Sanctuary – it’s a Lottery

22 Replies to “Sanctuary – it’s a Lottery”

1. I think one can be generally supportive of cycling without supporting everything british cycling gets up to.

2. I don’t buy Lottery tickets either.

   Whilst I recognise that many environmental NGO’s have put Lottery funding to good use, for instance my local WT has been very shrewd at both applying for and spending Lottery monies, I am of the opinion that the National Lottery is nothing more than a socially regressive tax which takes money from the poorest members of society and redistributes it amongst the more affluent middle classes. This should be the other way round.

   1. It is a somewhat patronising view of poor people, suggesting that they are incapable of deciding not to buy a lottery ticket.

      1. Jonathan,

         That is not really what I wrote is it ?

         My gripe is the way that Lottery funding is redistributed, the whole process favours those groups and organisations that are able to dedicate considerable resources into the bid writing, often employing the skills or professional bid writers. You don’t have to Sherlock Holmes to deduce that these groups tend to come from the more affluent sectors of society. Then we have the issue of match-funding requirements..

         This report is interesting:
         http://campaigndirector.moodia.com/Client/Theos/Files/NationalLotteryreport.pdf

         Perhaps my perception of the lottery is tainted by my experience with a junior football team where I used to help out with the coaching. They were based in one the most economically deprived inner-city areas in the UK, an estate where drugs and gun-crime are rife. They had a perfectly good lottery application rejected, whilst in the same year the affluent cricket club down the road in the stock-broker belt was able to refurbish their club house with lottery support.

         Personally I think the whole process stinks.

   2. It is also appears to becoming something of a slush fund for local authorities to apply to for spuriously marketed schemes under the guise of environmental projects.

3. Apologies for going slightly OT but on the subject of petitions, I see that 4793 fools have signed this ludicrous (and poorly worded) petition to ‘Prevent an ecological disaster to wildlife caused by the Otter’

   http://epetitions.direct.gov.uk/petitions/59529

   1. Probably a ‘ott-eaded’ fisherman, and one lacking in an ability to offer evidence based facts in the presentation of a case?

4. The conditions listed in relation to the planning consent include:
   “The compensation strategy shall secure the future preservation of the Alvaston Scrub land, as detailed within the Applicants Statement, submitted 21 January 2014, and provide details of its future enhancement and biodiversity opportunities.”

   Given that the Council has demonstrated that its designation of the Sanctuary as an LNR counted for nothing when a proposal to develop the site came along, how can anyone be confident that the “future preservation of the Alvaston Scrub land” will not itself turn out to be a purely temporary and disposable commitment when someone turns up with a scheme to develop that piece of land?

5. The NL will be devastated to learn that someone who has never bought a ticket will go on never buying one. I wonder if they have built that into their forward planning. I haven’t ever bought one either, but I’m not tellin’ ’em, Pike.

6. Spreading the appeal of cycling will probably have a more beneficial effect in the long term if people are encouraged to cycle more as a small isolated nature reserve with predominantly common species on it isn’t much use ecologically.

   The loss of an urban “nature reserve” that has a few Skylarks and a Dartford Warbler once every 30 years isn’t a massive hit. If it were for economic development then it would be a slightly different matter perhaps. But given what we really need to be doing something about at the moment – our contribution to the changing climate and the effects that will have – I can’t help but feel that this is yet again rearranging the deckchairs on the Titanic.

   1. Steve, more people cycling is certainly a good thing if it means making journeys they might otherwise have made in their car but I rather doubt that the national cycle track will have this effect. It seems much more likely that cycle racing enthusiasts will strap their bikes onto their cars and drive over to the track to do a few laps. I don’t blame them for doing that but it won’t be environmentally beneficial.
      The loss of the Sanctuary nature reserve will not, in the scheme of things be a massive loss perhaps, but it will be yet another chip away at wildlife in this country which is suffering ‘death by a thousand cuts’, each one insignificant by itself but collectively hugely damaging. The loss of the Sanctuary is made much worse by the precedent it sets that planning designations intended to protect wildlife can be so easily disregarded and overturned.
      You are right that we need to reduce the impact we have on the environment and encouraging more people to cycle instead of driving everywhere is part of that. However, the way to achieve that is by making the roads safer to cycle on and encouraging work places to provide decent facilities for cyclists not by trashing nature reserves to make cycling tracks and mountain bike practice.

