Dear friends,

You may recall that back in September 2023 I posted a letter I had sent to the planning officer of the North Yorkshire Council objecting to a planning application that had been submitted to build 28 houses on an ancient wildflower meadow at Bolton Crofts an area that provides essential habitat to the town’s wildlife. This location also offers one of the most iconic views of Richmond Castle and the historic town centre.

An amended proposal has now been submitted, this time for 27 houses and I have been busy writing another objection letter for the past few weeks.

My letter this time is much more in-depth looking more at the Ecological Impact Assessment and Biodiversity Net Gain Assessment as well as focusing on the view.

Once again, I’m sharing my letter to help raise awareness, and if anybody would like to join me in objecting and to help save an important ecological site from getting developed into a housing estate the details to do so can be found below.

One thing I will highlight is we only have until the 20^th of March to get our letters in.

I have sent my objection letter to the planning officer Fiona Hunter. Fiona.Hunter1@northyorks.gov.uk or you can email: PlanEnquiries.ric@northyorks.gov.uk

All letters and documents can be viewed publicly on the North Yorkshire Council website.

This link will take you to the planning portal for the amended proposal documents with a data stamp of the 26 of February 2024 North Yorkshire Council website:

Please title any objection letters with the Planning application number:ZD23/00449/FULL

Kind regards and together lets keep on keeping on

Stephen

Dear Fiona Hunter

I object to the development of the houses outlined in the Amended Proposal for the Planning Consultation for Application Reference ZD23/00449/FULL

Thank you for your letter allowing me the opportunity to add any further comments I may wish to make for the Council to consider before any decision is made on this application.

My original letter of objection still stands but now that the amended plans have been submitted, I would like to make additional comments.

Outline of additional comments.

• Views
• Land for biodiversity enhancement – Bolton Crofts
• Ecological Impact Assessment and Biodiversity Net Gain Assessment
• Grazing Land and the Emergency Link
• Area for public benefit

Views

In the Heritage Statement, Rev. C, reference is made to trees that will screen part of the new houses from the view of the castle. Quote: “A substantial part of the application site is screened by trees.”  This screen of trees currently consists of several mature trees. I say currently because every few years these trees get less in number. The trees are staggered in their planting, but each tree plays a significant role in providing the screen.

The removal of even a single tree is a concern, when mature trees have grown in groups, they are reliant on the position of each adjacent tree for their survival. When a tree is removed from the group be it through natural causes or human intervention a weakness is created due to new wind exposure that the tree has not compensated for during its main growing years.

I have concerns for the health of these trees, and I would like to recommend an independent health check be carried out. From my investigation, I have cause for alarm for the longevity of most of these trees. They look to be at the stage in their life where they can no longer be relied on for the future screening of a “substantial part of the application site”. Their value now lies in providing invaluable habitat for wildlife and birds, especially offering roosting opportunities for the many bats that forage over the adjacent wildflower meadow.

The above “Google Earth Maps” photo provided in the updated plans document; “3894-PD-223 BLOCK PLAN WITH GOOGLE SHADING”, are from 2018, “OpenSource Maps” have more recent satellite views which show more gaps in the number of trees.

The above map (OpenSource Maps) is much more representative of how the trees look for the 6 months of the year when they are not in leaf therefore not providing good screening.

The main reason I request a health check on these trees is because landscaping has been carried out on the grounds of what was the Sam Watson Rest Home for Miners Wives which has been converted into luxury housing. As part of the new landscaping, the ground level around some of the trees has been raised substantially, burying the base of the trees. Raising the soil level around a tree stops the vascular flow of water, oxygen, and nutrients from getting to the rest of the tree, leading to the tree dying.

I would also like to point out how unpredictable it is to expect so few trees to play such a key role in screening a “substantial part of the application site”.  In 1987 we had a weather event with 100 miles per hour winds that blew over 15 million trees throughout the United Kingdom.

With the latest climate models predicting more extreme weather events each year it’s only a matter of time before the remaining trees in this location get blown over.

This is without taking into consideration diseases in trees. In the 1970s one of my first clear memories as a child was the cutting down of all the Elm trees that lined Queen’s Road in Richmond, due to Dutch Elm disease. The United Kingdom is currently experiencing Ash dieback disease which is predicted to kill up to 80% of ash trees across the UK. Acute oak decline is taking place in southern England and Wales where oak trees are declining at an unprecedented rate due to drought, flooding, pollution, pests, and diseases.

The photographs below highlight the health of the trees which are said to play a significant role in providing the screening for a substantial part of the application site”.

In conclusion to this section, due to there being no succession of partially grown trees already in this area, Fiona, I ask you, what will the view look like from the castle in five years, ten years, or twenty years? We will not need to travel very far into the future to experience such a detrimental change in the once iconic view from the castle looking towards Bolton Crofts' ancient wildflower meadow to be met with a housing estate if this planning proposal is approved.

