Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
REPORT BY CORNARDS RESIDENTS ASSOCIATION PROPOSED LAND ALLOCATION SHELAA SITE SS0220, LAND SOUTH OF DAVIDSON CLOSE, GREAT CORNARD, SUDBURY
The Cornards Resident Association provide this report which covers many of the sections of the local plan which is applicable to the inclusion of site SS0220 Land South of Davidson Close Great Cornard Sudbury Suffolk, this site has been listed as a reasonable alternative site in the joint plan.
Our report shows a very strong set of reasons for this land not to be listed as a reasonable alternative site and we argue it is an inappropriate site for the Sudbury and Great Cornard area – arising from a number of wide ranging critical issues not least those emanating from safety outside schools, access, landscape, flood and environmental damage. In addition, there is now the cumulative impact of both the approved Chilton Woods and the proposed Tye Farm developments potentially overwhelming local infrastructure and inflicting catastrophic environmental damage.
Our report shows strongly that the SHELAA document's appraisal of Site SS0220 is wholly and materially deficient to the extent of being misleading, in not identifying the range of constraints that would require consideration before a Land Allocation being made.
We therefore submit in the strongest terms possible that this site must remain not only outside the Local Plan, but protected for future generations in perpetuity.
INDEX
• Road Traffic Safety Report
• Access Report
• Connectivity and Transport Report
• Biodiversity Report o Biodiversity Policy Report
• Flood Risk
• Open Space Report
• Landscape and Heritage Report o Landscape and Heritage Policy Report Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
Firstly and most importantly, it is absolutely essential that readers of this Report understand that its production has been very seriously and fundamentally impaired by the advent of the Coronavirus/Corvid 19 Pandemic.
It was originally intended that Cornards Residents Association conduct an extensive traffic survey in the localities affected by this proposed development. However, given the fundamental issues that arise from the lockdown, the closure of schools and the consequent impact of reduced traffic flows, this project has been postponed until normality returns. We are not prepared to put forward a skewed result and misrepresent the true facts. In this regard we reserve our position to produce such survey results when completed. Furthermore, we would make the observation that any attempt by the developer to undertake a traffic survey prior to normality returning will be vigorously challenged. Locations for any such surveys other than in Prospect Hill North of Horse Pond Close, Blackhouse Lane at both ends, and Wells Hall Road outside the schools and at each end, will likewise be vigorously challenged. As will any surveys conducted in the area of Carsons Drive, Kempson Drive and Shawlands Avenue.
However, very extensive evidence exists of the problems being experienced in the locality. This has been collected from residents and compiled herein for your consideration in the meantime.
1. BACKGROUND
A. THE WESTERN APPROACH
The proposed site borders Prospect Hill on its Western extremity with an “All modes of transport” access road indicated in the outline plans contained on the internet. It is proposed that the Eastern access point would enter the proposed development via a new roadway into Chaplin Walk.
Prospect Hill, Proposed - Western Access Route
The proposed Western boundary of the site abuts Prospect Hill and although this immediate area is on the Village edge it is deeply rural in its character and the infrastructure reflects this.
All traffic exiting via Prospect Hill and vice versa would be confronted with a choice of routes at the Prospect Hill/ Wells Hall Road junction; to continue straight ahead along Wells Hall Road and past the schools or turn left along Blackhouse Lane to the Bures Road.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
Prospect Hill is a single track country lane, very narrow and deeply sunken along the edge of the proposed site with an environmentally important ancient hedgerow immediately on the opposite side of the carriageway. It is unlit and has no footways. Half way along this ancient hedgerow is a small but important gap that acts as an entrance to the Cornard Country Park. Consequently, there are limited passing places and is entirely unsuitable for large vehicles. It is exceedingly rural in absolutely every respect.
Heading South up the hill there is a very sharp left hand bend where an important and picturesque public footpath joins the road that also acts as another walker’s entrance to the Cornard Country Park. This particular bend is a site of many minor road collisions witnessed by debris lying in the road or thrown into the hedgerows. The footpath here runs along an alluvial gully. Thereafter, a steep gradient takes you to the summit passing the entrance driveways of Woodlands, Prospect House and Quebec Cottage.
Heading North from the proposed site (towards Sudbury, i.e., you have now turned around), you immediately come to a left hand bend after the last bungalow in Eldred Drive. At this point, to the right, is an important and well used public footpath that joins the road, as does Black Brook as it runs under the road in a culvert. Still heading North, you now have on your right the curtilage hedge of Hollowtree House of Horse Pond Close and a very narrow footpath taking users down to the junction of Blackhouse Lane and Wells Hall Road.
On your left opposite the entrance drive of Horse Pond Close, you have Black Brook running parallel with Prospect Hill and immediately abutting the carriageway with an ancient and environmentally important hedgerow on the opposite bank including three veteran trees of significance. Black Brook forms the boundary of the extensive allotment gardens accessed via Blackhouse Lane. As Black Brook reaches the junction of Blackhouse Lane and Wells Hall Road, it passes through a culvert under the road and is now on the Northern side of Blackhouse Lane.
Prospect Hill for all its material part is a national speed limit road (60mph).
Prospect Hill and Wells Hall Road are both Suffolk CC. designated cycle routes (A2) for their entire length.
Blackhouse Lane
Blackhouse Lane is a narrow single track country lane with no footways and unlit for its entire length with few passing places but with many conflicting traffic issues.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
From the point at which you access the junction of Prospect Hill and Wells Hall Road:-
This junction is little more than a rural T-junction, with the Black Brook culvert compound on the left and the fence line of the Moat, with the Moat immediately behind the fence on the right. The Moat is an historic feature and also immediately abuts Wells Hall Road and has a drop to the water level of perhaps 1.5m. Slightly further along from this junction, on the left, is the National Grid/British Gas station with its entrance about 50m into Blackhouse Lane. Another 15m or so, you encounter the entrance to the car park of the allotment gardens. About 200m or so, on the right, is the entrance to the car park for the playing fields and The Cornard Country Park. Between these points are a number of unofficial passing places.
Black Brook runs immediately adjacent to the Blackhouse Lane carriageway on the right (North) for about half its length before passing under the road in a culvert and then running parallel with the road but again immediately adjacent to the carriageway, now on the left side (South) before making an abrupt 90’ left turn about 150m short of the B1508 into the grounds of Little Mere and onto Cornard Mere SSSI.
About 200m West of the playing field Cornard Country Park car park, on the left is the main pedestrian entrance to the Cornard Country Park. About 50m further along on the left, a public footpath joins the road on a blind bend. Just past this point there are two or three driveways serving various properties including a new development of two properties.
On the left is a gateway into some cottages and immediate thereafter, another gate serving as a farm yard entrance and also serving the redeveloped Black House Farm. On the right, a footpath from the new children’s play area joins the road. Just after Black House Farm on the left, is the entrance to the stables. Thereafter on the left, is the entrance to the Anglian Water Bore Hole facility. You then have a long length of road which on your right has an environmentally important ancient hedgerow with no verge at its base.
On the left there is a soft verge of about 50mm before Black Brook and a further ancient hedgerow on the opposite bank. Blackhouse Lane then runs down to the entrances of Little Mere and a newly converted property on the left and some form of elevated water pumping facility immediately on the right, just yards before the end of Blackhouse Lane as it joins the B1508 Bures Road.
Blackhouse Lane for all its material length is a national speed limit road (60mph).
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
Wells Hall Road
From the junction of Blackhouse Lane heading North. Immediately on your left you have the fence line of the Moat, protecting the approximately 1.5m drop down to the water that is protected by metal sheet piling installed after the road washed out in 2014. On your right you have the very narrow footway and the cartilage hedge of 2 Horse Pond Close. Wells Hall Road is for the most part is a narrow road, barely passable as a two way road but narrowing in parts. It has two narrow pinch points that only allow one vehicle at any one time to pass. There are various driveway entrances on the left (Western side), with a noticeable fall away from the road. On the right, a driveway and the entrance track to the Cornard balancing pond and a pull- in with driveways coming off the road.