   2. I think you may have missed the point Steve, the loss of this ‘small isolated nature reserve’ sets a very dangerous precedent (IMHO) in terms of local authorities actions when developers set their sights on designated (theorhetically protected) sites.

7. I know for a fact our local YMCA has received lottery funding all of which was used to help disadvantaged young people. Also, another example is a charity in Yorkshire which helps people suffering from dementia.
   The case in Derby is disgraceful and disappointing, but generalisations are not helpful.

8. It’s easy to carp from afar. Sometimes too easy. However…

   There are too many instances where Lottery money funded works that weren’t really wildlife friendly, e.g. the London Borough of Bromley’s felling of mature trees at Crystal Palace. Hopefully, providing money for nonsensical acts of that sort is mainly in the past – although bold (bad) visions which only include biodiversity considerations as an afterthought aren’t.

   Sport England have also aided and abetted the cause of giving conservationists ulcers. “We’re on a mission and we’ve got money to back it”. All those multi-sport, all-weather, floodlit areas, now covering over locally interesting bits of land and interfering with bats and moths. But what do you think a cash-strapped local authority to do when the offer of money that might go elsewhere is on the cards? New lighting systems help reduce such impacts but I’m sure I’m not alone in rueing some sport-centric developments that have been given the go-ahead.
   Sport England would appear to be a public body. As such it has a duty under Section 40 of the Natural Environment and Rural Communities Act to have regard to biodiversity when carrying out its normal operations, such as encouraging the proliferation of MUGAs and cycle tracks as part of its mission.

   Unfortunately, Sport England is one of those public bodies that hasn’t come to grips with the S.40 duty (Perhaps because it’s not very clear and there are neither sticks nor carrots to back it up. Note to legislators: FAIL). So you’ll find no glossy strategy document to highlight the SC‘s regard for biodiversity or how it goes out of its way to ensure that wildlife impacts are minimised and gains maximised via the projects it supports. No guidance to those initiating or delivering such projects and no pictures of any schemes that have benefited biodiversity. That seems rather a shame. Some might even say shameful.

   In these days of multifunctional greenspace and Green Infrastructure strategies (reflecting the loss of all those sports fields and other green bits in the last twenty years) – some of them even taking account of that new-fangled Ecosystem Services Concept, you would hope that Sport England would do better but search the website for ‘biodiversity’ or ‘wildlife’ and the result will be
   “Showing results 0-0 of Results found: 0” – An apt summary.
   [Note to Natural England/NRW – Exactly when will ‘the conservation of biodiversity become(s) properly embedded in all relevant policies and decisions made by public authorities’ And what percentage of such policies and decisions currently exhibit such engraining of nature?]

   Visit Derby’ Council’s website and you can quickly track down the planning application and the associated paperwork (https://eplanning.derby.gov.uk/acolnet/planningpages02/AcolNetCGI.gov?ACTION=UNWRAP&RIPNAME=Root.PgeDocs&TheSystemkey=95694)

   Do so and you’ll find that the Ecological Impact Assessment (EcIA) of the site was conducted by Mott MacDonald (https://www.mottmac.com/united-kingdom – Their website does mention biodiversity and a number of worthy projects, although they are very few in relation to MM’s overall activities).

   I do wish CIEEM (That’s the now-Chartered Institute of Ecology & Environmental Management – the professional body that serves to promote, improve and ‘police’ ecological consultants as part of its work – so you know its members ought to do a decent job) would introduce a reporting standard that required all the useful evidence and conclusions at the beginning of a report and stuck all the less useful guff in an appendix. ]. The report is OK [Note to consultants: PROOF READ], though some might disagree with the degree of impact and it’s always unsettling when, e.g. ‘a comprehensive floral survey was undertaken’ yet willows are aggregated as Salix spp. And wouldn’t using ISIS and Ellenberg numbers be really helpful in conveying information about the component parts of a site? Not doing the planned pitfall trapping because the ground was too hard? Whilst making statements of fact based on the absence of records is never a good thing. Ah well.