Land for biodiversity enhancement – Bolton Crofts

Following on from the question of views from the castle I raise my concerns over the proposed land for biodiversity enhancement at Bolton Crofts. Here I will also highlight the views, this time looking towards the Castle from the side of the proposed development site.

The following sections underlined in red are taken from the Biodiversity Net Gain Assessment: Bolton Crofts

8.1 Native scrub planting

• Plant between November-March
• Leave unplanted gaps to create open ground as part of the mosaic Mix species randomly; no single species should be dominant. Scrub species should be native; examples of suitable species include Dogwood (Cornus sanguinea), Hazel (Corylus avellana), Spindle (Euonymus europaeus), Guelder rose (Viburnum opulus), Field Maple (Acer campestre), and hawthorn (Cratageous monogyna).
• Scallop the edges of the scrub or scrub mosaic. To achieve this, plant patches of shrub in semi-circles and create areas of open ground in between.

For reference I would like to highlight the definition of Scrub – In the absence of management, most semi-natural UK grasslands would become invaded by shrubs and trees and pass through a phase of scrub before becoming secondary woodland.

Secondary woodland is woodland that has developed through natural processes on land previously cleared of trees.

Mixed Scrub - Eastern boundary

In the updated plans (see the below image), there is the addition of an area of scrub on the field boundary running adjacent to the public footpath that goes between the existing houses of Alma Place and the proposed new houses. In this scrub area will be the addition of five trees. As shown in the images below.

The above image clearly shows the locations of the new trees positioned in the “Land for Biodiversity Enhancement. (inside the red rectangle that I have added to the map)

The above graphics help to show the positioning of two trees. This location is the middle point on the existing footpath clearly showing a limited view of the castle from the footpath above the two trees.

To demonstrate this point further the below photograph makes clear that over time the additional two trees in the middle section of the public footpath alone will limit the view of the castle.

The additional planting of scrub into the area adjacent to this footpath will over time reduce the visibility of the castle even more.

Biodiversity Net Gain Assessment: Bolton Crofts

10.1 Mixed scrub

Establishment

The whips/scrub should be allowed to establish and mature for a period of 6-8 years. No management should be undertaken during this time.

Referring again to  8.1 Native scrub planting

• “Leave unplanted gaps to create open ground as part of the mosaic”
• “Scallop the edges of the scrub or scrub mosaic. To achieve this, plant patches of shrub in semi-circles and create areas of open ground in between.”

This style of planting is effective over a much larger area of land than is proposed here for biodiversity enhancement on this narrow strip of field boundary. We need to remind ourselves that the main purpose of this section of the field in the amended plans is to preserve the iconic views of Richmond Castle and the only view that also contains Holy Trinity Church Tower and Greyfriars Tower looking across one of the few remaining ancient wildflower meadows that still give Richmond that medieval feel to it. To highlight the point again and something that I feel keeps getting missed, we are not just talking about the view of Richmond Castle but the view of the three towers, Richmond Castle Keep, Holy Trinity Church Tower and Greyfriars Tower, it is all three of these structures that make this one of Richmond’s most iconic views.

I will point out here that the view to Greyfriars Tower from the top of the footpath next to the Yorkshire Water Reservoir gate, the place most people stop and take photographs of this iconic view will already be lost by the position of plots 16 – 17 if the planning application gets approval. (See the above photograph provided in the Heritage Statement)

During the establishment period of 6-8 years, there will be no management of the scrub in this area at which point the view of the three towers, Richmond Castle Keep, Holy Trinity Church Tower and Greyfriars Tower, will be lost. It is worth noting that native scrub species are fast-growing.

The management model proposed for these areas of scrub after the 6–8-year establishment period will be a continuous battle to keep open the view of the three towers, Richmond Castle Keep, Holy Trinity Church Tower and Greyfriars Tower.

Biodiversity Net Gain Assessment: Bolton Crofts

10 Habitat management

10.1 Mixed scrub

Management

Once established the scrub should endure an annual cut back. 10% of the scrub should be cut each year.

Areas of scrub should be cut in rotation – this will allow an age range of species to form alongside rides and glades within the scrub.

Cuttings should be stacked on-site as habitat piles.

Newly planted areas will be inspected 3 months after planting and again at the end of the first year after planting with additional checks being carried out following high wind events. Inspections will continue biannually for the first 5 years. Any losses or damaged plants will be replaced as appropriate and, where necessary, plants will be firmed into the ground or stakes/ties tightened.

Trees/shrubs will be replaced like-for-like replacements in event of failure.

As you can read from the above section this is a generic description for scrub management and does not represent the narrow areas set aside for biodiversity enhancement on Bolton crofts.

