained except for some areas of rush pasture in the north east. Altitude ranges between 20m in
the extreme south to 89m in the north west. The M32 motorway forms the eastern boundary for much
of the site’s length whilst the other boundaries of the site abut farmland and parkland which in turn are
enclosed within residential, industrial and institutional development.
1.9. The western third of the site overlies Jurassic limestones of the Lower Lias Series whilst Triassic
deposits distinguish the rest of the site: on the eastern side of the ridge the break of slope is marked
by a band of Rhaetic Clay which gives way to a broader band of Keuper Marl. East of the motorway
there are Triassic sandstones of the Keuper Series. A small area of foundered strata is present in the
centre of the site and is associated with the areas that experience waterlogging.
1.10. The restoration works are taking place within the part of the SNCI area that is owned by Bristol City
Council.
1.11. Some areas of grassland are subject to a hay cut in late summer.
1.12. A key feature of the site is the re-created Duchess Pond located in the north close to the site of the
original Duchess Pond which was destroyed as part of the construction of the M32. The replacement
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Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
pond has been landscaped and is fenced against the rest of the site; there is considerable angling
activity here, especially at weekends.
1.13. The site is complex and supports many plant communities in varying states of management and
succession. Planted trees (mostly alien species) are frequent in the south of the site whilst mature
field trees (mostly native species) are scattered throughout. Many grassland areas have scrubbed
over, particularly with bramble and thorn, within the restoration project works area. Elsewhere, the
character of the original parkland landscape has diminished due to further scrub and tree
encroachment.
Waterbodies
1.14. Waterbodies lying within the SNCI area shown on Figure 6.
Dew Pond
1.15. The Dew Pond comprises a small semi-circular water body at the base of a northern slope (see
Figure 1). The pond is rain-fed with an occasional outflow downhill to a small marshy area. The pond
is bordered by amenity grassland to the south, scrub and rough grassland elsewhere. The pond is
lined with stone setts (cobblestones) and has little marginal vegetation and no emergent vegetation
(see Plates 1-1 and 1-2). Several the stone setts have become dislodged with silt and stone debris
partially filling the pond. The pond is frequently disturbed by dogs.
Plate 1.1: Dew Pond Plate 1.2: Dew Pond
Duchess Pond
1.16. The Duchess Pond (see Figure 1, Plate 1-3) is an enlargement of a smaller water body which
replaced the original Duchess pond that stood in the path of the M32 motorway. The pond is broadly
linear and has a small rounded island (with semi-mature trees and shrubs growing on it) towards its
western apex. At the western end of the pond there is a considerable quantity of common reed
Phragmites australis; other emergents include sea club-rush Scirpus maritimus, branched bur-reed
Sparganium erectum, common spike-rush Eleocharis palustris, reed-mace Typha latifolia, great
sweet-grass Glyceria maxima and common water-plantain Alisma plantago-aquatica. Bankside
species include fleabane Pulicaria dysenterica, reed canary-grass Phalaris arundinacea, water mint
Mentha aquatica and great Willowherb Epilobium hirsutum; white water-lily Nymphaea alba is
present on the surface of the pond.
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Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Plate 1.3: Duchess Pond
Wildlife Conservation Pond
1.17. To the east of the Duchess Pond lies a small linear water body with adjacent riparian habitat and
marshy grassland.
Barn Wood Pond
1.18. Located approximately 260m north-east from the Dew Pond, Barn Wood Pond (see plate 1.4)
comprises an old cart dip enclosed on three sides by stone walls.
Plate 1.4: Barn Wood Pond
1.19. Historical records refer to a waterbody being located north of the northern boundary of Pale
Plantation, approximately 250m west of the Dew Pond. However, a site survey carried out in
September 2018, did not find any features on the ground indicating the presence of a waterbody that
holds standing water
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Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Details of Work
1.20. Between September 2018 and the end of March 2019 the following restoration works will take place:
• September and October 2018: clearance of dense bramble and thorn scrub that has
encroached upon former grassland areas (see Figure 1).
• Necessity for clearance, September 2018 to March 2019, of dense areas of bramble and
thorn scrub within woodland areas to take place at the discretion of the supervising ecologist
(see Figure 1);
• October 2018 to March 2019: areas of dense young ash and hawthorn to be thinned to favour
veteran trees, oak and other species, retaining 70% canopy cover; understorey to be cut
above ground level to enable access for park users and grazing cattle (see Figure 1);
• October 2018 to March/April 2019: historic hedgerows to be laid. All mature hedgerow trees
to be retained, to enclose grazed areas, and maintain habitat connectivity (see Figure 1);
• Late March/April 2019: historic hedgerows to be banked up, gaps replanted and fenced.
• October 2018 to March 2019: over mature hedges to be pruned to enable fencing, but not
laid until other hedges have regrown (see Figure 1);
• November 2018 to March 2019: fencing to be installed parallel to above pruned hedges;
• April to November 2018 and 2019: extension to cattle grazing;
• Autumn and Winter 2018 and 2019: Orchard and parkland tree planting; and
• All year round: general works in the park with volunteers.
Purpose of this Document
1.21. The purpose of this document is to summarise the background survey information relating to great
crested newt, reptiles and birds within the area of the proposed restoration works. It then presents
the specific precautionary methods of working to be adopted during the works. This information
justifies the conclusion that the specific works described may proceed without the need for a great
crested newt mitigation licence from Natural England and without the risk of committing offences
against common species of amphibians, reptiles and nesting birds.