   Wade through the report and you’re presented with the conclusions that (1) the Sanctuary is a site of county importance and that (2) the development (surprise, surprise) will have a significant impact on it.

   The report additionally looks at the development in terms of the loss of Accessible Natural Green Space, but (somewhat bizarrely) only in relation to the amount of land in the Derby area that is LNR designated (A seemingly dubious benefit), rather than ‘what it says on the tin’. Besides which, not all of the LNR is open to access). That said the ‘official’ figures suggest that the development will result in the loss of almost 10% of LNR land within Derby. However, although the loss of the ‘irreplaceable’ LNR is recognised as significant, there is no effort to quantify the impact beyond the loss of area.

   And so we turn our attention to Derby Council. Oh, dear….

   One thing that seems apparent from the EcIA is that, having saved part of the original site as an LNR, the local authority didn’t go out of its way to safeguard its interest. All those nettles and other nutrient greedy plants on the mound that covers the toxic waste repository? Professor Ellenberg says “NO”). And your heart has to go out to the poor sod who wrote a new 5-year management plan for the LNR in 2012. I expect there would have been plans to apply to HLF/BLF to fund some of it too.

   From the Ecological-cum-Impact-cum-Open-Space assessment you’ll see that the desktop study didn’t include a data search of biodiversity information at the local environmental records centre. And that, as you’ll see if you follow the appropriate links, is because

   “Unfortunately, due to recent budget cuts, the Derbyshire Biological Records Centre which was part of the Derby Museum and Art Gallery has now been shut”.

   And if that’s the case, one has to ask exactly how Derby Council is meeting its obligation to ensure it as access to all the necessary environmental information to guide its plans and to determine (even its own) planning applications in accordance with its own policies, the National Planning Policy Framework and the law. If, for example, I was to ring the Chief Executive tomorrow and ask about how the Council (as a public body with a responsibility to have regard to biodiversity conservation) was seeking to conserve species of ‘principal importance for nature conservation’, such as Acosmetia caliginosa for example, of which there are 943 for England. Perhaps we can offer a prize to the first Council member to name those found in Derby. It would be really helpful to have some sort of local record centre to provide such information wouldn’t it, to provide the necessary evidence base.

   And if we visit Derby Council’s website to look at that evidence base (http://www.derby.gov.uk/environment-and-planning/planning/local-development-framework/) we find not a mention of any biodiversity considerations. “But surely any local development plan that the Council might produce ought to comply with NPP requirements?” I hear you cry. [Actually if you search the whole website for ‘biodiversity’ you will get three results, leading you rapidly away to http://www.derbyshirebiodiversity.org.uk (where you can read about the defunct nature of the records centre) amongst other things.]

   Of course, although there is some money from Defra for supporting local records centres it isn’t very much (and there are always new hoops to jump through for it). This means that LRCs are dependent upon Service Level Agreements with the local authorities in their area (+/- money for providing access to that info which LAs ought to have. Of course, not all LAs enter into such agreements – c. 4 of London’s boroughs don’t for example (Do we think those are boroughs that ‘do well by biodiversity’, children?). And even where they do, that still leaves a funding gap, which is +/- made up by charges for the supply and use of information, with the result that the best funded LRCs tend to be those in areas with lots of development proposals. And the whole system (cutting a long story sh) is pretty skewed and inefficient, with not as much benefit to the interests of those who provided the records as one might hope. [Note to Defra: Please work with LRCs to find an effective funding model that will help to ensure that at least all needful biodiversity information will be provided and recording activities better supported in future AND look at sticks and carrots to ensure that local authorities are complying with their information obligations].