Hedgerow

There is also the addition of a hedgerow that winds itself down the field dividing the proposed area of land for biodiversity enhancement and proposed development. It is stated that:

Biodiversity Net Gain Assessment: Bolton Crofts

8.3 Native hedgerow

Plants should be planted in staggered rows, with densities of a minimum 6 plants per linear metre.

Shrubs should be planted in groups of 5 of the same species.

Hedgerows should be planted with native species which are beneficial to UK wildlife –suitable shrub species include hazel (Corylus avellana), dogwood (Cornus sanguinea), and guelder rose (Viburnum opulus), hawthorn (Crataegus monogyna).

The native hedgerow is going to be planted with some of the same types of species as the proposed area for scrub. The difference is the management of the hedgerow:

Biodiversity Net Gain Assessment: Bolton Crofts

10.1 Native hedgerows

Newly planted hedgerows should be allowed to establish and mature; approximately 10 years. Once mature hedgerows should be managed under regular hedgerow management.

In year two of planting, hedgerows should be assessed to determine if any areas require “gapping up”. This should be repeated in the following year if plants fail to establish.

 Once established hedgerows should be managed sympathetically for wildlife. Hedge maintenance should include bi-annual cutting/flailing.

In less than ten years, this hedgerow is going to be of a height that will restrict the view of the three towers, Richmond Castle Keep, Holy Trinity Church Tower and Greyfriars Tower.

A problem section to fully block the view.

There is a section of great concern on the amended proposal where several elements join to fully block the view of the three towers, Richmond Castle Keep, Holy Trinity Church Tower and Greyfriars Tower. I’ve highlighted this with the red circle in the below graphic:

I will cover trees in a later section but for the interest of the view it is worth understanding that the proposed trees in this location are to be “planted as extra heavy standard specimen trees; as a result, it is reasonable to suggest that half should achieve a >30cm diameter at breast height after 30 years growth to achieve ‘medium tree’ classification. These will be native species.” In layman's terms, these will be large enough to limit the view when the trees come into leaf the first season after planting.

The types of trees the report says will be planted “Suitable species include silver birch (Betula pendula), alder (Alnus glutinosa), and wild cherry (Prunus avium), which are relatively fast growing”. Trees such as these grown in open spaces will grow out as well as up due to the available light surrounding the tree. These trees alone will block any view of the castle for future generations. I’ll also note that due to the slope of the land, and the types of trees, you will not be able to see the castle under the branch line of the trees as they mature.

With the information just presented about the types of trees, focusing back to the red circle in the above graphic, you will notice two trees, a hedgerow, the scrub area, and finally add to this collection of view-blocking elements is a vehicle parking area. For the worst-case scenario let's park a Mercedes Sprinter van here. By bringing all these elements together, there will be no view of the three towers, Richmond Castle Keep, Holy Trinity Church Tower and Greyfriars Tower.

Native Scrub Examples

In 2012 Yorkshire Water built a new covered reservoir on the northeast corner of the field at Bolton Crofts a little further up the same public footpath that runs next to this biodiversity enhancement scrub area. Once complete Yorkshire Water included some of the same native scrub species in their biodiversity enhancement land improvements. I’ve included a few photographs to demonstrate the speed these species grow and the view-blocking properties that can be expected.

South Side of the Site - Biodiversity Enhancement

It is not just the land for biodiversity enhancement adjacent to the public footpath that concerns me. On the south side of the field along with a small strip above the proposed entrance and exit road to the proposed housing estate are more areas of land that are to be planted with native scrub using the same planting method as mentioned above.

What stands out here is that in their plans they have already highlighted that most of this area will be in constant shade throughout the summer due to the canopy of the existing trees. I will be fascinated to learn how they are going to grow native scrub in an area that is shaded throughout the growing season when native scrub needs sunlight to grow. As mentioned, scrub is the stage of a woodland before the trees grow and shade out the scrub growing below them, causing the scrub layer to die.

Trees

In this section, if I may I would like to raise a few concerns I have regarding the additional planting of trees on Bolton Crofts.

Biodiversity Net Gain Assessment: Bolton Crofts

6 Proposed design

6.1.5 - 22 trees will be planted on-site. These will be located outside of private ownership within the development, along the emergency link road, and in the scrub. These will be planted as extra heavy standard specimen trees; as a result, it is reasonable to suggest that half should achieve a >30cm diameter at breast height after 30 years growth to achieve ‘medium tree’ classification. These will be native species.

6.2 Off-site habitat

6.2.1 Bolton Crofts

6.2.4 12 trees will also be planted within this area. These will be planted as extra heavy standard specimen trees; as a result, it is reasonable to suggest that half should achieve a >30cm diameter at breast height after 30 years growth to achieve ‘medium tree’ classification. These will be native species.

