Response from WWGroup PDF format.
Philip Ridley 25 February 2010
Head of Planning Services
Suffolk Coastal District Council
Suffolk IP12 1AU
Dear Mr Ridley,
Adastral Park Revised Planning Application, January 2010, No. C09/0555
1. The revised plan grossly underestimates the potential increase in recreational use of the Deben Estuary AONB and SSSIs including Newbourne Springs and Martlesham Heath (by walkers, dogs, users of water craft and others), an underestimate that stems from the confusing and serious discrepancy reported between additional population estimates of 1800 and 4800 predicted to follow from this development.
2. Mitigation measures proposed for the AONB and SSSIs will be ineffective. They stand or fall on the ability of a warden to contain the behaviour of a potential 300 new visitors per day to these areas. The proposed measures fail to take into account relevant evidence from the behavioural sciences about human nature. Pollution (noise, air, light, chemical), which is a major disturbance to wildlife, would increase markedly and add to existing damage to fragile habitats. The mitigation proposed as a solution would be too late to prevent substantial and irreparable damage to the environment.
On behalf of the 41 members of the Waldringfield Wildlife Group, we strongly object to the revised application from BT to build at least 2,000 homes on the Adastral Park site. The objections we raised in our previous response to SCDC Housing Distribution – Updated Preferred Option 07/09 (17 November 2009) – still stand in their entirety, and we find nothing in this revision to alter our views. We urge Council to reject the application for the following reasons.
1. Impact on the environment
Our objections refer to the proposal for a large-scale single-site housing development on greenfield land east and south of Adastral Park that is currently agricultural and quarry. The proposal will have an adverse environmental impact on the surrounding countryside, especially on the Suffolk Coasts and Heaths AONB with its Deben Estuary (protected as a SPA and Ramsar site under European law) and the SSSIs at Newbourne Springs, Martlesham Heath and Ipswich Heath. The damage done to these vulnerable wildlife habitats and their plant and animal life would be irreversible.
The proposal to turn the quarry, when the mineral extraction is completed, into lakes surrounded by urban-style parkland, rather than restoring it to its original status as lowland heath (as stipulated in the original planning agreement), is a lost opportunity. Lowland heath thrives in the sandy soils of east Suffolk yet only remnants remain. Its unique plant and animal species are endangered. There is a great opportunity – many would argue an obligation – to restore the land to its original status and thereby save threatened species for future generations to enjoy. Indeed, The Biodiversity Action Plan declared its commitment in 2007 to the creation of 7,600 hectares of heathland by 2015 and doubling this by 2030 (Daily Telegraph, 13.10.07).
This proposed large single-site development would cause carbon, chemical, light and noise pollution to rise to unacceptable levels. The ensuing damage to the wildlife habitats of the AONB would endanger fragile plant, bird, mammal and invertebrate species. For example, the proposal to allow flexibility in the location of the playing field (previously planned for the eastern corner of the site, Environmental Impact Assessment Regulation 19 Statement, para 2.5) would not remove light and noise pollution unless the area is replaced by unlit wildlife-rich habitat. On the contrary, buildings are otherwise likely to occupy that corner.
We query the figures quoted on average Avocet numbers based on the BTO count taken in 2006/2007 of 1 or 2 Avocets during winter months (EIA Reg 19 Statement, Appendix 4.1, para 5.4.1). The figures may be out of date. Our observations suggest Avocet numbers on the Deben between Waldringfield and Martlesham Creek have increased over the last 3 years. It is not unusual to see 15-20 at any one time feeding at the water’s edge during the winter months. The inevitable increase in recreational disturbance from such development on this vulnerable SPA-protected species will reverse the positive trend observed.
The Ramsar-protected snail, Vertigo angustior, population in the saltmarsh at Martlesham Creek is under threat and in need of protection (EIA Reg 19 Statement, Appendix 4.1, para 5.4.2). Avoidance of recreational damage along the Deben Estuary further south could encourage growth of these snail colonies in the saltmarsh. Encouraging growth of vulnerable species as well as protection of current populations is a sound conservation principle that is not followed in this proposal.
The proposal asserts that breeding birds are unlikely to be susceptible to dog predation on the Deben Estuary, unlike heathland birds (EIA Reg 19 Statement, para 4.14, table 1.1). The heathland of Ipswich Heath SSSI would, of course, be susceptible but dog predation is also a problem for ground-nesting birds (eg Oystercatchers and Terns) on marsh and shingle above the high-tide mark of the Deben. Also, Barn Owls hunt on rough pasture adjacent to Waldringfield and Hemley marshes and are susceptible to disturbance by walkers, especially people with dogs. Waldringfield Wildlife Group is collaborating with Suffolk Wildlife Trust’s Community Barn Owl Conservation Project. Barn Owl nest boxes have been installed in trees nearby and are regularly monitored. An increase in recreational use of the Deben Estuary on the scale proposed would jeopardize a project which was set up two years ago and has involved a great deal of local resource. Barn Owls are an endangered species and we [with SWT) are working to increase their numbers in south-east Suffolk.
The proposal maintains that disturbance from dogs in Newbourne Springs SSSI would not occur because the undergrowth is too dense for people and dogs to penetrate (EIA Reg 19 Statement, para 4.14). This is nonsense: Newbourne Springs has large open spaces, produced by regular management and clearance, and an open meadow grazed by sheep in the summer. The undergrowth of the woodland would not deter dogs and people.