Thereafter on the left, vehicle entrance to one of the Thomas Gainsborough school car parks and a small loop road out again to Wells Hall Road. You then immediately hit an exceedingly dangerous pinch point where the road significantly narrows with no footways. Further North, you have a very busy service road to the school and nursery to the left. For the most part, only one side of the road or the other has a footpath, but in places there are none at all. Now on the right, you have cottages with no off-road parking, which continue along the road to be immediately opposite the primary school and nursery. Invariably there are parked cars in front of these properties.
In this area you also have speed bumps and a zebra crossing that serve two important public footpaths. Just prior to Nursery Road, you have another area on the left where invariably there are parked cars. This whole area, including the junction with Nursery Road, is subject to flooding in wet weather. Past Nursery Road, you have the Old school on the left and then immediately hit the junction with Head Lane, Canhams Road and Broom Street.
This is a 30mph speed zone from the Head Lane, Canhams Road junction to the junction with Blackhouse Lane and Prospect Hill.
Wells Hall Road carries the Suffolk CC. A2 designated cycle route for its entire length. Parking is becoming a significant problem in this area. The available car parking spaces were materially reduced when the Thomas Gainsborough School was developed and a small community car park and recycling area was taken for school car parking purposes and spaces denied to local residents.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
B. THE EASTERN APPROACH
Chaplin Walk - The Proposed Eastern Access Route
Chaplin Walk is a quiet suburban cul-de-sac designed for access only to the dwellings situated along its entire length with driveways and dropped kerbs to the carriageway. Built in the 1980s to the then prevailing road standards. It has footways on each side. The proposed entrance route would take you about 50m along Chaplin Walk, to then merge with the loop road serving the remainder of the Hedgerows estate known as Carsons Drive and/or Kempson Drive from an intersecting T-junction.
All traffic entering and exiting via this Eastern approach would be compelled to travel approximately 50m along Chaplin Drive, to the detriment of the residents of Chaplin Walk and potentially create a very busy T-junction. This then produces the option to turn left or right to exit the Hedgerows Estate.
Most road users favour Carsons Drive as the better route. Kempson Drive is more problematic with more direct driveways onto the road and parked vehicles. Carsons Drive then progresses North until intersecting with the controversial road junction at Canhams Road, Shawlands Avenue and Sheepshead Hill.
This junction was only recently re-configured as a result of the development at Woodlands Rise, and quite frankly, is an absolute catastrophe from a safety perspective. This is one of the most heavily used road junctions in Great Cornard but the most unsafe. We understood the original intention was to install a roundabout which would have been much preferable than the current staggered cross road design.
The safety issue is greatly affected by the increasing volume of motor vehicles that have recently started parking in Canhams Road immediately as you approach the junction from the West. This creates a conflict with those vehicles turning right from Shawlands Avenue into Canhams Road.
This junction cannot safely sustain any material increase in traffic flows.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
2. TRAFFIC SAFETY ISSUES
A. ACCESS TO THE PROPOSED SITE FROM PROSPECT HILL, BLACKHOUSE LANE OR WELLS HALL ROAD, WESTERN APPROACH
It is misguided and naive to consider the inclusion of this site in the plan without knowledge of the local infrastructure and the pressure that it is already under.
Prospect Hill, Blackhouse Lane and Wells Hall Road cannot sustain any increased vehicle traffic movements without considerable environmental harm, increased risk to all road users, local residents and the creation of Health and Safety Issues.
Access onto any of these roads from the proposed site would create extreme danger and materially reduce road safety with very limited opportunity to mitigate the risks posed.
Prospect Hill. Please see ‘1. Background’.
A resident of Horse Pond Close reports it is not unusual to witness HGVs traveling South, reaching the bend under which the Black Brook culvert runs and the public footpath joins, having to abandon their journey because they are too large to negotiate any further along Prospect Hill. They then have to reverse to the junction of Blackhouse Lane and Wells Hall Road to complete a reverse turn. They then have to return North along Wells Hall Road. Due to the very restricted room to manoeuvre, this can take in excess of ten minutes, depending on the time of day and other traffic conditions.
Similarly, with no ability to pass oncoming vehicles, it is not unusual to find several vehicles having to reverse along this stretch of road, finding themselves trapped between the high embankment adjoining the proposed site and the ancient hedgerow the opposite side of the carriageway.
This situation is exacerbated by the considerable number of dog walkers walking South along this road to gain entry into the Cornard Country Park having joined the road from the public footpath. It is not unusual to witness dog walkers having to scramble up this steep embankment hauling their animals with them to get clear of vehicles.
Prospect Hill South of Horse Pond Close is subject to a National speed limit of 60mph. Motor traffic coming down the hill heading North regularly exceed the speed limit until they reach the said bend and have to violently apply their brakes. Such occurrences are regularly observed by residents. This creates a very dangerous conflict between school children and parents walking to school via the public footpath and Prospect Hill.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
Furthermore, this bend being at the bottom of the hill with Black Brook passing under, is a site for water and other debris to accumulate during wet periods. This area remains at various stages of flood for much of the Winter months and freezes over in cold spells.
This road and Wells Hall Road being a designated cycle route attracts many cyclists, particularly at weekends during the Spring and Summer months. Indeed, two or three organized events with dozens of cyclists normally making their way South along Prospect Hill have taken place.
Furthermore, being bordered by a number of agricultural fields, large agricultural vehicles use this lane, particularly at peak seasonal times. Normally large tractors with implements attached.
With the development of the Thomas Gainsborough School with its attendant 1200 pupils, the traffic along Prospect Hill has grown exponentially as parents try to avoid the traffic congestion accumulating in Wells Hall Road at peak school times, particularly those traveling from further afield coming via the A134 and Joes Road. It has become a rat run with dangerous conflicts occurring with all users. Indeed, a number of minor road traffic accidents have occurred and in one instance, a more serious head-on collision involving a 4WD vehicle and a scrap man’s flatbed truck.
Pedestrian traffic is particularly exposed to traffic collision risk in the area of Horse Pond Close where the footways only transit from the public footpath exiting at Eldred Drive to the Blackhouse Lane/ Wells Hall Road junction. They are only 1m wide and cannot accommodate safely two persons walking side by side. One person has to invariably walk in the road. Invalid carriages likewise find it easier to use the road. The many dog walkers heading South for the Country Park also find themselves exceedingly vulnerable having to share the carriageway in a narrow confined space with no escape route if confronted with speeding traffic coming down hill, which they often are.
In bad Winters, Prospect Hill immediately South of Horse Pond Close, becomes quickly impassable in even moderate snow falls. Indeed, many locals resolutely refuse to use this lane during the Winter Months. Residents of Prospect Hill and Horse Pond Close also find that many visitors to their properties often request alternative routes avoiding the Joes Road way in from the A134. Indeed, some family members of residents resolutely refuse to use this route into their properties any time of the year given the extreme dangers that these lanes pose.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
A further material safety matter relates to the near absence of any vegetation control along parts of Prospect Hill. Evidence from residents from this immediate area confirms that the hedgerow bordering the Country Park and running up to Prospect House has only been cut three times in 20 plus years and on one of these occasions, it was a group of local residents with hand tools!
For these reasons, it is unsustainable for any increase in traffic to be permitted in Prospect Hill without major safety issues arising.
Blackhouse Lane. Please see ‘1. Background’.
If, as a resident of Horse Pond Close, you need to access the B1508 for Bures and beyond, Blackhouse Lane is the most direct route. However, during peak school times this is becoming very difficult as a result of the congestion being experienced in Wells Hall Road and parents using Blackhouse Lane to approach the schools from an alternative direction rather than get stuck in the traffic congestion at the Northern end of Wells Hall Road. This results in many instances of having to reverse up (in either direction), perhaps as many as three or four times to successfully negotiate the full length of Blackhouse Lane.
Interestingly, one local resident, whom uses this route, regularly has reported that his record number of times of having to reverse up currently stands at no less than eight times! Or put another way, Blackhouse Lane, since the new Thomas Gainsborough school was developed, has become a ‘Rat Run’ but the Rats have no space in which to run!