• Tree planting

Extra standard heavy specimens should be planted. Suitable species include silver birch (Betula pendula), alder (Alnus glutinosa), and wild cherry (Prunus avium), which are relatively fast growing. These should have a minimum starting girth of between 14-16cm.

With 22 trees on the proposed site and 12 trees located in the off-site habitat but still on Bolton Crofts this adds up to 34 trees in total.

Across the site, I count a total of 41 new trees, 20 new trees below the 92m line of new trees, and 21 above this line of new trees. I’m not counting any new trees that make up this line of trees in my counting.

Are these seven additional trees, or have seven additional trees been added to the map by mistake?

The location of this site where the trees will be planted, is the higher section of the south-facing valley side open to the west. The predominant wind is from the west blowing down through the Swale Dale Valley. The geology of the landscape also produces strong wiping winds that blast across the valley.

Any trees planted into this landscape are going to be extremely vulnerable to the strong winds. I appreciate when planting “Extra standard heavy specimen trees” they will be supported from getting blown over to start with, but once tree trees grow these supports become ineffective, leaving the trees very vulnerable to becoming blown over in such a location.

6.1.6 A line of trees (92m) will be planted along the northern perimeter of the development. This will be poor condition as the trees are unlikely to have veteran features or an undisturbed 6m buffer both sides due to proximity to residential gardens. It has also been presumed that the trees may not be native.

My first concern here is why is it presumed that the trees may not be native. Any trees planted in a conservation area presumably should be native trees by the very fact that it is a conservation area.

My next concern here is the design layout of the 92-meter line of trees. The angle of the proposed single line of trees moving gradually up the slope of the field puts every single tree that is part of this line on the western side of the emergency access link road in the direct path of the prevailing wind. Not only is a single line of trees an unnatural addition to an iconic landscape, but the same concern applies to this line of trees that I have for the trees planted in isolation in the field, and that is all these trees are going to be extremely vulnerable to strong winds.

Grassland and trees

As can be seen in the map below there are three descriptions of the current grassland, poor condition, moderate condition, and good condition.

The proposed houses will cover both the good and poor locations, (I’ll cover why the area stated “poor condition” is the way it is later in my letter.) Leaving the moderate condition area for biodiversity enhancement.

6.2.1 Bolton Crofts

6.2.2 0.1958ha of moderate condition other neutral grassland will be retained and managed as is on-site.

6.2.3 0.1475ha of tall forbs will be replaced by poor condition other neutral grassland as it has been presumed it may not reach a good representation of the habitat type as a precaution. This will be undertaken through management, including removal of species indicative of sub-optimal condition, including broadleaved dock, nettle, thistle. This area will be mowed annually, and arisings removed; plug planting may be used to increase diversity.

6.2.4 12 trees will also be planted within this area. These will be planted as extra heavy standard specimen trees; as a result, it is reasonable to suggest that half should achieve a >30cm diameter at breast height after 30 years growth to achieve ‘medium tree’ classification. These will be native species.

6.2.5 42m of native hedgerow in moderate condition will also be planted along the southern boundary of the off-site area.

The addition of so many trees to this small lowland meadow, a priority habitat of high ecological quality will change the soil microbiome due to the availability of extra nutrients caused by the decomposition of leaf fall. This will have major implications for the habitat that is currently in this area of the field and cannot be classed as biodiversity enhancement.

Section10 Habitat Management, of the Biodiversity Net Gain Assessment, states,

10.2 Other neutral grassland

Cuttings should be left in-situ for a few days (2-3) to allow seeds to drop. Cuttings should be later removed to reduce excess soil nutrients. Cuttings can be piled on-site, creating additional habitat for a range of faunal species.

The sixteen additional trees in this area will have a negative effect when trying to enhance a wildflower meadow. For this very reason, “Cuttings should be later removed to reduce excess soil nutrients.” Excess soil nutrients with be provided by the trees making the management of a small wildflower meadow near to impossible with so many large trees.

Monitoring and Management

Section 11 Monitoring of the Biodiversity Net Gain Assessment states,

It is recommended that the habitat creation, and off-site grassland enhancement, both at Bolton Crofts and Hornby are subjected to an appropriate monitoring scheme throughout the required duration for biodiversity net gain (30 years). Monitoring should focus on determining if the habitats are representative and achieve target conditions.

I have a concern with the monitoring and maintenance of both sites, Bolton Crofts, and Hornby if planning permission is granted.

Who will be responsible for overseeing the thirty-year monitoring period of the monitoring scheme throughout the required duration for biodiversity net gain? Will this be the North Yorkshire Council?

On page seven of the Design & Access Statement addendum, it states that “A Management Company will be set up for the maintenance of this area*, plus the areas for bio-diversity”.

