Rawcliffe Meadows Work Party 13th October 2019 – Tree Sparrow Nest Boxes

An outcome from the Rawcliffe Meadows Breeding Bird Survey of 2015 had been to place some Tree Sparrow nest boxes on the eastern bank of the Reservoir Basin (just below the allotments) as there was identified to be a paucity of suitable trees for them to nest in, it being mainly scrub there. The suggestion had been to hammer in some tall posts among the scrub, with suitable baffles to protect the boxes from Weasels or other similar predators.

Thanks to the York Ornithological Club we were provided with a grant earlier in the year and ordered boxes, hole plates along with steel sheet to make the baffles.

Despite the wet weather Julie, Mark, Judi and Mick got the materials to a suitable location and, after cutting a few tiny Blackthorn saplings, erected the posts adjacent to some Tansy and Elm planting.

The next job was to fix two boxes to each post at which point Kevin and Masha joined us. The scrub will soon hide the posts but some management may be needed to ensure there are no jumping off points for squirrels to attack the boxes.

It is not expected that the Environment Agency’s works will affect that area but who knows as there plans are so vague, but at least the small birds that frequent the Meadows will have somewhere to retreat to when the large sections and hedgerow and numbers of trees are eliminated forever.

Thanks to the six for braving the damp and the YOC for their financial assistance.

Next work party is Sunday 17th November 2019 when we will probably be repairing the fence around the Water Vole Scrape as the cattle have started making inroads. As well as Water Voles, this is now Great Crested Newt habitat and also of the Greater Water Parsnip, so the less trampling the better!

If there is now some juggling of work party tasks it is to avoid areas that the EA’s contractors are likely to damage when they come on.

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Goodbye Rawcliffe Meadows – update Friday 13th September

The planning committee meeting to decide upon the EA application occurred last night (12th September 2019) and is available to watch here https://www.youtube.com/watch?v=-vh5Y8-u3Ws&feature=youtu.be (after 10 minutes). It ended up taking until almost 19:30 to get a decision as around half the committee (Independent, Labour & Green) wanted refusal or deferment, whilst the Conservative and LibDem councillors were for the development without any further conditions or consideration. We must thank the Labour, Green and Independent councillors for their regard for the environment and the thirty years of hard work by the Friends. The application was approved by a small majority with an additional condition added. We now await whether the Secretary of State will as for a public inquiry.

The EA had wheeled in a consulting engineer from Jacobs to read out a statement from the Reservoir Supervising Engineer to the effect that if it wasn’t approved and the scheme didn’t go forward the bank might fail and repairs would have to be carried out under Section 10 which wouldn’t improve the defences to a 1 in 100 standard as the current application was doing. The legal and planning advice also suggested that members couldn’t ask for all the missing strategies to be brought following a deferment as that would be asking too much of the EA.

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Goodbye Rawcliffe Meadows

Rawcliffe Meadows Floodbank

Rawcliffe Meadows Floodbank (c) FoRM & Whitfield Benson

Officers recommend approval of the Environment Agency’s plans.

https://democracy.york.gov.uk/ieListDocuments.aspx?CId=132&MId=11246

Planning Committee 12th September 2019 4:30 pm

“The role of the Friends of Rawcliffe in managing the area will be in jeopardy and their funding will be lost; however this cannot be avoided through the planning process (we cannot specify that a certain 3rd party be required to manage the site). Officers are content that planning conditions can secure a reasonable level of mitigation over time; the
responsibility of which will lie with the applicants/developer; the EA. ”

Bye-bye thirty years of volunteer effort and £300,000 of public funding…

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The Ups and Downs of Tansy Beetle Numbers at Rawcliffe Meadows (Revised August 2019)

TB Pond South 6 (1024x949)

The Pond at Rawcliffe Meadows was excavated in May 1991, and the mounds and funnel that surround it were created from the spoil. Although Tansy Beetles had been seen along the Ings Dyke, that runs between Rawcliffe Meadows and Clifton Ings, and Blue Beck, that runs across the top of the site into the Ings Dyke,  previously and one copulating pair was found by Pond in 1993. These beetles had disappeared in 1994 but instead some were found that year in the New Meadow, just north of Blue Beck.  In 1994 some Tansy Beetles were found in the Blue Beck Copse ( a rough patch planted with saplings in 1993 between Blue Beck and the New Meadow) and alongside the hedge at southern end of Rawcliffe Meadows. The populations appeared to remain small from then onward.

