Bug House, Ham Lane Orton Waterville Peterborough, PE2 5UU Telephone: 01733 201 210 E-mail: info@buglife.org.

uk

Development Control Cornwall Council Lower Bore Street Bodmin PL31 2JX 08 October 2013

Dear Mr Warne, Application reference: PA13/03743 Proposal: Renewable energy project comprising the erection of 16 wind turbines each with a maximum tip height of 130 metres, together with associated access track, hardstanding areas, a substation/control room building and compound, borrow pits, a meteorological mast and a temporary construction and site storage compound Thank you for the opportunity to comment on the above application. Buglife The Invertebrate Conservation Trust objects to planning permission being granted due to inadequate ecological data to inform the decision. The site is of national importance for invertebrates due to the presence of the Tormentil mining bee (Andrena tarsta) and the Tormentil nomad bee (Nomada robertiana), but no invertebrate survey accompanies this application. The development will lead to the loss of and damage to the habitat and nesting site required for these species. The Tormentil mining bee is a species of principal importance in England; whilst it is widespread it is scarce and declining. The population present on the development site is thought to be regionally significant. The importance of this site has been amplified by the presence of the Tormentil nomad bee which is a cuckoo bee entirely reliant on the Tormentil mining bee for its conservation. This nomad bee is in serious decline and this is the only site, in England and Wales, where a population is known. This species is currently a Red Data Book species, classed as Rare. However such is the decline of its distribution it is expected to be re-classed as Critically Endangered when its status is reviewed. For these reasons the site and this population is of national importance. Paragraph 7.8.74 of the Environmental Impact Assessment identifies this site as important for a range of invertebrates and goes on to say that existing records are unlikely to capture the true diversity of the area. Despite this no invertebrate survey has been carried out and there have been no detailed surveys of the area to establish the extent of the Tormentil mining bee and Tormentil nomad bee populations.

President Germaine Greer Chairman Mark Felton CEO Matt Shardlow Buglife The Invertebrate Conservation Trust is a limited company by guarantee Company No: 4132695 Registered Charity No: 1092293 Scottish Charity No: SC040004 Registered in England at Bug House, Ham Lane, Orton Waterville, Peterborough, PE2 5UU www.buglife.org.uk @buzz_dont_tweet

Recommendations in the Environmental Impact Assessment are based on a limited desk based survey and it is likely that the distribution of the mining and nomad bees is wider than previously identified. We therefore request that this information is sought from the application before the application is considered by Cornwall Council to contribute to the Governments commitment to halt the overall decline of biodiversity (NPPF paragraph 109). If planning permission is to be granted we recommend the following condition is set: Prior to any development commencing on site a Landscape and Ecology Mitigation Plan shall be submitted to, and approved in writing by the Local Planning Authority. The plan shall be implemented as approved, unless otherwise agreed in writing by the Local Planning Authority. This plan shall have a primary aim of ensuring that there is no adverse effect upon biodiversity from the development. It must include the following: a) Strategies for each phase of development to mitigate the potential impacts upon local habitats and species from the development. This is to include detail of the micro-siting of turbine 7 and the fence to protect the nesting area, for the Tormentil mining bee and Tormentil nomad bee, during construction. b) Specific surveys to include invertebrates, including Tormentil mining bee and Tormentil nomad bee. Surveys to be undertaken in accordance with methodologies as agreed with the Local Planning Authority, ensuring that surveys are during the optimum survey period, by specialists in the particular species field and to take account of protected species and species and habitats of principal importance in England. c) Details of the survey and monitoring regime for Tormentil mining bee and Tormentil nomad bee with provision for on going monitoring and specific surveys to be carried out before and after each phase of development all against the site baseline of zero development. d) The Habitat Management Plan (HMP) steering group is to include an organisation such as Buglife, able to advise on habitat management to specifically benefit the Tormentil mining bee. If you would like further information on any of the points raised please do not hesitate to contact Buglife on the details above. We would be grateful if we could be kept up to date with the progress of this application and notified of any additional information submitted. Yours sincerely Alice Farr Planning Manager