WE NEED YOUR HELP NOW!!! Please sign up and send by e-mail the letter below or write your own letter to: eric.pickles@communities.gsi.gov.uk cc npcu@communities.gsi.gov.uk DNA are calling for the Secretary of State to intervene and hold a PUBLIC INQUIRY before he decides the planning application presented by the Homes and Community Agency for Major Development on the Cinderford Northern Quarter, mainly part of our national publically owned Forest of Dean with over 1300 species recorded to date. Simon Glover Chair of DNA said, “This is a national issue. We are putting at risk here not only the Forest of Dean but also the nation’s most treasured landscapes and wildlife. If the development gains planning permission it is likely to set a planning precedent for major development in other areas of the Forest of Dean, other national, publically owned Forests and other highly sensitive landscape and wildlife areas throughout the UK." REQUEST to the Secretary of State to intervene and hold a public Inquiry To: The Rt Hon Eric Pickles MP. Secretary of State for Communities and Local Government, Department for Communities and Local Government, Eland House, Bressenden Place, LondonSW1E 5DU.E:eric.pickles@communities.gsi.gov.ukcc npcu@communities.gsi.gov.uk I request the Secretary of State to intervene and to call in for his decision P0663/14/OUT Hybrid planning application affecting a public right of way A Hybrid planning application comprising demolition of existing buildings and structures and mixed use development and associated infrastructure and works to include: i) Full details of new highway infrastructure and improvements including a new link road between the A4136 and Broadmoor Road, associated means of access, earthworks, footpaths, landscaping, service infrastructure and other associated works and improvements; and full details of a new education campus including a building of 7,750 square metres (gross external area)(Use Class D1), associated means of access, car parking, earthworks, footpaths, landscaping, service infrastructure and associated works and improvements and, ii) Outline application with all matters reserved apart from access (in part) for up to 195 dwellings (Use Class C3); an hotel (Use Class C1) of upto 3000 sq.m, up to 18,800 sq.m. for employment uses (Use Class B1, B2 and B8) and a class D1 non-residential institutional use and associated internal estate roads, earthworks, car parking, footpaths, landscaping, service infrastructure and other associated works and improvements at the Northern Quarter Cinderford Gloucestershire currently to be decided by the Forest of Dean District Council, for the following reasons: The proposal is of more than local importance because it gives rise to substantial effects beyond the immediate locality, cross-boundary and national controversy, and conflicts with national policies on important matters: National Public Forests should not be used as cheap building land for major development. The majority of the development site is part of the Premier Heritage Forest of Dean, owned by the nation and the site should remain publically owned as recommended by the Independent Panel Report on Forestry wholly accepted by the Government. The site is classic Statutory Forest of Dean, forest and open forest waste with quiet enjoyment of recreation, wildlife and landscape experienced by local residents and visitors. This National Public Forest site will be dramatically and adversely changed into a busy noisy urban polluting environment, degrading landscapes within and vista viewpoints outside the area with 3 story buildings and a raised road running through the site carrying heavy traffic. If the development proceeds it is likely to set an unwarranted national planning precedent for major development in other areas of the Forest of Dean , other publically owned Forests and other highly sensitive landscape and wildlife areas throughout the UK . With the advent of Climate Change it is contrary to Government Policy not to protect such habitats from the destruction, fragmentation and degradation by this major development. It will cause the loss of feeding and breeding habitat and habitat connectivity. Heritage Forests are recognised to be the refuge habitat of many nationally important rare and endangered species. The complex ecosystem of the site will be destroyed by development. This site should never have been allocated for development because of its high ecological value and the raft of declining species it supports. The Environmental Statement (ES) does not recognize the full importance of the existing ecosystem and the interrelated nature of this very complex site, a mosaic of habitat types and part flood zone, which provides feeding and breeding grounds for a great variety of species which have links to or rely upon other species in a classic, interlaced whole ecosystem with the basis arising from the soils, plants and invertebrates providing food for survival. It is envisaged that development will take place from 2014 and continue over the plan period until 2026, whereas the site due to be destroyed, has taken at least 15 years to develop. Many species are unlikely to survive as the Mitigation Plan cannot reproduce compensation areas with the necessary complexity of the existing site in 1or 2 years, if at all, for the great variety of existing species to inhabit before development proceeds and there is no adequate consideration of the effects of disturbance, dust noise and pollution on species or habitat on which they depend, during and after construction. Over 1300 species have been recorded. Many of these species are EU and National protected species, a Lesser Horseshoe Bat maternity roost vital to the maintenance of the SAC, 12 different species of bat, Great Crested Newts, Dormouse, other BAP species of newt and reptile, butterfly, moth and dragon fly, notable and red data book species of birds including the iconic Turtle Dove and Hawfinch. The Wye Valley and Forest of Dean Bat Special Area of Conservation (SAC) is the most important area in the UK for lesser horseshoe bats containing 26% of the national population and is cross boundary. Yet it is to be subjected