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Cllr. Dan Daley Responds to Consultation on Bridge Nursery

May 13, 2014 2:55 PM

Bridge Nursery

Response by Cllr. D.S. Daley to S.18 Public Consultation May 6th 2014

Ref. SS1a/ H (H1)

This response follows the full appraisal paper I submitted in March 2013 which outlined my response to a previous opportunity of appealing for the total rejection of this site for housing development.

The latest consultation under ref SS1a shows some changes which are noteworthy but now must also take into account the results of the detailed ecological surveys which have taken place during the summer of 2013 by Lloyd-Bore Ltd. Canterbury on behalf of Ward Homes.

I start with the original description of the site which appeared in the URS Report of August 2012 which stated that this site was described as 'empty grassland with trees and scrub'.

We now know that this may have had some bearing on the fact that it was almost dismissed as not worthy of retention by the Planning Inspector in 2000

In 2000 the Inspector, when considering objections to the inclusion of Bridge Nursery in Maidstone Council's Borough-Wide Local plan over-ruled local objections to development stating that:

"Housing development will be permitted on land at Bridge Nursery, Maidstone as shown on the proposals map if existing trees and hedgerows within and around the boundaries of the site are retained as part of a landscaping scheme."

Despite this ruling, Bridge Nursery has continued to be freely accessible to the public since 2000 and, as no development has taken place, nature has remained unfettered and wildlife has flourished.

It is therefore necessary to produce a robust counter argument for removal of the Bridge Nursery site from the Maidstone Strategic Site Housing allocation which will stand up to close scrutiny.

I believe that a case for the total removal of this site from the housing Allocation can now be proposed because of the outcome of the detailed ecological surveys. These show that not only does the land provide a great deal of rare and diminishing habitat but also an usual soil makeup, including both acid and alkaline sandy substrates, unseen anywhere in this part of mid Kent. This means that the spread and wealth of wildlife is probably unable to be either replicated or mitigated should there be a need to translocate.

The Council is now in possession of the ecological survey results of the Lloyd-Bore consultancy of which the detailed survey of September 2013 shows a wide variety of birds, invertebrates, reptiles, bats, trees, shrubs and other plants. The line of Beech trees is already now covered by a Tree Preservation Order and the stand of Aspen is stated to be rare in this part of Kent.

Of especial note is a number of protected species which cannot be disturbed or habitat damaged or destroyed. Significant numbers of viviparous lizards and slow-worm and smaller numbers of grass snake (in breeding colonies) are now known to be present. There are also older records for adder on the site. These reptiles, though not yet rare in Kent, are declining through habitat destruction. This will lead to an inevitable high cost of mitigation should there be no change in the site's situation in the housing Allocation.

Lloyd-Bore state quite plainly that their appraisal and survey results of the habitation of this area shows that the total land area of 5.5Ha on the Maidstone side of the border with Tonbridge and Malling should be reduced to 3Ha for development with the remainder of the land on the Maidstone side of the border (2.5 Ha) - and the 1.5Ha (on the T and M side) being kept for nature conservation together with the existing footpaths and disturbed areas.

It is plain that this last remaining piece of open land in North West Maidstone is very rare and extremely precious for a wide variety of reasons. Among these is the presence of a large variety of nesting birds, including several in the red and amber list of conservation concern. The habitats of greatest concern are those of the existing trees and areas of dense scrub (which is used for nesting) and the presence of the rough grassland, berry, seed and nut producing plants for foraging.

All of this points up the way in which this land has evolved through time to produce a really first-class wildlife habitat which cannot be reproduced elsewhere in the area and is therefore to be celebrated, retained in its present condition, managed and conserved.

The remaining area suggested by the ecologists for development should this land still remain in the Allocation will comprise only 3Ha and that would immediately reduce the numbers from the present 165 to 90. However, even these reduced numbers would inevitably inflict habitat destruction during the construction phase, and ongoing disturbance and predation of wildlife by domestic pets once any housing scheme is complete.