Protected Species Risks
1.22. The existing species records and survey information confirm that a small GCN population exists
within the vicinity of Stoke Park Dew Pond.
1.23. As regards reptiles, existing records and survey information confirm that slow worm Anguis fragilis
and grass snake Natrix natrix populations exist at Stoke Park and are likely throughout most of the
site. A common (viviparous) lizard Zootoca vivipara record for the area adjoining the sites southern
boundary suggests that a population of this species might also be present at Stoke Park.
1.24. As regards common species of amphibians, existing records and survey information confirm that
smooth newt Lissotriton vulgaris, palmate newt Lissotriton helveticus, common toad Bufo bufo and
common frog Rana temporaria populations exist at Stoke Park and are likely throughout most of the
site.
1.25. As regards hazel dormouse Muscardinus avellanarius, the 2018 hazel dormouse nest tube survey
has found no evidence of hazel dormouse, it is therefore considered unlikely that hazel dormouse is
present at the site. Hazel dormouse is afforded legal protection as a European Protected Species
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Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
under the Conservation of Habitats and species regulations 2010 (as amended) and the Wildlife and
Countryside Act 1981 (as amended).
1.26. The existing species records and survey information confirm that a Stoke Park supports a wide range
of bird species.
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Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
2. Summary of Survey Results
Great Crested Newt
Dew Pond
Bristol City Council Estate’s Ponds - Great Crested Newt eDNA & HSI Survey May 2018 (Wild
Service)
2.1. In accordance with ARG UK’s Advice Note 5 (Oldham et al. 2000), a Habitat Suitability Index (HIS)
and a GCN eDNA (Biggs et al. 2014) survey was carried out for the Dew Pond (National Grid
Reference (NGR) ST6161977035) by Gloucestershire Wildlife Management, analysis by ADAS. The
Dew Pond HSI score was 0.58 and therefore considered of below average suitability for GCN. The
eDNA result was negative. However, during a subsequent egg search, a loose dock leaf was
observed on the surface of the water, partially opened, revealing the presence of a great crested
newt egg (see Plate 2.1). Further evidence of leaf folding was observed on blades of grass that were
overhanging the pond and lying in the water. After the egg search, at least one great crested newt
individual was seen swimming to the surface for air. As presence was confirmed, netting and torching
were not completed to minimise disturbance.
2.2. The aforesaid survey confirmed that the dew pond is utilised by GCN for breeding purposes.
Plate 2.1: GCN egg found at Dew Pond
Duchess Pond and adjacent Wildlife Pond
eDNA Great Crested Newt Survey Results 2017 Southern England (PondNet)
2.3. Stoke Park: Pond 1 (Duchess Pond, NGR: ST6184 7690), Pond 2 (Wildlife Pond, NGR:
ST61967692), GCN eDNA results negative for 5.6.2017.
eDNA Great Crested Newt Survey Results 2016 Southern England (PondNet)
2.4. Stoke Park: Pond 1 (Duchess Pond, NGR: ST6184 7690), Pond 2 (Wildlife Pond, NGR:
ST61967692), GCN eDNA results negative for 24.6.2016.
eDNA Great Crested Newt Survey Results 2016 Southern England (PondNet)
2.5. Stoke Park: Pond 1 (Duchess Pond, NGR: ST6184 7690), Pond 2 (Wildlife Pond, NGR:
ST61967692), GCN eDNA results negative for 2015.
eDNA Great Crested Newt Survey Results 2018 Natural England
10Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
2.6. Stoke Park: Pond 2 (Wildlife Pond, NGR: ST61967692), GCN eDNA results negative for spring 2018.
Habitat Suitability Index (HIS) methodology (Oldham et al 2000) score for Wildlife Pond determined
as 0.8 (excellent).
Barn Wood Pond
eDNA Great Crested Newt Survey Results 2018 Natural England
2.7. Stoke Park: Pond 3 (Barn Wood Pond, NGR: ST6205877374), GCN eDNA results negative for spring
2018. HSI score for Barn Wood Pond determined as 0.62 (average).
Other Waterbodies
2.8. There are no survey records for the defunct Pond North of Pale Plantation located at ST6137477083.
eDNA Great Crested Newt Survey Results 2018 Natural England
2.9. South of Stoke Park: Two waterbodies located approximately 1km south of the Dew Pond at
ST6107975958 and ST 6093276126, GCN eDNA results negative for spring 2018. HSI scores for
latter ponds determined as 0.4 (poor) and 0.36 (poor) respectively.
Bristol Regional Environmental Records Centre (BRERC) Data
2.10. BRERC supplied records of great crested newt within a 0.5km radius of Stoke Park.
2.11. The data search revealed three records of GCN within the search area. The nearest record is for the
Dew Pond at Stoke Park where individual male and female GCNs were recorded in 2009. The next
nearest record (1998) is approximately 460m west of the Stoke Park western boundary. The third
record (2000) is approximately 700m north-west of the Stoke Park boundary.
Other Amphibian Species
Dew Pond
Stoke Park SNCI Favourable Condition assessment Report, 2004.
2.12. Approximately 16 smooth newt efts were recorded in the Dew Pond.
Bristol Regional Environmental Records Centre (BRERC) Data
2.13. BRERC supplied records of amphibians within a 0.5km radius of Stoke Park.
2.14. There are two records of common frog within the search area, the nearest record (2009) of which is
for the Stoke Park Dew Pond.
2.15. There are nine records of common toad within the search area, the nearest record (2012) of which
is approximately 350m north the Stoke Park boundary.