*Note, “maintenance of this area” in the above statement refers to the Activity Play Area.

Is this management company going to be managing the areas of biodiversity for thirty years, the required duration for biodiversity net gain?

What happens after thirty years to the management of the areas of biodiversity? This is the period when the scrub will be looking to form a woodland if left unmaintained.

Will it be left to the North Yorkshire Council to take ownership of all the maintenance of Bolton Crofts?

Ecological Impact Assessment and Biodiversity Net Gain Assessment

I’ve covered sections of the Biodiversity Net Gain Assessment concerning the proposed biodiversity enhancement planting of scrub, hedgerows, and trees at Bolton Crofts, here I would like to reiterate the findings made after a site visit to Bolton Crofts by a North Yorkshire Council Ecologist regarding the Biodiversity Net Gain Assessment and the Ecological Impact Assessment.

Ecological Impact Assessment

I have the same concerns as documented in two letters after a site visit from Martin Hammond an Ecologist for the North Yorkshire Council concerning the findings of the Ecological Appraisal by MAB “differing significantly” from those of Dryad Ecology.

Quote: Martin Hammond

 “As we explained previously, the applicant has submitted contradictory assessments of the ecological quality of the grassland, the findings of the Ecological Appraisal by MAB differing significantly from those of Dryad Ecology. Neither assessment identified a number of plants credibly reported by local residents.”

Due to the exemplary credentials of Mr Hammond, and as an Ecologist for North Yorkshire Council, his advice for further botanical assessment is essential.

Biodiversity Net Gain Assessment

Yet again I am extremely puzzled at how an off-site area at Hornby, located approximately 8.7km from the proposed development site can even be considered to compensate for the loss of a wildflower meadow in Richmond.

Here I again strongly agree with Mr Hammond's conclusions regarding the biodiversity net gain assessment.

Quote: Martin Hammond

The biodiversity net gain assessment proposes to deliver an uplift of around 33% for area-based habitats, partly through off-site measures at Hornby. For the reasons explained in our previous response, our advice is that even if successful, grassland enhancement at Hornby would not compensate for the loss of habitat at Richmond due to isolation from other herb-rich grasslands.

Martin Hammond, Ecologist for North Yorkshire Council - Letter One; https://documents.richmondshire.gov.uk/civica/Resource/Civica/Handler.ashx/Doc/pagestream?cd=inline&pdf=true&docno=1826582

Martin Hammond, Ecologist for North Yorkshire Council - Letter Two; https://documents.richmondshire.gov.uk/my-requests/document-viewer?DocNo=1853864

Ecological Impact Assessment – Objections and Concerns

In this section, I would like to focus on the Ecological Impact Assessment and present my concerns.

Recent Field History

To give a clear understanding of one area of the field that has been identified as “Cock’s-foot (Dactylis glomerata) dominated species poor tussocky grassland.” Target note 3 (TN3). See the graphic below.

I would like to describe why this part of the field is currently going through a cycle of regeneration.

In 2012 Yorkshire Water built a new covered water reservoir, this can be seen in the top right section of the above map. When the covered water reservoir was being built the wildflower meadow in TN3 was fenced off with a security fence and used as a storage area for building equipment that was accessed by heavy plant machines moving over the land.

After the reservoir was completed in 2013, Yorkshire Water cleared the site of equipment and removed the security fence. What they never did was support the regeneration of the land back into a wildflower meadow, instead, they just left it compacted and devoid of plant life.

In the presiding years after the damage was done to this section of the field nature has moved in and this area of land has changed considerably over several years. Initially, docks and thistles grew taking advantage of the disturbed ground and the new source of bio-available nutrients in the now fertile soil created from the decomposed plants that had been growing before being smothered by pallets of equipment or compacted into the ground by machines driving over them.

After a few years, the docks and thistles exhausted their preferred nutrient sources in the soil and began to die back allowing cock’s-foot grass to take hold. After the cocks-foot grass smoothed out most of the remaining docks and thistles, the grass thrived on the soil nutrients that were made available due to the decomposed roots of the docks and thistles.

It is now noticeable that the cock’s-foot grass has peaked, allowing the next phase of regeneration to take place. Due to the lowering soil fertility in the coming years, more wildflowers will fill the gaps made by the cock’s-foot dyeing back permitting the field to slowly continue its cycle of regeneration back to the low fertile soil preferred by wildflower meadow plants.

The above photograph was taken on the 8^th of May 2009, this is before the Yorkshire Water Reservoir development destroyed the section of the wildflower meadow the young gentleman is about to walk through on his way to his school prom.

The photograph to the left shows the same area before the Yorkshire Water Reservoir development destroyed the section of the wildflower meadow that is identified in the Ecological Impact Assessment as “Cock’s-foot (Dactylis glomerata) dominated species poor tussocky grassland.”  