There were sightings by the Pond in early 2000 but beetles were not seen later that year probably due to the severe flooding of the River Ouse that summer, although beetles were noted by the Blue Beck and Ings Dyke in 2000.

Beetles were sighted by the Pond again in June 2001 and in 2002 they were noted again by Blue Beck (on 8 April), plus at the Pond and by the New Meadow. The  2004 record was 100 by the Pond, a further 36 on the Ings Dyke bank (at the north by theold oak tree) and 101 on the Blue Beck bank with an additional 3 seen on the New Meadow and  4 near cattle grid leading the Copse.

In 2006 121 were counted at the Pond, with several on the New Meadow. Unfortunately in the previous year the Blue Beck verge was massacred by the Internal Drainage Board and that expanding population of plants and beetles were wiped out. Beetles continued to be sighted at the Pond and New Meadow during 2007.

By 2010 the Pond mounds were noted as a major habitat, and planting of tansy was extended further over  them. Unfortunately there were none recorded that year in the New Meadow

In 2012 the western edge of the New Meadow was fenced off to protect tansy and beetles from grazing and eight beetles were introduced from the Pond in June of that year and the count in late August had a total of 175. By that year we had recognized the significant effect that shading had on tansy plants, and hence beetles so that with the assistance of funding from Yorkshire Water which we received in 2013 we began cutting back and coppicing trees shading the Pond mounds, along with pollarding the trees overlooking the western edge of New Meadow (winter 2013/spring 2014). We also introduced cutting around  the tansy patches at the Pond, New Meadow and plants that started to reappear alongside Blue Beck. The count for 2013 was 208, which jumped to 368 in 2014 with all the care and attention to surroundings (with 60 on western edge of New Meadow and a single one to the south).

Following discussion with Geoff and Roma Oxford of the Tansy Beetle Action Group (TBAG) we decided in 2013 to manage the area to the south of New Meadow for tansy, along with the area near the cattle grid, and those adjacent to Blue Beck and the Ings Dyke where there were existing records of beetles. This has been started by regular cuts of the competing vegetation, and then fencing where practical. Other actions will be considered as we learn more about tansy, the beetles and their habitat needs.

With Rawcliffe Meadows being home to between 10% and 20% of the UK population of Tansy Beetles we feel it is important to try and increase our own stock of beetles in a manner that will leave many protected in the event of the unseasonable floods or other environmental issues that might wipe out an isolated population. The graph below should demonstrate the variations to the populations, whilst the Blue Beck, Ings Dyke and Cattle Grid are areas that once supported plants and beetles but being reinstated. During 2014 we put additional plants in the New Meadow, further around the Pond, by the cattle grid at the north, in the Reservoir Basin, and by Blue Beck. Whilst some of the areas were better prepared than others and may take years to establish properly, some are fenced off from grazing/public access, others are not. Only time will tell where the beetles  and plants best prosper, and perhaps answer some questions as to why. In 2019 we have a volunteer regularly observing the Tansy Beetle population at New Meadow – we hope that might give shed some light on the variations.

It must be noted that the numbers are a snapshot from the day of the survey. Additional Tansy Beetles may be discovered at the other locations on sunnier days later in August or early September. As in the case of September 2015 when Tansy Beetles were found in large numbers at the south of the Pond (where there had been none a few weeks before), along with being on plants by Blue Beck and over the Barrier Bank along the Cricket Field fence. The 2018 figures on 21st August are disappointing in that the 35 counted on New Meadow is well down on the 206 on 4th May 2018, whilst the 147 counted in August by the Pond is less than half the 363 quickly counted in May.Perhaps the exceedingly hot, dry summer had an effect. The leaves of the plants were noticeably well eaten, and for the first time we sighted galls on the tansy flowers, whilst the browning off (blight) was reduced from 2017.

