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					                         REASONS TO BE TEARFUL: PART ONE


    1. The existing quarry has already damaged the area. It is questionable as to whether environmental
       controls laid down by the Council are respected. Therefore, we believe there is evidence to expect
       further disregard and desecration of the Wenvope/Wrinstone area.
    2. It would cause unacceptable and irreversible damage to a landscape enjoyed by walkers, horse riders,
       cyclists and nature lovers from a wide area of South East Wales.
    3. It would destroy high quality landscape with a 26 acre, 150ft deep scar on the crest of a visually
       important hilltop location. The noise, dust and blasting would ruin the public and visual amenity and
       be an unacceptable nuisance to nearby residents.
    4. It is contrary to the Vale’s own policy regarding Protected Species, harming the habitats of rare bats,
       endangered dormice and badgers and otters, birds of prey, all European and UK protected species.
    5. About 900 yards of ancient hedgerows would be destroyed. Moving the hedgerows, as proposed in
       the plan, is a preposterous idea.
    6. New aggregate reserves are not needed for the Vale during the period of their Urban Development
    7. Here are some of the Welsh Assembly Government policies this ‘superquarry’ contravenes:

        Planning Policy Wales (2002)
        Minerals Planning Policy Wales (2000)
        Minerals Planning Guidance (MPGW) (2004)
        Minerals Technical Advisory Notes (MTAN) Wales 1 Aggregates (2004)

It is also in direct contravention of the Vale of Glamorgan’s own policies:

        ENV 9 :   Conservation of the Countryside
        ENV 10:   Protection of Landscape Features
        ENV 14:   Local Sites of Nature Conservation Significance
        ENV 15:   Protection of Built and Historic Environment.

The Plan is also contrary to the Vale’s Biodiversity Action Plan, which actually proposes to make this a ‘Site
of Interest for Nature Conservation (SINC)’ and departs from their controversial Draft Deposit Unitary
Development Plan because the extensive conveyor and access route is not designated for development.

When the National Assembly’s Planning Guidance Wales 2002 says ‘Ancient and semi-natural woodlands
are irreplaceable habitats of high biodiversity value which should be protected from development that would
result in significant damage’, then this application, which destroys 2 acres of such woodland, must not be
allowed to proceed.

Martin Lucas
Minerals Officer
The Planning Department
Vale of Glamorgan Council
Dock Office
Subway Rd
Barry CF63 4RT
Vale of Glamorgan                                                                             March 29th

Dear Martin
These comments are in connection with the Air Quality Health Impact Assessment
Scoping Report (AQHIASR) associated with the proposed new quarry at Wrinstone
Farm (Wenvoe Quarry Extension 09/00801/FUL).

In the Executive Summary of this report it states that the nearest dust
sensitive receivers are over 400m to the south east of the site and likely to
experience a "very low" frequency of dry north westerly winds which would
present the highest risk of potential dust emission and dispersal. However on
page 5 it states that the nearest dust sensitive receivers, Cwrt yr Ala and the
Coach House, are located east south east of the extension area - a contradiction
and change from east south east in the text to south east in the executive
summary. Also in the same sentence in the text it states the frequency of dry
winds towards this location "will be low". This is changed in the Executive
Summary to "a very low" frequency of dry north westerly winds.

The reference to distances from the site to the nearest dust sensitive
properties are all incorrect. The distance from the application site, for
example to Wrinstone House, Cwrt yr Ala is 275m. Quarry activity, movement of
heavy plant, movement of top soil (all dust generating activities) occurs all
over the application site.

Prevailing winds are winds which blow most frequently. The velocity of the wind
is not taken into account. The dominant wind is decided using two factors, wind
direction and wind velocity. We are all aware of the north westerly and west
north westerly gales and storms which blow into South Wales from the North
Atlantic and are frequent, particularly in the winter. In terms of movement of
dust the greater the velocity of the wind further the dust will be carried. The
smaller dust particles, which present the greatest health danger, are carried
further than the heavier larger particles. The majority of heavier dusts from
quarries will be deposited on trees and vegetation in the quadrants of the
prevailing westerly winds. This dust may build up during periods of lighter
wind but be blown off vegetation, leaves etc when gale force winds occur.