   Meanwhile back at the Council. …

   In general, those viewing the Council’s website/strategies will probably be disappointed by how far down the food chain, biodiversity considerations are, but the position is certainly better than some. The Council’s Nature Conservation Strategy of 2006, reads rather well in fact. Amongst other things touching on LNRs, it says this >>

   The special protection to be given to Local Nature Reserves (LNRs) 50 –
   Local Nature Reserves (LNRs) are designated by the City council following discussion with English Nature, primarily designated as a natural resource for local communities. LNRs are often Wildlife Sites or RIGS, but don’t need to be. Once designated, the area covered by the LNR designation will be treated for CDLP policy purposes as if it was a site classified as being of the “most important wildlife site” in terms of protection from harmful developments (even if the site is yet not quite at that biological standard). This is because of the importance such sites offer for public access to high quality semi- natural open space

   So that being the case, what does that suggest about the actual level of protection or indeed the Council’s whole approach to biodiversity conservation? The fine words above, preceded the recession and you have to wonder what will happen when the Council is tempted with other offers of funds in future (Perhaps the Committee confused ‘riding over interests’ with ‘over-riding interests’). It looks like all those objecting to the Sanctuary proposals rather had a point. And it should be said that time and the introduction of the NPPF strengthen rather than weaken the above.

   In contrast to some LPAs, and what some would consider transparency and best practice, DCC does not share its own officers’ reports with the public. Although that can result in some (for some) humorous moments when the officers make recommendations in accordance with policy and their planning committee acts in complete opposition to this , so that the refusal notice is based on entirely different policies [Hello, Basingstoke]

   And what of that opposition?
   Look at the Derbyshire Wildlife Trusts site: http://www.derbyshirewildlifetrust.org.uk/what-we-do/sanctuary-local-nature-reserve and you’ll find a pretty clear commentary on what was wrong with the decision (and what appears to have influenced it) and with the unacceptable nature of the compensation proposals.

   And here are the RSPB’s comments on the ‘evolved’ proposals https://eplanning.derby.gov.uk/acolnet/DocumentsOnline/documents/74162_21.pdf

   Look at the various responses to the proposal and you’ll see that there are lots of well-made points from individual organisations and individuals. Is there a better way of coordinating activity at a local level – and benefitting from past triumphs and failures elsewhere – both to influence local plans, policies and strategies and to respond effectively to development proposals?

   On a personal level, I have no interest in the Sanctuary as a site. What concerns me, and perhaps you, are the following –
   (a) The manner in which the proposal was dealt with
   (b) The inadequacy of the compensation (despite how it is painted in the decision letter)
   (c) The utter lack of consideration of biodiversity in the evidence base for informing the Council’s plans and decisions. The way in which
   (d) How those championing biodiversity conservation locally respond to proposals of this sort
   (e) How professionals and the wider conservation movement deals with ‘sustainable development nationally’.

   So far as (c) is concerned, there is a huge disconnect between all those national Biodiversity 2020 targets and the means of actually achieving them. Whatever the goals set by agencies or government at a national scale, it is at a local level at which species and habitats are gained or lost. Continuing with the NPPF, the planning system is now meant to not only minimise environmental or ecological damage but to result in net enhancement for biodiversity. Given (b) I see no sign of that here and, with (a) no sign that, in its role as local planning authority, the council is acting, is equipped to act or considers it necessary that it acts in a way that is likely to foster biodiversity conservation, despite its aforementioned obligations.

   And so, with each apparently uninformed, off-policy DCC planning decision, biodiversity will be a little worse off. In the absence of information to guide and encourage positive action, or to mitigate negative outcomes, each individual case will be a little worse than it need have been. I wonder what DCCs annual contribution to a Local Record Centre would be, in comparison to the grants for cycling facilities, say.

   And of course, with all those authorities that are slightly better, or somewhat worse than Derby City Council, biodiversity declines cut, by cut, by cut. There is an urgent need for national conservation organisations and the national agencies to ensure that sustainable development, does do what it says on the NFFF tin, and actually further rather than harm biodiversity.

   Does it make much difference if the Sanctuary is lost, whether LNR or no? Locally – It clearly does. The new Derbyshire Wildlife Trust CEO is in for an interesting time. Within the region – How can it be judged without adequate, up-to-date information?