A further 720 tansy plants were nurtured from seed provided by us into 9 cm pots by Brunswick Organic Nursery during 2015. These were being used to extend tansy coverage through the existing areas as well as on the banks of the Reservoir Basin. These plants were funded jointly by the Yorkshire Wildlife Trust and Yorkshire Water . The increasing number of tansy clumps can be seen on the graph below. The existing clumps are also spreading, seeding and in some cases disappearing. The dip in 2018 is a mixture of the cattle eating and trampling the tansy due to the reduced herb growth from the dry summer, along with the developing clumps merging together into bigger ones. The cattle had a similar effect in 2019 many of the cattle-accessible clumps flourishing only at ground level.

However, the count team when they went out on 29th August 2016, a relatively sunny day, we disappointed to see numbers had dramatically fallen from the previous year, and even a fortnight before when the clumps at the Pond had been managed – might this be as a result of the flooding and standing water on their habitat for almost all of the winter? The numbers at New Meadow had slightly increased, although it had been more days earlier, as were the new population along the Ings Dyke. In 2017, despite seeing large numbers of Tansy Beetles over an extended period in the Spring and Summer, and the tansy foliage being voraciously attacked by beetles and larvae, the numbers have still only gently risen at the time of counting.

The count team in 2018 (c) Ian Smith

The count team in 2018 (c) Ian Smith

We now have an established population of tansy plants and the challenge is to get the newer clumps inhabited by Tansy Beetles and expanding in the new locations to ensure that areas like the Pond, which was under water for a lengthy period of the winter of 2015/2016 are not the only expanding populations. However, whilst cattle trampling the plants may be beneficial for their spread, it doesn’t do a lot for counting them in late summer! The August heatwave of 2019 also appears to have had a disastrous on count numbers as there were many more in earlier weeks, despite many of the enclosed plants appearing to be in excellent condition!

We also need to understand why some tansy clumps ‘brown off’ before flowering as can be seen in the picture below, which is a drastic occurrence in this instance but then seemingly recover in subsequent years

p1080250-1024x768

A 'blue' Tansy Beetle

A ‘blue’ Tansy Beetl

Tansy clump in 2019

Tansy clump in 2019

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Rwacliffe Meadows Work Party Report 11th August 2019

We’d ignored the Bee Bank for a few months but now was time to cut back encroaching vegetation.

Fortunately for Mick the three people who had said they couldn’t make it did and so he wasn’t on his own. Whilst deciding on a plan of action we got a good view of young Roe Deer buck who made his way down the fallow, across the track and into the Reservoir Basin away from us. Our first job was pulling the Field Horsetail growing among the now establishing Sedum of the green roof above the bank, then cutting off the encroaching grasses whilst avoiding any pollinating plants.

In addition holes were drilled in the oak sleeping shoring up the bank to encourage further use of the bank by solitary bees or wasps. Whilst rooting around the sleepers two White Ermine Moth caterpillars were sighted, along with a largish toad. The wire netting installed without our consent by the Environment Agency to keep out Badgers is a nuisance to maintenance and probably to the Hymenoptera we are seeking, we also may have a leak in the liner beneath the bank.

White Ermine moth caterpillar

White Ermine moth caterpillar

Following on from the bank we went over to the New Meadow to clear up some hay and remove encroaching vegetation from the hedge. There are numbers of Tansy Beetles on the New Meadow verge.

Thanks to Judi, Julie and Mark, and Mark T for their efforts and energy.

The next work party is planned for Sunday September 1st when we’ll be again venturing into the Water Vole Scrape to pull out any Reed Mace and cut back half of the Phragmites. Waders or wellies advisable. Shears and glove provided.

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Friends of Rawcliffe Meadows – What may the Future Hold?

Friends of Rawcliffe Meadows logo

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 (12th 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!

