Newcastle Great Park Consortium has submitted revised plans for sports pitches in Cell B1 of Newcastle Great Park.
Our latest objection is detailed below.
Save Newcastle Wildlife is concerned with protecting wildlife and green space in Newcastle. This application, if approved, would see a significant adverse effect on wildlife in and around Havannah and Three Hills Local Nature Reserve and the loss of a much cherished green space.
We have objected vociferously to the outline and original reserved matters application for this development and we maintain our objection in light of the updated reserved matters application, which will still see inappropriate development in the Green Belt, loss of strategic open space and public rights of way, as well as further erosion of an important wildlife corridor and encroachment on Havannah Nature Reserve.
We understand the landscaping and drainage aspects of the application have been reviewed in attempt to make this inappropriate development more palatable, however, this does not alter the fact that Cell B1 is not allocated for any form of development in the local plan. Cell B1 is Green Belt and strategic open space and should remain as such to allow for the free movement of wildlife and people.
The proposals contravene a number of Core Strategy and Urban Core Plan (CSUCP) and Development and Allocations Plan (DAP) policies, namely CS14 Health and Wellbeing, CS16 Climate Change, CS17 Flood Risk and Water Management, CS18 Green Infrastructure and the Natural Environment, CS19 Green Belt, DM27 Protecting and Enhancing Green Infrastructure, DM28 Trees and Landscaping and DM29 Protecting and Enhancing Geodiversity, Biodiversity and Habitats. The proposals also contravene key policies in the National Planning Policy Framework (NPPF) on Green Belt, climate change and flooding and conserving and enhancing the natural environment.
Policy CS14 states that the wellbeing and health of communities will be maintained by creating an ‘inclusive natural environment’ and ‘access for all to green spaces’. Access to green space is essential for physical health and mental wellbeing. The city’s green spaces are in demand, now more than ever, as a result of the recent pandemic and the associated lockdown and social distancing measures, however, it is unclear how the proposed sports pitches will be made available to the community. This development would see the loss of accessible green space for the local community. Paragraph 99 of the NPPF states that existing open space should not be built on. The recent pandemic means there is now an even stronger case for Cell B1 to remain as Green Belt and strategic open space.
Policy CS16 states that development should be ‘sustainable, able to function effectively in a changing climate and address impacts on climate change emissions’. It also states that ‘development should provide resilience to the ongoing and predicted impacts of climate change.’ Flooding, is one of the predicted impacts of climate change and the flood risk increases with each greenfield site that is developed. This proposal would see a greenfield site, not earmarked for any form of built development, transformed into playing pitches, which are susceptible to becoming waterlogged and flooded. Flooding is an increasingly serious issue in the immediate area, as vast areas of permeable surfaces are paved over in Castle Ward. Last year saw unprecedented levels of flooding in and around Havannah Nature Reserve, very likely as a result of overdevelopment in the area. Gosforth Letch borders the eastern boundary of the application site and land alongside this watercourse is liable to surface water flooding. The applicant’s flood risk assessment acknowledges that the site will be at risk from surface water flooding. Policy CS17 states that development will avoid and manage flood risk and take into account the impact of climate change by locating development in areas with the lowest risk. Paragraph 162 of the NPPF states that development should not be permitted if there are reasonably available sites in areas with a lower risk of flooding. There are other suitable sites with a lower risk of flooding and minding this application for approval – on land that was not allocated for development – will put local communities and wildlife sites at risk from flooding in a rapidly changing climate.
Policy CS18 seeks to maintain ‘a high quality and comprehensive framework of interconnected green infrastructure that offers ease of movement and an appealing natural environment for people and wildlife’. Fencing off the proposed development site with a 1.8-metre-high fence will severely hamper movement of both wildlife and people. This application, if approved, would undermine the Council’s commitment to maintaining and enhancing a comprehensive framework of green infrastructure.
Policy CS19 states that the Green Belt should ‘safeguard the countryside from encroachment’ and ‘check unrestricted urban sprawl’. This development would encroach on the Green Belt and see further urban sprawl. Paragraph 147 of the NPPF sets out that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. There are no very special circumstances to justify this development and the Council has clearly not examined fully all other reasonable options for meeting the need for development.
Policy DM27 states that ‘any development that would have an adverse impact on green infrastructure assets will be required to demonstrate that the benefits of any development will outweigh the harm.’ This development would have an adverse effect on green infrastructure assets and there is no evidence that the benefits would outweigh the harm. The proposed development would undermine the Council’s commitment to protecting green infrastructure assets.