2.16. There are two records of palmate newt within the search area, the nearest record (2009) of which is
for the Stoke Park Dew Pond.
2.17. There are six records of smooth newt within the search area, the nearest record (2009) of which is
for the Stoke Park Dew Pond.
2.18. Reptiles
Stoke Park Reptile Survey, 2013.
2.19. Between April and June 2013, a reptile survey was carried out by Bristol City Council. Including the
area of the Stoke Park subject to restoration works, a total of 39 artificial refugia (mats) were installed
and checked on five occasions. Totals of ten slow worms and three grass snakes were recorded.
11Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Although limited in extent, the survey findings suggest, particularly within areas of favourable habitat,
Stoke Park likely supports a high population of slow worm and a medium population of grass snake.
Bristol Regional Environmental Records Centre (BRERC) Data
2.20. BRERC supplied records of amphibians within a 0.5km radius of Stoke Park.
2.21. There are three records of common (viviparpous) lizard within the search area, the nearest record
(1998) of which is approximately 300m south of the Stoke Park southern boundary.
2.22. There are thirteen records of slow worm within the search area, the nearest record (2005) of which
is for the southern end of Stoke Park.
2.23. There are two records of grass snake within the search area, the nearest record (2012) of which is
for the Duchess Pond at Stoke Park. There’s also a record (2012) approximately 200m south of the
Stoke Park southern boundary.
12Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
3. Legislation and European Protected Species Licenses
Legislation
3.1. This report has been prepared in accordance with relevant legislation. Primary documents of
relevance are:
• The Wildlife and Countryside Act 1981 (as amended);
• The Countryside and Rights of Way Act (CRoW Act), 2000 (as amended);
• The Natural Environment and Rural Communities Act (NERC Act), 2006; and
• The Conservation of Habitats and Species Regulations 2017.
3.2. No part of this report should be considered as legal advice and when dealing with individual cases,
the client is advised to consult the full texts of the relevant legislation and obtain further legal advice.
Great Crested Newt
3.3. Great crested newt is legally protected as a European Protected Species under Regulation 41 of the
Conservation of Habitats and species Regulations 2010 in respect of:
a. Deliberate capturing, injuring or killing of an animal;
b. Deliberate disturbance of animals;
c. Deliberate taking or destroying the eggs of such an animal; and
d. Damaging or destroying a breeding or resting place of such an animal.
3.4. ‘’Deliberate disturbance of animals (meaning (according to case law) the species) includes in
particular any disturbance which is likely:
a. To impair their ability:
i. To survive, to breed or reproduce, or to rear or nurture their young or
ii. In the case of animals hibernating or migratory species, to hibernate or migrate.
b. To affect significantly the local distribution or abundance of the species to which they
belong.
3.5. GCN are also protected under the Wildlife and Countryside Act 1981 (as amended) in respect of
intentionally or recklessly:
a. Disturbing any such animal while it is occupying a structure or place which it uses for
shelter or protection.
b. Obstructing access to any structure or place which any animal uses for shelter or
protection.
Vegetation clearance
3.6. Bristol City Council officers have consulted Natural England and a suitably qualified consultant
ecologist regarding as to whether an EPS licence needs to be obtained for the vegetation clearance
and habitat enhancement works. The consensus is that an EPS licence is not required provided the
proposed works are reasonably unlikely to result in an offence under Regulation 41. It is considered
that as long as the risk avoidance measures (RAMS) set out in Section 4 of the document are
carefully adhered to, no offence will be committed.
13Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
3.7. As follows, there are several reasons why no offence in relation to GCNs is expected in relation to
vegetation clearance:
• No ponds are to be affected by the restoration works;
• Low risk of harm to GCNs due to small population size, low pond density, short works
period;
• All vegetation within a 60m buffer zone of the Dew Pond will be retained (see Figure 3);
• The vegetation clearance of the most suitable (moderate risk) GCN terrestrial habitat
(dense and scattered scrub, rank vegetation) will be undertaken outside of the GCN
hibernation period, generally accepted to be late October to late February (weather
dependant), and when the temperature, including overnight, is 5°C or above;
• Suitable GCN refugia will not be disturbed November 2018 to March 2019;
• The restoration works are not a development activity but a land management and habitat
enhancement and restoration activity, therefore, suitable GCN habitat will be retained
with no net loss of suitable habitat;
• Other than the Dew Pond, given the distance and presence of barriers (main roads and
urbanisation) between Stoke Park and the next nearest GCN records, potential impacts
on GCN at Stoke Park are considered most likely confined to within a 250m radius of
the Dew Pond.
• Should a GCN be found, Natural England will be consulted;
• As required, vegetation clearance and hedgerow restoration works will be supervised by
a suitably qualified ecologist;
• If there is any doubt that vegetation removal would lead to an offence being committed,
further advice will be obtained from Natural England and relevant specialists; and
• Any additional measures deemed necessary by the project ecologist during the works
will be applied immediately and recorded on the Ecological Permit to Work and Task
Risk Assessment.
3.8. Based on the points outlined above, Reasonable Avoidance Measures (RAMs) are the appropriate
course of action in respect of GCN at the site.
Other Amphibian Species
3.9. The four widespread species of amphibian, the smooth and palmate newts, the common frog and
common toad, are protected only by Section 9(5) of the Wildlife and Countryside Act 1981. This
section prohibits sale, barter, exchange, transporting for sale and advertising to sell or to buy.
Collection and keeping of these widespread amphibian species is not an offence. Under the NERC
Act 2066, common toad is also a species of principal importance in England.
