Ecology, Landscape & Trees
I consider the plan to be unsound. These are my supporting comments.
MX2-39 site is recognised as an historically rich, bio-diverse and Ancient Woodland space that was first managed by the Gascoigne family from 1545 AD.
The definition of ‘Ancient Woodland’, classes any wooded area that has been wooded continuously since at least 1600 AD. as Ancient Woodland. The definition further includes ‘ancient semi-natural woodland’ mainly made up of trees and shrubs native to the site, usually arising from natural regeneration and ‘plantations on ancient woodland sites’ areas of ancient woodland where the former native tree cover has been felled and replaced by planted trees, usually of species not native to the site MX2-39 woodland complies with this definition and the site can be further described as below.
- MX2-39 Estate is one of the best intact examples locally of a country estate, incorporating recreation areas for family use;
- The estate is Greenbelt and is considered to be of exceptional historic interest;
- Leeds City Council recognises MX2-39 is an important site with a long heritage for East Leeds’s history;
- MX2-39 has proven to be a rich source of archaeological interest, Medieval, Roman and Bronze Age finds have been discovered on parts of the site – and the remainder of the site it anticipated to yield further artefacts;
- MX2-39 Gardens House, Home Farm, Gamekeeper’s Cottage and many estate lodges are all fully operational;
- MX2-39 in its current format affords the only location on the East side of Leeds that provides recreational usage to the public via footpaths and bridleways in such a historic setting;
- MX2-39’s Ancient Woodland is an irreplaceable habitat;
- Ancient woodland comprises 2% of the woodland in UK and is rigorously protected – the same protection should apply to MX2-39;
- Protecting Ancient Woodland also requires care and protection of the areas around and neighbouring onto the woodland too so that the eco-system remains intact and that current habitats remain untouched;
- The eco-system will be damaged by building permanent structures in, adjacent to or nearby the Ancient Woodland, and the construction, the buildings and human interference will result in a significant decline;
- MX2-39’s land should be considered to be a special conservation area as well as greenbelt or, if not, a special class of greenbelt and should not be considered for development at all;
- As MX2-39 includes Ancient Woodlands the entire site requires special consideration and its use cannot be changed or affected by any planning application other than protection of the ancient Woodland and associated eco-systems;
- The National Planning Policy Framework published in 2012 is the government policy document relating to planning decisions affecting ancient woodland. The importance of ancient woodlands as an irreplaceable habitat is set out in paragraph 1181 of the NPPF, which states: ‘planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss.’;
- The National Planning Policy Framework (NPPF) sets out the “Government’s planning policies for England and how these are expected to be applied” (National Planning Framework 2012 p.1) These comments are framed in relation to the 12 core planning principles contained therein. The 7th principle sets out that plans should “contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, where consistent with other policies in this Framework”. MX2-39 is of key environmental value;
- Ancient woodland indicator species, such as bluebells, yellow rattle, lesser celandine, wood anemone, and primrose are found throughout MX2-39;
- Ancient Woodland is an irreplaceable resource of great importance for its wildlife, soils, recreation, cultural value, history and the contribution it makes to our diverse landscapes. It is a scarce resource, covering only 2% of England’s land area. Local authorities have a vital role in ensuring the protection and conservation of ancient woodland and veteran trees, in particular through the planning system.” (https://www.woodlandtrust.org.uk/blogs/woodland-trust/2014/04/outstanding-advice/);
- Yorkshire’s and the UK’s Ancient Woodlands cannot be reduced or damaged by any development MX2-39;
- An ancient woodland ecosystem cannot be moved. Standing Advice for Ancient Woodland applies to all planning authorities in England “The irreplaceable nature of Ancient Woodland and veteran trees means that loss or damage cannot simply be rectified by mitigation and compensation measures. Therefore, where measures seek to address issues of loss or deterioration of ancient woodland or veteran trees, through for instance, attempting to minimise the area of ancient woodland affected (mitigation), or through the provision of replacement habitat (compensation), our advice is that these should be issues for consideration only after it has been judged that the wider benefits of a proposed development clearly outweigh the loss or damage of ancient woodland.”
