Appendix 1: Conservation Target Areas
Eco-towns Team
Housing and Growth Programmes
Department for Communities and
Local Government
2/H9 Eland House
Bressenden Place
London SW1E 5DU
27th June 2008
Dear Sirs,
Consultation response ÒEco-towns Living a greener futureÓ
Introduction
The Berkshire, Buckinghamshire and Oxfordshire Wildlife Trust is
a nature conservation charity working to secure a region rich in wildlife for
the benefit of the our members and the general public. We represent over 50,000
members, principally living within the Upper Thames counties. We own Woodsides
Meadow Nature Reserve which falls within the proposed boundary of the eco-town
at Weston Otmoor. We acquired the site in 1989 to secure its future management
for the benefit of wildlife and people.
The consultation document requests our views on three specific
issues:
Ò¥ the way in which the eco-towns concept is being developed and
the different potential benefits that an eco-town could offer;
¥ how particular features such as greenspace or innovative
approaches to housing can best be developed in an eco-town;
¥ preliminary views on the 15
locations going forward for further assessment;Ó
it then poses specific questions to elaborate on
this last issue. Our response follows that framework. However, we have serious
concerns about two specific aspects of the procedure being followed. These
relate to the information provided to CLG which led to the inclusion of the
Weston Otmoor site on the provisional short-list, and to the presentation of
information regarding the Weston Otmoor site within the consultation document
itself. These concerns are raised at the end of this response.
Summary of response
a)
the way in which
the eco-towns concept is being developed and the different potential benefits
that an eco-town could offer;
We believe that the eco-town concept is poorly
conceived. Whilst the environmental benefits that the concept hopes to place at
the centre of the proposed new settlements are highly laudable, the approach
adopted is highly likely to undermine those very concepts.
b)
how particular
features such as greenspace or innovative approaches to housing can best be
developed in an eco-town;
We believe that features such as greenspace, and
indeed other innovative approached to housing, should be incorporated in all
new developments, and should not be solely focussed upon in the eco-town
context.
c)
preliminary views
on the 15 locations going forward for further assessment
The Weston Otmoor site is the only one that falls
within BBOWT's region. We believe that the choice of the Weston location is
completely unsustainable, will result in irrecoverable ecological damage, and
as such serves to undermine the entire eco-town initiative.
In addition, the information which led to the
inclusion of Weston Otmoor on the provisional list of locations was misleading
and inaccurate, and the consultation document itself is misleading in the way
information relating to the Weston Otmoor location has been presented.
Detailed comments
The eco-town concept should have a positive impact
on wildlife in two ways. Firstly, it is becoming clear that wildlife
populations will come under huge amounts of increasing stress as a result of
climate change. A program such as the Òeco-townsÓ proposal should help to
ensure that the carbon emissions resulting from both the construction of the
new towns, and from the use of the towns by their inhabitants, should help to
mitigate the impact of new development.
Secondly, the eco-towns concept should have allowed for
opportunities to maximise wildlife gains from planned green infrastructure to
enhance biodiversity-rich habitats. The eco-towns prospectus, although
worryingly light on the concept, did at least state that eco-town proposals
should ÒIntegrate green space and
features to enhance biodiversity.Ó and would be expected to ensure ÒAppropriate use of land in terms of quality
and mitigation of impacts on biodiversity.Ó
However, the process then put in place to seek expressions of
interest direct from housing developers has served to undermine the normal
planning checks that would ensure that developments which were likely to have
severely detrimental impacts on wildlife did not come forward. The Weston
Otmoor site would clearly not have come forward through the normal planning
process, given the greenbelt location, the transport issues – adjacent to
the M40 / A34 junction raises huge concerns about the possibilities of limiting
out-commuting – and the massive potential for wildlife impact, as the
site lies on the brow of the watershed that feeds two hydrologically sensitive
Sites of Special Scientific Interest (SSSIs).
The inclusion of the Weston Otmoor site on the eco-town list,
which has arisen because of the method chosen for bringing forward sites
outside of the plan-led planning process, therefore serves to undermine the
entire eco-town concept.
The Berks, Bucks & Oxon Wildlife Trust seeks to
engage with the planning process and with developers to seek wildlife
enhancements through the development process. As such we endorse the stated aim
within PPS9 that planning should seek Òto
conserve, enhance and restore the diversity of EnglandÕs wildlifeÓ.
Paragraph 12 of PPS9 sets out the importance of
networks of important habitats in securing corridors for wildlife dispersal. To
inform landuse decisions the Thames Valley Environmental Records Centre was
commissioned by the local authorities in Oxfordshire to establish where such
networks exist in Oxfordshire. The Weston Otmoor development proposal impacts
directly on one of the networks identified (see Appendix 1), and lies directly
between that Conservation Target Area and one to the North-West of the proposed
site.
