Alison Fure is a field ecologist specialising in studying the effect of light pollution on wildlife: particularly bats and river corridors. She moderates the Yahoo Group Lights and Wildlife and gave evidence to the Royal Commission on Environmental Pollution (R.I.P). She is the south London contact for the London Bat Group and a local bat warden for Natural England. Alison is an active member of the District and County Bird socs (mainly TQ16, where there are 81 breeding species) and after writing this blog went out to help count a ring-necked parakeet roost in north Surrey.
Indulge me. Close your eyes. Think of an area of open space near your home, possibly urban or suburban in nature. Not a peach, but a raisin, but one sufficiently precious to cause much letter writing when a scabby development may have threatened a portion of the site (Definition of a raisin: not sufficiently NVC-able to have its own robust statutory nature conservation designation that would have prevented the application in the first place.
It may have been a modest development proposal, but sufficient to create a queue of dedicated NGO professionals at subsequent Public Tribunals, waiting to discuss National Priority Species and Habitats, European Protected Species, strategic location, wildlife corridors, light pollution, etc. etc. Your council may have even spent £20,000 on fighting the appeal and it may have its own website. Remember the nice warm feeling when the Victory and Justice headlines appeared in the local rag.
Now be afraid, be very afraid, because we have a scheme in our borough that if approved could be rolled out on your shining jewel or your sacred floodplain. It will bear no resemblance to the original seed kernel, that modest proposal that shyly aspired to occupy a small portion of that riparian site whilst donating 2/3 of its pride to nature. No, it will be the whole nut, its shell and all its siblings, spinning and weaving texts from offshore portals, to baffle Planning Authorities, whose ecological expertise has been sorely depleted due to ‘smaller government’ policies.
A scheme that purports to be the ‘greenest ever constructed in the town’, achieving Code 5 for Sustainable Homes, yet provides 180 car spaces on chalk grassland, a unique habitat in the area (including 4 plants rare to the region).
Designed to retain water in a Flood Cell, whilst its new floating owners admire riverside views, yet evicts every bird, bat and aquatic invertebrate species that has ever loved sweet, dark and uncontaminated, water (including 5% of Surrey’s little grebe breeding population and one of only 4 known Daubenton’s bat maternity colonies in the London Region).
The Planning Inspector stated at the Local, Development Framework hearings (September, 2011) that this was clearly the most designated site in the borough so ‘not to worry luvvies’. But he hadn’t seen this: http://www.communities.gov.uk/planningandbuilding/planningsystem/planningpolicy/planningpolicyframework/ with a clear “presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking” (Para 14).Where, Local Plans should “plan positively for development” (Para 157), “decision-takers at every level should seek to approve applications for sustainable development where possible” (Para 187) and “in assessing and determining development proposals, local planning authorities should apply the presumption in favour of sustainable development” (Para 197) along with a statement to “encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value” (Para 17).
And he hadn’t seen this http://www.defra.gov.uk/publications/2012/03/22/pb13724-habitats-wild-birds-directives/ where Defra has identified four key areas where change will improve implementation of the Directives for the benefit of both the economy and the environment:
• Facilitating nationally significant infrastructure projects
• Improving implementation processes and streamlining guidance
• Improving the quality, quantity and sharing of data
• Improving the customer (i.e. developer) experience
See the above link for a list of the 28 measures put forward to address the above areas for change.
So watch this, to follow our news as a barometer of the effects of the NPPF http://alisonfure.blogspot.co.uk
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One of the most frightening aspects of the site you have described is that the Council in whose area this site lies has only recently agreed, and had passed by a Government Inspector as sound, a new Core Strategy which contains policies and statements which should pevent without question any deveopment on the site. In deed in their evidence the Council stated categorically that the site ‘is not suitable for housing’. And yet at public meetings Councillors and officers discuss all sorts of issues but never that Core Strategy. One wonders why the Council and the Government spent so much public money (i.e. our money) on developing and ‘consulting on’ the Core Strategy only to appear to ignore the policies it contains at the first hurdle!
Thank you for your comment Jill. For this reason it will be interesting to see how paragraphs 113 and 114 in the NPPF will be applied here. Para 113 states Local planning authorities should set criteria based policies against which proposals for any development on or affecting protected wildlife or geodiversity sites or landscape areas will be judged. Distinctions should be made between the hierarchy of international, national and locally designated sites, so that protection is commensurate with their status and gives appropriate weight to their importance and the contribution that they make to wider ecological networks (so there’s the mention of Local sites or SNCI’s)
114. Local planning authorities should: set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure;
This is very difficult to unpick when grouped together like this (as enhancement can be a ‘weasel word’) but I gather the underpinning document Circular 06/05 Biodiversity and Geological Conservation – Statutory Obligations and Their Impact Within the Planning System is still valid. This refers to the Defra ‘Local Sites’ guidance. As the London Plan policy on Local Sites (SNCI’s /SINCs) is consistent with this advice, the council’s new Special Planning Guidance for Biodiversity should reinforce this (provided it doesn’t change too radically from the draft document). If it doesn’t it should be pointed out.