Objection to planning application 20/00419 in response to further submissions on Ecology by Quinn Estates. October 2020.
The Friends of Betteshanger object to the above application on the grounds of Planning Policy and Ecology. This document relates to Ecology and is in response to:
The TN2 Ecology Technical Note, the Invertebrate Survey (11/9/20) the amended Open Mosaic Habitat Management Plan (9/ 2020) and the Senior Natural Environment Officer’s Submission (30/9/20)
It is now possible to make a meaningful assessment of the biodiversity interest of the Betteshanger development site. Most of the ecological surveys have been completed, including one for invertebrates, and they reveal a site, not just of importance locally, not just of importance in East Kent, but of wildlife importance at a County level.
We have consulted with Kent Wildlife Trust (Lucy Carden and Dr. Richard Bloor) and sent them a brief summary of the biodiversity interest of the site (see Appendix 1) as shown by the surveys carried out, and they are of the opinion that the site would be very likely to qualify as a Local Wildlife site.
This is what Lucy Carden, assistant Conservation Officer, from Kent Wildlife Trust said:
“From the records you provide within your email, it sounds like it is a particularly good habitat for a variety of species and could potentially be considered as a Local Wildlife Site due to the matrix of habitats present and the range of species present within. I would suggest it would largely meet the criteria of ‘WL3 composite/matrix sites’ and potentially, VP2 for its vascular plant composition and equally meeting criteria for both bird and reptile species composition.
I have had a look in our records too and can see that it is within our list of candidate LWS.
Pennyroyal and grasspoly for example are both listed on the Kent Rare Plant Register. Typically for a site to be designated for its vascular plants, it would need to meet a score of at least 150 based on:
- Nationally rare (i.e. UK Red Data Book) - 100
- Nationally scarce – 50
- Rare in Kent (Kent Red Data Book, 1,2,3 or K status) - 40
- Listed in the current version of the Kent Rare Plants Register – 25
With 7 additional plants listed under the Kent Rare Plants Register alone, this would suggest that it would be likely to meet this criteria.”
What is a Local Wildlife site and why are they important?
Local Wildlife sites are exceptional areas of land and some of the UK’s most valuable wildlife areas. They have a huge part to play in the natural green fabric of our towns and countryside. They make up a web of stepping stones and corridors forming key components of ecological systems and helping to recreate wildlife habitat on a landscape scale. They are identified and selected using robust, scientifically determined criteria and detailed ecological surveys. (see Appendix 2 for a link to the Local Wildlife site criteria)
How relevant is this to the planning application in question?
We believe that the likely qualification, as a Local Wildlife site, provides irrefutable proof that the Betteshanger site is of such significant ecological value that it should be saved from development.
Should Dover District Planning Authority be minded to grant planning permission they would be responsible, in effect for irreparable damage to a potential Local Wildlife site. In our view such action would be impossible to justify, particularly given the Authority’s statutory duty to conserve biodiversity under the terms of the Natural Environment and Rural Communities Act of 2006. Our view is that such action would constitute ecological vandalism.
We are of the opinion that the biodiversity value of the site has been downplayed by the applicant’s ecologists from the beginning of the appraisal process.
We strongly dispute their claims in the Executive Summary of the Updated Ecological Appraisal that ‘the proposals have sought to minimize impacts on biodiversity’ and that ‘it is considered unlikely that the proposals will result in significant harm’ (subject to appropriate avoidance, mitigation and compensation measures) For example, when the proposals are going to destroy Rare plants and invertebrates of National importance (as shown in the results of the Plant and Invertebrate surveys) how can it be claimed that impacts on biodiversity have been minimized, particularly when species cannot be translocated with any guarantee of success ? It is obvious that the proposals will result in irreparable damage or destruction of, a wide range of species and habitat, that will not be compensated for by the proposed plan for Betteshanger Park.
The downplaying is also evidenced by the disputed assessment of the Open Mosaic Habitat on the development site. Both the Natural Environment Officer and the Kent Wildlife Trust have come to the same conclusions about the assessment and claims for biodiversity net gain, made by Aspect Ecology, and shown that they cannot be justified.