The essential and key issue of whether Michaelston Le Pit and particularly the
residents close to Cwrt yr Ala House (eight properties and twenty-one residents)
are downwind of the quarry is decided by the facts concerning the prevailing
winds and more importantly the dominant wind. On page 5 of the AQHIASR it
states. "The nearest dust sensitive receivers, Cwrt yr Ala and Coach House, are
located east south east of the extension area." In fact the nearest dust
sensitive receivers are Wrinstone House Cwrt yr Ala -at 275m. Therefore the
figures given in the AQHIASR and stated as 'closest distance to the site' are

These properties, as stated, are east south east of the application site, as is
Michaelston Le Pit.

They are in the path of the prevailing westerlies from the application site and
crucially, directly in the path of the west north west dominant wind. "The
direction of the prevailing wind in the vicinity of Wenvoe is from the west and
the direction of the dominant wind is from the west north west." This is a
quote from Professor Gareth Jones' report 'An examination of noise generated by
the proposed new quarry at Wenvoe'. Professor Jones' data is supplied by the
Met Office.

"The nearest dust sensitive locations downwind of the prevailing south westerly
winds are over 1.5km from the extension area and very unlikely to experience any
increase in dust levels. On this basis there is no reason for recommending a
more detailed Health Impact Assessment." (Final extract from AQHIASR Executive
Summary). This statement is incorrect. It takes no account of the dominant
west north west wind which blows directly from the site to the nearest dust
sensitive properties and Michaelston Le Pit. The dominant wind has a greater
capacity to carry dust over distance and is also a prevailing wind, although
less prevailing than the lighter westerly and south westerly winds.

This extract is from Minerals Planning Policy (Wales) MIN TAN (Wales) 1
Aggregates Mar. 2004 75 page 31:

"The Better Health Better Wales Strategic Framework sets out the Assembly's
plans and priorities for action to improve the health impact assessment in
Wales. The potential impact on health must always be considered in relation to
proposals for aggregates extraction and a health impact assessment should be
carried out for any proposal for a new quarry or sand and gravel pit located
within ONE KILOMETER of an existing community."
Hence should not the residents of Cwrt yr Ala, Michaelston le Pit, qualify for a
health impact assessment especially in consideration of the dominant west north
west wind which blows from the proposed new quarry to the properties which are
east south east of the site?

 I believe these facts show the AQHIASR to be unsound and inadequate. Therefore
a new scoping report is required, and given the above facts it is clear that a
more detailed health impact assessment is required. Once again, another aspect
of the EIA appears inadequate.

Yours sincerely

Graeme Jones


The reports by Formaggia Environmental Ltd and Soltys Brewster Ecology on the
ancient hedges of the Wenvoe Quarry Extension provide conclusive evidence that
they are a dormouse habitat. Also, that this habitat is protected by law in the
European Habitats Directive (92/43 EEC).

The report by Formaggia Environmental Ltd also concludes that this part of the
applicant's EIA was inadequate and came to the wrong conclusion in not
recognising the ancient hedges as a dormouse habitat:

"Although the field hedgerows within the proposed scheme are mature and species
rich, they appear to be trimmed and managed regularly and appear to be of
limited value to dormice." (0900801/FUL Wenvoe Quarry Extension EAI Vol. 1
Ecology Ch. 2 pg. 14)
As a consequence of this the EIA does not address the Habitat Directive clauses
i). Is there an alternative to the development?
ii). Is the development imperative for reasons of overriding public interest
including those of a social or economic reason?

"The ecology chapter of the full E.S. 7.0 accordingly concludes in summary, that
in the absence of any physical works within the woodland, there would be no
'disturbance' to the population of dormice within the woodland. As a
consequence there will be no need to seek a licence to 'derogate' the dormouse
population, and there is no need to address the tests which are applied in
seeking to obtain a licence to derogate, including a need to demonstrate that
there is no 'satisfactory alternative.' (0900801/FUL Wenvoe Quarry Extension
EIA Vol. 3 non-tech summary pg. 14)
The EAI is seriously flawed in the crucial 'protected species issue' with
inadequate, misleading and factually incorrect information. I believe the
application should be dismissed through an inadequate EIA provided to the
Planning Authority.

In the recommendation to REFUSE the previous Wenvoe Quarry Extension application
(03/00633/FUL) the Planning Authority states:

1. The applicants have failed to demonstrate that no satisfactory alternative
exists or that the proposal is in the interests of public health and public
safety or other reasons of overriding public interest, including those of a
social or economic nature and beneficial consequences of primary importance for
the environment, despite the site hosting European protected species. The
proposal therefore fails to meet the requirements of the Conservation (Natural
Habitats &c.) Regulations 1994 and EC Directive 92/43 EEC (the Habitat
Directive) and is contrary to the Planning Policy Wales 2002 and the objectives
of Policies ENV 15 (Local Sites of Nature Conservation Significance) and ENV 16
(Protected Species) of the Vale of Glamorgan adopted UDP 1996-2011.

