ECOLOGY DUE DILIGENCE REPORT

ECOLOGY DUE DILIGENCE REPORT Saunderton Data Centre GP Limited, Haw Lane, Saunderton November 2010 Our Ref: JSL1776-R-003 RPS Lakesbury House Hiltingbury Road Chandlers Ford Hampshire SO53 5SS Tel: 0238 0810 440 Fax: 0238 0810 449 Email: rpsso@rpsgroup.com

QUALITY MANAGEMENT Prepared by: Nicholas Betson Authorised by: Craig Thomson Date: November 2010 Project Number/Document Reference: JSL1776/ Due Diligence Report DISCLAIMER The opinions and interpretations presented in this report represent our best technical interpretation of the data made available to us. However, due to the uncertainty inherent in the estimation of all parameters, we cannot, and do not guarantee the accuracy or correctness of any interpretation and we shall not, except in the case of gross or wilful negligence on our part, be liable or responsible for any loss, cost damages or expenses incurred or sustained by anyone resulting from any interpretation made by any of our officers, agents or employees. Except for the provision of professional services on a fee basis, RPS does not have a commercial arrangement with any other person or company involved in the interests that are the subject of this report. RPS cannot accept any liability for the correctness, applicability or validity for the information they have provided, or indeed for any consequential costs or losses in this regard. Our efforts have been made on a "best endeavours" basis and no responsibility or liability is warranted or accepted by RPS. COPYRIGHT RPS The material presented in this report is confidential. This report has been prepared for the exclusive use of Saunderton Data Centre GP Limited and shall not be distributed or made available to any other company or person without the knowledge and written consent of Saunderton Data Centre GP Limited or RPS.

CONTENTS EXECUTIVE SUMMARY... 1 1 INTRODUCTION... 2 2 BASELINE ECOLOGY SURVEYS... 4 3 ECOLOGICAL IMPACT ASSESSMENT... 7 4 CONCLUSIONS... 9 5 REFERENCES...10

EXECUTIVE SUMMARY The development of a new data centre by Saunderton Data Centre GP Limited at Saunderton, Buckinghamshire on a former industrial site was granted planning permission in November 2008. An Environmental Statement (ES) for the development was produced by King Sturge LLP in 2008 with the ecology information based on work undertaken by Ove Arup & Partners Ltd in 2007. This in turn was based on ecology work previously completed by Enviros in 2006 (Enviros 2006). This report describes an analysis of the work completed to inform the development against good practice standards and relevant legislation/policy operating at the time to ensure it was fit for purpose. It is concluded that the work undertaken by Ove Arup & Partners Ltd in 2007 is consistent with good practice and, although undertaken over a shorter time period than would normally be recommended, is unlikely to have missed anything of material importance, given the highly developed nature of the site. The work is therefore considered to be adequate to inform the subsequent impact assessment of the development of the site. The Ecological Impact Assessment (EcIA) completed by King Sturge LLP and reported within the ES for the data centre development was undertaken according to standard guidelines, is considered to provide a robust description of impacts and offers sufficient mitigation to account for them. It goes on to provide details of significant appropriate enhancements to the site and is therefore considered to be fit for purpose and fully compliant with all legislation/policy operating at the time it was produced. Overall, the combination of the two work elements is considered to be fit for purpose and provide sufficient detail to ensure all legislation/policy is complied with during the development of the data centre at Saunderton.

1 INTRODUCTION 1.1 The development of a new data centre by Saunderton Data Centre GP Limited at Saunderton, Buckinghamshire on a former industrial site was granted planning permission in November 2008. An Environmental Statement (ES) for the development was produced by King Sturge LLP in 2008 (King Sturge LLP 2008) with the ecology information based on work undertaken by Ove Arup & Partners Ltd (hereafter referred to as the Arups Report) in 2007 (Ove Arup & Partners Ltd 2007). This in turn was based on ecology work previously completed by Enviros in 2006 (Enviros 2006). 1.2 RPS Ecology were commissioned by Saunderton Data Centre GP Limited to produce a due diligence report of the work completed by Ove Arup & Partners Ltd, along with the subsequent assessment within the ES by King Sturge LLP, to ensure that all ecological issues identified were correctly addressed according to best-practice methodologies and legislation in force at the time they were written. 1.3 This report therefore presents a brief overview of the results from each piece of work and assesses them against accepted standards and legislation/policy. Extent of site and description 1.4 The data centre site comprised mostly a mix of buildings and hard standing interspersed by occasional areas of short-mown amenity grassland, covering approximately 10 ha. 1.5 The site is located approximately half a mile to the west of the existing settlement of Saunderton on Haw Lane, accessed by vehicle via the Wycombe Road (A4010). It is set within the rolling Chiltern landscape of chalk hills and dry valleys. Outline of development proposals 1.6 The works would proceed in phases and in brief would include: Demolition of existing buildings; Construction of four data centre buildings in four distinct phases; Creation of a pond during phase 1; Planting of phase-appropriate landscape scheme; and Adoption of appropriate management within fields adjacent to the site. 1.7 A significant feature of each phase of the development is the inclusion of substantial green roofs across the majority of the roof space of each building. These are to be planted and managed as calcareous meadow, in keeping with the surrounding Chiltern countryside. Assessment criteria 1.8 The criteria against which the ecological work completed to inform the impact assessment is to be assessed includes the legislation/policy and best practice survey guidelines that were in force at the time the work was completed.