Another resident who regularly uses this route has reported having to abandon journeys as a result of service vehicles having no option but to block the lane whilst they make their deliveries of oil or pump out cesspits, creating long tail backs of frustrated drivers who cannot go forward or backwards. This becomes an absolute nightmare when roadworks are taking place in Wells Hall Road (or vice versa) and the only route out of the area is via Keddington Hill or the very long detour via Joes Road.
The situation is further exacerbated by the many dog walkers whom have parked their cars in the Cornard Country Park/playing field car park and walk along the road to the main entrance to the Cornard Country Park on the left. Further along, you then have two additional public footpaths joining the road with pedestrians all having to share the same road space with motor vehicles and other road users.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
With levels of frustration rising with motor vehicle users of Blackhouse Lane, some attempt to pass each other. This can prove disastrous if you do not know the road. Indeed there have been several instances of vehicles trying to pass each other in close proximity to the soft verge and Black Brook, with the inevitable consequences of vehicles getting bogged down or going fully into Black Brook. This can then block the road partially or entirely, depending on the size of vehicle, until recovery pulls them out. Indeed, this is becoming a regular event and is greatly exacerbated during late Spring and Summer as a result of vegetation growth when it is impossible to see the Brook.
Hedge and verge cutting should only be conducted to ensure road safety to the minimum extent necessary and in strict accordance with both the law and farmer cross compliance regulation, given the special environmental nature of this lane. Signage could be much better warning of the dangers!
Blackhouse Lane will become even busier, as a result of two bungalows being up graded to much more substantial properties and two new properties adjacent to Moorlands Barn being developed.
Furthermore, with the development of the Woodlands Rise site (some 166 properties), and planning approval for 40 plus properties along the Bures Road, many who will no doubt have children attend school or nursery in Wells Hall Road, this situation is set to deteriorate materially.
The already difficult situation at peak periods is further compounded by sporting events held on the playing fields, mainly at weekends but not always. Large numbers of parents and children descend upon the playing fields to attend various sporting events. Many are from out of area (away sides) and hence do not know this area. The Cornard Country Park/playing field car park fills to capacity very quickly, as does the car park that serves the allotment gardens acting as overspill.
Confronted now with being late for events, parents search for anywhere they can to park. This normally results in the unofficial passing places at the eastern end of Blackhouse Lane being parked in, as well as the Southern end of Wells Hall Road and into Prospect Hill, with instances of gateways being obstructed or entirely blocked and abuse leveled at residents whom dare to challenge such inconsiderate behavior.
On Sunday mornings, the Football Club, after pressure from local residents, put out no parking cones at the Southern end of Wells Hall Road to ensure that the road junction is kept clear of obstruction.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
This area is becoming a potential accident black spot as a result of vehicles parking on the narrow footway and only leaving a very restricted amount of space for small cars to pass. Thus forcing all road users in to a long narrow road space and being trapped with no escape route either side, as a result of the numbers of vehicles parked up on one side and the Moat, the other. Emergency services likewise would have been prevented progressing along Prospect Hill and Blackhouse Lane. This situation then forces parking along Prospect Hill and in some instances onto the lawns of Horse Pond Close properties. In one particular instance, a motor vehicle was observed to use the central flower bed of a Horse Pond Close property front garden as a roundabout!
Being a weekend, if the weather is fine, a further ingredient is then added to this volatile mix. Horse riders from the stables normally make their way East from the stables to access Prospect Hill and ride South into open countryside.
Also, it is not uncommon to encounter large agricultural vehicles in Blackhouse Lane connecting with Prospect Hill, particularly during harvest time or in some cases Wells Hall Road (for instance to cut the playing and school fields grass ).
The passing places along Blackhouse Lane are in the main the driveways of private properties or field entrances. One important such passing point is the Anglian Water borehole entrance. However, if Anglian Water staff are in attendance, on many occasions their vehicles will be occupying this space and this creates yet further difficulty for drivers trying to pass each other, having to reverse for long distances.
There are a number of areas along the length of Blackhouse Lane that flood at peak water flows due to the inadequate culverts along Black Brook and the appalling lack of maintenance of this water course.
It can be observed that the increased traffic usage is causing degradation to the verges as vehicles attempt to pass each other at inappropriate points as frustration mounts.
Blackhouse Lane is not fit for purpose at current traffic levels. Further increases of traffic are completely unsustainable and will create massive additional safety issues, with little opportunity for mitigation. No additional traffic whatsoever should be encouraged.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
Wells Hall Road. Please see ‘1. Background’.
Wells Hall Road has always been one of the busy areas of Great Cornard at peak times, due to the primary school and parents dropping off children along the road from their vehicles and two important public footpaths merging with the road in close proximity to each other and the primary school. Large numbers of parents and children emerge from the footpaths to cross the road and make their way to school. This results in long tail backs of traffic in both directions of Wells Hall Road exacerbated by inconsiderate parking of vehicles by parents and open car doors accessing small children in the rear. This situation was tolerable for the most part. However, with the development of the Thomas Gainsborough School, the situation has become absolutely insane.
With the limitations of Wells Hall Road to accommodate traffic volumes of this magnitude, huge traffic conflicts occur during these times, exacerbated by ‘Rat Run’ traffic from Blackhouse Lane, the odd school bus and HGV. Also, the access road that serves as a secondary entrance to the Thomas Gainsborough School and a nursery joins Wells Hall Road opposite an area where vehicles are normally parked. This entrance road for some reason now seems to be the preferred route for most parents and traffic use is growing rapidly. With departing parents trying to turn left or right into a single line of traffic because of parked vehicles. This road exhibits no priority signage. This creates a situation where traffic often has to back up or mount the footpaths that are packed with parents and school children just to free up the grid lock. Residents of Cornards Residents Association are on record of witnessing many near misses at this point, a considerable number involving young children.
The design and allowed usage of this road joining Wells Hall Road from the school amounts to gross negligence on the part of SCC Highways and Education. This all needs to be put into the context of there being very limited footway space for the volumes of children and parents present at peak times and the extremely limited space available at certain points. Further complications arise in wet weather with localized flooding immediate adjacent to the primary school and into Nursery Road. The whole of Wells Hall Road is nothing short of a national disgrace insofar as Health and Safety is concerned and reflects exceedingly badly on our appointed representative.
For residents of Horse Pond Close and Prospect Hill wanting to exit in the direction of Sudbury at these peak times, it can take upwards of 15 minutes to make their way to the junction of Head Lane and Canhams Road or onto the B1508 Bures Road. With the Woodlands Rise development East of Carsons Drive by Persimmon and other extensive housing developments planned or in the course of build out in the locality, these problems can only but deteriorate exponentially.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
Wells Hall Road is not fit for its current traffic levels and any increase in traffic volumes is unsustainable. Furthermore, additional traffic on this road will create a very serious Health and Safety issue not only for the parents and children attempting to drop off for school, but all the residents of Horse Pond Close and Prospect Hill as emergency services will be seriously impeded in gaining access to these properties.
In this regard we rely on an incident that occurred in the Summer of 2015. A resident of Horse Pond Close suffered a serious fall and the attendance of an emergency ambulance was required. This was late morning/early afternoon. The only ambulance available was from Addenbrookes with an out of area crew. The direct route into Horse Pond Close is via Wells Hall Road. The ambulance on arriving in Wells Hall Road with ‘Blues and Two’s’ fully operational was confronted with a traffic jam as a result of a large HGV trying to make a reverse turn and getting stuck and completely blocking the road. The paramedic on board the ambulance then had to sprint the length of Wells Hall Road South with his emergency kit, whilst another resident had to sprint North along Wells Hall Road to redirect the ambulance into Horse Pond Close via Blackhouse Lane. The ambulance had to reverse the length of Wells Hall Road to find a turning point and get on its way to Horse Pond Close. If this was not serious enough, the ambulance then encountered difficulties along Blackhouse Lane because of traffic and the limited passing places. The ambulance, from the time of the paramedics’ arrival in Horse Pond Close on foot, was delayed by an additional full 25 minutes. Fortunately this was not a heart attack!!