- For MX2-39 Standing Advice states emphatically that “An ancient woodland ecosystem cannot be moved” and “Whilst the translocation of ancient woodland soil to a new site is sometimes proposed as a compensation measure for the loss of ancient woodland, it is not possible to replicate the same conditions at another site. In that circumstance it will no longer be ancient woodland.”
- Not only does the advice now cover veteran trees and wood pasture, it credits the Woodland Trust’s Ancient Tree Hunt dataset as “currently the only record of the locations of some veteran trees“;
- The proposal relies on an ecological survey performed by M & G and/or M & G’s agents and Leeds City Council which is well out of date (1998). It is unsound that any final decision to interfere in any way with this land should occur prior to a new survey being undertaken by an independent party. Leeds City Council’s SAP is unsound without an independent survey. A new survey is required so that any decision can be based on accurate, up to date information;
- The hedgerow between the former Deer Park and the adjacent field, which runs roughly north south from Parlington Lane beyond the bank of beech trees by the east end of the Dark Arch towards Hook Moor shows evidence of being an ancient roadway;
- The MX2-39 construction project’s build phase infrastructure would be centred also on or next to Ancient Woodland. The landscape and ecology of the surrounding villages, the roadways and pathways would be damaged and even put out of action for prolonged periods;
- MX2-39 has not been compared in any meaningful way with other locations or development strategies in terms of matters such as sustainability and landscape impact;
- The ecology of Parlington means that it cannot be proposed for 5,000 houses for the reasons above;
- The Council’s SAP on page 9 informs “The promoters also state there is the potential to provide an on-site renewable energy facility to make use of the extensive woodland, which is managed across the estate”. This indicates that trees outside the planned area for house building will be cut down and replanted with fast growing biomass forest and fauna and thereby change the ecology, landscape and trees in the greater Parlington Estate;
- The need for significantly enhanced and mass-transit transport infrastructure will additionally damage the Ancient Woodland, and destroy the remaining land (currently greenbelt);
- The Ancient Woodland will also be damaged by the effects of persistent light – e.g. street lights after sunset. The new sources of will have a serious effect on all wildlife. (Light pollution will affect the wildlife in the wider surroundings);
- The eco-system and habitats be destroyed by the buildings, and there will be added destruction from domestic/household pets;
- Hook Moor is a site of special scientific interest (https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=S1005559&SiteName=Hook+Moor+&countyCode&responsiblePerson);
- Hook Moor is a Site of Special Scientific Interest (SSSI) due to the presence of “Orobanche Reticulate” which is a protected species and is found only in Yorkshire within Britain, is nationally scarce and, because of its localised distribution, is additionally classified as ‘near threatened’. It is largely restricted to the narrow band of Magnesian limestone within Yorkshire and is subject to legal protection under Schedule 8 of the Wildlife and Countryside Act 1981 (as amended). Given that the proposed development is less than 50m from the perimeter of Hook Moor and has a Magnesian limestone ridge as part of its topography there is a high chance that the Orabanche Reticulate could be found to be a native species within the development area.
- The area of MX2-39 is vital as part of the local ecology and flood protection creating natural protection and regulation of water run-off into the local Cock Beck and River Crow thereby protecting the local villages of Aberford and Stutton from flood risk;
- Flooding has already occurred in recent years in 2000, 2008 and 2014 and is a fear for villagers in Aberford. The mitigation plans have not been presented to the public other than referred to in previous documents such as Leeds’s SAP 60469705 dated March 2016. References are made to the use of Cock Beck and River Crow as well as using living rooves, basins, ponds, filter strips, swales, soakaways, permeable surfaces and tanked systems. All of these techniques will have a detrimental effect on the Ancient Woodland and surrounding land are, therefore, not valid.