3.10. The scarce species natterjack toad Epidalea calamita is afforded additional protection under Sections
2 and 5 the Conservation of Habitats and Species Regulations 2010 Wildlife and Countryside Act
1981 (as amended). UK and European law which makes it an offence to kill, injure, capture or disturb
them; damage or destroy their habitat; or possess them or sell or trade them in any way. This also
applies to larval stages and eggs.
14Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Vegetation clearance
3.11. Offences under the W&CA 1981 relating to common amphibians are, in the context of the works, not
licensable under the legislation.
3.12. It has been concluded by the consultant ecologist that the offences of intentional killing or injury of a
common amphibian are unlikely to arise during the vegetation clearance and habitat enhancement
works as long as the RAMS set out in Section 4 is carefully adhered to.
Reptiles
3.13. All native British reptiles are protected in accordance with Section 9 of the Wildlife and Countryside
Act 1981 (as amended). There are two different levels of protection afforded to reptiles through the
Wildlife and Countryside Act 1981; these result from different parts of Section 9 of the Act applying
to the different species (as specified in Schedule 5).
3.14. The common (viviparous) lizard, slow-worm, grass snake and adder are protected against killing,
injury and sale, etc. Only part of sub-section 9(1) and all of sub-section 9(5) apply; these prohibit the
intentional killing and injuring and trade (i.e. sale, barter, exchange, transporting for sale and
advertising to sell or to buy). It is not an offence under the Wildlife and Countryside Act 1981 to
disturb or possess these animals.
3.15. In 2000, the Wildlife and Countryside Act was supplemented by the Countryside and Rights of Way
(CRoW) Act, which places a statutory duty on government departments to have regard to biodiversity
conservation.
3.16. In June 2007 the UK List of Priority Species and Habitats was presented in a UK BAP report. Within
this report slow-worm, smooth snake, sand lizard, grass snake, adder and common (viviparous)
lizard are listed as species that are priorities for conservation action under the UK Biodiversity Action
Plan (UK BAP).
Vegetation clearance
3.17. Offences under the W&CA 1981 relating to reptiles are, in the context of the works, not licensable
under the legislation.
3.18. It has been concluded by the consultant ecologist that the offences of intentional killing or injury of a
reptile are unlikely to arise during the vegetation clearance and habitat enhancement works as long
as the RAMS set out in Section 4 is carefully adhered to.
3.19. As follows, there are several reasons why no offence in relation to reptiles is expected in relation to
vegetation clearance:
• The vegetation clearance of the most suitable reptile habitat (dense and scattered scrub,
rank vegetation) will be undertaken outside of the reptile hibernation period, generally
accepted to be November to early March (weather dependant);
• Suitable reptile refugia will not be disturbed November 2018 to March 2019;
• As required, vegetation clearance and hedgerow restoration works will be supervised by
a suitably qualified ecologist;
• Any additional measures deemed necessary by the project ecologist during the works
will be applied immediately and recorded on the Ecological Permit to Work and Task
Risk Assessment; and
• If there is any doubt that vegetation removal would lead to an offence being committed,
further advice will be obtained from relevant specialists and Natural England.
15Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Nesting Birds
3.20. Key legislation for birds in the UK includes:
3.21. Council Directive 79/409/EEC on the conservation of wild birds (the EC Birds Directive); and,
3.22. Wildlife and Countryside Act 1981 (as amended) [WCA].
3.23. Annex 1 of the EC Birds Directive lists rare and vulnerable species of regularly occurring or migratory
wild birds that are subject to special conservation measures. The Directive also provides for the
designation of SPAs for the protection of these species, which form part of the Natura 2000 network
of sites protected by European wildlife legislation.
3.24. Part 1 of the WCA sets out how the provisions of the Convention on the Conservation of European
Wildlife and Natural Habitats (the 'Bern Convention'), the EC Birds Directive and the EC Habitats
Directive are implemented in Great Britain. Under Part 1, Section 1 of the WCA it is an offence to:
• Kill, injure or take any wild bird intentionally;
• Take, damage or destroy the nest of any wild bird while that nest is in use or being built;
and
• Take or destroy the egg(s) of any wild bird.
3.25. Schedule 1 of the WCA lists a number of species which, in addition to the provisions listed above,
are protected by special penalties at all times, including against disturbance when breeding.
3.26. The WCA requires the prosecuting authority to prove that an offence was intentional, however the
Countryside and Rights of Way (CROW) Act 2000 strengthens the provisions of the WCA by
introducing an additional offence of "reckless" disturbance, which means that ignorance of the
presence of a protected species cannot be used as a reliable defence should a breach of the WCA
be committed.
Vegetation clearance
3.27. Offences under the W&CA 1981 relating to nesting and non-nesting birds are, in the context of the
works, not licensable under the legislation.
3.28. It can be assumed that it is highly likely that a range of bird species will nest within the working area
during the breeding season, which is generally accepted to be between February and early
September (weather dependant).