   Meanwhile, the RSPB is advertising for a planning case officer. I very much hope that, in addition to responding to major cases, they working with other organisations will help set something up that could empower local communities to get involved more effectively with influencing local authority plans and strategies as well as responding to individual developments.

   And more widely? It would be good to see DCC’s handling of their own proposal called to account, partly in relation to possible maladministration but particularly in relation to the points above and how it might influence local planning authorities for the better.

   HLF? Sport England? Defra? Perhaps the Sanctuary Affair might also influence them too.

   Yes, carping from afar is easy, but sometimes there are points worth making. Let’s hope others pick them up and get them across better than I.

   [It’s the Reddish Buff, Adam. And it’s not one of the 943 you need to worry about]

9. Steve: this is indeed a small site with really only local significance in terms if its biodiversity. However, the campaign that has been mounted has had a lot of benefits, certainly locally and increasingly nationally. It has shown the city council that conservationists are watching them closely and won’t tolerate damage to other LNRs in the city without putting up a fight, it has brought many wildlife groups together to work alongside each other pretty much for the first time (which bodes well for future, bigger battles here and elsewhere) and it has rattled a few cages at NE and the EA. In addition, it has made other counties aware that their LNRs are by no means safe from development and it is beginning to get the attention of the national media because of the resonance with biodiversity offsetting quite apart from the threats real and imagined to LNRs (the compensation offered here is laughable!).
   And ‘we ain’t done yet’ as they say!
   Nick
   Ps What’s more, it has provoked possibly the longest comment ever to this (or any?) blog from Joe Friday……

10. So, now the decision has been made, is this a clear case for some of the new-fangled Biodiversity Offsetting perhaps? At a ratio of 3:1 or 10:1……

11. I quite like what that Mr Friday had to say. He must be exhausted, poor dear. Something about proof readin and making conservashun more effective with all those diffrent bird-fanciers an tree-huggers working together wasn’t it? Well maybe some one like that George Morbius will follow it up when he’s not unleashin the wolves of yore. I’m not sure. Phraps he was on at us about proofreadin too.

    I like a nice lark meself but I don’t think that that Mr Wally will be a’callin this Sanktry scheme in, even though he don’t swing the same way as most of the Councillors from what I read. But I’m glad he’s realised he likes all those HNC people after all. Just between you, me and Mr Ravery tho’, he does seem to have rather a shaky grasp of herodity.

    Did you know it was that nice Mr Darwin’s birthday today, dear. He didn’t know anything about herodotory either. But look at him now. So maybe there’s hope for Mr Wally and for the skylarks after all too.

12. Sorry Mark but you need to correct something in your blog post. You mention the lottery gives 28 pence for every lottery ticket brought (one pound) however a lottery ticket is now £2 and they now donate 62 pence which IS still bad return unless you’re a really small charity that doesn’t receive big publicity and donations I bet it’s a welcome revenue stream….in fact and correct me if I’m wrong but hasn’t your Stanwick Lakes received funding from the lottery?

    1. Rockingham Trust=£500,000 for encouraging traditional woodland jobs and woodland crafts the end result the oak beam barn/conference room.
       £9,900 to improve access for elderly and disabled
       £5,500 for something about beekeeping (the exact details aren’t availiable what this one was about but I’ve never seen any bee hives have Mark)
       A cycle route (undisclosed amount)
       I wonder where the money for those projects would’ve come from if hadn’t been for the lotto, perhaps from the profits of your books Mark!

13. If the decision including the compensation package doesn’t follow Council policy and could potentially be considered manifestly unreasonable then a challenge through the Local Authority Ombudsman may be worth thinking about. The costs should be a lot less than going through a judicial review. I find the prospect of a Council determining their own application in such controversial circumstances quite troubling for obvious reasons!

14. Thanks Adam…..pretty sure that option is being followed up among several others.
    Nick

15. Pingback: Breaking news: Sanctuary LNR - important stay of execution | Mark Avery

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