With 118 documents to assimilate in 30 days or less it’s unfair to expect any but the hardened campaigner to respond to a major planning application. To make matters worse planners and politicians do not appreciate standard pro-forma replies. However for the sake of those who like the Rawcliffe Meadows environment below is a brief list of what may be found wrong in planning application 19/00007/FULM that can be responded to at https://planningaccess.york.gov.uk/online-applications/applicationDetails.do?activeTab=makeComment&keyVal=PKPRC5SJHM900 before 8th March 2019 by email to firstname.lastname@example.org or by post to Development Management, City of York Council, West Offices, York YO1 6GA. The Council should publish responses to consultations on their Planning Access pages, removing the telephone number, email address and signature. In order for your comments or objections to be registered, and for them to be able to send you further correspondence relating to the application, you must include your name and your contact address.
The reference number of the application: 19/00007/FULM
The address of the property to which your comments relate to: Construction of new and improved flood defence works, compensatory habitat creation and other associated works (Clifton Ings Barrier Bank Project) | Clifton Ings Flood Alleviation Barrier To The South Of Shipton Road Rawcliffe York YO30 5RY
Along with your comments and / or objections
Some of the issues as Friends of Rawcliffe Meadows see them (currently)
- The current Barrier Bank development option appraisal favours destroying SSSI whilst edging out solutions like sheet piling that would preserve it, it also preserves ground on the dry east side towards which the barrier might be moved, saving the SSSI, IF the engineers wished.
- In the National Planning Policy Framework there can be no mitigation for the loss of rare MG4 grassland – it is unlikely to be relocated successfully as the current mitigation proposes and whilst alternative areas can be used to attempt to replace it, it will never be MG4 – the land at Rawcliffe Ings is degraded, weed-infested, improved grassland that will possibly take many years work and careful monitoring to get it anything like Rawcliffe Meadows – in fact preparatory work on that should have started much earlier
- When more than £14M of public money is being spent to protect around 140 homes we would like to think the preparatory work has been done well and the options fully explored but we believe the consultants employed have been largely desk based and much historical and ecological detail has been missed in the process
- The council’s scoping opinion 18/01737/EIASP states among other things that:
- There will need to be sufficient information to give confidence that avoiding adverse impacts through good design has been fully explored and that mitigation and compensation measures can be implemented effectively
- A habitat survey (equivalent to Phase 2) should be carried out on the site
- Full details of any mitigation or compensation that might be required
- The mitigation should be managed in perpetuity to ensure their value is never diminished by other pressures
- An essential component of the EIA will be to examine whether the receptor site is capable of supporting compensatory habitat with similar characteristics to the areas of old floodplain meadow which will be destroyed or damaged; and also whether the applicant has the expertise, resources and long-term commitment to achieve this objective.
- The is a lack of information in the PEIR about Necklace Groundbeetle, a NERC Act Species of Principal Importance which is also categorised as Endangered in the British Red List. There is also a lack of information about impacts on the numerous birds which occur regularly at Rawcliffe Meadows and are Species of Principal Importance. These include Dunnock, Bullfinch, Linnet, Tree Sparrow, Yellowhammer, Corn Bunting and Reed Bunting. There is almost no reference to the arable habitat on the Cornfield Nature Reserve, which has been managed for farmland wildlife since 2000 and in some years supports regionally important numbers of threatened farmland birds. This arable habitat also supports several declining cornfield plants such as Corn Spurrey, Corn Mint and Corn Marigold
- Section 5.4 of the PIER refers to soils and ground conditions. A proper understanding of effects on soils is essential since soil structure is fundamental to the condition of the SSSI grassland and its capacity to produce a high-quality hay crop. Previous, small-scale repairs to the Barrier Bank have resulted in serious soil compaction and structural damage within the SSSI, one symptom being the proliferation of rushes in reinstated areas
- Consultation feedback provided to date challenges the current justification for the flood defence works as proposed and whether the mitigation will be adequate. These issues should be addressed in the EIA
The Environmental Statement and Non-Technical Summary add very little additional light on these eight points and more that are expected from the scoping. Some of the surveys with the application and other material provided are out-of-date or irrelevant just bulking up the application, presumably to balance the lack of quality with quantity.
In addition one can appreciate that nearly thirty years of volunteer effort has gone into the site with little thanks or funding from the landowners (the Environment Agency) and that given this record how can it be believed that they will spend decades ensuring the lost SSSI will be truly compensated for.
PLEASE DO EXPRESS THINGS IN YOUR OWN WORDS AS FAR AS POSSIBLE, PRECISING THE PHRASES ABOVE WHERE YOU AGREE TO PROJECT YOUR OWN SENTIMENTS. YOU CAN ADD THOUGHTS IN THE COMMENTS OR ASK US QUESTIONS VIA THE SAME ROUTE.
THANKS FOR HELPING