2. Notwithstanding the mitigation measures required the proposal would cause
adverse impacts upon material of nature conservation value, European Protected
Species, ....... and protected Hedgerows and would therefore be contrary to
Policies ENV 11 (Protection of Landscape Features) ENV 15 (Local Sites of Nature
Conservation Significance), and ENV 16 (Protected Species) of the Vale of
Glamorgan adopted Unitary Development Plan 1996-2011."

I would submit that all of the above reasons for refusal are valid for the
current application (09/00802/FUL. There is a loss of dormouse habitat (ancient
hedges, protected by the Habitats Directive) but the applicants have not made a
case for the application being 'imperative for reasons of overriding public
interest,' neither have they made a case for there being 'no alternative' as
they are required to do. It can be concluded that they have failed these two
tests. In any case the Planning Authority found they had failed the two tests
above in the refusal in 2008 of previous application 03/00633/FUL.

The applicants have not demonstrated any significant changes in the situation
since then. I therefore conclude that this precedent still stands, and that the
application must be refused on the Protected Species issue (Habitats Directive).

The current UDP, in reference to the Wenvoe Quarry Extension, specifically
allocated the site "for quarrying within the plan period to 2011" and also "the
site being allocated for mineral extraction in the UDP plan period."

The summary of proposed timings (Wenvoe Quarry Extension EIA Protected Species
Mitigation Strategy 5.3) shows a three-year time span for mitigation completion.
Mitigation planting will require longer to become a viable dormouse habitat.
New hazel plantings (whips) require seven years to produce nuts. (Dormouse
Conservation Handbook 2nd edition) This time scale means that no mineral
extraction will occur as stated in the UDP "within the plan period to 2011." In
fact if permission is granted mineral extraction will first occur well into the
new UDP period.

The extension should not be examined in the light of the outgoing UDP (as it is
in Chapter 15.3 Wenvoe Quarry Extension EIA pg. 189 and frequently elsewhere in
the EIA) but rather examined against the mineral policies of the more relevant
LDP as all extraction at the Wenvoe Quarry Extension (if granted) will take
place during the LDP period.

In the refusal of the previous 2003 Wenvoe Quarry Extension application on 4th
February 2008 it states:
"4.   Having regard to
i). the matters identified in reasons 1-3 above.
ii). The proposed timing of the development.

iii). The expiry date of the Adopted Vale of Glamorgan Unitary Development Plan
"v). work has commenced on the Local Development Plan 2001-2026.
the balance of advantage is against the grant of planning permission."

More than two years have passed since this refusal (Report to Committee). The
LDP period begins in 2011 next year. The UDP policies on minerals will not
longer be relevant. The following quote from the Dormouse Conservation Handbook
2nd edition pg. 46 is relevant to the application:

" Local Planning Authorities do have powers (eg Town and Country Planning
(Applications) Regulations 1988) to direct developers to provide any information
the Authority may reasonably require to enable it to determine the application.
The High Court has ruled ( R versus Cornwall County Council exparte Jill Hardy
22nd September 2000) that for developments requiring an EIA where there are
grounds for believing that protected species may occur environmental information
(primarily survey results) has to be provided to the LPA before determination."

The Wenvoe Quarry Extension: Protected Species Mitigation Strategy Jan 2010
Addendum to Environmental Statements 5.1 (a) pg. 8 states:

a). Re-survey prior to site clearance (dormouse). Depending on the period of
time between the 2009 surveys and commencement ..."

And Wenvoe Quarry extension: Protected Species Mitigation Strategy Jan 2010
Introduction pg. 1 paragraph 4:

"CCW and the Vale of Glamorgan ecologists also requested the following.   A
commitment to re-survey the application site and surroundings to update
protected species information."

As we have shown the EIA of the Wenvoe Quarry Extension was inadequate and
incorrect in its assessment of the ancient hedges of the site and the
information it provided to the LPA was mistaken and misleading.

"Although the field hedgerows within the proposed scheme are mature and species
rich, they appear to be trimmed and managed regularly
and appear to be of limited value to dormice." (0900801/FUL Wenvoe Quarry
Extension EAI Vol. 1 Ecology Ch. 2 pg. 14).