The density of housing necessary to provide the
proposed levels of development without impacting on the greenbelt (with
residential housing, at least) precludes the possibility of securing viable
habitat linkages between the target areas, and would lead to exactly the type
of Òfragmentation and isolation of
natural habitatsÓ that PPS9 seeks to avoid.
Incorporating greenspace in a way that allows
ecological enhancement should be at the core of the proposed eco-towns. Sadly,
the process undertaken to bring them forward, stepping outside of the normal
plan-led approach, has led to proposals such as the Weston Otmoor site coming
forward which undermine such enhancement possibilities.
The lack of any ecological input into the panel
giving advice on eco-towns is hugely disappointing, and implies that ecological
considerations do not actually lie at the heart of the eco-towns concept.
The Berks, Bucks & Oxon Wildlife Trust believe that the
Weston Otmoor proposed site should NOT be brought forward as an eco-town. In
our view its inclusion would serve to undermine the credibility of the eco-town
concept as it is not possible within the time-frame set out for eco-towns to
bring forward development on this site with any acceptable level of certainty
that it would not result in enormous damage to the natural environment.
The Weston Otmoor site lies principally on low-lying land, and
intercepts a section of the indicative floodplain as set out in the Environment
AgencyÕs floodplain maps. The site rises gently towards the north, and probably
hydrologically feeds both the Wendlebury Meads and Mansmoor Closes SSSI to the
south and the Weston Fen SSSI to the north-west. Both of the sites are
hydrogically dependant – that is, the rare habitats that they support are
dependant on both ground water and surface water flows being within acceptable
limits, which change throughout the year.
Such sites are incredibly sensitive to hydrological
interference. Monitoring work on the Cricklade Meadows National Nature Reserve
showed that habitats similar to those found within the Wendlebury Meads and Mansmoor
Closes SSSI were lost after three years of heavy rainfall following changes to
the drainage of the site: Òthe data show
a dramatic change in community type over just 3 years. MG4 grassland [species-rich
floodplain grassland of the type at Wendlebury Meads] has retreated considerably whilst swamp communities have expandedÓ[1]
The
proposed location of a new train station and associated parking lie directly to
the north-east of the SSSI. This is of particular concern, given that this is
upstream of the wet grassland SSSI. Given the dependence of the Weston Otmoor
eco-town proposal on the link to the railway line and provision of
park-and-ride facilities, we cannot see how it is possible to proceed with the
development whilst ensuring that ÒThe
scheme will need to ensure adequate protection for the Wendleby [sic] Meads
and Mansmoor grassland SSSI on the southern boundary of the site, which is a
nationally important unaltered lowland hay meadow and will need to be
safeguarded against potential impactsÓ as
stated in the consultation document.
Should the Weston Otmoor site be named in a Òlocation specificÓ
PPS on eco-towns it would clearly come into conflict with current government
planning policy as set out in PPS9.
The grassland habitats found on the SSSI, and within our own
Woodsides Meadows nature reserve, are also highly susceptible to recreational
pressure. The nature reserve itself is merely 3.5ha in size, whilst supporting
incredibly rare habitats (there is thought to be less that 1000 ha of the MG4
grassland that typifies much of the site left in Britain[2]).
The developers have recently issued revised plans which
incorporate a proposal for a wetland area to the north of the SSSI. This does,
on the surface, provide an imaginative approach to mitigating some of the
possible recreational pressure. However, the proposed wetland areas raise
additional questions about the impact on hydrology, and the recreational issues
still remain as the proposal still brings a tramway alongside the SSSI, and
leaves a car parking area within meters of the SSSI.
We welcome the inclusion of a Òsustainability appraisalÓ within
the proposed eco-town process. However, the timescale set out for the process
in the consultation document is woefully inadequate. Hydrological monitoring to
provide information on potential impacts on sensitive habitats needs to be put
in place at least three years before any useful conclusions can be drawn from
the data.
At Oxley Meadow SSSI, in Milton Keynes, which is hydrologically
affected by development, a scheme of monitoring was agreed with English Nature
before a mitigation plan could be put in place. For that scheme eight years of
data have been collected prior to development commencing. Similarly, the Oxford
flood relief channel proposal has required successive years of hydrological
monitoring to be put in place to ensure that the habitats on the Oxford Meadows
Special Area of Conservation, botanically equivalent to those found at
Wendlebury Meads, are not adversely affected.