We find no convincing evidence in the proposal that the ‘precautionary principle’ has been followed with respect to protection of SPA- and Ramsar-protected species (birds, mollusc, plants). The arguments given are confusing and contradictory. For example, on the one hand the proposal concludes that ’adverse impacts’ are ‘most likely to be a problem for avocets … due to an increase in small craft, and for dark-bellied brent geese … caused by walkers (with and without dogs)’ and on the other hand, that the ‘ ”precautionary principle” was adopted’. (EIA Reg 19 Statement, Appendix 4.1, para 5.4.2). How can the precautionary principle have been adopted when the proposal admits that recreational damage would increase?
The proposal acknowledges but does not follow the Regional Planning Guidance 6 – East Anglia that ‘Development likely to significantly affect sites of international importance for nature conservation should be allowed only if there are no alternative solutions’ (EIA Reg 19 Statement, Appendix 4.1, para 7.3). Yet there is an alternative solution, namely, dispersing the housing needed across the county in small developments rather than planting it all on one large site. The dispersion strategy spreads the benefits and any drawbacks and would help rejuvenate community life in villages and small towns currently in decline. It would cost less because much of the infrastructure needed exists or could be enhanced relatively easily (schools, roads, shops, pubs etc). Above all, a housing dispersion strategy would spread the effects (positive and negative) of increased visitor numbers across the East Anglian countryside, and avoid potential further damage from recreational disturbance to the Deben AONB and its adjacent SSSIs caused by this proposed single-site development.
For this revised proposal, BT consulted a number of external bodies but not, as far as we can tell, wildlife authorities such as Suffolk Wildlife Trust, the Royal Society for the Protection of Birds and the Council for the Protection of Rural England. Why not?
2. Numbers/statistics underpinning the proposal
The proposal’s new resident population predictions are based on statistics that are confusing, dubious and contradictory. Are BT’s predictions calculated on a basis of 1800 or 4800 residents in the new development? There would be a significant shortfall in the necessary allocation of public space on the site if the population prediction has been underestimated (EIA Reg 19 Statement, table 1.1).
We share Pat Williams’ (Natural England) concerns that have not, we feel, been adequately resolved in BT’s response (op cit), even taking into account the mitigation measures proposed. For example, the predicted 10% increase in visitor numbers to the Deben Estuary SPA would be devastating for wildlife habitats. Even a 1% increase would cause unacceptable damage (see evidence by the Suffolk Coasts & Heaths respondent in LDF Appropriate Assessment document, 21.9.09, Appendix 6).
The conclusion to para 5.4.2 (EIA Reg 19 Statement, Appendix 4.1) states that 2000 additional homes (1800 people) ‘would result in an additional 100 people using the paths … everyday and an additional 10 people using small craft along the water’s edge everyday.’ This is an unacceptable increase as it stands but, if the true population increase is nearer 4800 the additional 100 people would be closer to more than 250 every day. Even with the 1800 estimate, this conclusion contradicts the assertion made in the proposal that the ‘precautionary principle’ has been followed.
3. Mitigation measures
The mitigation measures proposed to offset adverse impacts on the protected AONB, SPAs and SSSIs involve a warden, restricting dogs off leads, provision of appropriate signage and publicity material, board walks, way-marked routes and visitor monitoring and management (EIA Reg 19, para 4.9, 4.10). It is our view that these mitigation measures will be marginally effective at best. In fact, this view seems to be implicitly acknowledged in the proposal. Para 4.10 states that ‘Should monitoring of the Deben Estuary SPA/SSSI attributes show that the above mitigation measures are not succeeding in mitigating for the increased recreational pressures of the Adastral Park development, and the population of wintering birds are not being maintained at the current levels, then further mitigation measures would be required.’
Mitigation is no substitute for prevention. Avoiding a large single-site development is the obvious solution and is feasible with a dispersion strategy, as recommended by the LDF for other areas in the Suffolk Coastal District. The statement about further mitigation measures begs many questions. For example, how soon after the initial mitigation measures are installed would an assessment be made to see if they are working? Who would carry out the further assessment? Who would pay for it? What further mitigation measures are envisaged? Above all, irreparable damage would have occurred before any re-assessment is made: a clear case of too little too late.
The proposal’s response to Natural England’s comments (EIA Reg 19, para 4.14, table 1.1) states that ‘mitigation measures can negate the need for an assessment of potential impacts.’ This is beyond our comprehension. The type and extent of mitigation needed must surely depend on the adverse impact predicted and such a prediction, if it is to be valid, requires a full, rigorous and truly independent assessment. We have not found evidence in the proposal that the mitigation measures proposed would be sufficient to offset any adverse impact.
Sally Redfern, Anne Maddison, Christine Fisher Kay
On behalf of the Waldringfield Wildlife Group (41 members)
Cc: WWG members
Rt Hon. John Gummer MP
Councillors Patricia O’Brien, Veronica Falconer
Waldringfield Parish Council
Steve Piotrowski Suffolk Wildlife Trust
Nick Collinson, Suffolk Coasts & Heath Unit, AON
John Jackson, Natural England
Trazar Astley-Reid, Deben Estuary Partnership