3.29. Nevertheless, it has been concluded that no offence against nesting birds is likely as long as the
RAM set out in Section 4 is carefully adhered to. As follows, there are a number of reasons why no
offence in relation to nesting birds is expected in relation to vegetation clearance and habitat
enhancement works:
• The vegetation clearance will generally be undertaken outside of the bird breeding
season;
• As required, vegetation clearance works will be undertaken under the strict supervision
of a suitably qualified ecologist and in accordance with the restrictions noted on the
Ecological Permit to Work and Task Risk Assessment;
• Should works take place in September, the end of the nesting season, or March, the
start of the nesting season, legally the absence of nesting birds would need to be
confirmed by a suitably experienced ecologist prior to any clearance works. Where an
16Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
active nest is found, a suitable buffer will be established around the nest. The nest site
must remain undisturbed until it has been confirmed that the nest is no longer in use;
• It’s anticipated that no Schedule 1 bird species are known to nest and or roost within the
works area;
• Should potential impacts upon a Schedule 1 species be identified, an appropriate buffer
will be put in place, and pending consultation with Natural England, works within these
areas will cease as a precaution;
• Any additional measures deemed necessary by the project ecologist during the works
will be applied immediately and recorded on the Ecological Permit to Work and Task
Risk Assessment; and
• If there is any doubt that vegetation removal would have an impact on any bird species
further advice will be obtained from relevant specialists.
European Protected Species licences
3.30. Natural England has produced guidance in its publication ‘’How to get a Licence’’ as to when a
Natural England licence is needed in respect of European Protected Species (which includes GCN):
3.31. ‘’Natural England’s view is that:
A licence is needed if the consultant ecologist, on the basis of survey information and specialist
knowledge of the species concerned, considers that on balance the proposed activity is reasonably
likely to result in an offence under Regulation 41 (animals) or 45 (plants); or
If the consultant ecologist, on the basis of survey information and specialist knowledge of the species
concerned, considers that on balance the proposed activity is reasonably unlikely to result in an
offence under Regulation 41 or 45 then no licence is required. However, in these circumstances
Natural England would urge that reasonable precautions be taken to avoid affecting EPS during
works, and that an audit trail is kept on the decision-making process. If EPS are found, then works
should cease until you have assessed (in consultation with a consultant ecologist) whether you can
proceed without committing an offence. A licence should be applied for if offences are committing an
offence. A licence should be applied for if offences are unavoidable and the work should not be re-
started until a licence is obtained’’.
RAMs Evaluation:
3.32. The RAMs evaluation is based upon Natural England guidance and the ecologist's expert knowledge
of the species and its requirements. In this instance it is considered that the proposals are not
licensable as potential impacts can be effectively removed by the implementation of RAMs.
3.33. In accordance with Natural England’s advice, without the implementation of RAMs the effect on GCN
would be low impacts and might include small numbers of individual newts being encountered, and
thus disturbed during the restoration (vegetation clearance) works.
3.34. If RAMs are implemented, then the risk of harm to GCNs can be removed and the effect on GCN is
predicted to be no effect-negligible.
3.35. English Nature’s Great Crested Newt Mitigation Guidelines, 2001, states: ‘’Small scale losses of
terrestrial habitat, especially over 250m from the breeding pond, will probably have little effect on
populations but some mitigation may be required’’
17Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
4. Risk Avoidance Measures (RAMs)
Purpose of this Section
4.1. This section sets out the manner in which the vegetation clearance and habitat enhancement works
shall be undertaken.
4.2. As a precautionary approach RAMs will be adopted in order to avoid and/or minimize any unforeseen
disturbance impacts on local GCN populations:
Scope and Programme of Stoke Park Restoration Works
4.3. This Non-Licensable Method Statement covers Stoke Park parkland restoration works due to take
place between September 2018 and the end of March 2019.
4.4. It should be noted that this methodology has been set out so as to protect against the risk of harm
from the project arising to protected species. The project ecologists will work with this principal in
mind. The project ecologists will be at liberty to depart from this methodology if (i) he/she considers
that this is preferable in the interests of protected species or on the basis that the departure will have
no worse impact on protected species: and (ii) no offence will consequently arise: and (iii) where a
Variation from the Non-licensable Method Statement form is completed.
General Site Management
4.5. All consumables and equipment are to be stored inside suitable storage containers or raised off the
ground to prevent the creation of habitats suitable for protected species, including GCNs.
Access to Works Areas
4.6. Access to the areas of restoration works will be via established vehicular access tracks (see Plates
4-1 to 4-3).
4.7. Use of established tracks will maintain any required buffer zones around sensitive ecological
features.
4.8. The Ecological Permit to Work and the Task Risk Assessment will set out a description of the relevant
access route and will note any prohibited areas.
4.9. Vehicles will not be permitted within the vegetation clearance areas unless necessary, ideally only
tracked or low ground bearing plant is to be used in such circumstances. The routes used must also
be agreed in advance with Bristol City Council and the project ecologist and the procedure below
followed:
• There will be a preliminary ecological walkover of the proposed route;
• An Ecological Permit to Work and Task Risk Assessment will be undertaken;
• Long reach flail/excavator access will be strictly limited to areas of relatively flat ground
on the outside of the site woodlands eastern and northern boundaries;
• As required, a hand/fingertip search of the proposed route of the vehicle will be
undertaken by the project ecologist;
• Other than GCN, if any protected species are identified then the ecologist will capture
and translocate the animal in accordance with best practice as appropriate. If a GCN
or nesting birds are found, taking into consideration the context and safety of the
animal/s, they will be left in-situ with a suitable buffer zone left around it and an
alternative route used. Natural England will then be consulted of any GCN found.
• The Ecological Permit to Work and Task Risk Assessment will then be updated and
issued and the route or an alternative route can then be used when permitted by and
18Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
as specified in this document. Any GCN or suitable GCN resting place will not be
disturbed and Natural England notified of any GCN found; and
• This will be repeated as frequently as is considered necessary by a project ecologist
when vehicles will be using that route. This will vary depending on the ground conditions
and the features present along the identified access route.