This situation is further illustrated as a result of roadworks in Wells Hall Road and Prospect Hill. Wells Hall Road was completely closed and un-passable due to cable laying works from the junction of Blackhouse Lane and Prospect Hill with traffic diverted along Blackhouse Lane onto the B1508. Some idiot in Highways then authorized road works on the B1508, with a full closure of the B1508, with a diversion into Blackhouse Lane and into Prospect Hill from Keddington Hill for traffic coming from Bures. Apart from many residents being unable to exit their drives due to traffic and the seriousness of the matter, it was like an all-day comedy. Large vehicles trying to turn into Blackhouse Lane, including double-decker buses, to be confronted by traffic coming in the opposite direction with nowhere to pass. This situation persisted until mid-afternoon when the penny dropped in Highways that no vehicles could make their way along Blackhouse Lane, let alone emergency vehicles! The roadworks on the B1508 were subsequently abandoned as a result.
Speeding in Prospect Hill and Wells Hall Road is another developing problem, especially at night. Frequent issues with HGVs not being able to make it past Horse Pond Close not only raises massive safety issues, but also begs the unavoidable question of how building materials and the necessary heavy plant would be able to access the proposed site.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
B. ACCESS TO THE PROPOSED SITE FROM CHAPLIN WALK, CARSONS/KEMPSON DRIVES
These areas have reported a large number of incidents relating to the inappropriate parking of motor vehicles and speeding, particularly in Carsons Drive. Chaplin Walk cannot sustain the sort of levels of road traffic likely to be generated by this proposal, without seriously compromising safety of all road users and residents alike. Chaplin Walk was never designed or built to operate as a busy estate feeder road. Again, safety at the T-junction with Carsons Drive will be compromised, not designed for the levels of traffic that is likely to be generated by this proposal. This is clearly evidenced by the children's play area immediately opposite the Chaplin Drive T-junction and creates a further danger to local children playing in this area.
The issue of the road junction at Canhams Road, Carsons Drive, Shawlands Avenue and Sheepshead Hill is a subject in itself. Attention is drawn to the background information provided above (1). With other housing developments taking place along Shawlands Avenue and further planned developments in the area, this already troublesome junction is set to become an accident black spot. Parking along Shawlands and its immediate area is becoming so problematic, a separate group of residents have formed a lobby group to deal with this issue in isolation. Local new build estates have not provided sufficient parking spaces and overspill is now occurring onto feeder roads, compromising road safety further.
3. CONCLUSION
Although our planned traffic survey had to be postponed as a result or Coronavirus, as you can see there is nevertheless a very significant body of available evidence demonstrating that the roads in the area are already unsafe this particularly being so on the Western side of the proposed development, given the very rural nature of the infrastructure and the ever increasing traffic volumes.
The most material and concerning feature of the proposal arises from the large increase of traffic likely having to transit along Wells Hall Road and past the schools. It is no exaggeration to say that this area is already beyond capacity at peak school times with Wells Hall Road never having been designed or upgraded to a level compatible with current usage, let alone able to safely sustain another material increase in traffic.
To demonstrate this point we refer to our Connectivity and Transport Report wherein we provide survey results of residents’ vehicular traffic movements. The proposed development site has a housing bias to the Western side of the site. The proposal is for 150 homes. The bias on the Western side is approximately 67% or thereabouts of the total development. Therefore, applying our survey results to this bias =
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
67% of 150 = 100 x 4.567 movements per property, plus an uplift of say 20% for increased distance = 548 potential additional traffic movements per day in and out of Prospect Hill, of which more than half would probably transit past the schools in Wells Hall Road. For the developer and promoter to even suggest this given all the existing known problems outside the schools, is both reprehensible and morally corrupt.
A further matter of growing concern and debate locally that underscores the issues being experienced relates to the rise of the internet shopping phenomenon. Whereas previously someone would use their motor vehicle to go shopping, maybe in Sudbury or perhaps Colchester or even Ipswich, and purchase say five items and make only one journey. We now have a situation where those five items are purchased on the internet and in an endeavor to save money ,are bought from five different retailers. You therefore end up with an uplift of 400% of applicable traffic movements.
Anecdotal evidence further suggests that some households are now almost entirely reliant on deliveries of their day to day needs, when you add supermarket deliveries into the equation. We therefore submit that the above figures are exceedingly conservative and understate the true likelihood of traffic volumes likely to be generated by this ill-thought out proposal.
Our submission is therefore, this proposal fails on any basis whatsoever to pass the sustainability test for a presumption in favour of development on traffic and road safety issues alone and should be dismissed out of hand with no further consideration whatsoever.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
Photographs – Traffic and parking obstructions on Wells Hall Road
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ROAD TRAFFIC SAFETY ISSUES
Photographs – Traffic and parking obstructions on Wells Hall Road
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ACCESS REPORT
1. REFERENCE DOCUMENTS USED IN THIS REPORT
Suffolk Highways Design Guide Road Types pages 95 to 103
Suffolk Design Guide Shape of Development pages 14 to 27
Boyer Representations on the BMSDC Joint local plan consultation (Reg 18 preferred options) dated September 2019
2. RESPONSES
In the Boyer representation Appendix Four-Access appraisal, it states the following:-
3.1 At this stage, the details of the proposed development are not yet well defined. The land holding is considered to be able to provide up to 150 residential units. It is anticipated that a Transport Assessment would be required to support planning application.
Our response is:-
It must not support the application, it must be the deciding factor. If the access is deemed unacceptable by reference to Suffolk Highways Design Guides, then it must be thrown out. You cannot allow a development which is unacceptable according to Suffolk Highways Guides.
4.2 Eldred Drive, Davidson Close and Chaplin Walk are all MINOR access standard highways, constructed in the 1980’S with 5.5m wide carriageways with footways on both sides.
5.1 A vehicular access can be provided from Chaplin Walk via an existing landscaped area associated with a public footpath. The footpath will need to be diverted to facilitate this access.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ACCESS REPORT
Our response is:-
Boyer have stated that the above roads are MINOR access standard highways. Suffolk Highways have informed us that for a development of this number, the access road will have to be under the design guide of a MAJOR access road. So instantly this throws into considerable doubt the possible access through Chaplin Walk, as this will have to merge from the proposed entry point into a MINOR access road for a distance of over 50m until the junction with the estate loop road. This MINOR access road has no potential for widening or meeting the other stringent bend radiuses required for a MAJOR access road due to the built up residential nature of peoples driveways and parking on this road.
5.2 Prospect Hill will provide a second access location for all transport modes. Improvement to Prospect Hill will be required, subject to confirmation of land under the control of the highway authority.
Our response is:-
The inclusion of Prospect Hill is unbelievable, Prospect Hill is a lane. The current lane width at the worst pinch point is only 3.6m with no footpaths. If you couple that with some blind bends, it is quite obvious even to the un-educated that this access point is totally unsuitable, due to the requirement of 5.5m road width and two footpaths either side of 1.8m to meet the Suffolk Highways Design Guide for a MAJOR access road.
In addition to the road width and footpath requirement criteria regarding bend/corner radius needs, the road at the bottom of Prospect Hill then leads into Wells Hall Road, which in places only obtains a carriage width of 4m and in places has no footpaths either side. The opportunity to expand and develop this road is non-existent. The road and footpaths are mostly used for school children walking to the various schools along Wells Hall Road early in the morning and late afternoon. The road has to be a MAJOR access road for safety reasons, which quite clearly it cannot be as it is restricted with the existing Wells Hall Road.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
ACCESS REPORT
4. CONNECTED/AFFECTED LANE/ROADS SUMMARY
A. PROSPECT HILL
This is a deeply sunken single track lane, little more than a farm track with historically and environmentally important hedgerows and a number of veteran trees, with few passing places.
Bordered at some of its narrowest points by Black Brook running immediately adjacent to the carriageway.
It is designated a Suffolk CC. cycle route.
Note should also be taken that the bottom of Prospect Hill is a major flooding risk. We have covered this in the Flood Report.
B. BLACKHOUSE LANE
Narrow lane single track with few passing places. Bordered for most of its length on one side or other by Black Brook running immediately adjacent the carriageway with historically and environmentally important hedgerows.
