Mr Richard Fidler South Holland District Council Council Offices Priory Road Spalding Lincolnshire PE11 2XE Banovallum House Manor House Street Horncastle Lincolnshire LN9 5HF Tel: 01507 526667 Fax: 01507 525732 31 July 2013 Dear Mr Fidler Application No: Development: Location: H14-0110-13 Installation of 9 wind turbines (allowing for 50m micro siting), with a maximum height to tip of 126m, substation, access tracks, access bridge, hardstanding areas, external transformers, temporary construction compound and associated infrastructure Land at Fen Farm South Fen West Pinchbeck Spalding Thank you for providing the Lincolnshire Wildlife Trust with the further comments from Wild Frontier Ecology Ltd submitted in response to the comments from the Lincolnshire Wildlife Trust and Natural England. Having reviewed the response made by Wild Frontier Ecology Ltd, the Lincolnshire Wildlife Trust’s comments in relation to this application remain the same as those made in our letter dated 28 March 2013 and reiterated in our response dated 18 June 2013. We continue to have very serious concerns regarding the proposal for a wind farm in this location. It is the opinion of the Trust that the proposed site directly adjacent to two Trust nature reserves, Willow Tree Fen and Pinchbeck Fen Slipe, would be totally unsuitable for the development of a wind farm. The Lincolnshire Wildlife Trust therefore wishes to maintain its objection to this planning application. Whilst the Trust’s position on this planning application remains the same we would like to make some comments in response to some of the statements made by Wild Frontier Ecology. The statements on which we wish to make comments are shown in italics below followed by our response. The data provided by LWT gives no indication that much higher numbers of birds were present on the wind farm site, which would have been overlooked by the lower number of observation hours at dawn and dusk. The bird data that we attached in Appendix 2 of our response dated 28 March 2013 was data that we requested from the Lincolnshire Environmental Records Centre for Willow Tree Fen Nature Reserve and Pinchbeck Fen Slipe Nature Reserve. The area covered by the records did not therefore cover the wind farm site but only land adjacent to the wind farm site. Additionally, bird sightings at the two nature reserves have been made on an ad hoc basis. The records we have for the reserves simply depend on when bird watchers are visiting the reserves and happen to record what they see and submit these sightings to the Lincolnshire Environmental Records Centre. There has been no systematic survey carried out as there has been for the wind farm site. If systematic surveys had been carried out on the two nature reserves we would expect significantly more bird records to be available. The records were included with our original response to demonstrate the significant bird interest of the two nature reserves considering records are ad hoc, and also to show that the Environmental Statement for this proposed development did not include all the relevant bird records relating to the two nature reserves which therefore gave the impression that far fewer bird species are present in the area than there actually are. The LWT data does not appear to indicate a particular concentration of owl activity across the area, with a scattering of records over a number of years. As mentioned above the records from the two reserves are ad hoc records and have not included any systematic nocturnal bird surveys. It is therefore not surprising that there are only a scattering of records over a number of years and we do not feel that these records can be used to make an assessment of owl activity across the area. WFE have now belatedly received the bird records for Willow Tree Fen and Pinchbeck nature reserves, which were not available before the assessment took place, nor before our first response, and have reviewed this data in respect to our observations over the course of the fieldwork phase of the assessment. As stated in our letter dated 18 June 2013 the records we submitted in Appendix 2 of our original response, with the exception of some of the 2012 records, would have been available from the Lincolnshire Environmental Record’s Centre when the data search was undertaken for this development in July 2012. The relative lack of records for scarcer raptors from the two nature reserves agrees well with the data collected by WFE, and would seem to indicate that the area is not particularly important for these species. The LWT data contains just 9 records for marsh harrier, 3 records for hobby, red kite and osprey, and single records for peregrine, merlin and hen harrier, compared to WFE totals of 15, 2, 12, 12, 5, 1 and 0 for these species respectively. We would reiterate that the records from the two nature reserves have been collected on an ad hoc basis. The records from the nature reserves are therefore not comparable to those from the wind farm site where many hours of systematic surveys have taken place. Given the lack of systematic surveys on the nature reserves we do not feel that the records from the reserves can be used to say that the area is not particularly important for the scarcer raptors. Records for nocturnal species (owls) are also fairly scarce, with just 10 of short-eared owl within the dataset, including 6 present in 2011. Barns owls are recorded more frequently (27 records), including three breeding records at Pinchbeck Slipe, although records for the wind farm study area relate to foraging birds, as no breeding habitat is present here. This again would seem to support the view that nocturnal surveys are unnecessary at this site. As mentioned above the records from the two reserves are ad hoc records and have not included any systematic nocturnal bird surveys. Lack of records is therefore an indication of a lack of survey effort rather than a scarcity of owls, and we feel that this data does not therefore justify the view that nocturnal surveys are unncecessary. Wildfowl records show relatively small numbers using the two nature reserves, the most abundant species being wigeon, with numbers peaking at 600 in 1998. There appears to have been a decline in numbers over more recent years, with 165 in 2011 representing the highest recent total, which compares closely with the peak of 180 noted by WFE over the course of the vantage point study. Records for wintering wader species (golden plover and lapwing) also show relatively low numbers occurring on the nature reserves, aside from peaks of 500 golden plover in 1999, and 1000 Lapwings in 2011. The highest recent total for golden plover is just 35 in 2010, compared to the peak count recorded by WFE of 350 during 2011. We would again reiterate that the records from the two nature reserves have been collected on an ad hoc basis. There has been no systematic survey carried out as there has been for the wind farm site. The records can not therefore be used to say that there has been a decline in number of wildfowl such as wigeon or that relatively low numbers of wader species occur on the nature reserves. If systematic surveys had been carried out on the two nature reserves we would expect significantly more bird records to be available. Only on the results of such surveys over a number of years would it be appropriate to base conclusions on population numbers and declines. Thank you again for the opportunity to comment on this additional information. If you have any queries regarding the above please do not hesitate to contact me. Yours sincerely Elizabeth Biott Conservation Officer
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