4.10. In addition to track ways, no go areas, such as prohibited scrub, will be briefed to all staff who will
also be provided with plans where necessary (these may form part of the Ecological Permit to Work
and task Risk Assessment). Such areas will also be demarcated with construction tape if necessary.
Plates 4.1 to 4.2: Existing access routes across Stoke Park
Plate 4.3: Existing access route leading to Dew Pond area in photo background
19Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Vegetation Clearance
4.11. Given the survey findings, likely low population status of the site for GCN, the suitability of the site
habitats for GCN within the vicinity of the Dew Pond, the area of vegetation within a 50m radius of
the pond is considered a high-risk zone for disturbing GCNs, the area of vegetation between 50 and
250m of low to moderate risk, beyond 250m of negligible to low risk (see Figure 3).
Clearance of dense bramble and thorn scrub
4.12. All dense bramble and thorn vegetation clearance within 250m of the Dew Pond will be undertaken
under the strict continuous supervision of a suitably qualified (Natural England GCN Class licence
holder) ecologist. Ecological supervision requirements for dense bramble and thorn scrub clearance
outside of the 250m pond buffer zones will be at the discretion of the supervising ecologist.
4.13. Areas of most suitable GCN habitat (dense bramble and thorn scrub) within a 250m radius of the
Dew Pond will be cleared by the end of October 2018.
4.14. No vegetation removal will be permitted unless authorised under an Ecological Permit to Work and
Task Risk Assessment.
4.15. Vegetation clearance will be undertaken by a specialist contractor under the instruction and
supervision of a suitably qualified ecologist.
4.16. All areas of dense bramble and thorn scrub within a 60m buffer zone of the Dew Pond will be retained
(see Figure 1).
4.17. Two 6m wide corridors of vegetation will be retained connecting the retained vegetation (restored
hedgerows) within the Dew Pond buffer zone to retained areas of dense nature trees and thorn scrub
(see Figure 5).
4.18. Both prior to and during vegetation clearance works, under ecological supervision, seven artificial
hibernacula will be constructed at suitable locations (see Figure 2) on the peripheries of the areas of
retained vegetation. The provision of new artificial hibernacula will increase shelter, including
hibernation, opportunities for amphibians and reptiles. Proposed hibernacula design is shown on
Appendix 4.
4.19. Features with potential to shelter GCN will be left undisturbed. If a GCN is found, taking into
consideration the context and safety of the animal, it will be left in-situ with suitable buffer zone left
around it. Natural England will then be consulted.
4.20. Any reptiles and common species of amphibians found during ecological searches and or vegetation
clearance works will be moved by the supervising ecologist to the nearest suitable place of shelter,
including artificial hibernacula (see Figure 1).
4.21. Where possible, areas of vegetation clearance will be subject to pre-clearance, including
hand/fingertip, searches by a suitably qualified ecologist before being cut to the specified height.
4.22. All vegetation cleared as part of the clearance works will be sensitively initially reduced to a minimum
height of 15cm and no lower to the ground, thereby reducing the potential for animals to be injured
or killed.
4.23. The clearance of vegetation will start from the middle of an area outward, to minimise any animals
becoming stranded in ‘vegetation islands’.
20Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Long reach flail use
4.24. Where ground conditions and ecological constraints permit (see Section 4.9), access routes for
machinery will be created through the areas of vegetation to be cleared. The use of a long reach flail
has several advantages over the use of machinery such as a relatively short reach tractor mounted
flail or hand-held power tool reduction of scrub as this method reduces the number of access routes
needed thereby reducing the likelihood of trampling/crushing animals. The following de-veg
procedure will be adopted for long reach flail clearance of bramble/thorn scrub area:
• If possible due to dense bramble, ecological search followed by cutting, no lower than 15cm
above ground, of first access route using hand held power tools only;
• In order to avoid leaving a deep layer of mulch on the ground into the amphibian and reptile
hibernation period, and in order to facilitate further ecological searches, above access route
to be raked off, using wooden hay rakes with blunt teeth only, soon after being cut;
• Metal rakes are not to be used and rake tooth contact with the ground should be avoided;
• Further ecological search undertaken;
• Long reach flail will enter and use access route to reach out and cut vegetation 15cm above
ground level within a wide area;
• Under no circumstances should the flail cutting head come into contact with the ground;
• Long reach flail will leave above work area via same access route;
• Strip of flailed vegetation, searched, raked off, will be used as the next long reach flail access
route;
• Above procedure repeated,
• Subject to further ecological searches, during the amphibian and reptile hibernation period,
areas of vegetation previously flailed to 15cm above ground level, using brushcutters only,
will be cut down to ground level and the arisings removed soon thereafter, and
• Potential amphibian and reptile natural refugia will be left in-situ.
Hand held power tool (brushcutter and chainsaw) use
4.25. Within areas deemed unsuitable for machinery such as excavator mounted long reach flail,
vegetation clearance will be undertaken using hand held power tools such as brushcutters and
chainsaws only, and adhere to the following de-veg procedure:
• If possible due to dense bramble, ecological search followed by initial cut, no lower than
15cm above ground level;
• In order to avoid leaving a deep layer of mulch on the ground into the amphibian and reptile
hibernation period, most of the arisings will be lightly raked off, using wooden hay rakes with
blunt teeth only, soon after being cut;
• Metal rakes are not to be used and rake tooth contact with the ground should be avoided;
• Subject to further ecological searches, during the amphibian and reptile hibernation period,
areas of vegetation previously cut to 15cm above ground level will be cut down to ground
level and the arisings removed soon thereafter, and
• Potential amphibian and reptile natural refugia will be left in-situ.