Blackhouse Lane, Prospect Hill and Wells Hall Road have become significant rat runs following the development of the Thomas Gainsborough School. HGVs transit Wells Hall Road to often find they cannot proceed any further than the junction of Blackhouse Lane and Prospect Hill and have to make a dangerous reversing manoeuvre, sometimes getting stuck and causing dangerous traffic conflicts that have in the past prevented emergency vehicles attending Horse Pond Close.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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D. WELLS HALL ROAD
This road at its narrowest point is only 4m width with one very narrow footpath on one side only. Along its length from the Prospect Hill and Blackhouse lane junction, at points it has no footpaths either side, hence pedestrians have to walk along the road for a distance of approximately 30m. The road is not well lit and is very busy with the drop offs to the numerous schools along its length. The ability to improve this road is non-existent as residential properties line the road on both sides.
To consider this as a main feeder road into the Prospect Hill access point is totally against any design guides published by Suffolk Highways, so on this point alone the access to this proposed site must be rejected.
5. SUMMARY
The flow of traffic and parking is a major concern, whether it is school children being dropped off to the various schools along Wells Hall Road or the football matches which take place along Blackhouse Lane. We have photographic evidence of the severe congestion and parking issues which occur. Trying to punch a MAJOR access road through MINOR access roads and lanes is not acceptable.
Another point to consider is that vehicles will also travel up Prospect Hill, and into Little Cornard or Newton, to gain access to the A134 or B1508 to Colchester. This will result in major traffic movement issues for these MINOR lanes, all of which are narrow winding lanes, with no footpaths. Another factor which must be considered is that all this extra traffic will most certainly affect the wildlife as mentioned in our Biodiversity Report.
Taking all the above into account, this site is clearly unacceptable based purely on an access issue. Boyer’s representation is ill-thought out with no real explanation to how this major problem will be overcome. To propose a major housing development is not based upon the size of the land but one of the most important issues is access. This land should be left for agricultural use only. Notwithstanding all the other issues we have identified on this proposal, on this point alone this site must not be included in the Local Plan 2019.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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Photographs - Prospect Hill approaching narrow blind bends.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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Photographs – HGV reversing into Blackhouse Lane having found he cannot manoeuvre around the bends
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
CONNECTIVITY AND TRANSPORT REPORT
1. BACKGROUND
This report is produced in response to the inappropriate submission by Huntstowe Land and Boyer as appointed representative of landowners to promote for building development the Site known as SS0220 identified in the Babergh and Mid Suffolk Joint Local Plan: Consultation Document of August 2017. (See map page 179).
Attention is also drawn to the well developed and detailed proposal of Huntstowe/Boyer available on the internet.
The Hedgerows estate was built on open farmland during the 1980s, bordering on the existing developments of Great Cornard including the 1960s London overspill council estate.
As such, the Hedgerows is a typical middle-class housing estate with infrastructure limited to that what pertained to the 1980s, with little thought for residents day to day needs other than a few green spaces. Indeed, the ill-conceived and controversial Woodland Rise development has significantly impinged on the quality of life with increased urbanisation and the feeling of enclosure for certain residents, but again very little thought was given to local day to day needs.
Despite what silken tongue planners may promote, there is little local provision for services outside Sudbury itself. Indeed, the nearest services for essentials are the two small Co-Op stores in very close proximity to each other in Canhams Road and the Drift. The doctor’s surgery is somewhat further distant and the Health Centre sits on the outskirts of Long Melford and Great Waldingfield. The nearest Pubs are in the Bures Road and further distant.
The South Western edge of the Hedgerows which is most distant, is very rural in character, served for the most part by very narrow country lanes with ever growing traffic volumes, with virtually no footways or cycle paths. Where footways do exist, they are exceedingly narrow, not conforming to current planning standards and cannot accommodate two persons walking side by side or even an invalid carriage. Indeed, it is from one of these very lanes that the proposed site is anticipating to use as a main entrance.
It is therefore very unsurprising that there is almost total reliance on motor vehicles by the Hedgerow’s residents for day to day functions.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
CONNECTIVITY AND TRANSPORT REPORT
2. THE ISSUE
The proposed site is planned to abut the Hedgerows Estate, expanding the village further and more distant into the open countryside up an incline. As such, it will be further distant from the sparse facilities that exist within Great Cornard and it is disingenuous to believe that residents would be prepared and/or able to use anything other than motor vehicles for day to day travel purposes.
Accordingly, to support this observation, the Cornards Residents Association conducted a survey in December/January 2019/20 of the modes of transport used by residents of the Hedgerows Estate. It should be remembered that the proposed new estate (SS0220) will be more distant from facilities than those surveyed and furthermore, many of the survey respondents actually lived on the Northern extremity of the Hedgerows Estate and hence put them materially closer to the very limited facilities.
The results were as follows;
A total of 104 households responded to our questionnaire. (Please see Appendix A, for the individual streets included in the survey).
The 104 households had access and use of 185 motor cars. An average of 1.8 per household.
Each household was asked to estimate the number of daily movements to and from the property. The 104 households estimated a total of 475 such movements or an average of 4.567 movements per property per day.
Of the working households of which there were 82 working adults, 64 drove to work in a motor vehicle (78%), only 8 were able to walk, 7 cycled and 3 were able to use public transport.
Asked how do you get to the shops, 58.6% said they drove, the remainder used a combination of walking, cycling or public transport, (in some instances this involved the use of a local taxi service) or internet deliveries.
It is our opinion, that the above figures categorically disprove the disingenuous misrepresentation that this new estate will be well served and connected to local essential services. This is particularly so given the Hedgerows estate is materially closer to the sparse and limited local shops, whereas the new estate will be somewhat further away and for some, on a steep incline. This view is further supported by measurement of the actual distances involved (straight line measurements from OS map).
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
CONNECTIVITY AND TRANSPORT REPORT
Taken from the Co Op Canhams Road being the most convenient.
From the proposed entrance road of the new development in Chaplin Walk. 600m
From the centre of the new proposed estate. 700m.
From the estimated furthest property on the new proposed estate. 800m.
The distances by road will be somewhat greater than the straight line distances quoted and dependent on route up or down inclines
The reality is that few, if any, new residents will walk or cycle for the purposes of work, shopping or attending other local amenities, it is just too far.
In support of this submission, we rely upon the Appeal Decision - APP/D3505/W/19/3230839 handed down by Andrew Smith BA (HONS) MA. MRTPI of the Planning Inspectorate dated 27th September 2019. This Decision dismissed a proposed development for eight houses the other side of Prospect Hill, a matter of only a few metres from the proposed development of site SS0220.
We quote from paragraph 14 of his decision “ Either walking or cycling to Great Cornard, or Sudbury, in order to satisfy day-to-day needs would be unlikely to represent an attractive option for future occupiers of the development, particularly when factoring in the not insignificant distances involved”.
And we quote again from the same decision paragraph 18 “that the need to travel by car is minimized and that a presumption in favour of only sustainable development is applied” and Conflicting with Core Strategy policies CS1 and CS15
Therefore, the test of sustainability, when reasonably applied to the proposed site SS0220, clearly and demonstrably fails.
Furthermore, these facts are underpinned by other key considerations.
Local bus services have been considerably curtailed, with the withdrawal of regular services to and from the Hedgerows Estate. The nearest operational bus stop is now in Canhams Road (distances not materially different from those stated above). From an operational stand point, the bus service is infrequent and non-existent after early evening.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
CONNECTIVITY AND TRANSPORT REPORT
I would challenge any decision maker reading this report to simulate a normal working day commuting by bus and foot, to say the British Sugar Beet factory at Bury St Edmunds, after walking and returning to/from a new property on the outer reaches of the proposed new estate, in the depths of Winter when engaged in shift work. Or to attend a late afternoon hospital appointment at the West Suffolk Hospital when their Consultant is running late and you are suffering from a debilitating condition. Older residents of the area whom do not drive are now struggling to attend appointments at the local Health Centre, in many cases reliant on friends or relatives to drive them or hire taxi services. This has been a regular feature in the local press.
The area is very poorly served with dedicated cycle lanes, with no or little space to accommodate cycle lanes on the limited road space, many with no footways or footways of a narrow nature and in places on only one side of the road.
