Draft Local Plan - Supplementary Consultation

No. Local Wildlife Sites and potential Local Wildlife Sites (LWS) have been inconsistently considered in decision making. Some potential LWSs have been assessed by the LWS team against the criteria to inform decision making and some have not. Those that have not should be assumed likely to qualify under the precautionary principle until further survey can be undertaken. LWSs should form a significant constraint to development - currently some sites are included for allocation which would destroy one of these sites of country value to nature conservation.

The Ecological Assessment (Jan 17) for this site identifies habitats of high and moderate ecological value including ponds, species rich hedgerows, veteran trees and meadow grasslands. It makes recommendations for the retention and restoration of the meadow rich grasslands, retention of the species rich hedgerows and the network of ponds which are thought likely to contain Great Crested Newts (protected species).
The Developer proposal does not retain these areas of significant ecological value and therefore we do not support thier concept plan.
The SMBC Illustrative Emerging Concept Masterplan shows the areas of significant ecological constraint are retained along with the hedgerows and some ponds. We would better support this concept plan for the site, but recommend that there is a requirement to provide net gain for biodiversity within the site itself (rather than compensate off-site) given the current value of the natural environment and its position within the landscape.

The Ecological Assessment (Jan 17) identifies areas of woodland and meadow grassland that are of significant ecological value along with species rich hedgerow and veteran trees.
The concept plan proposed by Pegasus and Richbrough Estates retains the some of the meadow grassland, but dissects the field with the access road. The SMBC concept plan shows the access road to one edge of the meadow grassland which would allow better management of the space as one unit. We therefore support the SMBC concept plan.

The Ecology Assessment (Jan 2017) identified significant ecological features; marshy grassland and pond. In addition there is a known population of Great Crested Newts near to the site; they are a protected species and will need mitigation.
Currently neither concept plan retains all the ecological features recommended within the Ecology Assessment (2017); we therefore recommend that the SMBC Concept Plan is amended to show the semi-improved grassland to the centre, south of the site as being retained as natural open-space.

The site has a number of significant ecological features including 3 designated Local Wildlife Sites (LWS) of country importance, a potential LWS, species rich hedgerows and ancient woodland. These are all shown on the Landscape Assessment.
The Developer Site Proposal would destroy both the grassland LWSs and therefore we strongly object to this proposal. LWSs are of county importance and form key components of our ecological network.
The SMBC Illustrative Emerging Concept Masterplan retains the LWSs and more of the hedgerows within the site. We are therefore more supportive of this concept plan. However, it is unclear what the buffer will be between the development parcel and the ancient woodland; as per guidance from the Woodland Trust we recommend that for a development of this scale a minimum of 50m of semi-natural space if provided to buffer the ancient woodland and protect it from harm. In some cases up to 150m buffers have been recommended subject to further information. We therefore recommend that the SMBC concept plan is amended to clearly show a woodland buffer of at least 50m.

The Ecological Assessment identifies that the northern parcel contains two Local Wildlife Sites; Purnell's Brook Woodland and Purnell's Brook Meadow which was surveyed and designated in 2018 by the Local Wildlife Sites Team.
The meadow is thought to be a degraded example of MG4 flood meadow. This type of grassland is extremely rare nationally and locally and would potentially qualify as a habitat of principle importance under section 41 of the Natural Environment and Rural Communities Act (2006). This habitat should be protected and enhanced as part of any development proposal in this area.
Whilst the consultation text refers to the LWSs, they are not shown on the Landscape Assessment informing the draft concept masterplan. Nor have the LWSs been retained and protected within either proposed concept masterplan.
We therefore strongly object to this site allocation as it doesn't appear that the LWSs can be retained. Local Wildlife Sites are of at least county value and should be protected as part of the planning process. They are core components of our ecological network/ Nature Recovery Network.

The Ecology Assessment (2017) identified the key ecological features at the site to be priority semi-improved grasslands, hedgerows and small woodlands, ponds, Rotten Row Fields Local Wildlife Site and 'Meadows Near Landsdowne Farm' potential Local Wildlife Site (LWS).

We understand that the Local Wildlife Sites Team have surveyed part (3 of 5 fields) of the potential LWS in 2017 and that this section has been designated a LWS due to the good example of semi-improved neutral grassland, small pool and hedgerow network.

The remaining 2 fields are yet to be surveyed. A precautionary approach would be to assume that they do qualify as LWS (and therefore should be retained) until sufficient evidence indicates otherwise.

We therefore object to all the concept plan options as they all indicate the loss of the grasslands which haven't been surveyed. We wish to see a concept plan that retains all areas of species rich grassland on a precautionary approach until such a time that a LWS survey indicates they would not qualify and are therefore less than of county significance.

There is a traditional orchard (ref: SP1680) identified on Natural England's Priority Habitat Inventory, accessed via magic.defra.gov.uk/magicmap which has been identified as a notable habitat within the concept plan document landscape assessment section. As a priority habitat, traditional orchards should be retained within development proposals.
The orchard is to the east of the rejected Pinfold Nursery LWS which has been identified as being of high ecological value due to the semi-improved grassland.
The Developer Masterplan proposes to retain the orchard but not the grassland and SMBC's concept plan identifies the need for ecological assessment before a decision is made about the development potential of those field parcels.

Pow Grove LWS and ancient woodland has been identified within the concept plans; however it is unclear what size the semi-natural buffer is that has been left between the woodland and developable areas. The Ecological Assessment has recommended that this buffer is a minimum of 30m to protect the woodland from harm.
We recommend that the concept plans are updated to be clear that the size of the buffer is 30m between the woodland and the development.

The Ecological Assessment (2017) recommends:
The site is part of a potential local wildlife site (Fields SP28G4) which has been recommended for survey but permission to survey has not been granted. The site has an interesting mix of habitats and there is potential for it to be incorporated into a larger local wildlife site incorporating the grassland, open scrub and pond with other nearby habitats.
There are on site and offsite opportunities to restore the grassland to semi-improved quality, reduce the density of scrub and protect the pond and maintain habitat connectivity along the stream and amongst stretches of hedgerows.
The ecological constraints plan identifies constraints across the majority of the site. We therefore object to the allocation of this site due to the significant impact on an ecological feature of country value for nature conservation (using the precautionary approach).