Here is a copy of a letter from Gareth Hurd, an Alton resident who works in the conservation sector, to Simon Jenkins; Head of Planning at East Hants District Council.
Below the letter are 2 PDF documents for your download and perusal: Gareth’s letter with appendices, and an Outline Ecological Mitigation and Management Strategy done in 2014 by WSP Ltd, which is referenced in the letter.
Gareth Hurd’s Letter
Dear Mr Jenkins,
I am writing regarding the proposed residential development and country park at the former Lord Mayor Treloar Hospital Site, Chawton Park Road, Alton 30021/064. In accordance with the Preserve Treloars Meadows Campaign (PTMC), I believe absolutely in the necessity for further environmental impact assessment before permission for this development is granted, and I believe the outline proposal will have a highly detrimental impact on sites of local and national wildlife importance.
Given that many, less environmentally impactful housing developments have already been approved for the Alton area, I feel that to allow this disproportionately damaging project to go ahead would be a failure of the strategic role planning is supposed to play on society’s behalf, and that the restraints which PTMC are asking to be placed upon this development are both proportionate and necessary.
I argue that the outline proposal’s gestures towards environmental mitigation are tokenistic and misrepresented, and that in fact the outlined proposal seems designed to have as much detrimental impact on the existing sites of wildlife importance within and adjacent to the development area as possible.
Affected Area 1
The foremost objection regards the adverse impacts this development will have upon adjacent Ackender/Alexandra Wood, a designated ancient woodland. The proposed housing extends right the way up to the edge of Ackender Wood. A recent study by Yorkshire Wildlife Trust (Appendix 1, p.4) found that the incidence of litter and fly-tipping, damage and disturbance by dogs and other domestic animals, anti-social behaviour including vandalism, graffiti, barbecues, theft and destruction of wildlife and property, and damage by cars was more than double on a reserve within 100m of any sort development compared to if it was 100-500m away.
We are advised by the author of the YWT report (Lauren Garside, Team Leader, Central Delivery Team, Yorkshire & Northern Lincolnshire Area Team, Natural England), that the NPPF is currently being updated and one of the changes is that ancient woodlands will receive the same protection as SSSI’s with regards to planning: See https://www.woodlandtrust.org.uk/blog/2018/03/good-news-for-ancient-woodland/.
This has clearly been in response to recent losses of ancient woodland and therefore not to acknowledge the value of ancient woodland such as Ackender/Alexandra Wood is to miss the spirit of the legislation. Ackender Wood has populations of protected species such as Hazel Dormice and bats that will be severely threatened by the introduction of domestic pets, particularly cats. Dense woodland edges are the ideal dormice habitat, and the houses being built only 15m (the minimum statutory distance) away are liable to have the heaviest possible impact on this vulnerable species.
Affected Area 2
The Site of Importance for Nature Conservation (SINC) containing White Heleborines (a Red Listed species) will be completely surrounded by housing, which will exponentially increase foot traffic, littering and dumping of garden waste, thereby destroying the undisturbed ecology the Heleborines (the reason for the SINC in the first place) need to survive. The developer proposed to ‘translocate’ these notoriously temperamental and difficult to grow orchids, which would have a very low success rate, and would be tantamount to destroying them.
Affected Area 3
The Outline Ecological Mitigation and Management Strategy done in 2014 by WSP Ltd, (attached as separate doc), states that the bats resident in the water towers prefer to hunt along the edge of Ackender Wood north of the site and the ‘shelter belt running east-west through the centre of the site’. The proposed housing surrounds this shelter belt on all sides, replacing the grassland which their invertebrate prey inhabit. If the foraging grounds the bats need to survive are removed, then designating the water towers as an SINC in order to protect the bats is pointless.
Affected Area 4
As evidenced in Appendices 1 and 2, conversion of the remaining grassland into a ‘country park’ is likely to degrade its value to wildlife through increased disturbance by people disturbing the wildlife, littering and damaging the grassland. There is a children’s play area proposed in the middle of it, which is unnecessary due to the existence of a play area in the Treloar Heights estate.
The surrounding species-rich grass nearby is very likely become a magnet for dog mess and litter, obliging the managing agents to mow more and more of the adjacent site short, and turning it into a wildlife-poor amenity area.
If an additional play area was deemed necessary, and the developer was serious about protecting the environment, it would put the play area INSIDE the housing area for the convenience and safety of local residents and not, as seems to be its preference, preserving as much housing area for itself whilst exporting the disruptive play area out into the ‘country park’.
As evidenced in the 2014 Outline Ecological Mitigation and Management Strategy there are protected species and SINCs littered across the former Lord Mayor Treloar Hospital site, and by law each of these merits individual local protections to be put in place to safeguard their right to life.
Ackender/Alexandra Wood, moreover, is an even more significant consideration: as an ancient woodland the priority is to ‘avoid damage’ and ‘mitigate against damage’:
As these safeguards are likely to be strengthened in the forthcoming NPPF to SSSI level, requiring the adverse effects on the ecology of ancient woodlands to be taken into account, as evidenced by Appendix 1, the impact of this development on Ackender Wood must be thoroughly investigated before building is permitted to proceed.
I have outlined above the areas of greatest potential environmental damage and disruption both during building and thereafter once families move into the new houses, namely points 1, 2, 3 and 4. From an environmental perspective, removing the block of housing encircled in yellow in the image above from the development would be the minimum requirement to mitigate against the worst of the damage.
The nearest housing would then be more than 100m away from Ackender Wood, which would reap a more than 50% reduction in harmful activities, according to YWT’s report (Appendix 1, p4), significantly lowering the impact that housing would have upon Ackender Wood in terms of damage to wildlife, littering and vandalism. This would also bring the housing line down from the crest of the hill where it overlooks the old centre of Alton town, and it would make the bat and heleborine populations more sustainable in the SINCs (although in order to truly protect these delicate species, the block of housing below points 2, 3, and 4 should also be considered for removal).
The location of the proposed play area and the roads proposed to run through the ‘country park’ would also cause irreparable damage to the wildlife rich meadow area, which should be maintained as it currently stands, in order to minimise disruption.