Object

Draft Local Plan

Representation ID: 13470

Received: 19/03/2016

Respondent: Dr Philip Gibbs

Representation Summary:

[The Local Wildlife Site review recognises the woodland along the Mar Dyke Tributary as ancient woodland. The NPPF gives protection to ancient woodland and veteran trees from developments. The site is an important Green Corridor linking the Country Parks of Langdon Hills and Thorndon. Local residents have reported the presence of Greater Crested Newts and bats which are also protected. I believe that the species and habitats already identified are sufficient to prevent development of the area but If the Dunton garden Suburb proposal is to be continued it is vital that a detailed year round habitat assessment be carried out to get an accurate picture of the impact it will have on biodiversity in the area.]
Loss of Biodiversity at Dunton Hills. Read full comment as the details are important and no longer than necessary.

Full text:

Loss of Biodiversity
Although the location of the proposed Dunton Hills Garden Village development is not designated as a conservation area it is nevertheless an area with protected species and protected habitats. Indeed, as an area outside the nearby country parks at Langdon Hills and Thorndon is has been less disturbed by public access and this in itself has made it a refuge for some of our more timid species.
The wooded area stretching from Eastland Springs along the Mardyke Tributary is a Local Wildlife Site listed in the Brentwood Local Wildlife Site Review of 2012. There is another potential Local Wildlife Site listed at Green Meadow. These sites were left out of the habitat assessment for Dunton Garden Suburb even though Local Wildlife Sites on the other side of the A127 were noted. This omission is very serious and needs to be investigated publically to establish why it happened so that it is possible to ensure that it does not happen again.
The Local Wildlife Site review recognises the woodland along the Mar Dyke Tributary as ancient woodland. There are also scattered oak trees along field boundaries throughout the Dunton Hills location some of which have a measured girth of 350cm. This leads to an estimate for their age over 200 years which puts them in the category of ancient trees and makes them important as wildlife habitats. There is also a small L-shaped area of woodland at the top of Dunton Hills which is also likely to be ancient woodland. The NPPF section 118 gives protection to ancient woodland and veteran trees from developments.
I have visited the site of the proposed development in the company of Dr Annie Gordon who is a conservation expert from the Essex Wildlife trust. She has identified the area as an important green corridor linking to the Country Parks of Langdon Hills and Thorndon and opposes its development.
I have personally photographed badgers and tawny owls and a heron on the site. These species and their habitats are protected under the Wildlife and Countryside Act 1981 and the Protection of Badgers Act 1992. Other recent sightings of protected species include song thrush, barn owl, buzzards and kestrel. There are several established ponds in the area. Local residents have reported the presence of Greater Crested Newts and bats which are also protected. Other protected species that might be found in these habitats include water vole, slow worms, smooth snake, rare butterflies and orchids.
The hedgerows and ditches along the field boundaries show clear signs of the presence of small mammals. There are likely to be many other protected species in the area due to these habitats but they will only be evident later in the year. I believe that the species and habitats already identified are sufficient to prevent development of the area but If the Dunton garden Suburb proposal is to be continued it is vital that a detailed year round habitat assessment be carried out to get an accurate picture of the impact it will have on biodiversity in the area.
The Natural Environment and Rural Communities Act 2006 section 40 states that "Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity." This goes far beyond the need to protect conservation areas and sites of special scientific interest. Most of the green belt is not designated as any other kind of conservation area yet it contains areas of important habitats. Sites like Dunton Hills form part of the ecological network of habitats that connect the conservation areas.
Part of the proposal for Dunton Hills Garden Village could include preserving a belt of countryside along the Local Wildlife Site and biodiversity rich public parks. However, many of the more sensitive species will not support the pressure from nearby housing and the presence of domestic animals.
It is not acceptable to lose areas such as this to housing. The loss of biodiversity cannot be mitigated by moving the animals and plants to other areas or increasing protection in more limited spaces. The loss of the green belt and its biodiversity under pressure from an increasing population is analogous to the loss of the rainforest in developing countries. If we cannot find solutions to our housing shortage that do not require the loss of important wildlife habitats then we will no longer be in a position to ask developing countries to preserve theirs.