This is of particular significance as the biodiversity net gain percentage and the compensation measures proposed depend upon this assessment. It has now been confirmed that under the terms of the forthcoming Environment bill, developers must show a 10% biodiversity net gain so plans need to show how this will be achieved.
Response to the Submission by the Senior Natural Environment Officer.
We agree with all the comments made in relation to TN2 an Ecology Technical Note.
We would also draw attention to the fact that the Invertebrate Survey is incomplete, as surveys were not carried out to assess invertebrate activity in the Spring (contrary to the advice from Natural England) Also survey efforts were focused on the development platforms, at the request of the applicant, so we do not have a complete picture of the site’s value as a whole for invertebrates.
Also missing is a lichen/bryophyte survey despite historical records which show the site could be significant for this group.
In relation to the plans for compensation at Betteshanger Park, we agree with the Natural Environment Officer’s view that the areas currently proposed for enhancement are valuable habitat in their own right. Removing species rich grassland to create open mosaic habitat does not, in our minds, constitute a gain for biodiversity. We are concerned that no botanical data has been seen for area R2 where Aspect Ecology propose scrapes to enhance OMH. Why is this?
Surely before any compensatory plan can be decided upon a full ecological assessment of the proposed area needs to be undertaken to ascertain its current value, as it may well be that to change it would result in an overall biodiversity loss. Unless this is done it will make a mockery of the whole compensation/biodiversity net gain requirement.
We maintain that the ecological value of the development site has been downplayed by the applicant’s ecologists. Are we now seeing the same thing happening with the area at Betteshanger Park proposed for compensation?
We agree that the proposals for creating Turtle Dove habitat are inadequate and we reiterate Natural England’s advice that plans should ‘provide like for like habitat replacements …in a safe position to provide a long term home’.
Given that bird species such as ringed plover and long eared owls have disappeared from Betteshanger Park as a result of human disturbance, we do not believe it would provide a ‘safe home’ for Turtle Doves as they are very wary of people, and given that park activity is bound to increase it would not provide a ’long term home.’
Dover District Council Planning Authority and its responsibility to conserve biodiversity.
The Government requires all public bodies to conserve biodiversity. This duty is enshrined in the Natural Environment and Rural Communities Act 2006. It is also required as part of the National Planning Policy Framework which says:
174 b) Plans should ‘promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species.’
It is widely acknowledged that we are living at a time of unprecedented crisis for the natural world and the Planning Officer and Planning Committee have to decide whether they can justify the irreparable harm that the proposed development will wreak on a potential Local Wildlife Site.
Our view is that they should signal their commitment to conserving biodiversity by rejecting this application.
Evidence of the perilous state of the natural world is currently coming to us from so many different sources that no one can be in any doubt that we are facing an ecological catastrophy.
The Prime Minister, Boris Johnson, signed the Leader’s Pledge for Nature at the UN’s Summit on Biodiversity in September this year. This includes commitments to prioritise a green recovery post covid and deliver ambitious biodiversity targets. This is what he said:
‘We cannot afford to dither and delay because biodiversity loss is happening today and it is happening at a frightening rate. Left unchecked the consequences will be catastrophic for us all. Extinction is forever so our action must be immediate.’
This follows the television programme, Extinction, by David Attenborough and his use of Instagram, and a suite of other recent reports from the Convention on Biological Diversity, the Worldwide Fund for Nature and others, documenting the unprecedented damage the human species is wreaking on the natural world and how it is going to impact us all. There is an excellent overview of the situation by the BBC (follow the link in Appendix 3)
Out of the 90 public comments that this application had received by 1st October, I have counted 57 that state the loss of the site as wildlife habitat as an objection or concern. This does not include the petition. This shows that local people are well aware of the significance of such losses and we hope their concerns will be given sufficient weight in the decision making process.
There has never been a more important time for Dover District Council to show its commitment to stemming biodiversity loss.
The decision on the Betteshanger application provides an opportunity for the Planning Officers and the Planning Committee to show the local community that they take this responsibility seriously and are willing to play their part in stemming the tide of wildlife declines. We urge them to refuse this application.
Sue Sullivan for the Friends of Betteshanger
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