 

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Rawcliffe Meadows Work Party Report 1st August 2019

Don’t know if it was the leaden skies or the fact that it was Yorkshire Day but Mick felt like a lonely bunny as he took control of the thistle, docks and brambles making their way out of the Cricket Field Copse at the southern end of the Meadows. However, before long Evie (our Tansy Beetle monitor at New Meadow) and her dad Kevin appeared to take away the isolation.

As it is difficult to cut with modern, large equipment this section between the Barrier Bank and Cricket Field Copse often needs manual intervention, especially as the Environment Agency messed everything up this year. However, the cows, bullocks and little calves have been doing their best and the area wasn’t as bad as it might have been but the weeds and brambles still needed tackling.

Between the three of us we made a good stab at cutting them back and relocating under the Hazel copse to mulch down. More hands would have done more but it was not to be.

The next session is on Sunday 11th August at the Bee Bank in the Cornfield Reserve arable. The hay cut will have left some standing vegetation and there will be some fine weeding required. Following a suggestion we will also drill some additional holes in the Oak sleepers that surround the bank to make potential nests for solitary bees.

The 2019 generation of Tansy Beetles are rising up now so keep your eyes peeled.

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Rawcliffe Meadows Work Party 21st July 2019 New Meadow

Green-veined White Butterfly

Green-veined White Butterfly

Although we had intended to start on the New Meadow Tansy plants we took our shears to the Creeping Thistle that has suddenly sprouted along the southern bank of Blue Beck below the Copse. Pete, Richard, Ron, Fiona and Mick cleared back what Creeping Thistle had started to grown among the Tansy plants along Blue Beck. This was made slightly difficult as the cattle had trampled everything and the Tansy was difficult to locate in places. We then moved up to the cattle grid but again the cattle had trampled and nibbled the Tansy plants there. We then moved into the Tansy enclosure around Blue Beck and cut back competing vegetation against the Tansy there. No Tansy Beetles were sighted and there was sign of “browning off” of some plants whilst no Tansy Aphids were see. Lots of butterflies around including Ringlet, Green-veined White and Gatekeeper (Hedge Brown).

Blue Beck bank before

Blue Beck bank before

Blue Beck bank after

Blue Beck bank after

 

 

Gatekeeper Butterfly

Gatekeeper Butterfly

The next work party is on Thursday 1st August from 6:30 pm when we will hopefully tackle to areas of the Barrier Bank that haven’t been cut by them or our grazier i.e. in front of Cricket Field Copse and around the Hazel Copse at the south of the site over from the Pond.

 

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Rawcliffe Meadows Work Party Report 4th July 2019

Having pulled and trampled Himalayan Balsam growing in patches around the Pond on the Wednesday with students from Bootham School in York, this Thursday’s work party was able to focus first on bringing some control to vegetation in the enclosure running north along the Ings Dyke where we planted tansy a few years previously. This wasn’t an ideal spot for the plants due to the shade but where the sun was able to peek through we found that the plants were flourishing if suffering competition from Cleavers and other vegetation.

Thanks to Judi, Pete, Masha, Julie, Anne and Mick the enclosure was cleared and a few Tansy Beetles discovered at the same time. After a quick break for a drink we returned to the Pond and did some delicate work there where Creeping Thistle or Cleavers were getting too close, and again a number of active Tansy Beetles were found making the evening’s total of over a dozen which is good for the time of the year.

We’ll borrow a couple of Tansy Beetles from here for the Insect Festival on Sunday 7th August in Museum Gardens, returning them later ready for their summer underground vacation. The next work party is planned for 10:30 onward on Sunday 21st July when we’ll be at the north of the site bringing under control the western bank of Blue Beck where it joins the Ings Dyke that appears to have become the victim of Creeping Thistle rather than Himalayan Balsam, after which we’ll double check on the plants on the bank of New Meadow a few hundred metres north, where we usually work.