This photograph alone shows how important it is to return this area of land to a species-rich wildflower meadow and not to bulldoze away this beautiful view of the town forever.

Ecological Impact Assessment - Desktop study

The following sections unlined in red are taken from the Ecological Impact Assessment - Desktop study.

3.1.1 North and East Yorkshire Ecological Data Centre (NEYEDC) were commissioned to provide records of protected or notable species within 2km of the site.

I am very concerned with the quality and vagueness of the records provided in this report by the North and East Yorkshire Ecological Data Centre (NEYEDC). The records they have provided concerning species and species groups for the MAB Ecological Impact Assessment are inaccurate, therefore making the whole of the Ecological Impact Assessment unreliable due to the inaccuracies it contains.

In the below segments, I will highlight my concerns with the information provided.

5.3 Species and species groups

5.3.4 Birds:

Many records were returned for bird species within this area. A selection of species identified include, Goosander (Mergus merganser), Pied Wagtail (Motacilla alba), Curlew (Numenius sp.), Spotted Flycatcher (Muscicapa striata), Sand Martin (Riparia riparia) and many more.

This information has no relevance to the wildflower meadow of the proposed housing development. Can we please have the full list of birds seen in the 2km circumference of this site, along with records of birds seen at the site?

5.3.5 Bats

Six records were held for bats in this area, species include Daubenton’s bat (Myotis daubentonii), Noctule bat (Nyctalus noctula), Common pipistrelle (Pipistrellus pipistrellus) and soprano pipistrelle (Pipistrellus pygmaeus). No records were held for the site itself.

Six records were held for bats in this area. Remembering this is a 2km circumference area of the site. This alone should invalidate any further data provided by the North and East Yorkshire Ecological Data Centre. Are we expected to believe we have no bats roosting in the old buildings of Richmond town? This is inconclusive information for the site regarding such an important mammal that is seen regularly foraging over the field.

As requested in my last letter, Fiona, can we please have a proper Bat Survey carried out for the site?

5.3.6 Badgers

Two records were identified in the record search for Badgers (Meles meles). These were historic records, the most recent being from 18 years ago. These were recorded in Low wood and Temple grounds respectively. No records were held for the site itself.

This is incorrect data. Badgers are common in the 2km circumference of this site, as well as sightings on the site itself.

5.3.8 Otter

Records were held for otter (Lutra lutra) within the area, four records were found within Richmond. These centred mainly around the River Swale, with only one being from the last ten years. No records were held for the site itself.

This is incorrect data; please consult Richmond Fishing Club they will confirm regular sightings of Otters on the river swale within the 2km circumference of this site.

I’m not claiming there are otters on the field but highlight the fact that the information provided by the North and East Yorkshire Ecological Data Centre is incorrect and therefore cannot be used for this Ecological Impact Assessment.

5.3.9 Hedgehog

No records were held for hedgehogs (Erinaceus europaeus). Hedgehogs are a SOPI under the 2006 NERC act, and therefore are scoped into the assessment.

I am very surprised that the North and East Yorkshire Ecological Data Centre hold no records of Hedgehogs within a 2km circumference of this site. The below picture was taken from a trail camera video recorded in my garden which is situated next to the field, as you can see it contains six hedgehogs.

Fiona, from this photograph I’m sure you will agree that the field of the proposed housing development is of HIGH IMPORTANCE for Hedgehogs, a species of principal importance (SOPI). The Natural Environment and Rural Communities Act 2006 (2006 NERC act) section 40 states: “Duty to conserve biodiversity”.

It is only by default that hedgehogs due to their SOPI status have had to be included in the “5.3 Species and species groups list” of the Ecological Impact Assessment whilst at the same time stating that “no records were held for Hedgehogs” within the 2km circumference of this site.

Assessment of effects and mitigation

The proposed mitigation measures contained in the Ecological Impact Assessment, are inappropriate due to the lack of, and incorrect information contained in the report.

Only when a detailed Ecological Impact Assessment has been carried out can any mitigation measures be proposed.

It is worth noting that in the Assessment of effects and mitigation section Hedgehogs do get a mention. Hedgehogs as a species of principal importance and are protected by The Natural Environment and Rural Communities Act 2006 (2006 NERC act) I will share in full what this Ecological Impact Assessment’s mitigation measures are for Hedgehogs.

7.7 Hedgehogs

7.7.1 Effects

Hedgehogs are likely to be using the site though no evidence was noted. The residential development will provide habitat for hedgehogs but commuting routes may be blocked if access isn’t retained and mammals may fall in trenches while the development is being built.