As stated earlier adequate survey results of protected species (dormouse) must
be provided to the LPA before determination. The applicants in the mitigation
strategy are apparently wishing to perform their first adequate dormouse survey
after determination in order to seek a derogation licence, contrary to Town and
Country Planning (Applications) Regulations 1998 (as quoted fully earlier).

The following from MIN P Policy MIN TAN (Wales) Aggregates (Mar 2004) 61 pg. 25
is relevant to the derogation licence process:

"Planning authorities are under a duty to have regard to the requirements of the
Habitats Directive in exercising their functions. To avoid aggregates
extraction projects with planning permission subsequently not being granted a
derogation in relation to European protected species, planning authorities
should take the three requirements for derogation into account when considering
proposals where a European protected species is present. The Welsh Assembly
government intends to bring forward legislation that will place a specific
obligation on LPAs to satisfy the requirements of the Habitats Directive with
respect to European protected species as part of the planning process."


1). At the Wenvoe Quarry Open Day I took the opportunity to question David
Goodman and his planning staff on the alternatives issue. David Goodman told
me, and has told me since, that stone from Taffs Well Quarry had been brought
into Wenvoe Quarry and used for Tarmac production and ready-mix concrete, and
also that Taffs Well aggregate is used at the ready-mix concrete plants at
Cardiff Dock. I am sure that Mr Goodman would speak to the Planning Authority
on this issue for confirmation.

I also asked about the use of Taffs Well aggregate for ready-mix concrete
production. I was told that the disadvantage was that the ready-mix concrete
produced was a shade darker than when Wenvoe aggregate was used to produce
ready-mix concrete, and that it had been known for an architect to specifically
request the lighter shade. This was the only reason given.    I would suggest
that this must represent a very small percentage of overall sales. David
Goodman did not say this although he was present when one of his planners did.

2). I note that it states in the EIA of the new application (Wenvoe Quarry
Extension 09/00801/FUL chapter 3 pg. 9) that limestone at the extension is not
of the high quality that has been mentioned in the previous application (quality
limestone only being found at the deeper levels of the extension). It will
require blending with stone from the deeper levels of the old Wenvoe Quarry 0m
a.o.d. However it also states that winter flooding is preventing extraction at
the deeper levels of the old quarry. The extension only provides 5 million tons
- this is a relatively small amount for such widespread ecological damage.

I contacted David Goodman (CEMEX area manager) by telephone requesting
permission to access the site of the Wenvoe Quarry Extension. He agreed to
this. He suggested that he would telephone the farmer and vendor of the land,
Mr Gwyn Rees, to meet myself and our ecology consultant. Mr Rees met us at the
site in August 2009. After introductions he left.

You may be aware that our ecology consultants met with the applicants'
ecologist (Cresswells) at the site. David Goodman and I were also present. The
site visit was at my suggestion. Our intention was to present our evidence in
situ in the hedges i.e. three dormouse nests, possibly even a dormouse as had
been found previously and various other items evident of dormouse presence. Our
ecologist, Chris Formaggia, found that all evidence had been removed from the
hedges. He felt duty bound to report this criminal act to both CCW and the
Wildlife Crime Police Unit at Bridgend. This is now an on going investigation.
It is important to stress that I attach no blame to anyone in this matter nor do
I have any idea who was responsible.

I have mentioned this issue because I am uneasy about further surveys. Dormice
are easily removed from dormouse tubes and boxes as they are often in a torpid
state. In such a remote area it is possible that unlawful acts may occur.

Graeme Jones
Chair - Conservation Glamorgan
March 2010


Graeme Jones is warden of the Woodland Trust site at Dinas Powys, which is the most visited
Woodland Trust site in Wales, and has been closely involved with its development and expansion.
He is involved in conservation on a full-time voluntary basis.

Conservation Glamorgan has worked closely with the Woodland Trust since 1996. We are
committed to the conservation of the ancient woodlands and ancient species rich hedgerows of the
Vale of Glamorgan. These habitats often represent the last remnants of our biodiversity of flora and
fauna in landscapes of intense agriculture.

The survival of field patterns, sometimes medieval, with the associated hedgerows and sometimes
woodland, is nationally important. However, the lack of survey data and historic landscape
appraisal is almost universal in the Vale of Glamorgan, even when such aspects are priorities in
Local Biodiversity Action Plans. I understand that lack of funding and priority is often the cause.

Without such data landscapes cannot receive designation which recognises their value and assigns
them protection. Conservation Glamorgan opposes the use of greenfield sites for development
where alternative brownfield sites are available.

