Paul Sterry West Wit, New Road Little London, Tadley RG26 5EU Date
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To: Russell Stock From: Paul Sterry West Wit, New Road Little London, Tadley RG26 5EU Date: 31 December 2019 19/02372/FUL | Erection of 4 new dwellings | Land At O/s Ref 461271 159753 I wish to comment on the Biodiversity Impact Calculation document submitted in support of the above application. The document states that it is ‘intended to provide an objective measure of the losses and gains in biodiversity resulting from the current proposed layout and determine if the development will provide a net gain for biodiversity of 10% of more.’ By its own admission and using its own data, the document fails to meet the council’s metrics requirements since it only claims a 9.8% Net Gain. As with all desk-bound exercises in statistics, the outcomes and conclusions are only as good as the inputted data. I suggest that the figure of 9.8% is extremely optimistic and should be discounted because it is not based upon informed and reasonable data. The two main areas of interest and concern for me are: 1) The assessment of the site’s grassland as being ‘poor’ 2) The inferred biodiversity contribution that would be made by creating a ‘wildflower meadow’ Firstly, at the risk of stating the obvious it is worth pointing out that the biodiversity of an area of grassland and marginal scrub/hedgerows comprises more than just its floral elements. It relates to the web of life that the community supports, including vertebrates and invertebrates. For the sake of this argument I will concentrate on two comparable sites in the vicinity, and two taxa groups where relevant and informed data exists: floral diversity; and moths and butterflies, whose caterpillars feed on, and are dependent upon, plants. Above: An Ordnance Survey UK Grid Reference map showing the location of the following sites: 1) the planning application; 2) a comparable area of land at RG26 5EU; 3) Bentley Green Meadows SSSI; 4) Pamber Forest SSSI; 5) ‘restored’ grassland. 1) The assessment of the site, including the grassland, appears to have been made on the basis of a single visit in October. It is hardly surprising that little of floral interest was discovered at this botanically-unpromising time of year and I fail to see how any other outcome could have been achieved. Rough, traditional grassland is a rare commodity in the vicinity of the planning application site, given that the majority of fields in the Parish are either grazed intensively by horses and other livestock, or seeded with perennial ryegrass and sprayed, thereby obliterating most of their biodiversity. With this in mind it is useful to look at two comparable areas of undeniably good quality grassland in the neighbourhood. Firstly, a garden further along New Road (numbered 2 on the above map, roughly 0.2 hectares where wildlife takes precedence) and secondly Bentley Green Meadows SSSI (numbered 3 on the above map). If you were to visit both sites 2 and 3 in October, then to an untutored eye the floral composition would be akin to that discovered during the ecological survey at the planning application site. However, the reality is rather different if you monitor the sites throughout the flowering season: excluding grasses, 101 species of native wildflower have been recorded at site 2 (see Appendix below), and at the last count the number at site 3 exceeded 250 (see British Wildlife Magazine, volume 11, no.1, 1999). This diversity is also reflected in other taxa groups: at site 2 more than 450 moth and butterfly species have been recorded (see attached document: New Road Biodiversity), while at site 3 the number exceeds 530. That’s getting on for 20% of the entire British Lepidoptera fauna, a remarkable number by anyone’s standards. In addition, between them both sites harbour 4 of the UK’s 6 native reptile species and 5 of the 7 native amphibian species, not to mention grassland specialists such as Harvest Mouse. None of these species would be evident in October. I suggest there is no reason to suppose the grassland subject to the planning application is substantially different from sites 2 and 3 and in my view the assessment of the site as ‘poor’ cannot be shown to be accurate; there is every reason to suppose it supports far richer biodiversity than suggested in the report. 