7.7.2 Mitigation measures

7.7.3 As a precautionary measure, during construction deep trenches and excavations should be covered overnight, or left with a plank or similar, with a slope of no more than 45 degrees to allow hedgehogs, and small mammals escape if they fall in.

7.7.4 If any boundary fencing is installed on-site (i.e around gardens), holes will be put into the bases, allowing hedgehogs to move across the site and into the surrounding landscape.; holes should be 13cm x 13cm.

7.7.5 To provide additional habitat 2 long lasting professional quality hedgehog houses should be installed on-site. These should be located in sheltered areas away from roads, where there is good connectivity to the wider landscape.

Once again, the Ecological Impact Assessment is downplaying the importance of Hedgehogs as a Species of Principal Importance living on the site by stating “Hedgehogs are likely to be using the site though no evidence was noted.”

Recommendations for ecological enhancement & compensation 

As we know by now a detailed Ecological Impact Assessment needs to be carried out on the site before any development proposal can be considered. It would only be fair for me to cover the Recommendations for ecological enhancement & compensation contained in this Ecological Impact Assessment.

8.1.1 Additional landscape planting is recommended, where feasible, and will comprise of native trees and shrubs, which provide food sources for birds, such as hawthorn, hazel, dogwood, guelder rose, birch, willow, field maple. Non-native planting often used in developments such as laurel has very little value for birds and should be avoided.

To summarise, a whole wildflower meadow ecosystem will be removed and replaced with about half the area going into housing and infrastructure, the remaining area will more resemble that of a wood pasture parkland ecosystem. This means a complete habitat change for any flora and fauna living on the site, in short, an ecological disaster, a total habitat collapse.

8.1.2 Bat and bird boxes should be integrated within the proposed new build properties. Integral habitat is preferable, as when it is well-placed it can be completely out of sight, and any droppings should fall out into unoccupied areas. We recommend 1 bat and 1 bird unit per 5 properties. The bird boxes should be swift boxes.

With twenty-seven houses to be built, taking the calculation to the nearest whole, this will be five bat boxes and five swift boxes. Not to forget the two Hedgehog boxes mentioned in the mitigation measures for Hedgehogs.

No swifts are nesting on this site, swifts are birds of habit and nest in the same locations each year. The likelihood of swifts using these nest boxes is slim to non-existent.

Five bat boxes to compensate for the destruction of their foraging habitat, please do not insult the bats.

My records of Birds and Wildlife on the Site

I posted these in my last letter but after reading the Ecological Impact Assessment and the lack of credible data I shall resubmit my list here to show how important this field is to wildlife and birds and Richmond as a whole.

Birds

Butterflies

Animals

Grazing Land and the Emergency Link

Directly behind the proposed development is a small area designated as grazing land. This area is a contained space with a stock fence on the west side of the field and a 1.2m post and 5 rail stock-proof fence dividing the grazing land from the remaining section of land for biodiversity enhancement next to Green Howards Road. There is also a 1.2m post and 5 rail stock-proof fence enclosing the “Open Space” section where the proposed public activity play area will be located.

I have a concern here regarding the emergency link and its accessibility in the event of an emergency e.g. a house fire when seconds are crucial to saving lives.

Access to the emergency link from Green Howards Road is through a bollard system, from the plans, there are also two stock-proof gates to navigate through. The first is in the middle of the field part of the 1.2m post and 5 rail stock-proof fence. The second is as you reach the road from the emergency link taking you onto the proposed development.

A good question to raise here would be how the developer is going to ensure the gates are not left open when cyclists, children and the public in general use them.

Due to the gradient of the field, the gates will need to open away from the slope which will allow them to easily swing open. Will these gates need to be padlocked to keep any grazing animals from wandering out of a left-open gate into the proposed housing estate or onto Green Howards Road? We must remember that there is no gate just bollards securing the top part of the field access onto a very fast and busy road with a blind summit next to the gateway into the field. This poses another question, is it even safe to use this emergency access road with such a poor exit point not to mention this emergency access road doubles as a cycleway, leading cyclists onto Green Howards Road at the worst point possible, a blind summit?

Move back to the concern of a house fire, with two extra gates to open, presumably not closed after going through them in an emergency such as a fire, (risk of escaping animals) along with the removal of the bollards which will need to be locked to prevent them from being removed by people wanting to use the link as a shortcut in their cars to avoid traffic congestion on Quakers Lane, Queens Road etc, how effective at saving lives will this emergency link be if access from Bolton Avenue is blocked?

The other consideration is who will be responsible for maintaining the bollards. Over time locks will seize up if not used or maintained.

Fiona, in the event of a house fire, and the fire engine being unable to access the site from Bolton Avenue it would be very wise to perhaps consult the North Yorkshire Fire Brigade as we are now both aware of a possible fire risk due to the obstacles placed on the “emergency Link” road to hear their opinions regarding the locked bollards and two gates. Consulting North Yorkshire Fire Brigade on this matter may save lives.