Conservation Glamorgan has so far been involved with:

   1. Withdrawal of two major housing development applications adjacent to Plymouth Great
      Wood SNAW and the Ely River Conservation Area (Snowdon Road and Pethybridge Road
      housing developments) with the Woodland Trust.
   2. Withdrawal of application for mixed housing/business at Pencoedtre Great Wood ASNW
      with the Woodland Trust and CCW and others.
   3. Withdrawal of 2003 application for Wrinstone Quarry (Wenvoe Quarry Extension) with the
      Woodland Trust.

We are currently involved with the forthcoming LDP and opposition to the new Wenvoe Quarry
Extension application.

Comments on Wenvoe Quarry Extension (new Wrinstone Quarry) Species Mitigation
Strategy (addendum to Environmental Statement January 2010.

1) Disturbance of hibernating dormice
The Dormouse Conservation Handbook (2nd edition 2006) states on page 6 that “dormice
hibernate in or under the ground from about October until April. They are thus affected by ground
disturbance in winter and early spring.” The new quarry will blast with explosives two to three
times a week. The driving of the tunnel 300m through the limestone bedrock will be accomplished
using explosives. This would be on a daily basis for twelve months. (Wenvoe Quarry Extension
EIA no. 09/00801/FUL). The effect on hibernating dormice or active dormice which are sensitive
to ground disturbance is likely to be very damaging.

2) Dormouse population in the ancient hedges
The dormouse found by Soltys Brewster in the ancient hedges was weighed and classified as an
adult, therefore I find the following statement from the mitigation survey unscientific: “Surveys in
August 2009 (Soltys Brewster) have confirmed the presence of occupied dormouse nests in part of
hedgerow H4 although it is still theoretically possible that these nests represent the seasonal
occupation of the hedgerow network by dispersing juvenile animals which would not persist if the
established pattern of annual cutting continues.” The adult dormouse persisted under the long
established pattern of annual cutting. I therefore see no sense in this statement at all. Cemex has
agreed to our request to manage the hedgerows on a three-year cutting cycle. This was however
after the discovery of the dormouse population by our consultants. We have begun a campaign of
distribution of literature promoting this regime including information from an agricultural college.
This includes Wrinstone Farm which manages the hedgerows at the Wenvoe Quarry Extension.

This is the first time that anyone has intervened to support the dormouse population at this location
despite the fact that the rare dormouse is extremely rare in the Vale of Glamorgan. Dormice are a
Biodiversity Action Plan and Local Action Plan priority species requiring action from the Local
Authority and CCW.

3) Mitigation strategy based on misleading data
The strategy of the removal of the ancient hedges of the site (application no. 09/00801/FUL) is
taken from the original EIA: “As stated above the conclusion drawn based on survey information
available at the time of writing the ES was that removal of hedgerows during the winter months
would be unlikely to result in the disturbance of dormice, loss of active dormouse nests, or loss of
habitat of particular value for dormice. However, following the identification of active dormouse
nests in hedgerow H4 it is now considered that, on a precautionary basis, removal of all the
hedgerows during site clearance should be considered a licenceable activity. A Welsh Assembly
Government licence will therefore be obtained in advance of site clearance works.”

“The seasonal restriction to the removal of hedgerow vegetation described in the ES is still
considered appropriate.” (Wenvoe Quarry Extension Protected Species Mitigation Strategy
addendum to ES Jan 2010 5.1 Dormice page 8).

This was written before the survey information from Soltys Brewster and Formaggia Environmental
was known and is therefore out of date and inappropriate. The strategy is fundamentally flawed and
is not in accordance with the Dormouse Conservation Handbook (2nd edition 2006). The applicants
will clear the hedges as if they were not a dormouse habitat protected by the Habitats Directive.
This is totally unacceptable.
The dormouse population present in the ancient hedges, which may be active and out of hibernation
at some point in April and May, (Dormouse Conservation Handbook 2nd edition 2006) could face an
extremely long journey (900m of ancient hedges will be lost) before they reach the woodland of
Coed Cwm Slad, over hedges that have been cut down to their base. For an arboreal species, which
only returns to the ground to hibernate, this would be impossible. Added to this the applicants also
desire to breach the hedge in a number of places for heavy plant crossings and it is the opinion of
our consultants (which is in accordance with the Dormouse Conservation Handbook) this it is
unlikely that any dormice from the hedges would reach the woodland of Coed Cwm Slad. If they
did they would be forced into the territory of other dormice, which is not a sound or acceptable
conservation practice.