1.9 The principal legislation and policy to be accounted for includes: Wildlife and Countryside Act 1981, as amended; The Countryside and Rights of Way Act 2000; Natural Environment and Rural Communities Act 2006; The Conservation (Natural Habitats &c.) Regulations (1994); UK Biodiversity Action Plan (BAP); PPS9; Buckinghamshire County Structure Plan 1991-2011; Wycombe District Local Plan to 2011; and Buckinghamshire & Milton Keynes BAP (2000-2010). 1.10 Each element of the survey work and subsequent assessment was set against the requirements of the relevant section of legislation/policy to ensure compliance. Compliance was taken to mean that the survey/assessment, as described within the relevant report, gave due regard to the above legislation and policy. 1.11 Similarly, each piece of survey work was compared with the relevant accepted methodologies (as described in each section below) to ensure the assessments were based on sufficiently robust data. For example, surveys completed at the correct time of the year, using the correct level of survey effort etc. Should any element of the work be deemed not to be in accordance with these requirements, this is highlighted and corrective action to ensure compliance proposed. 1.12 It should also be noted that the survey work described here is over two years old, with the data search described three years old. As such, if in the future, further development were proposed, surveys to update those described here, along with a further data search from BMERC, would be required. This would ensure that the development preceded in a lawful manner, accounting for changes to protected species status, BAP species etc that may have occurred since the Arup/Enviros work was completed. Limitations 1.13 It should be noted that the assessments made here are based on the information provided in the Arups Report (2007); no ground-truthing of survey results has been possible. Therefore, if, in the process of undertaking the original survey work, something of ecological importance was missed (the presence of a Badger sett, for example), it would be beyond the scope of this report to identify that. However, every effort was made within the report to determine if any material issues were potentially missed. 1.14 The 2006 Enviros survey work (Enviros 2006) was not available for review and is therefore not assessed in this report. However, the work completed subsequently (by Arups and King Sturge LLP) should provide sufficient information to inform the assessment undertaken here of due diligence.

2 BASELINE ECOLOGY SURVEYS 2.1 This section provides an overview and assessment of each of the ecology surveys presented in the Arups Report (2007). These included: An extended Phase 1 Habitat survey; Bat survey; and Reptile survey. Extended Phase 1 Habitat Survey 2.2 A walkover survey of the site was completed by an Arups ecologist on the 13 th September 2007 to map the habitats present and identify any that had potential to support protected species. The survey found the site to largely comprise buildings, hardstanding and amenity grassland with some small areas of scrub, immature broad-leaved woodland and semi-improved calcareous grassland. A small, artificial concrete water body was also noted as present. 2.3 Although not stated as such within the report, the description of habitats and associated field map demonstrate that the survey was apparently completed according to accepted best-practice methods (JNCC 2003). 2.4 The timing of the survey in mid September is within the standard habitat survey season (April to September), although, as acknowledged in the Arups Report, some species etc may not have been visible at the time of survey. This limitation is present for all botanical surveys and, from the detail provided, is not considered to have impacted on the final definition of habitats given within the report. 2.5 The assessment of the relative conservation importance of the habitats notes that the majority of those present within the site are of little ecological value, beyond those of semi-natural origin (the calcareous grassland, for example), all of which are to be retained within the final development. The assessment goes on to provide potential enhancement measures, in accordance with PPS9, to further the aims of both UK and Buckinghamshire & Milton Keynes BAP (provision of ponds and increased areas of calcareous grassland). 2.6 As well as classifying the habitats present, the survey sought to identify those features of the site that had potential to support protected or otherwise notable species. From this, further surveys for bats and reptiles were recommended and the potential presence of breeding birds within vegetation noted. The potential for protected or rare amphibians within the water body recorded on site was discounted on the basis of that the habitat was not suitable, lacking sufficient vegetation. 2.7 From the information presented in the report, it is considered the conclusions were justified and, given the information presented in the Arups Report, the recommended further surveys the only ones necessary to fully inform an impact assessment of the development. 2.8 It is therefore concluded that the Extended Phase 1 Habitat Survey conducted by Arups was undertaken at an appropriate time of year to recognised standards and that the further work/assessment of conservation significance is supported by the evidence presented.