It is noted that the Consultation document stipulates an entrance to this site only on to the A20 London Road. To achieve this will necessitate breaching the mature hedge-line on London Road thus creating yet another traffic light controlled cross-road opposite Beaver Road. All of this means that the traffic build up due to ATS interference at frequent intervals would add to the existing traffic congestion on the main road in the peaks leading to extensive tail-backs in both directions affecting the junctions at Coldharbour, St. Lawrence Avenue, Beaver Road, Castle Road and as far East as Grace Avenue. This is at perhaps the narrowest part of the whole length of the A20 just before the pinch point at the railway bridge.

In light of the special nature of the land demonstrated by the various ecological surveys and the importance of it to the local population as expressed in a >1100 signature petition, I would hope that the Cabinet (and especially the Leader who had previously made such a suggestion) seeing this evidence would now agree to the total removal of this site from the Housing Allocation and its declaration to be a site of natural beauty and conservation value.

The site is currently allocated in the LDF as being capable of producing 165 houses. I hope that I have shown that this is now evidenced as being unachievable if the ecological survey evidence is accepted. That evidence is suggesting that no more than 3ha could be developed which would produce 90 houses. Other evidence exists that since December 1st 2013 until February 29th 2014 there were windfalls of 150 houses. It is my contention therefore now that this site could be excluded from development altogether to enable the retention of exclusive wildlife habitat that otherwise will be lost and irretrievable - but that there would be no real loss overall of the housing numbers.

There would also be a gain in not having to accommodate a difficult exit from the site into an already overcrowded and often gridlocked road at a point which it would be awkward to engineer without creating the need for further traffic control and more congestion at times.

Reference to the Town Map will show that this is now the sole remaining area of its type in this sector of the Maidstone Borough in an otherwise a completely built-out area, which 110 years ago was purely a hamlet with cherry and other fruit orchards and farmland.

Under the heading 'Conserving and Enhancing the Natural Environment' the NPPF, paragraph 109 states:

The Planning system should contribute to, and enhance, the natural and local environment by

  • Protecting and enhancing valued landscapes, geological conservation interests and soils
  • Recognising the wider benefits of ecosystem services
  • Minimising impacts upon biodiversity and providing net gains in biodiversity where possible, contributing to the government's commitment to halt the overall decline in biodiversity including by establishing coherent ecological networks that are more resilient to current and future pressures.

Here then is a prime chance to exercise these principles by ensuring that this particular piece of land, so rich in biodiversity and with a proven possibility of improving and conserving species which are 'on the edge', is now protected from any development and to protect it for all future time by declaring it to be the Nature Reserve that it already truly is.

'Irreplaceable' really does mean what it says in this instance. This piece of open land is truly unique in Maidstone.

In 2000, neither objectors, nor the Inspector, gave any consideration to the intrinsic value of the site itself in public amenity, scientific importance or recreational terms, or gave thought to the environment and the site's sustainability in relation to its geology and biodiversity.

It is our contention that whatever may have been the situation in 2000, it is entirely different fourteen years later. Significant change in government thinking has taken place, not least in the way we are now asked to protect and look after the remaining precious open wild spaces on the edge of urban extensions. The Bridge Nursery site falls neatly into this category on several counts as explained above.

It is for these and the other reasons outlined above that we confidently can ask now for the total removal of this site from the Housing Allocation in the emerging Local Plan to 2031.

As the Rt. Hon Greg Clark MP, Minister for Planning, stated in his introduction to the NPPF:

Our natural environment is essential to our well-being, and it can be better looked after than it has been. Habitats that have been degraded can be restored. Species that have been isolated can be reconnected.

Planning must be a creative exercise in finding ways to enhance and improve the places in which we live our lives.

Given this statement and the spirit in which the NPPF should be regarded, it seems outright lunacy to even consider putting housing on a site which, through sheer good fortune, has remained unspoilt and has supported such a wonderful and diverse flora and fauna for so many decades. Its destruction or diminution would rightly be regarded by residents as an act of wanton vandalism.

Dan Daley: also on behalf of Cllrs. Mrs. Robertson and Mrs. Watson

May 6th 2014

(Residents and Members for Allington Ward)

I am still in possession of the signatures on the petition, not yet presented but feel that this response is on behalf of all those who signed it.