“5.7.2. Avoidance of disturbance, killing and injury.
The Habitats Regulations and Wildlife and Countryside Acts are constructed to give protection to
individuals as well as breeding sites and resting places. This means that precautions must be taken
to avoid the deliberate killing or injury of dormice, an action that is most unlikely to be permitted
under licence…” (Dormouse Conservation Handbook 2nd edition 2006 page 48).

Surveys for dormouse in the nearby Woodland Trust ancient woodland have produced negative
results for two years. It is known that the dormouse population in Cwm Slad and Coed y Cymdda
exist under sub optimal conditions. (These woodlands are very narrow remnant strips). I would
remind you that our previous report by Phil Morgan of Just Mammals Consultancy states:
“Although it is recognised that dormice as a species exist at low density, the current situation is
that they are living in a sub optimum habitat and may only just be able to survive in these woods.”
(Page 1 Executive Summary Just Mammals review of ES July 2005).

4) Translocation of dormice

“Where habitat suitable for dormice would be unavoidably lost as a result of development, the
extent of this loss will determine the appropriate course of action. Where habitat loss can be
limited to a strip of woodland or scrub less than 50m wide, or its equivalent, (less than the radius of
a typical dormouse home range) and this strip remains linked to a larger continuous area of
dormouse habitat, then displacement of the resident animals is the most appropriate option. This is
also the most appropriate option where LESS THAN 100m of hedgerow would be removed. Where
greater areas (or lengths of hedgerow) need to be removed in any one season, then translocation of
the animals should be considered.” (Dormouse Conservation Handbook 2nd edition 2006 page 48).

We calculated the length of the hedgerow to be approximately 900m. All three of our consultants,
including the botany consultant, give the width as 3 - 4m. The 2m width of the hedges given in the
mitigation strategy is incorrect.

According to JNCC policy, and, I believe, also CCW policy the translocation of an ancient habitat
(ancient woodland or ancient hedgerows) is not an alternative to in situ conservation and is not
accepted as mitigation to development. Also, the translocation of a species (dormouse) is not an
alternative to in situ conservation and is not accepted as mitigation to development.

Regarding the translocation of dormice, the Dormouse Conservation Handbook page 49 states:

“This is the least favoured option because of the difficulty of catching all the animals and
establishing them at an appropriate site elsewhere. Where a large area of dormouse habitat has to
be removed in a single season, translocation is the only option, but a suitable recipient site must be
identified in advance. Guidance on translocation (and reintroduction) is given elsewhere in this
manual, but it should be noted that translocation requires much preparatory work and finding
suitable release sites can be difficult. Releasing translocated dormice into sites with existing
populations is unlikely to be acceptable to the licensing authorities.”


“Sites suitable for releasing dormice have the following features:
    1. A diverse, unshaded and productive understorey, preferably dominated by hazel.
    2. A variety of other supportive tree and shrub species.
    3. At least 20 ha of suitable habitat, less only if the site is well connected to other woods.
    4. At least 100 nest boxes in place, with appropriate monitoring arrangements.
    5. A commitment to suitable site management in the future.” (Page 58).

“Checklist of things to resolve before releasing dormice:
   1. Are there dormice already present? If so, why are more being released?
   2. Is the site big enough to support a viable population in the long term (that is, more than 20
   3. Is the habitat and its management suitable? If so, why are dormice not present already?
   4. Where are the dormice coming from; are there sufficient numbers?
   5. Have relevant licences and permissions been obtained?
   6. Are the necessary 100 plus nest boxes available, with people to put them up?
   7. Are pre-release cages available and ready to put up?
   8. Is there a team of people organised to ensure daily feeding at the crucial time?
   9. Is there someone who will check the nest boxes regularly, now and in the future?

   10. Have English Nature or the Countryside Council for Wales, and the relevant County
       Wildlife Trust been informed?
   11. Have arrangements been made (and licences obtained) for permanent marking, where long
       term monitoring of individuals is part of the project plan?” (Page 59).

The translocation of dormice carries a great risk of failure. The Dormouse Conservation Handbook
states on page 5 in the forward: “Examples of successful mitigation are still relatively rare.”

Best practice from the Dormouse Conservation Handbook in this case requires you to recommend
translocation of the species because of the length of the hedgerows to be lost. However, it must be
recognised that successful translocation of the species is very unlikely. You cannot therefore have
any certainty that the population of dormice in the hedgerows will maintain their favourable
conservation status, and consequently on a scientific basis you are required to object to this

Graeme Jones
April 2010


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