2) Well-intentioned though it might seem I would suggest that the benefits of planting a wildflower meadow for biodiversity in this situation are greatly exaggerated. Decent wildflower meadows take decades, sometimes centuries, to reach their potential for biodiversity in the true sense. In the same way you can plant trees but can’t plant an ancient woodland – it takes centuries for the community of wildlife associated with it to develop – neither can you create a wildlife-rich meadow simply by scattering seeds. With these misgivings in mind it is worth considering the fortunes of grassland immediately to the west of the planning application site, numbered 5 on the above map. In 2004 its use changed from arable to hay production with seasonal grazing by sheep. Presumably in an attempt to kickstart botanical colonisation, an extraordinary mix of ‘wildflower’ seeds was scattered, most species of which were entirely inappropriate despite been used on the basis they were ‘suited to clay’. A multitude of floral diversity presented itself in the year of seeding but the species numbers diminished rapidly year by year; today, 15 years on, you would be lucky to find more than 30 flower species excluding grasses. This floral paucity is reflected in invertebrate diversity (or the lack of it): to my knowledge the field supports just three meadow- associated butterfly species (in small numbers) whereas site 2 (tiny by comparison) can boast seven species in relative abundance (see attached document: New Road Biodiversity). For the above reasons I suggest that the conclusions drawn from the biodiversity metric calculation are not accurate. Expanding on this, I suggest that the creation of a new ‘meadow’ (which, in a short space of time is likely to become a dismal collection of born-survivor weeds) is no compensation for the loss of an existing area of natural rough grassland that, in the absence of full empirical data, should be assumed to harbour rich biodiversity. Appendix 1 – wildflower species recorded at Site 2 black bryony Tamus communis ivy Hedera helix hop Humulus lupulus common nettle Urtica dioica redshank Polygonum persicaria black bindweed Bilderdykia convolvulus broad-leaved dock Rumex obtusifolius lesser stitchwort Stellaria graminea common chickweed Stellaria media common mouse-ear Cerastium fontanum red campion Silene dioica white campion Silene alba meadow buttercup Ranunculus acris creeping buttercup Ranunculus repens lesser celandine Ranunculus ficaria hedge mustard Sisymbrium officinale common wintercress Barbaris vulgaris hairy bittercress Cardamine hirsuta wavy bittercress Cardamine flexuosa cuckoo flower Cardamine pratensis shepherd's purse Capsella bursa-pastoris common whitlow-grass Erophila verna garlic mustard Alliaria petiolata agrimony Agrimonia eupatoria dog rose Rosa canina bramble Rubus fruticosus tormentil Potentilla erecta silverweed Potentilla anserina wood avens Geum urbanum common vetch Vicia sativa grass vetchling Lathyrus nissolia tufted vetch Vicia cracca ribbed melilot Melilotus officinalis greater birdsfoot trefoil Lotus pedunculatus black medick Medicago lupulina hop trefoil Trifolium campestre red clover Trifolium pratense white clover Trifolium repens herb robert Geranium robertianum cut-leaved cranesbill Geranium dissectum common dog violet Viola riviniana broad-leaved willowherb Epilobium montanum hoary willowherb Epilobium parviflorum cow parsley Anthriscus sylvestris hogweed Heracleum sphondylium ground elder Aegopodium podagraria hemlock water-dropwort Oenanthe crocata wild carrot Daucus carota wild angelica Angelica sylvestris primrose Primula vulgaris cowslip Primula veris creeping jenny Lysimachia nummularia hedge bindweed Calystegia sepium field bindweed Convolvulus arvensis common cleavers Galium aparine common comfrey Symphytum officinale early forgetmenot Myosotis ramosissima self-heal Prunella vulgaris ground ivy Glechoma hederacea white dead-nettle Lamium album red dead-nettle Lamium purpureum betony Stachys officinalis wild basil Clinopodium vulgare bittersweet Solanum dulcamara yellow toadflax Linaria vulgaris common figwort Scrophularia nodosa germander speedwell Veronica chamaedrys foxglove Digitalis purpurea greater plantain Plantago major ribwort plantain Plantago lanceolata teasel Dipsacus fullonum daisy Bellis perennis ox-eye daisy Leucanthemum vulgare scentless mayweed Matricaria perforata pineapple mayweed Chamomilla suaveolens fleabane Pulicaria dysenterica yarrow Achillea millefolium sneezewort Achillea ptarmica tansy Tanacetum vulgare feverfew Tanacetum parthenium coltsfoot Tussilago farfara ragwort Senecio jacobaea hoary ragwort Senecio erucifolia groundsel Senecio vulgaris greater burdock Arctium lappa marsh thistle Cirsium palustre spear thistle Cirsium vulgare creeping thistle Cirsium arvense smooth sowthistle Sonchus oleraceus perennial sowthistle Sonchus arvensis nipplewort Laxana officinalis dandelion Taraxacum Section Vulgaria goat's-beard Tragopogon pratensis common catsear Hypochaeris radicata snowdrop Galanthus nivalis ramsons Allium ursinum yellow iris Iris pseudacorus lords and ladies Arum maculatum Pyramidal orchid Anacamptis pyramidalis common spotted orchid Dactylorhiza fuchsii broad leaved helleborine Epipactis helleborine BIODIVERSITY AND ENVIRONMENT OF NEW ROAD, LITTLE