4.26. The arisings will be raked up, and where possible removed from the site.
21Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
4.27. No artificial lighting will be permitted, and no twilight, dusk or night working is permitted.
4.28. All plant, equipment and consumables are to remain inside the defined areas at all times.
Plates 4.4 to 4.6: Dense bramble and thorn scrub within vicinity of Dew Pond
Areas of dense young ash and hawthorn thinning, understorey removal
4.29. As required, thinning works will be undertaken under supervision of a suitably qualified (Natural
England GCN Class licence holder) ecologist. With particular regard to areas of dense
bramble/scrub, areas of habitat affording significant opportunities for supporting GCNs, continuous
ecological supervision will be required for works within 250m of the Dew Pond (see Figures 3 and
6).
4.30. In order to avoid the bird nesting season, all thinning works will be completed by early March 2019.
4.31. No thinning operations will be permitted unless authorised under an Ecological Permit to Work and
Task Risk Assessment.
4.32. Thinning works will be undertaken by a specialist contractor under the instruction and supervision of
a suitably qualified ecologist.
4.33. Both prior to and during thinning works, five artificial hibernacula will be constructed at suitable
locations on the peripheries of the areas of retained vegetation. The provision of new artificial
hibernacula will increase shelter, including hibernation, opportunities for amphibians and reptiles (see
Figure 2).
22Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
4.34. Any reptiles and common species of amphibians found during ecological searches, including
hand/fingertip, and or thinning works will be moved to the nearest suitable place of shelter, including
artificial hibernacula.
4.35. Features with potential to shelter GCN will be left undisturbed. If a GCN is found, taking into
consideration the context and safety of the animal, it will be left in-situ with suitable buffer zone left
around it. Natural England will then be consulted.
4.36. For areas within 250m of the Dew Pond, searches will be undertaken prior to thinning works. For
areas beyond 250m, searches will be carried out at the discretion of the suitably qualified ecologist.
4.37. Thinning will be undertaken using hand held power tools, including brushcutters and chainsaws.
Vegetation will be assessed for potential to support protected species. Vegetation will be reduced to
ground level where features affording negligible potential to support protected species are absent,
or where suitable features are present, the presence of protected species can be ruled out. For
vegetation affording potential to support protected species where the absence of protected species
cannot be ruled out, the vegetation/tree will either be left in-situ, or if reduced in height, stumps will
be reduced to a minimum height of 30cm.
4.38. Regarding processing of thinned vegetation, the following procedure will be adopted:
• Large timber, together with some smaller brash will be used to create habitat piles, including
linear dead hedging, within suitable locations within retained areas of tree cover.
• The use of machinery will be limited and restricted to existing access tracks, sparsely
vegetated areas and other areas affording negligible opportunities/potential refugia for
hibernating animals. All machinery access routes and working areas will be subject to
ecological searches carried out prior to machinery access.
• Some timber will be chipped. Chipping should either take place in suitable areas outside
thinning areas and then removed off-site, or alternatively, chippings will be added to habitat
piles, thinly dispersed throughout woodland floor or used for future path surfacing works.
• No artificial lighting will be permitted, and no twilight, dusk or night working is permitted.
4.39. All plant, equipment and consumables are to remain inside the defined areas at all times.
23Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Plates 4.7 to 4.8: Woodland subject to ash and hawthorn thinning
Historic hedgerow laying and associated bank profiling, gapping up and fencing/Over mature
hedge pruning and fencing
4.40. As required historic hedgerow restoration works will be undertaken under supervision of a suitably
qualified (Natural England GCN Class licence holder) ecologist. For areas of habitat affording
significant opportunities for supporting GCNs, continuous ecological supervision will be required for
works within 250m of the Dew Pond.
4.41. In order to avoid the bird nesting season, the vegetation clearance works appertaining to the
hedgerow restoration works, and any hedge laying, will be completed by early March 2019.
4.42. In order to avoid potential disturbance to hibernating amphibians and reptiles, fencing and ditch
excavation works within areas of suitable GCN habitat will take place outside the amphibian and
reptiles hibernation period i.e. during spring 2019.
4.43. No works will be permitted unless authorised under an Ecological Permit to Work and Task Risk
Assessment.
4.44. Hedgerow restoration works will be undertaken by a specialist contractor under the instruction and
supervision of a suitably qualified ecologist.
4.45. Both prior to and during hedgerow restoration works, two artificial hibernacula will be constructed at
suitable locations on the peripheries of the areas of retained vegetation. The provision of new
artificial hibernacula will increase shelter, including hibernation, opportunities for amphibians and
reptiles (see Figure 2).
4.46. Any reptiles and common species of amphibians found during ecological searches and or works will
be moved to the nearest suitable place of shelter, including artificial hibernacula.
4.47. Features with potential to shelter GCN will be left undisturbed. If a GCN is found, taking into
consideration the context and safety of the animal, it will be left in-situ with suitable buffer zone left
around it. Natural England will then be consulted.
24Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
4.48. For areas within 250m of the Dew Pond, as required, searches, including hand/fingertip, will be
undertaken prior to hedgerow restoration works. For areas beyond 250m, searches will be carried
out at the discretion of the suitably qualified ecologist.
4.49. Vegetation clearance will be undertaken using hand held power tools, including mechanical
brushcutters and chainsaws. Vegetation will be reduced to a minimum height of 15cm.
