Dear Mr Simon Rees Planning Officer and The Wychavon Planning Committee.
I strongly object to the Application W/13/01511/PN and would like to draw your
attention to Impacts on local wild life and Protected species & Issues with the
applicants Ecology Survey which I urge you to consider and reject the application as a
result.
The residents of the local parishes are concerned the local wildlife and biodiversity
areas of concern are going to be greatly affected or lost if the proposed broiler
chicken farm is permitted and the emissions that will emanate from the activities
potentially polluting the following sites or wildlife receptors:
‐
The nearby piddle brook
‐
Naunton Court Meadows SSSI
‐
Worcestershire
Wildlife
Trust
Naunton
Court
Fields
http://www.worcswildlifetrust.co.uk/reserves/naunton-court-fields
Grassland habitats.
‐
Worcestershire
Wildlife
Trust
–
Piddle
brook
Meadows
http://www.worcswildlifetrust.co.uk/reserves/piddle-brook-meadows
‐
North Piddle Meadows – on the Wychavon register of Special wildlife
species Site : SO95/19
‐
A number of Ponds on land adjacent and nearby to proposed site which
provide great crested newts with breeding ponds and surrounding land
up to 1km from the ponds providing forage and hibernation habitat for
the newts.
We would like to draw your attention to a Local residents Wildlife blog that
they have developed showing the wildlife they see in the local area and their
concerns about the impacts of the proposed chicken farm
http://worcestershirewildlifediary.blogspot.co.uk/
The applicant has conducted a “phase 1 extended habitat survey” which is
available on the planning case file webpage. The survey only appears to have
covered the habitats within the applicants site i.e. the building foot print and
access track to the buildings and 25m from this footprint. The applicant has not
sought permission from the local land owners at Froghall farm to conduct a
survey of the surrounding land. The survey has not covered the adjacent land
and ponds within the localised area in which the land owners and local
residents state great crested newts have been seen and found. The applicant
has also refused permissions to the action group to allow it to do their own
ecology survey of the land.
We would like to draw your attention to a map I have produced shown In
appendix 1 to indicate the location of the ponds and the close proximity to the
applicants land and proposed building location. The ponds were mapped with
permission of the land owners.
A large number of the ponds are within 1km of the proposed building footprint
and therefore the building is likely to be on the foraging and hibernating
habitat of the Great Crested Newts. There is also a pond on a within 1km north
of point 2 on the map near North piddle this pond also has great crested newts
in it. Also if you look on an OS map of North Piddle which is north of the
applicants site there are a number of ponds in and around the village on the
map which residents indicate have varying populations of great crested newts.
The ponds and land ditches that link some of them all the way down to Piddle
brook provide a unique wildlife corridor and habitat for the newts and other
important wildlife species that residents feel will be detrimentally affected by
interruption of the wildlife corridor and run off pollution from the proposed
broiler farm.
The applicants survey stated there are no records of great crested newts within
1 km of the site, however the land owners of where the ponds are located are
insistent that they have been found on their land. So just because there is not
a formal record of the species there does not mean they don’t exist. Therefore
the residents do not feel the survey is representative of the wider picture and
extensive enough to establish the wider localised habitats, protected species
and potential impacts. 6.6.12 of the applicants survey states ‘The surrounding
habitat is potentially important and the development site many impact upon
mobile species.’
As there is some uncertainty over the distribution of great crested newts in the
immediate area adjacent to the proposed site it is difficult to be sure whether
there is any likelihood of them occurring in and around the proposed site.
Although there are no water bodies within the site and therefore no breeding
site for amphibians. It is possible for newts to occur during their terrestrial
phase and this could be the case if they are present in any ponds within the
500m dispersal range. There may be suitable habitat between the site and the
ponds that may intercept the newts.
If great crested newts do occur within the site it then becomes part of their
habitat and should be subject to protection under the Wildlife and Countryside
Act 1981 (as amended) and the Conservation of Habitats and Species
Regulations 2010 but without data regarding their confirmed presence (and if
present the population size) it is not possible to say whether there is any
potential for an offence. This can only be properly determined after dedicated
surveys on all of the ponds within 500m of the site, which would require
permission from the respective landowners.
Without the additional extended surveys being carried out it should be assumed
that great crested newts may be affected by the proposal and that an offence
under the Conservation of Habitats and Species Regulations 2010 is possibly
likely and therefore this application should not proceed.
North Piddle Meadows Grid reference SO969536 which is on the Wychavon
District Council register as a site of special wildlife status since 28.09.1990.
The total area of the site is 14.9 hectares. It has a range of habitats and
diversity of grassland flora containing species of importance such as the
Narrow-leaved birds-foot trefoil, common spotted orchid and adders tongue
fern. The grassland site is stated as being important to vertebrates, fungal and
microbiological diversity that then provide food for a range of other species
creating an abundance of biodiversity. Such grasslands have considerable
cultural importance and aesthetically pleasing adding colour and visual
diversity to the landscape contributing to the unique character of our
countryside. Such Habitats are under threat 97% of such habitats have been
lost in Worcestershire between 1930 and 1984 (National Conservancy Council
1984 figures) therefore any pollution or damage to this habitat will add to this
decline.
Appendix 1 - Map of Ponds
Key:
1- pond 1, 2: Red rectangle -Footprint of proposed broiler buildings, 3: Pond 2, 4:Pond 3, 5: Frog Hall farm Compost
heap where great crested newts have been found, 6: red indicated land ditch that joins some ponds to others and
Piddle brook, 8: Piddle Brook, 9: Pond 4, 10: Pond 5 at Church Farm, Naunton Beauchamp. The applicants land
boundary is bordered in blue.
2
The Wychavon Local Plan Policy - ENV7 PROTECTION OF WIDER BIODIVERSITY
States Proposals which would have an adverse impact on the integrity of other habitats,
species and features will only be permitted where:
a) the reasons for the proposal outweigh the impact on the intrinsic nature
conservation value of the habitat, species or feature;
This proposal will have an adverse impact on the habitats and species found locally and
at this stage cannot be stated that it does not appear to out weigh the impact on a
protected species conservation and the value of its habitat that are protected by
legislation. The biodiversity of the localised area will be reduced if habitats are
reduced and protected species decline.
Section 4 on Protecting the environment of the Wychavon Local Plan states
‘The quality and diversity of these assets contribute enormously to the quality of the
District’s environment and to the quality of life of residents. Policies in the Plan seek to
protect and enhance these assets not only for their own sake and for the benefit of
future generations but also for the contribution they make to the social and economic
well-being of the area.’
This short sighted proposal is in an inappropriate place which is not in line with the
Local Plan and therefore should not be permitted on such grounds. Future generation
will be deprived if protected species are allowed to die out if this application is
approved.
Yours Sincerely
Philippa Neal
Resident of Upton Snodsbury.