to the experimental manoeuvre of attempting to relocate a large maternity roost vital to the maintenance of the SAC and the demolition of an existing maternity roost to allow development, contrary to the Habitats Directive and Habitats Regulations. Contrary to National Policy the Planning Application is not accompanied by a comprehensive Appropriate Assessment for public scrutiny as required by the EC Habitats Directive (92/43/EEC) and the Habitat Regulations (amended 2010) as the pre-cautionary principle applies. An Appropriate Assessment must consider effects either alone or in combination with other plans or projects using best scientific evidence. The National Planning Policy Framework suspends the presumption for sustainable development when an Appropriate Assessment is required because of the over riding importance of the Habitats Regulations and Habitats Directive. Therefore it is contrary to Government Policy to have a Biodiversity Strategy Technical Guidance that “only works on the basis of supporting and guiding regeneration proposals, from an ecological perspective. It cannot and should not be seen as a method of deterring development or changing the established planning policy for the AAP” It is not acceptable or ethical to have a Biodiversity Strategy whose foundation has been written by the applicant, to control development on site and be so biased in favour of development to the detriment of Biodiversity. The Forest of Dean (and in particular Linear Park) is the only area in Gloucestershire where the Wood White butterfly can still be found and where the Small Pearl-bordered Fritillary butterfly is still breeding. The proposed development will cause the loss of breeding habitat and habitat connectivity of a number of UK BAP Priority Species of butterfly and moth including the Wood White and the Small Pearl-bordered Fritillary. This is not Sustainable Development as there is no proper weighting given to or between social, economic and environmental considerations and is inadequate in not supplying a comprehensive baseline for comparative study or consider quality of life issues. The District Council received derelict Land Grant funding with a still active condition for unrestricted public access for most of the development site which will now be grossly restricted and the development severely reducing the quiet recreational enjoyment of the site for residents and visitors particularly for those walking the cross boundary national routes, the Gloucestershire Way and the Wysis Way which go through this site. Tourism makes a significant contribution to the Public Forest Estate and the economy of the District. The biodiversity of this site could significantly contribute to the economy of the Public Forest Estate and the economy of the District by ecotourism, as illustrated by the economic generation achieved by the Peregrine Falcons for the Wye Valley and as an educational resource for study and research which could attract EU funding. By the national Indices of Deprivation which uses the 20% percentile to indicate deprivation the Forest of Dean and Cinderford is not a deprived area as their individual percentile sum total is above the 20% percentile. The site is a partial flood zone and Government policy is avoidance for built development. The issue of the interrelated nature of ground water movement both surface and underground, being altered throughout the site by building displacement and the possible effects on the site including underground movement and pollution and on other areas both far and near (eg Laymore Quag) has not been adequately investigated. Alternative solutions are not fully explored such as alternative sites for the different elements of the major development and the effects of the different elements are not explored in full. The site is designated by the Coal Authority as a “High Risk Area” but has not addressed the issue from the viewpoint of alternative sites including retaining the College on the existing larger site The creation of a new college building, hotel and housing is highly inadvisable in an area riddled with mine shafts, post open cast mining infill and part flood zone. There is significant risk of massive overspending of taxpayers' money on the vast additional engineering necessary to prevent collapse of buildings and roads throughout the site. This is not good planning and is not value for money for the taxpayer. The ES does not address the adverse effects on the commercial centre of Cinderford by establishing an isolated satellite development a mile away from the town. o Some existing industrial units closer to Cinderford are unused. o There are vacant areas of land nearer Cinderford Town which are already designated for Industrial use which should be developed in preference to the CNQ. This would be more beneficial to Cinderford than the current proposals and would be far less damaging to the rare and diverse wildlife of CNQ. Additional comments: NAME…….................……………………..PRINT NAME..............………………………… ADDRESS……..........……………………………………………….. POSTCODE.................. Have you objected to the Planning application? If not please use the letter below or write your own letter and send it to planning@fdean.gov.uk OBJECTION TO PLANNING APPLICATION To:Emma Norgate, Council Offices, High St , Coleford, GL16 8HG E planning@fdean.gov.uk Ref: P0663/14/OUT HYBRID Planning Application: A Hybrid planning application comprising demolition of existing buildings and structures and mixed use development and associated infrastructure and works to include: i) Full details of new highway infrastructure and improvements including a new link road between the A4136 and Broadmoor Road, associated means of access, earthworks, footpaths, landscaping, service infrastructure and other associated works and improvements; and full details of a new education campus including a building of 7,750 square metres (gross external area)(Use Class D1), associated means of access, car parking, earthworks, footpaths, landscaping, service infrastructure and associated works and improvements and; ii) Outline application with all matters reserved apart from access (in part) for up to 195 