Additional factors also bear consideration. One of the largest employers in the locality whose facility is within walking distance has announced its imminent closure. Debate rages locally as to whether the site can be retained for industrial purposes or be developed for housing. One local resident of this organization works at a different location, at what will now be the nearest industrial employer to the proposed estate. Many of the current employees of this firm live locally including on the Hedgerows. This resident has gone on the record to state that “99% drive to work every day!”.
The train service from Sudbury is on a branch line to Marks Tey with only an hourly service, constrained by the single track, with no direct service to Liverpool Street, without changing at Marks Tey and crossing over a steep foot bridge. Car parking capacity at the Station is now becoming an issue also. There is no early morning bus service to and from the train station (first trains 5.30am and 6.30am) and it is just not feasible to walk the potential distances involved from the new proposed estate. Estimated to be in excess of 4k.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
CONNECTIVITY AND TRANSPORT REPORT
3. CONCLUSION
The Government in Sections 2 and 9 of the NPPF (2019) indicates sustainable developments that promote walking and cycling and the disengagement and reliance away from motor vehicles as being the test for presumption in favour of a positive planning decision. As demonstrated above, even based upon the figures compiled from the Hedgerows Estate residents, this test would be failed miserably. However, human nature what it is dictates that with the new proposed estate being somewhat more distant from essential facilities, a reasonable uplift of motor vehicle usage would be incurred by residents occupying new properties on the proposed SS0220 site.
We therefore fail to comprehend how on any basis whatsoever this proposal can be regarded as even coming close to passing as a sustainable development as defined by the NPPF (2019).
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
CONNECTIVITY AND TRANSPORT REPORT
APPENDIX A
Hedgerows Estate roads in which survey conducted for modes of transport used by:
• ABBAS WALK • BRANDS CLOSE • CARSONS DRIVE • CHAPLIN WALK • DAVIDSON CLOSE • DE GREYS CLOSE • ELDRED DRIVE • HORSE POND CLOSE • KEMPSON DRIVE • KINGSBURY WALK • LARSONS DRIVE • LAYZELL CROFT • LIONEL HURST CLOSE • MALLARD WAY • PARMENTER DRIVE • PEACOCKS CLOSE • TURKENTINE CLOSE • WALSINGHAM CLOSE • WELLS HALL ROAD
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close BIODIVERSITY REPORT
Contents
Introduction______1
The Landscape and Habitats of the Site (SS0220)______2
Methods______2
Results ______3
Summary of the Results for Site: Tower Hill Field, Kiln and Old Orchard Meadow, lower Prospect Hill, lower Crab Hill, valley bottom and sides______3
The Wildlife Corridor, East and West of the Site______4
Summary of the Results for East of Proposed Development Site (Sheepshead Hill to Newton Road including Abbas Hall Woods, Woodland Rise Area, Shawlands and Joe's Road)______4
Summary of Results for West of Prospect Hill, valley bottom and sides (Country Park, Cornard Mere including Blackhouse Lane)______5
Conclusions ______7
The Site's Importance at the Centre of a Wildlife Corridor______7
Protected Species______8
Appendices______9
Appendix 1: Key to bird tables______9
Appendix 2: Summary of Selected Bird, Flora and Fauna Records: Old Orchard, Kiln & Tower Field (Potential Development Site, Centre Corridor)______10
Appendix 3: Summary of Selected Bird, Fauna and Flora Records: East End of Corridor- Newton Rd to Sheepshead Hill incl. Abbas Hall Wood, Woodland Rise Area, Shawlands and Joe's Road______12
Appendix 4: Summary of Selected Bird, Fauna and Flora Records: West End of Corridor, Country Park and Blackhouse Lane______14
Appendix 5: Summary of Bird, Flora and Fauna Records: West End of Corridor, Cornard Mere ______17
Appendix 6: Notable Invertebrate Records for the Described Corridor______20
Appendix 7: Table of Barn Owl Breeding Evidence______22
Appendix 8: Data Sources and Acknowledgements______22
BIODIVERSITY REPORT PAGE 1
Introduction
The proposed land allocation SS0220, which has been proposed for development by Huntstowe Land, sits in the valley of Black Brook on the southern edge of Great Cornard, and is at the centre of a natural wildlife corridor linking Cornard Mere and Cornard Country Park to the west, and Abbas Hall Wood, the Persimmon Habitat Creation, Shawlands and the orchards around Joe's Road to the east. The site's biodiversity is valuable both in itself and as part of this important wildlife corridor. The aim of this report is to describe the special habitats, and provide evidence for its rich biodiversity and importance as part of an ecological network which must be protected.
The Landscape and Habitats of the Site (SS0220)
The site sits to the east of lower Prospect Hill, a narrow sunken lane, with Great Cornard Country Park to the west. The site consists of part of Tower Hill field (an arable field), Kiln meadow and part of Old Orchard meadow, with Crab Hill lane at the centre; forming the valley of Black Brook which flows along the bottom of the site (then along Blackhouse Lane and into Cornard Mere SSSI). The key habitats here are the Brook; the springs, streams and marshes on the hillside; hedges; willow scrub; the grassland of Kiln Meadow; and the hillside grassland which includes much acid land and both dry and wet land. Grazing is maintaining the grassland, and preventing it from falling down to scrub or secondary woodland. The site is unspoilt, with a natural countryside character. The Brook is Sudbury area’s only remaining natural watercourse, this side of the Stour. This site is a survival of unimproved grassland habitat with dry sandy tops and natural wetlands. All such survivals are exceptional and should therefore be left as green space and not drained, kept ungrazed, nor replaced by planted trees. (Secondary woodland is to be found adjacent, and as the commonest non-arable habitat type in lowland England, it is no substitute for the existing unimproved flowery grassland.) Spring flushes are characteristic of the glaciated moraine landscape of the Stour Valley area which is exceptional for East Anglia, consisting of sands above London Clay. Elsewhere these flushes have mostly been agriculturally drained, so generally remaining examples are in wet woodland. The nearest similar examples are at Bures below Arger Fen, at Raydon below the Church, and Sulleys Hill at Shelley.
Methods
Many thousands of records exist for this area, and have been submitted by local observers carrying out systematic surveys such as the breeding birds survey and bird ringing, as well as regular casual records. Biological records (birds, mammals, reptiles, amphibians, invertebrates, flowering plants), were selected from several sources (BTO, RSPB, JNCC, SBIS, SCBOP - see appendix 6).
Limitations - The records have been selected to give an impression of the biodiversity of the land , and of the sites to the east and west of SS0220 which are considered to be a valuable wildlife corridor; up to date and most recent records were prioritised but are inevitably a summary (see tables Appendix 1-5) due to the sheer volume of records that exist. This in itself is testament to its importance for wildlife.
BIODIVERSITY REPORT PAGE2
Results
Summary of the Results for Site: Tower Hill Field, Kiln and Old Orchard Meadow, lower Prospect Hill, lower Crab Hill, valley bottom and sides)
See Appendix 2.
Kiln Meadow has good populations of two attractive plants, Musk Thistle and Toadflax, both plants of open grassland on rather dry ground. The hillside fields have several areas with Sticky Mouse-Ear and Lesser Chickweed, which are characteristic plants of very dry sandy ground, and a good range of attractive plants of wet ground, growing in abundance. These include Fleabane, Great Horsetail and Hemp Agrimony. Most of these plants are very attractive to pollinating insects and most are strongly suppressed by any shade. A wide range of butterflies, moths and other invertebrate species are present.
Viviparous Lizards are present on the dry sandy parts of the site.
The headwaters of the Brook have a good community including Water Vole (photographed 2020), Freshwater Shrimp and Crayfish, and birds such as Whitethroat and Lesser Whitethroat nest in the vegetation at the edges of the brook, wagtails feed in the brook.
The birdlife is typical of countryside and traditional farmland including breeding populations of red listed species which have seen recent significant declines because their habitat is under threat, such as Linnet and Yellowhammer. The hedges are used for breeding by a range of finches, warblers and tits and Starlings, Dunnocks, Thrushes (Song Thrush, Mistle Thrush, Fieldfare, Redwing)feed on the fields. These are species which need the hedges, rough grassland, wet meadow, etc characteristic of this site. Cuckoos, another seriously declining and iconic species, are present every summer.