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Clifton Ings Barrier Bank, SSSI Mitigation Strategy Version 2 (May 2019) – Objection from Friends of Rawcliffe Meadows

Introduction

The above document has been submitted by the developer (the Environment Agency) as an addendum to their Environmental Statement (ES) for the Barrier Bank planning application. It contradicts some of the assertions made in the ES but it is unclear which take precedence. As the ES is the primary evidence upon which a decision will be made, Friends of Rawcliffe Meadows believe the ES needs to be consistent with appended documents and as such the applicant should be required to publish an updated ES to avoid ambiguity.

Access route

The level of damage to Clifton Ings & Rawcliffe Meadows SSSI must be the primary consideration of the Planning Authority in determining the application. Table 1 of the SSSI Mitigation Strategy needs to be incorporated into a revised and republished Environmental Statement since it fundamentally alters the assessment of impacts.

It is stated that “the restored access route will be spread with green hay to promote re-establishment of target grassland species” (page 6). However, no methodology is explained, e.g. measures to reverse compaction, management of re-establishing vegetation. The applicant seeks merely to reinstate the access route in situ and does not propose any additional mitigation or compensation. Given the requirements of the NPPF (e.g. Paragraph 175), ODPM Circular 06/2005, Government’s “biodiversity net gain” commitment and the fact that the applicant categorises the haul route as constituting permanent damage to the SSSI, this cannot be considered compliant with planning policy.

The Environment Agency has a long history of damaging the nature conservation interest of the grassland at Rawcliffe Meadows and simply walking away. For example, the best SSSI grassland north of the pond was used as a storage area for previous bank repair works with nothing done to relieve soil compaction; as a result, the affected area has suffered a significant deterioration in condition and is now rush-infested. Given the duration of impacts (>10 years according to the applicant), how would the Planning Authority ensure that the applicant is capable of addressing long-term impacts? The Planning Authority needs to consider its limited resources available for monitoring and enforcement, and the likely political constraints on taking enforcement action against a statutory agency.

Installation of drains and lack of consideration of cumulative impacts

The applicant claims that up to seven subsurface drains can be installed with no requirement for mitigation. It is very unlikely that works of this extent and scale can be undertaken without permanent and significant impacts on the SSSI grassland. Nothing has been said about impacts on medieval ridge-and-furrow, which is a non-statutory archaeological feature.

Account must also be taken of cumulative impacts. Considering the already narrow and linear layout of Rawcliffe Meadows, there will be cumulative impacts from: embankment reconstruction on a much-enlarged footprint; permanent damage on the access route and working areas; drain installation; proliferation of noxious weeds (docks, ragwort, thistles) on disturbed ground. In combination, these impacts will undoubtedly result in marked deterioration of the site as a whole and could render future restoration of traditional agricultural management unviable. The existing SSSI grassland will be reduced to a narrow vestigial strip along most of Rawcliffe Meadows and FoRM have no faith in the applicant’s interest in or capability of ensuring its future. For nearly 30 years, our experience has been that the Agency promises the earth, causes damage then walks away, all assurances forgotten or left unfulfilled.

Sustrans route diversion

FoRM welcome the proposal to permanently re-route the cycle path onto the well-worn strip running parallel to the Ings Dyke on the Clifton Ings side. We agree that this would have minimal impact on the integrity of Clifton Ings. However, the Planning Authority needs to see evidence that appropriate legal agreements are in place prior to determination. Clifton Ings was never legally enclosed so, as we understand it, there is no freehold ownership. Land tenure comprises ownership of the hay crop divided into numerous parcels held by various parties together with un-extinguished common rights pertaining historically to numerous properties in Clifton and elsewhere. The ownership of the underlying soil is unclear and was formerly vested in the tenant-in-chief of the manor of Clifton. It is likely that the situation is legally complex and a simple statement of intent by the applicant does not suffice to demonstrate their ability to deliver this proposal.

Proposed mitigation measures

As we demonstrated in detail in our previous submission, habitat translocation is a discredited method of mitigating loss of nationally-important grassland; it is, at best, a salvage operation. We have pointed out that Natural England has, on other grassland SSSIs, opposed translocation as a credible mitigation strategy.