Bat surveys 2.9 The Bat survey presented in the Arups Report comprised an inspection of the interior roof voids of two buildings identified as having potential to support bat roosts and emergence/activity surveys within the wider site. The surveys did not identify any roost within the buildings to be demolished but did note bat activity (foraging and commuting) along the boundary with Haw Lane and the southern site boundary. No activity was identified within the majority of the (developed) site. 2.10 All bat surveys were noted in the Arups Report as being undertaken according to the best practice guidelines; Bat Mitigation Guidelines (English Nature 2004) and Bat Surveys; Good Practice Guidelines (BCT 2007). The survey methodology, as described, for both internal inspections and emergence/activity surveys is consistent with this statement. 2.11 The internal inspections were carried out on the 24 th September 2007. Such surveys can be completed at any time of the year. 2.12 The emergence/activity surveys were completed on the 13 th and 24 th September 2007 with a dawn swarming survey on the 25 th September. This survey effort is in accordance with good practice guidelines for a site of this nature (highly developed and therefore low potential) requiring three survey visits (including a dusk/dawn within one 24 hour period). 2.13 Although the survey guidelines state that the period for such surveys is between March and September, the optimum period of activity is between June and August (BCT 2007). However, given the low quality nature of much of the site for bat foraging/commuting it is considered that this is unlikely to have compromised the findings of the survey. 2.14 The assessment of the importance of the site for bats takes account of the relevant legislation and acknowledges that some short-term impacts to bats using the site are possible during the construction phase from increased activity on site. However, the report also provides suitable enhancement suggestions to ensure that, in the long-term, the quality of the site is improved for bats. 2.15 Although the emergence/activity surveys were conducted outside of the optimum period, it is concluded that this is not likely to have materially impacted the results (given the low quality habitat available on the majority of the site). The survey work in relation to bats is therefore considered to have been completed to a suitable standard and it is concluded therefore that the assessment of the impacts on bats is sufficiently robust. Reptile surveys 2.16 The reptile surveys completed on site presented in the Arups Report assessed the semi-natural fringes of the site, as identified during the Extended Phase 1 Habitat Survey. No reptiles were recorded as being present within the areas surveyed. 2.17 The Arups Report stated that the methodology for the reptile surveys followed that of standard guidelines (Froglife 1999, Gent & Gibson 1998 and HGBI 1998). Methodologies described in the Arups Report support this. 2.18 Although surveys for reptiles can often be undertaken until mid-late October, depending on the weather conditions, and September is considered to be an optimum time as young reptiles will

be active enough to be detected, it is generally recommended that the period over which the survey is undertaken is extended as long as possible (Froglife 1999), thereby allowing time for any reptiles present to find the refugia. Therefore, only allowing five days between laying the refugia in the field and the start of surveys, combined with undertaking the surveys over seven consecutive days means that the survey took less than two weeks to complete. While this is still compliant with the requirements of the standard guidelines and, as described in the report, any substantial population present is likely to have been detected, it may be that a small population may not have been recorded. 2.19 However, those areas of habitat that may support such small populations are being retained within the final development and landscape measures suggested provide enhanced habitat for reptiles overall. Therefore, it is considered that the conclusions within the Arups Report will not have been impacted by this short survey period. Background data search 2.20 A background data search from the Buckinghamshire and Milton Keynes Environmental Records Centre (BMERC) had been undertaken previously by Enviros in 2006 (Enviros 2006). This was reported again within the Arups Report. The government website Multi-Agency Geographic Information for the Countryside (MAGIC) and Natural England website Nature on the Map were also consulted to provide information on local designated sites. 2.21 The range of sources consulted is consistent with good practice in ascertaining existing background ecological data to inform impact assessment. Although no update was compiled for the Arups 2007 report, it is considered that this will not have impacted the final conclusions within this report.

3 ECOLOGICAL IMPACT ASSESSMENT 3.1 The ecological impact assessment (EcIA) undertaken by King Sturge LLP and presented in the ecology chapter of the ES for the data centre was based on the site work undertaken by Arups which in turn updated that completed by Enviros in 2006. It presented an assessment of the impact of the development of the data centre on the ecology on and around the Haw Lane site. Consultation 3.2 Along with the data presented within the Arups Report, the EcIA presented consultations with a range of statutory and non-statutory bodies including: Natural England; Environment Agency; RSPB; Chilterns Area of Outstanding Natural Beauty Board; National Trust; Wildlife Trust; Berkshire and South Buckinghamshire Bat Group; North Bucks Bat Group; and Wycombe Wildlife Group. 3.3 Responses from the consultation exercise are included within the final ecology chapter and have been incorporated, where relevant into the final EcIA. 3.4 The range of bodies contacted is consistent with good practice in ascertaining a sufficient level of background detail and the views of relevant stakeholders. Impact assessment 3.5 The King Sturge LLP EcIA states that it was completed according to the Guidelines for Ecological Impact Assessment in the United Kingdom (IEEM 2006). This involves assigning a value to an ecological resource within the site dependent on a range of factors such as geographic frame of reference, biodiversity value etc. The impact assessment then considers the potential impacts and effects to each resource (negative/positive, magnitude etc) and the significance of that impact based on the size/value of the resource, the duration of the effect etc. Finally, potential mitigation/enhancement is presented to reduce/avoid any negative impacts identified. 3.6 The methodology used to complete the EcIA is consistent with standard industry good practice and the evidence relating to how this methodology was applied to the data centre development presented within the ecology chapter supports this. 3.7 From the data collected by Arups, the following ecological resources (with the assigned ecological value shown in parenthesis) were identified on or near the site:

Bradenham Woods, Park Wood and the Coppice Site of Special Scientific Interest (National); Hearton Wood County Wildlife Site (Regional); Locally designated sites (County and Regional); Bats (foraging and commuting) (Local); Birds (District); and Significant Habitat Features (Local). 3.8 The rationale behind the selection of these resources and their respective value, although not presented in detail within the chapter, is logical and accounts for the ecological features found on site during the Arup / Enviros surveys. 3.9 The subsequent assessment of effects and significance accounts for both the construction and operational phases. Each resource is dealt with in turn and a coherent description of the potential for impacts as a result of the development and its significance is presented. The impact assessment and the manner in which each resource is dealt with is consistent with good practice and is considered to appropriately describe the potential impacts to ecology of the development. 3.10 Potential mitigation to minimise/eliminate those impacts is also presented along with future enhancement. This includes: The implementation of an appropriate lighting regime to avoid impacts to bats; Clearance of vegetation outside of the breeding bird season; Protection of retained vegetation to ensure continuity of bird nesting habitat; The creation and implementation of a full landscape and ecology strategy and management plan for the site to ensure habitats are managed for biodiversity benefit; Creation of ponds as part of drainage management; Reinforcement of hedgerows; Creation of calcareous grassland green roofs on all four of the data centre buildings; and Management of two adjacent fields to encourage their reversion to calcareous grassland. 3.11 The range of mitigation proposed is considered to adequately account for the impacts described and therefore ensure that the overall direct impact of the development on ecology is negligible. The range of enhancement measures, taken on top of the mitigation, is considered sufficient to provide an overall increase in the biodiversity value of the site, in line with government policy. 3.12 Overall, it is considered that the EcIA completed by King Sturge LLP presented within the ecology chapter of the ES for the data centre development is consistent with good practice. It provides a robust description and analysis of impacts including sufficient mitigation/enhancement to ensure the overall development provides a net gain for biodiversity in the area.

4 CONCLUSIONS 4.1 The work relating to ecology undertaken to inform the development of the data centre at Saunderton has been reviewed for consistency with good practice and compliance with legislation/policy. 4.2 From the information available, it is concluded that the survey work and background data search undertaken by Arups in 2007 is consistent with good practice. Although the reptile survey was undertaken over a relatively shorter time period than would normally be recommended, this is unlikely to have missed anything of material importance. The work is therefore considered to be adequate to inform the subsequent impact assessment of the development of the site. 4.3 From the information available, the EcIA completed by King Sturge LLP and reported within the ES for the data centre development was undertaken according to standard guidelines and is considered to provide a robust description of impacts and offers sufficient mitigation to account for them. It goes on to provide details of significant enhancements to the site and is therefore considered to be fit for purpose and fully compliant with relevant legislation/policy.

5 REFERENCES Bat Conservation Trust (2007) Bat Surveys- Good Practice Guidelines. Bat Conservation Trust, London. English Nature (2004) Bat Mitigation Guidelines. English Nature, Peterborough. Enviros (2006) Extended Phase 1 Habitat Report. Enviros. London. Froglife (1999) Reptile survey: an introduction to planning, conducting and interpreting surveys for snake and lizard conservation. Froglife Advice Sheet 10. Froglife. Halesworth. Gent T. & Gibson S. (1998) Herpetofauna Worker s Manual. JNCC, Peterborough. Herpetofauna Groups of Britain and Ireland (HGBI) (1998) Evaluating local mitigation/translocation programmes: Maintaining best practice and lawful standards. HGBI advisory notes for ARGs. HGBI c/o Froglife, Halesworth. IEEM (2006) Guidelines for Ecological Impact Assessment in the United Kingdom. IEEM, Winchester. JNCC (2003) Handbook for Phase 1 habitat survey a technique for environmental audit. JNCC Peterborough. King Sturge LLP (2008) Molins Site Haw Lane, Saunderton: Environmental Statement. King Sturge LLP, London. Ove Arup & Partners (2007) e-shelter Saunderton: Baseline Ecology Report. Ove Arup & Partners, London.