York Natural Environment Trust (YNET) took over the management of what is now Rawcliffe Meadows at the request of the then National Rivers Authority (NRA) in 1990, so almost 3 decades of work have gone into transforming the once poached pasture covered in Creeping Thistle into a Site of Special Scientific Interest (SSSI), a Freshwater Habitats Trust Flagship Site and a Buglife Urban Buzz Flagship Site. This approximates to around £300,000 worth of volunteer hours over the last 28 years. Unfortunately the NRA ended up as a part of the Environment Agency a few years later and much support disappeared.

What the two planning applications by the Environment Agency affecting Rawcliffe Meadows are noticeable for is not the amount of content but the lack of information upon which to base a decision. How many people have taken the time to consider the supposed option appraisal provided? Not many I must believe because if they had they would have found it to be rigged with little consideration to avoiding dry side development. We carried out FoI requests to determine what consultation the EA had done with landowners on the dry side – none! So the intention has always been to develop on the rare SSSI grassland.

Natural England are still awaiting two key documents before they give consent to development “A Habitat and Landscape Management Plan” and a “A Tansy Beetle mitigation strategy” – why were these not provided when asked for by NE initially. Can the EA be trusted to provide them, or more importantly deliver on them?

The Council’s ecologist has similarly requested a Clifton Ings and Rawcliffe Meadows SSSI Mitigation Strategy, a Clifton Ings and Rawcliffe Meadows SSSI Restoration and Compensatory Habitat Management Plan, a  Clifton Ings and Rawcliffe Meadows SSSI and Rawcliffe Ings Biodiversity monitoring strategy (and remedial measures), a Tansy Beetle Mitigation Strategy, a Construction Environmental Management Plan (Biodiversity), a Habitat and Landscape Mitigation and Management Plan (non-SSSI features), a Great Crested Newt European Protected Species Licence and Mitigation Strategy, all of which should be part of the application you are being asked to consider, not add-ons, possibly provided, after permission has been granted.

The Council’s ecologist has also had to remind the EA that “under the Wildlife and Countryside Act 1981, as amended (section 1), it is an offence to remove, damage or destroy the nest of any wild bird while that nest is in use or being built.” The EA having carried out such acts already without planning consent, and similarly netted off the large bee bank constructed by the Friends without their consent, or the landowners!

The EA has had the missing information from its EIA pointed out repeatedly in the last eight months, why have they not acted sooner? Probably because they believe that the flood defence card will trump any objections.

The so-called Environment Agency in this region appears to have little understanding or respect for nature, so how is this work going to be controlled not just for the construction period but for the many decades of mitigation required after, and will they have the budget? In mid-May this year the EA carried out unprecedented cutting of the flood banks along the Ouse in complete ignorance of their own department’s National Pollinator Strategy and wasting tons of what might have been excellent hay. The applicant appears to only look after the environment when they are forced to and in this instance that force appears to be absent.

If councillors approve these applications they are undermining guidance that is there to protect SSSI’s nationally and will likely open the proverbial floodgates to SSSI destruction elsewhere and on this basis we have asked for the Minister to call in the application should Members approve it.

Another key element that is missing from ALL these reports, and that includes the Council and Natural England is the very existence of the Friends of Rawcliffe Meadows (FoRM) – where do FoRM fit into all this after the decision has been made as we aren’t considered anywhere? We coordinated those £300,000 hours of work that people gave voluntarily that made the site what it is. There is no consideration of future funding or whether there is even a role for FoRM.

Those present at the meeting in November 2018 that “Friends of Rawcliffe Meadows do not wish to be involved in any mitigation where we consider the proposals inadequate, inappropriate or under-funded.” As the planning application stands the proposals are inadequate, inappropriate and (probably) underfunded and there is nothing in any of the documents about how the remaining parts of the site will be managed and funded into the future, which as it is FoRM whose management has restored and expanded the Tansy Beetle population and maintained New Meadow, Copse Meadow and the Reservoir Basin, who will pay, and perhaps most importantly given the dire treatment, should FoRM carry on?

We are saying all this when we have yet to see the Council planners proposal and the decision of the Councillors but they’re not being fully informed. Do FoRM wish to have a further meeting before or after the next timetabled planning meeting (12^th September) as any work by FoRM after a decision is made in the light that we have no funding promised and presumably zero status in the eyes of all concerned seems worthless? Let us know!