Bergen op Zoom, 25 juli 2006
Aan Burgemeester en Wethouders
der Gemeente Bergen op Zoom
Postbus 35
4600 AA Bergen op Zoom
Betreft: vleermuizen, ons kenmerk LK/6037
Geacht College,
In februari 2005 aanvaardde de gemeenteraad de MER-rapportage “Woningbouwontwikkeling Bergse Haven”. In de veronderstelling dat de daarin aangegeven waarden en mitigerende maatregelen realistisch zijn en derhalve terecht kunnen dienen als basis voor het verkrijgen van ontheffing van de flora- en faunawet.
In de betrokken MER staat aangegeven en wordt benadrukt het belang van het betrokken gebied voor vleermuizen: “Bijzondere aandacht dient echter besteed te worden aan de vleermuizen. Hoewel vaste verblijfplaatsen voor deze dieren ontbreken is het verlies van de Waterschans en de dijk als rijk foerageergebied toch een aantasting van het leefgebied”(pag. 93).
Ook uit figuur 8.4 op pag. 89 blijkt hoe belangrijk het gehele plangebied is voor maar liefst 6 soorten vleermuizen, waaronder in Brabant zeldzame soorten als de rosse en meervleermuis.
Ook in het boekwerk 135.11419.02, waarin de actuele natuurwaarden en de maatregelen worden aangegeven, wordt het bijzondere van deze soorten benadrukt (pag. 16).
Wat ook helder is: het plangebied en de Binnenschelde zijn als geheel een belangrijk foerageergebied voor alle vleermuizen. Ten aanzien van de dwergvleermuis is helder dat zijn verblijfplaats de stad zelf is, maar zijn foerageergebied mede het plangebied betreft.
Als binnenstadbewoner neem ik waar dat vleermuizen graag verblijven in de binnenstad.
Alle vleermuizen zijn extra beschermd op grond van de flora- en faunawet vanwege hun vermelding in bijlage IV van de Habitatrichtlijn.
Op pagina’s 31/33 van het boekwerk 135.11419.02 worden een aantal maatregelen beschreven ten behoeve van de vleermuisverblijven, zoals het creëren van nieuwe verblijven, waaronder de betonnen buiselementen.
In het boekje Vleermuizen van Waanders Uitgevers Zwolle is op pagina 136 te vinden dat betonnen kokers niet door vleermuizen worden gebruikt c.q. ze zijn er niet in aangetroffen.
Compenserende maatregelen zijn goed als ze werken. Als ze slechts dienen om een ontheffing van de flora- en faunawet te krijgen zijn ze zinloos en misleidend.
– Op welke onderzoeken zijn de voorstellen van de maatregelen ten behoeve van vleermuizen gebaseerd?
Graag een schriftelijke opgave van de onderzoeken.
Tenslotte een opmerking in het kader van de zoet/zout-discussie. Bij een eventueel verzilten van de Binnenschelde is een MER rapportage zeker ten aanzien van vleermuizen geboden!
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