Although the comments above are focussed on the Wendlebury Meads
SSSI, the hydrological and recreational impacts are equally relevant to the
Weston Fen SSSI site (see Appendix 2 for citations). Although the habitats on
that site are botanically different, they are habitats which are equally
sensitive to hydrological and recreational pressure.
Beyond
the boundaries of the SSSI there are also ecological concerns relating to the
Weston Otmoor site. The SSSI is known to support populations of threatened
butterfly species, including the brown and black hairstreaks. The Highways
Agency and English NatureÕs Butterfly Handbook[3]
states that ÒThe route of the proposed
Waterstock – Wendlebury motorway extension to the M40 was altered mainly
because of the predicted impact it would have to a population of Black
Hairstreak.Ó
These
species occur within the hedgerows on the Wendlebury Meads SSSI, but their
distribution beyond the SSSI is not clear. The sustainability appraisal process
set out in the eco-towns consultation document does not give ample time for an
assessment of the impact on these species to be adequately completed. These
species fly only for very short periods of the year.
The
most recent plans for the Weston Otmoor site show a road link to the A34 / M40
junction. A screening for appropriate assessment (AA) will have to be carried
out to ascertain whether or not an AA will be required, given that the A34 runs
directly through the Oxford Meadows SAC. It is not at all clear from the
consultation document how the eco-towns growth proposals are to be integrated
into the AA of the emerging South East plan, which should be undergoing a
review prior to the issuing of the proposed changes. Given the requirements
within the habitats regulations for assessments of plans and projects to be
considered Òin combinationÓ we cannot see how this fits with the eco-towns
timeline as set out in the consultation document.
We feel that the department for Communities and
Local Government was potentially mis-lead by the information submitted by the
applicants in their Òexpression of interestÓ document.
In particular, the statement under the heading of
ÒEcologyÓ that a Òdetailed assessment has revealed an ecologically mundane
situationÓ is clearly highly misleading. Not only is there no reference to
protected species resulting from this Òdetailed assessmentÓ (there are Great
Crested Newts, protected under European legislation, in the area), highly
significant issues such as the presence of two species of hairstreak butterfly
are not mentioned at all.
It seems clear to us that, although a phase 1
habitat survey had been carried out, together with a ÒwalkoverÓ survey, no
detailed assessment had been carried out at all. If one had been, it would
certainly not have led to a conclusion that the site was Òecologically mundaneÓ.
Even ignoring the presence of one of the most important grassland SSSI
complexes in Britain this fails to recognise the protected species and the
Ancient woodland site within the development boundary.
The same page of the document (page 7) is also
completely incorrect in its presentation of ownership. It stated quite boldly
that Parkridge controls (under option) the site, excluding the MoD owned area.
That is clearly not true. We are the freehold owners of the nature reserve, and
had not even been approached by the developers prior to the submission of their
expression of interest.
The statement continues by stating that Òa
relatively minor part of an SSSI is within the site boundaryÓ. In fact more
than a quarter of the SSSI lies within the boundary drawn on the same page of
the document – presumably this fact led to the removal of the reference
to Òa minor partÓ from the web-version of the document made available to the
public after the provisional list had been drawn up.
The section concludes with a statement that
ÒEcological [É..] assessments have revealed no insurmountable constraint to the
development of the eco-townÓ, yet the developers have not been able to provide
any information indicating that the issue of hydrology has been investigated at
all, potentially the single most damaging aspect of the development proposal
for ecology. They were therefore not in any position to make such a statement
on the basis of the available information.
We
find the CLG consultation document itself highly misleading. The text relating
to the Weston Otmoor site refers to the need to protect the ÒWendlebyMeads [sic] and Mansmoor grassland SSSI on the southern boundary of the siteÓ.
The locations given in the document are described as coming Òwith a
broadly indicative map markingÓ. In the case of Weston Otmoor this marking is shown only to the North of the A34.
We
have received a number of enquiries from our members asking why we are
concerned about the impact of the development on the Wendlebury Meads site when
the government consultation shows the development being all to the north of the
A34. Taken with the statement about the SSSI being on the southern boundary
this has potentially led people to conclude that the development is
sufficiently distant from the SSSI.
We are also concerned about local confusion between the
governmentÕs consultation document and those being issued by the developer in
the surrounding area. I have today received a message from a member of the
trust asking whether the information provided with a document issued by the
developers which states that the consultation deadline is extended to the end
of August relates to the government consultation. The developersÕ document fails
to make clear that it has been produced by and for themselves. It is therefore
being misconstrued as a government document, and the deadline extension is in
danger of creating considerable confusion
Yours faithfully,
Matt Jackson
Head of Policy, Planning and Wider Countryside
Appendix 1: Conservation Target Areas
Appendix 2: SSSI citations