Even if translocation was accepted as a viable strategy, it will require an exhaustive, painstaking and long-term commitment to ensuring optimal management of the receptor site. The applicant proposes simply to ensure an annual cycle of hay cutting and aftermath grazing of the receptor site. This is likely to be woefully inadequate given the known and empirically-evidenced problems with translocated grassland. Friends of Rawcliffe Meadows have no interest in being involved with management of translocated habitat so the onus will therefore fall on the Environment Agency’s local Operations team, who are not conservation land managers.

The applicant states that “The additional area required to compensate for habitat loss will be delivered by other restoration methods such as green hay, seed spreading, plug planting”. They offer non-committal references to using “various techniques” to introduce additional plant propagules along with the extremely vague statement that “It is recommended that a mixture of techniques would be desirable across all fields identified if this were feasible”. Further wording like “this option should be considered” and “guidance suggests” do not constitute a strategy. At the very least, the Planning Authority must surely require the applicant to present a portfolio of evidence demonstrating that they have applied these techniques elsewhere to achieve a quality of compensatory habitat creation commensurate with offsetting damage to a nationally-important and irreplaceable habitat.

Friends of Rawcliffe Meadows have attempted to engage with the applicant on restoration techniques based on our nearly 30 years experience but the applicant has chosen to ignore this advice. On page 87 of the ES, the applicant refers to our Copse Meadow restoration as “…an excellent example of what can be achieved within 10 years” and “Targets can be set for the restoration of Rawcliffe Ings based on the Copse Meadow success”. We dispute their interpretation – it will take decades for the Copse Meadow to acquire the characteristics of mature MG4 grassland – but at least this was a commitment to follow empirical best practice. The relative success of Copse Meadow has been based on nutrient reduction by topsoil scraping and painstaking, labour-intensive management that the applicant can never hope to achieve. Having over-run their budget, they are now reneging on this position and offering instead a low-cost, minimalist approach which cannot possibly achieve adequate compensation relative to the impact of the proposed development.

We have pointed out the extensive literature showing that hay/seed spreading onto roughly-prepared existing grassland achieves, at best, modest improvements in species diversity over long time periods even under the most optimal circumstances. It is evident from the literature that scattering seed and planting plugs into the existing, heavily degraded and agriculturally-improved grassland on Rawcliffe Ings will not achieve anything remotely like SSSI quality grassland.

We dispute that “The work done to date by the FMP shows all possible mitigation zones (A-E) show very good potential in terms of soil fertility, for restoration”. In fact, the very limited data produced by FMP demonstrates that soil P levels are towards the upper end of the parameters for meadow restoration. Given the fact of annual flooding by nutrient-enriched water, there is little possibility for re-creating species-rich floodplain meadow on Rawcliffe Ings without substantial measures to reduce soil nutrient loads.

Because the applicant’s insufficient budget, they are refusing to undertake topsoil scraping, which in our experience would be essential to create favourable conditions for creation of species-rich grassland. Instead they cite Natural England guidance for agri-environment schemes to claim that “receptor site preparation to achieve a short sward and 50% bare ground should be sufficient” (page 12). This guidance (Natural England Technical Information Notes TIN063 and TIN064) has nothing to do with SSSI compensation and is intended for farmers aiming to achieve modest botanical diversification of existing grassland: a worthy objective in the context for which the guidance is intended but certainly inadequate to re-create grassland of sufficient quality to compensate for the destruction of over 2 hectares of nationally-important, 400 year old SSSI grassland.

FoRM have written to the Secretary of State for the Environment regarding the developer’s drastic back-tracking on their previous commitments as we believe this strengthens the case for the application to be subject to Public Inquiry.

Assessment of duration of impacts

In Table 5.8 (page 99) of the ecology chapter of the ES, the applicant asserts that there will be “No significant effect [on MG4 grassland] at a National Level, in the Long Term”. Now, in the new SSSI Mitigation Strategy, they accept that restoration of floodplain meadow requires “long time periods”, which are specified as “10+ years”. It is impossible for both statements to be correct: the truth is the claims made in the ES are hyperbolic and mendacious. Again, this stresses the need for a revised, and hopefully more honest and evidence-based, Environmental Statement.

 

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