dwellings (Use Class C3); an hotel (Use Class C1) of up to 3000 sq.m, upto 18,800 sq.m. for employment uses (Use Class B1, B2 and B8) and a class D1 non-residential institutional use and associated internal estate roads, earthworks, car parking, footpaths, landscaping, service infrastructure and other associated works and improvements. I object to this planning application and the accompanying Environmental Statement (ES) and ask that permission be refused because:Members of the public are put at a disadvantage by the size, scope and complexity created by the rolling up of 5 major planning applications into 1 planning application and the relatively short period of time before the decision is likely to be made in August 2014. More time should be allowed for responses in a fair and even handed manner. An Appropriate Assessment (AA) is required to accompany this planning application as no Habitats Regulations Assessment (HRA) has been presented with the application. The EC Habitats Directive (92/43/EEC) and the Habitat Regulations as amended 2010 the pre-cautionary principle applies. Possible effects need to be excluded by the promoter therefore without a HRA potential effects become likely significant effects and remain. The Planning Application has been lodged BEFORE the adoption of the Biodiversity Strategy Technical Guidance by the Forest of Dean District Council and the ES does not adequately meet the needs of this Guidance. The baseline in all areas covered by an ES is inadequate in not supplying a comprehensive baseline for comparative study. The majority of the Cinderford Area Action Plan (CAAP) development site is Statutory Forest , a national asset, and should remain so, as recommended by the Independent Panel Report on Forestry. The characteristics of the landscape of the site is classic Forest of Dean Statutory Forest and open forest waste with quiet enjoyment of recreation, wildlife and landscape experienced by local residents and visitors. This will be dramatically and adversely changed by this major development into a busy noisy urban polluting environment, degrading landscapes within and vista viewpoints outside the area with a raised road running through the site carrying heavy traffic and 3 story buildings. The District Council received derelict Land Grant funding with a still active condition for unrestricted public access for most of the development site which will now be restricted much reducing the recreational enjoyment of the site. The quiet creational enjoyment of the site will be greatly affected by the adverse effects of the whole development and degrade the enjoyment of the national walking routes, the Gloucestershire Way and the Wysis Way, which go through this site. The ES does not recognize the full importance of the existing ecosystem and the interrelated nature of this very complex site, a mosaic of habitat types which provides a home for a great variety of species which have links to or rely upon other species in a classic, interlaced whole ecosystem with the basis arising from the soils, plants and invertebrates providing food for survival. The Gloucestershire Wildlife Trust recognises the proposed site as one of the most important Key Wildlife Sites in Gloucestershire, home to many protected species. This site should never have been allocated for development because of its extremely high ecological value and the raft of declining species present, many of these species are EU protected species, a Lesser Horseshoe Bat maternity roost vital to the maintenance of the SAC, 12 different species of bat, all species of newt including Great Crested Newts, many species of reptile including adders, the dormouse, BAP species of butterfly, moth and dragon fly, notable and red data book species of birds This area is extremely important to a number of UK BAP Priority Species of wildlife, all listed because of rapid recent declines, both locally and nationally. The Forest of Dean (and in particular Linear Park) is the only area in Gloucestershire where the Wood White butterfly can still be found and where the Small Pearl-bordered Fritillary butterfly is still breeding. The proposed development will cause the loss of breeding habitat and/or habitat connectivity of a number of UK BAP Priority Species of butterfly and moth including the Wood White and the Small Pearl-bordered Fritillary. If the development proceeds, it is likely to set an unwarranted precedent for development in other highly sensitive wildlife areas in the Forest and throughout the country. The Planning Application has been lodged BEFORE the adoption of the Biodiversity Strategy Technical Guidance by the Forest of Dean District Council and the ES does not adequately meet the needs of the Guidance. There is no adequate consideration of the effects of disturbance, dust noise and pollution on species or the habitat and feeding grounds on which they depend, during and after construction. The ES recognises that the site is designated by the Coal Authority as a “High Risk Area” but has not addressed the issue from the viewpoint of alternative sites including retaining the College on the existing larger site. The creation of a new college building, hotel and housing is highly inadvisable in an area riddled with mine shafts and post open cast mining infill. There is significant risk of massive overspending of taxpayers' money on the vast additional engineering necessary to prevent collapse of buildings and roads throughout the site. This is not good planning and is not value for money for the taxpayer. The ES does not address the adverse effects on the commercial centre of Cinderford by establishing an isolated satellite development a mile away from the town. Some existing industrial units closer to Cinderford are unused. There are vacant areas of land nearer Cinderford Town which are already designated for Industrial use which should be developed in preference to the CNQ. This would be more beneficial to Cinderford than the current proposals and would be far less damaging to the rare and diverse wildlife of CNQ. Additional comments: NAME……................... PRINT NAME................ ADDRESS……............ POSTCODE..................