4.50. For areas identified by the project ecologist as affording negligible risk for disturbance and or harm
to come to protected species, the use of machinery and equipment such as vehicular mounted post
drivers for fencing operations, small tracked excavators for ditch digging/ soil dispersal will be
permitted. Ecological searches will be carried out for all areas where the use of the latter is needed.
Regarding processing of cut vegetation, the approach outlined within Section 4.39 will be adopted.
4.51. No artificial lighting will be permitted, and no twilight, dusk or night working is permitted.
4.52. All plant, equipment and consumables are to remain inside the defined areas at all times.
Plates 4.9 to 4.10: Historic hedgrows
25Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Plates 4.11 to 4.13: Over mature hedgerows
26Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
Orchard and parkland tree planting
4.53. Given that this activity will take place during the winter, reptile and amphibian hibernation period, and
within areas of cleared vegetation and amenity grassland etc, it is considered that no ecological
supervision of orchard and parkland planting operations is required.
General works in Stoke Park with volunteers
4.54. It is considered that no ecological supervision of orchard and parkland planting operations is
required.
Ecological Supervision, Risk Assessments and Permits
4.55. As has been described above, no work or mobilisation is to take place relating to these vegetation
clearance and habitat enhancement works without the following documents having been
completed/signed off by one of the project ecologists:
• The Ecological Permit to Work and Task Risk Assessment (see Appendix 1); and
• Where necessary, the Variation from Non-Licensable Method Statement (see Appendix 2).
4.56. The variation from the Non-Licensable Method Statement form is to be used in the unlikely event
that unforeseen circumstances require an alteration to the methods described within this document.
This form will be completed by a project ecologist. As noted above the project ecologist will be at
liberty to depart from this methodology if (i) he/she considers that this is preferable in the interests of
protected species or on the basis that the departure will have no worse impact on protected species;
(ii) no offence will consequently arise; and (iii) where a Variation from the Non-Licensable Method
Statement form is completed.
4.57. The Ecological Permit to Work and Task Risk Assessment includes the following details:
• Description and location of task including vegetation clearance/habitat enhancement works
and location plan (if considered necessary);
• Description and location of access routes including location plan (if considered necessary);
• Confirmation that work team (contractor) has attended site induction and/or attended daily
briefing;
• Confirmation that the risk assessment section has been completed and actioned and a
summary of the constraints raised by this – this assessment is for ecological purposes only
to address the risk to protected species not covered by the EPS licence;
• Confirmation that all pre-works checks have been made by a project ecologist; and
• Confirmation of the level of supervision required during the works – supervision may be
constant if there is on-going ecological risk or regular checks made during the works if the
risk is considered to be minimal. This will be noted on the permit and made clear to the work
team (contractor).
4.58. This permit will only be valid for the day and the task in respect of which it is issued. If a task is to
span more than one day, more than one permit will be required. This is to ensure that any changes
to the working area are recorded and addressed appropriately.
4.59. Daily logs and photographs will be maintained as part of the Ecological Permit to Work to
demonstrate full traceability and an ecological audit trail. Records of any animals found will be noted
on the permit along with any additional notes or observations of relevance to the works. A recording
form will be used to keep records of species discovered and other information to be recorded will
include:
• Project ecologist present;
27Non-Licensable Method Statement - Stoke Park Restoration Works September 2018 to March 2019, November 2018
• Duration of ecological supervision;
• Weather (percentage cloud cover/rain/sun);
• Temperature;
• Species discovered;
• Sex of individual discovered;
• Age of individual discovered (adult/juvenile);
• Area on site from which individual discovered;
• Individuals of species seen but escaped; and
• Other - general observations.
4.60. Project ecologists will be identifiable either through the use of approved, project specific badges or
through carrying approval letters. Project ecologists will also be introduced each day to all staff as
part of the daily site briefing.
Response in the event that great crested newt, reptile or nesting bird or other animal is found
during the works
4.61. If a great crested newt, reptile or nesting bird or other animal is found during the works when a project
ecologist is not present, the works must cease whilst a project ecologist is notified and determines
the appropriate course of action. Non-ecological site staff must not touch move or in any way disturb
the animal. Any material which or within which the animal is taking refuge will be replaced
immediately with caution taken not to harm the animal.
4.62. In the event that this occurs, a project ecologist will undertake a full assessment as to the next steps.
If a GCN is found, taking into consideration the context and safety of the animal, it will be left in-situ
with suitable buffer zone left around it. Natural England will then be consulted. Reptiles and common
species of amphibians will be moved by one of the project ecologists.
Inductions/Toolbox Talks and Site Briefings
4.63. A suitably experienced project ecologist will deliver an ecological toolbox talk as part of the overall
site induction to all members of the site team, including the additional supervising ecologist, as the
start of the project (prior to commencement of any works). Attendees will be required to sign a register
(see Appendix 3) to confirm their presence and understanding.
4.64. The induction including the tool box talk will be repeated for any new full or part time staff (including
contractors) member who joins the project after the first day. They will also be required to sign the
register. They will not be permitted to commence works until this is completed.
4.65. The tool box talk will cover the following key issues:
• Background to the site restoration works;
• Basic ecology and identification of GCN, common species of reptiles, common species of
amphibians and nesting birds and how to identify their features of importance;
• Legislation, offences and penalties;
• The Non-Licensable Method Statement;
• Permit to work system including an explanation of the Ecological Permit to Work and task
Risk Assessment; and
• Explanation that if a GCN, reptile, common species of amphibian, nesting bird or any other
animal is unexpectedly discovered then works will cease whilst the project ecologist is
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