Barn Owls :
Barn owls are a Schedule 1 species afforded extra protection under the 1981 Wildlife and Countryside Act. This area is a barn owl hotspot; no fewer than four pairs, and up to six pairs, breed within 1km of the site, one of these pairs breeding only m away in the country park (records from monitored boxes and ringing, most recent records June 2020 - see Appendix 6, Suffolk Community Barn Owl Project) The owls hunt regularly over Kiln and Old Orchard Meadow and are frequently seen flying over Tower Hill Field from the country park to these meadows; this is also an indication of a good population of prey species, small mammals such as voles, in the long grass of the meadows. This is the centre of an obvious, and important, barn owl corridor.
Top Predators:
The presence of breeding predator species such as kestrel, sparrowhawk, buzzard, three owl species, being top of the food chain, indicates a healthy and thriving ecosystem with a community of species adapted to these traditional farmland and countryside habitats
Nocturnal Species:
Three species of owl, bats, foxes, badgers, hedgehogs thrive here because as well as being suitable habitat, it is relatively dark and quiet at night. Clearly the light and noise pollution that would come with a new development would, as well as spoiling the character of the area, threaten this nocturnal community. There is an active Badger sett in the adjacent country park with outlier setts on Prospect Hill and Crab Hill Lane. Badgers are frequently sighted. There are many regular and recent Hedgehog sightings with camera trap and photographic evidence (2020). Hedgehogs, a BAP species, are in very serious decline nationally.
Glow worms are present along the flowery banks of Prospect Hill, and can be seen in the breeding season when the female glows. This scarce insect is very vulnerable to disturbance because the female does not fly and means they have probably been present here for a very long time. Any disturbance along the bank of the roadside such as extra traffic or widening would probably wipe them out.
The Wildlife Corridor, East and West of the Site
Summary of the Results for East of Proposed Development Site (Sheepshead Hill to Newton Road including Abbas Hall Woods, Woodland Rise Area, Shawlands and Joe's Road)
See Appendix 3.
The area to the east of the proposed development site is characterised by farmland and a mixture of other habitats: Black Brook flows down the valley and hedges, some ancient, connect fragments of woodland. The farm hedges are important for many pairs of red listed Yellowhammers, Dunnocks and Linnets, and summer breeding warblers. Skylarks breed in several of the fields and having already been dis-located from the Persimmon development (Woodland Rise area) east of Sheepshead Hill their breeding populations are particularly important. A winter flock of up to 50 Skylarks, mixed with a few Meadow Pipits, is present annually and roves around the fields.
Abbas Hall wood and surrounds provides good habitat for typical woodland species and larger birds such as Rooks and Buzzards. Brown Hares are a regular sight. The orchards and scrub either side of Joe's Road provide habitat for pollinating insects and food for birds such as Bullfinch and other finches, warblers, and in the winter large flocks, in most years numbering in the thousands, of red listed Fieldfares and Redwings which commute between the orchards and the fields to feed. Viviparous Lizard, Grass Snake and Slow Worm are all present in good numbers in the orchards.
The Common Toad has disappeared from many areas in our locality, but such a significant population is present along Joe's Road that the crossing point between their breeding pond and terrestrial habitat in the orchards has been given a 'Froglife' designation ("Joe's Road 845"). This year well over 500 toads crossed here. Extra traffic resulting from the potential development site would put this population at obvious risk as they complete their annual crossing to the breeding pond and back again.
Shawlands Wood Local Nature Reserve has woodland, scrub and wildflower meadow which has a range of plants including three species of orchid (Bee, Common Spotted and Pyramidal). It is rich in butterflies (such as the scarce Small Heath, White-letter Hairstreak and Green Hairstreak) and many moth species, as well as grasshoppers and crickets (such as one of the earliest colonies of the now successful Long-winged Conehead Cricket). Viviparous lizards are numerous and the reserve has been used as a release site for both Lizards and Slow Worm relocated from development sites such as Cat's Lane. Surveys in recent years have revealed an 'Exceptional viviparous lizard population' ('Froglife' advice sheet 10 1999). Again the scrub and woodland support a thriving community of birds.
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Summary of Results for West of Prospect Hill, valley bottom and sides (Country Park, Cornard Mere including Blackhouse Lane)
See Appendix 4 and 5.
Cornard Country Park is managed carefully as a highly valued green space with a mixture of habitats including scrub and heath, fragment ancient woodland, mature and ancient hedgerows, wildflower meadow and ancient native trees including oaks. There are a number of scarce and interesting plant species (such as Sulphur Clover, Nettle-Leaved Bellflower, Ploughman's Spikenard, Moschatel and Pignut, and Wild Marjoram is an important invertebrate food source) and a very wide variety of plant species in the various habitats. Lesser Calamint is nationally scarce and found on Danes Hole and on the corner of the road bank at the bottom of Prospect Hill. The remnant woodland is carpeted with Bluebells, Wild Garlic and Dog's Mercury in the late spring. The flowering plants in the country park support many invertebrate species including scarce moths and butterflies, such as Skipper species in good numbers, Small Heath and Green Hairstreak regularly recorded. There is a very wide variety of bird species (due to the variety of habitats and abundance of food), many of which are red and amber listed species of conservation concern (see Appendix 4). Many of the birds breed in the country park but feed over a much wider area (such as the owl species and other birds of prey), or visit the country park in greater numbers at different times of the year, such as Reed Buntings and Linnets which increase in the winter. Barn owls breed and hunt in the country park and beyond. There are several House Sparrow (red listed) colonies in and around the country park, near the allotments and along the Brook in Blackhouse Lane.
Badgers are active in the country park and their territory extend across Prospect Hill towards Crab Hill Lane as well as across Blackhouse Lane. Several species of bat are regularly recorded.
The Country Park has important populations of three reptile species; the native population of Viviparous Lizard has been increased further by the release of translocated lizards from nearby development sites; Grass Snake and Slow worm are also regularly recorded here and in the Allotments.
The Country Park is separated from Cornard Mere SWT nature reserve by an arable field and connected by hedges along Blackhouse Lane and Kedington Hill. Black Brook flows along Blackhouse Lane into Cornard Mere. The Brook is an attractive habitat and source of water for birds, Kingfisher, Snipe and even occasionally Water Rail as well as commoner species are seen feeding in the Brook which contains small fish, amphibians and invertebrate larvae. The hedges along the lane are used by birds for food, breeding and cover and species such as Yellowhammer and Reed Bunting feed between the hedges and the arable field in winter.
Large numbers of winter thrushes, finches, corvids and geese feed on this field in the winter as well as a winter flock of up to 50 Skylarks and some Meadow Pipits which roves around the area.
Cornard Mere SSSI is special due to its mix of open water, fen and wet scrub. Phragmites reedbed is surrounded by blackthorn, elder, bramble etc with mature poplars and willows including dead decaying wood beneficial to many species. It is difficult to do justice here to the biodiversity of the Mere but it should be noted that many of the bird species present move between the Mere and Country Park; for example Barn Owls hunt the whole area, Reed Buntings breed at the Mere but move along the hedges and fields, Hirundines
(martins and swallows) feed over the water as well as the fields, Cuckoos fly between the Mere, Country Park and across Prospect Hill to Old Orchard Field, Kestrel, Red Kites and Buzzards fly across the whole area.
Cornard Mere supports many breeding reed birds such as Reed and Sedge Warblers, Cettis and other warblers breed in the scrub. Nightingales have recently returned to breed and Water Rail, Little Grebe and several duck species breed. Over 20 species of Dragonfly have been recorded as well as many other rare and scarce invertebrates.
In the autumn Swallows and House Martins use the reedbed to roost before migrating and flocks of finches, buntings and winter thrushes are present in the winter months.
Otter, Hedgehog, Harvest Mouse and Water Shrew are among the mammals regularly recorded, and Grass Snakes are common.