Area for public benefit

The below section is taken from the: Design & Access Statement addendum.

Open Space & Play

Additional open space and on-site play provision is now proposed, and the area of land extends to 1240m2, situated within the view corridor to the castle through the middle of the site. The precise details of the layout and equipment is to be agreed but the following page shows some initial thoughts and ideas for discussion. The area of land is considered particularly desirable, providing added public benefit by the additional play opportunities, designed to take advantage of the sloping nature of the site, and with places to rest and relax in a safe and accessible environment and enjoying new opportunities for views towards the town and castle. A Management Company will be set up for the maintenance of this area, plus the areas for bio-diversity.

The sloping site brings opportunity for imaginative play, taking advantage of the change in level to accommodate elements such as slides, climbing nets, and tunnels. Rustic and natural play equipment, such as timber and rock, will be incorporated to blend and complement the environment. Large boulders, together with timber benches, will provide opportunities for rest and relaxation and to take advantage of the new publicly accessible views towards the town and castle.

Concerns

I would like to raise concerns I have for “The area of land is considered particularly desirable, providing added public benefit by the additional play opportunities, designed to take advantage of the sloping nature of the site, and with places to rest and relax in a safe and accessible environment”.

• No disabled parking – With no disabled parking anywhere close to this area of play and relaxation how can it be claimed that this “area of land is considered particularly desirable, providing added public benefit”. The proposed plans have made this an exclusive area of land for abled-bodied people only. With no parking for disabled people, it is inaccessible for parents and guardians with limited mobility who want to access the park with their children or experience anything in this area of land that is stated to provide “added public benefit”.
• No parking – This area of the development is said to be providing “added public benefit”, where are people going to park? I’ve mentioned that there is no disabled parking, but there is no parking at all included in the proposed plans. Due to the steep hill leading to the proposed development site, people will come to this area in cars. The nearest place to park will be on Green Howards Road, which is a very fast and dangerous road with constant trading estate traffic including HGV’s. There are no double yellow lines on Green Howards Road so people will park there to access the park and relaxation area. As somebody who lives in Alma Place, I can assure you that there is no available parking in this area, and I’m told the same applies to Bolton Avenue.
• Safeguarding “a Child or Young Person” and “Adults at Risk” from Abuse -Due to the secluded location of this play area, what measures are going to be put in place to safeguard “a child or young person” and “adults at risk” from abuse? Ronaldshay Park - Quakers Lane has a main road next to it allowing the police easy visibility into the park, it also has a bowling club next to it and the park has constant foot traffic both through and next to the park. The location of the proposed play area is going to be shielded from the view of the proposed houses by a line of trees, and due to the slope of the landscape, there will be no visibility from Green Howards Road.
• Health and Safety – Has there been a full risk assessment carried out on the proposed plan for the children's activity play area? Once again, I reiterate the secluded location of the “Activity Play Area” with no roads overlooking it, and what will be limited foot traffic in this area. In the event of a child having an accident what measures are going to be put in place to mitigate such an eventuality that is bound to happen?

A health and safety risk assessment must also consider the types of animals that will be kept on the grazing land surrounding the play area. Access to this area from Green Howards Road involves children entering the grazing land through a gate on the Emergency link/Cycleway from where they will be in the same area as roaming animals. This also applies to children entering the field on the Emergency link/Cycleway from the proposed housing estate gate. It’s not just children that this applies to, trampling by grazing animals is a major risk to people. Any animals grazing in this area will be constantly alarmed by children screaming and shouting whilst having fun in the activity play area making the animals extremely susceptible to panicking which can lead to the trampling of people.

The above graphic is taken from the document titled; “Design & Access Statement addendum” This highlights that the proposed Activity Play Area will not be visible from Green Howards Road.

In the above map, the two red circles highlight the stock-proof gates on the emergency link/cycleway. Once entered people are now in the same area as the grazing animals. To note, the Activity play Area is protected by a post and rail fence. The yellow circle with the 7, is stated in the document titled; “3894-PD-222A ILLUSTRATIVE PHOTOMONTAGES + ENVIRONMENTAL PUBLIC BENEFIT PLAN” as a “Suitably sized turning head for service and emergency vehicles” Therefore we can conclude by this statement this will be a no parking area.

In closing

As I draw my letter to an end, I once again thank you Fiona for the opportunity to add any further comments I may wish to make for the Council to consider before any decision is made on this application. To end with Fiona, I ask you to consider wisely this application for planning permission on this ancient wildflower meadow in Richmond that is home to an abundance of flora and fauna, which if planning permission is approved will sadly come to an end forever.

Yours sincerely

Stephen Andrews