Policy DM28 states that development will be required ‘to protect, enhance and manage existing trees and landscape features.’ This application would see widespread removal of existing vegetation, trees and hedgerows in Cell B1 to make way for sports pitches. We note that Newcastle Airport has requested the planting mix for mitigation works to be limited to no more than 10% berry-bearing species. We understand a significant number of hawthorn trees would need to be removed to make way for this development. Removing existing berry bearing species will result in a net loss for biodiversity, contravening the Council’s commitment to conserving and enhancing biodiversity and protecting existing tree stock. Further tree removal would be likely within the adjacent Local Nature Reserve to facilitate the proposed strategic route, which will run through the middle of the nature reserve. The proposed development would undermine the Council’s commitment to protecting existing trees
We are gravely concerned by proposals for a 3-metre-wide asphalt walkway and cycle way straight through Havannah Nature Reserve. This will require widening of the existing footpath, which will result in loss of trees and vegetation in the nature reserve. The reserve is valued for its mosaic of woodland, grassland, wetland and heathland habitats, which should be maintained and enhanced, not eroded to make way for unsustainable development. Presumably this route will also be lit, which will have a significant adverse effect on nocturnal wildlife. There is no mention of how the playing pitches will be lit and, should planning permission be granted, we would expect to see a legal agreement in place to ensure the area is not artificially lit once developed. Paragraph 185 of the NPPF states that planning decisions should limit the impact of light pollution from artificial light on nature conservation. This proposal would see an artificially lit path in a site of nature conservation. We trust the planning committee will be made aware that this unsound application would necessitate development within Havannah and Three Hills Local Nature Reserve.
Policy DM29 specifically states that:
‘Development which directly or indirectly causes significant harm to a Local Nature Reserve (LNR), Local Wildlife Site (LWS), Local Geological Site (LGS), and/or Site of Local Conservation Interest (SLCI), as designated on the Policies Map, and/or protected species should be avoided.
This development would inflict significant harm on Havannah and Three Hills LNR; harm that could easily be avoided by relocating the schools provision to where it was originally intended: in Cell A. The application site and adjacent reserve support a number protected species. The City Council has a duty under Section 40 of the Natural Environment and Rural Communities Act (2006) to conserve biodiversity. Minding this application for approval would contravene the obligations under this duty. Paragraph 175 of the NPPF highlights the need to ‘avoid ecological impact where possible and, if this is not feasible, to undertake mitigation or seek relevant compensation.’ As previously stated, it is perfectly possible to avoid the ecological impact of this development by asking the applicant to deliver schools provision in line with the local plan.
The application site lies within the Ouseburn Catchment Wildlife Enhancement Corridor, which has already been adversely affected by overdevelopment. Important species and habitats, many of which are supposedly protected in the Newcastle and North Tyneside Biodiversity Action Plan, would be adversely affected by this development. Policy DM29 states that:
‘Development which would have an adverse effect on the biodiversity value or connectivity and function of the Wildlife Enhancement Corridor as designated on the Policies Map, will only be permitted where adequate mitigation is secured.’
Adequate mitigation has not been secured because it is not possible to provide adequate mitigation when the application site itself has already been designated as ecological mitigation for development of the Sage and park and ride. Development in Cell B1 could – and should – be avoided to minimise harm to the biodiversity and function of the wildlife corridor. The applicant will likely argue that land in Cell C3 will mitigate for the loss of Cell B1, however, Cell C3 was supposedly mitigation for development in Cell C, in the same way that Cell B1 was supposed to be mitigation for development in Cell B. Paragraph 174 of the NPPF sets out how planning decisions should contribute to and enhance the local environment by minimising impacts on and providing net gains for biodiversity. This application, if approved, would see a net loss of biodiversity.
We are concerned by the lack of input from the Council ecologist, who appears to have limited knowledge of the site and the likely impact of the proposed development on important species and habitats within Havannah Nature Reserve. Havannah Nature Reserve is a major site within the CSUCP and the Council highlights the need for protection of major sites through the planning system to ensure their survival. At present Cell B1 is heavily used by walkers – many of whom have dogs. Fencing off this area will see a rise in dog walkers using the nature reserve, which is already suffering from a huge increase in recreational pressure, and an adverse effect on important species and habitats in the reserve.
These proposals would necessitate stripping the top soil, which would harm biodiversity and release carbon into the atmosphere. Soil is essentially a non-renewable resource and national guidance calls for development to protect the best and most versatile soils. Soils in the local area are good to moderate, yet they are being lost at an alarming rate to overdevelopment. Soils should be preserved for carbon capture, food security and their ecological value.
In line with Paragraph 180 of the NPPF, Newcastle City Council should ask the applicant to relocate the schools provision to a site with less harmful impacts on biodiversity. This can be achieved by asking the applicant to deliver all schools provision in Cell A. The NPPF states that applications should be determined in accordance with the development plan, unless material considerations indicate otherwise. There is still time to act in the interests of local people and wildlife by refusing this application and asking the applicant to deliver schools provision in line with the local plan – in Cell A.
Should this application be minded for approval, we would expect to see significant financial contributions to secure a full-time ranger for Havannah Nature Reserve – secured by condition – as well as additional financial contributions for the upkeep of the reserve to mitigate for the increase in recreational pressure. We would also like to see the creation of new areas for nature conservation, not just areas set aside as mitigation.
We understand the Council will be concerned by the prospect of an appeal by the applicant, should the application be refused, however, it is in the public interest to refuse this application. Almost 13,000 people have signed a petition against the plans and will be looking to Newcastle City Council to make the right decision for the people and environment it serves, not for the marauding developers.
Approving this application would contravene multiple local and national policies and leave the Council open to further legal challenge. We trust officers will recommend refusal for the proposed development, which would have a significant adverse effect on wildlife and green space in Newcastle.