BIODIVERSITY REPORT PAGE 6
Conclusions
The proposed land allocation 'SS0220', for which Huntstowe Land has produced a Landscape Statement as part of a developer's document, is a biologically diverse landscape with special habitats which should not be lost to development. It has exceptional value because of its mix of natural wetland, acid dry land and unimproved grassland but also because of its position in the centre of an important wildlife corridor. The results described above and summarised in the tables in the Appendices are evidence for the biodiversity of this site and the areas to the east and west which form this corridor.
Any development of this site would result in key habitat loss; The Landscape Statement produced by Huntstowe Land in their development proposal states that:
"The site boundaries include some strong tree belts in places. These features should be retained, enhanced and reinforced ....with the potential for introduction of new woodland structure, improving the connectivity between existing features"
and
" Appropriate ecological surveys should be undertaken to confirm the presence of important habitats and/or protected species. Where required appropriate mitigation will be incorporated during the design development phase, with appropriate enhancements to biodiversity included with any landscape strategy."
We challenge these statements because;
• The idea that 'enhancement' and 'mitigation' would result in a net gain in terms of landscape is flawed in this case because it results in the loss of scarce habitats with their accompanying ecosystem. Tree planting is inappropriate here and would result in biodiversity loss rather than enhancement. • Established Barn owl territory cannot be mitigated. • Any widening of or changes to Prospect Hill, together with increased traffic, as well as changing the character of the area would threaten species such as Hedgehog, Common Toad, Barn Owl which are all vulnerable to road kill as well as habitat loss. Loss of the flowery banks would result in the fewer invertebrates and loss of a population of Glow Worm. • The statement that "Appropriate ecological surveys should be undertaken to confirm the presence of important habitats and/or protected species..." is an admission that no such surveys were undertaken or therefore considered in the formation of the proposal. The assumption has therefore been made that it would be possible to mitigate without considering the evidence or consequences. • Any development of this site would result in a significant change to light and noise levels; this would have a detrimental effect on nocturnal species, ie. the three species of owl, badgers, bats and hedgehogs etc. which inhabit the area.
The Site's Importance at the Centre of a Wildlife Corridor
The National Policy Planning Framework (Para 174) requires Local Authorities to "identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks...wildlife corridors and stepping stones that connect them"
This site is immediately identifiable as being at the centre of the fringes of Great Cornard forming a link from the River Stour meadows to the line of Babergh's 'Green Arc'. Many of Suffolk's habitats are fragmented and isolated within the agricultural landscape but here is an established wildlife corridor with connected habitats which would be 'cut in half' if this site were to be allocated for development, dividing and isolating important wildlife populations rendering them far more likely to become locally extinct.
The site is within the proposed Dedham Vale AONB extension (whose purpose is to conserve and enhance the natural beauty of the area) and therefore should not be developed.
Protected Species
The identified wildlife corridor has a very high biodiversity as can be seen from the tables of data (Appendix 2-5). As well as the species which would suffer from habitat loss, there are some key species of conservation concern which occur along the whole corridor and as well as breeding, some move to different areas within it at different times of the year, (for example large flocks of up to 50 Skylarks roam the fields in winter; Yellowhammers and Reed Buntings also form winter flocks which move along the hedges and fields of the whole area to find food) which would be particularly affected if this land were to be developed:
IUCN Red listed Species of Conservation Concern
Skylark, Linnet, Yellowhammer, Spotted Flycatcher, Song Thrush, Mistle Thrush, Redwing, Fieldfare, Cuckoo, Starling, House Sparrow
IUCN Amber listed Species of Conservation Concern
Snipe, Stock Dove, Tawny Owl, Kestrel, Dunnock, Meadow Pipit, Bullfinch, Reed Bunting
Barn Owl is a Schedule 1 Species and the whole of this corridor is important as barn owl hunting territory as well as breeding - at least four breeding pairs in 2020.
Badgers and all bats are protected species and Hedgehogs are listed as vulnerable.
All three of the Reptiles which occur here (Grass Snake, Lizard, Slow Worm), as well as hedgehogs, are UK BAP priority species.
Invertebrates - An impressive array of scarce, local and red data species of conservation concern have been recorded in recent years, (Appendix 6), an indication of a healthy ecosystem and habitat loss would undoubtedly result in the loss of some of these species.
Photograph by Ron Smith
BIODIVERSITY REPORT PAGE 8
Appendices
Appendix 1.
KEY to bird tables
Cons Status (BoCC4): Green - least conservation concern Amber- medium concern Red - High concern Schedule 1 species - illegal to disturb, licence needed to approach nest
Frequency: *** very likely to be seen (at right time of year) ** fairly likely to be seen (at right time of year) * seen occasionally (at right time of year) (*) no longer recoreded Migration Status: R Resident S Summer visitor W Winter visitor M Seen on migration
BIODIVERSITY REPORT PAGE 9
Appendix 2
Summary of Selected Bird, Flora and Fauna Records: Old Orchard, Kiln & Tower Field (Potential Development Site, Centre Corridor)
Cons. Mig. BIRD SPECIES Status Frequency Status (Latest records) /notes Sch.1 Barn owl Sp * R Breeds within 0.5 km, hunts regularly over Kiln field and Old Orchard field (2020) Black headed gull Amber ** R Annual Blackbird Green *** R Common breeder Blackcap Green *** S Common breeder Bluetit Green *** R Common breeder Buzzard Green ** R Regular, probable breeding near Abbas Hall (2020) Carrion Crow Green *** R Common breeder Chaffinch Green *** R Common breeder Chiiffchaff Green *** R Common breeder Domestic Mallard Amber ** R Occasional by water Dunnock Amber *** R Common breeder Fieldfare Red ** W Winter flocks feed on fields and in hedges Goldfinch Green *** R Common breeder Great Spotted Woodpecker Green ** R Annual breeder Great tit Green *** R Common breeder Green Woodpecker Green ** R Regular, commutes between CpP and Old Orchard Field (2020) Greenfinch Green *** R Common breeder House Martin Amber ** S Feeds over fields House Sparrow Red *** R Colonies along Tower Field boundary (2020) Jackdaw Green *** R Common breeder Jay Green *** R Common breeder Kestrel Amber ** R Breeds and hunts over all three fields (2020) Linnet Red *** R Breeds in hedges by Old Orchard Field (2020) Little Owl * R Regular lower Prospect Hill and Crab Hill (2020). Breeding.
Long tailed Tit Green *** R Common breeder Magpie Green *** R Common breeder Meadow pipit Amber ** R,W small winter flock with skylarks near Kiln meadow Mistle Thrush Red ** R Feeds on fields Pheasant Green *** R Common Pied wagtail Green ** R Regular by water Red Kite Green * R Regularly recorded (2020) Redwing Red ** W Winter flocks feed in hedges and on fields Robin Green *** R Common breeder Rook Green ** R Common, nearby rookery Skylark Red *** R Several pairs breeding on adjacent land and using Kiln/Old Orchrd field (2020) Song Thrush Red ** R Annual breeder, feeds on fields Sparrowhawk Green ** R Annual breeder, regular Starling Red *** R Common breederand feeds in small flocks on fields Swallow Green ** S Feeds over fields Swift Amber * S Occasional over Tawny Owl Amber * R Heard regularly Prospect Hill.Breeding. Whitethroat Green *** S Common breeder in hedges Woodpigeon Green *** R Common breeder Wren Green *** R Common breeder Yellowhammer Red ** R Annual breeding in field boundary hedges (2020) Yellow Wagtail Red * S Occasional, 2020
Flowering Plants Location (latest record) Scarce: Small-leaved Lime 2019 Abbas Hall Wood Amphibious Bistort 2013 Woodland Rise Area Musk Thistle 2020 Kiln Meadow Hornbeam 2020 Crab Hill Lane Spurge Laurel 2020Crab Hill Lane Less Scarce: Bluebell 2019 Abbas Hall Wood Honeysuckle 2013 Woodland Rise Area Toadflax 2020 Kiln Meadow Sticky Mouse-ear 2020 Hillside grassland Greater Horsetail 2020Hillside grassland Wild Angelica 2020 Hillside grassland Three-nerved Sandwort 2020 Hillside grassland Hemp Agrimony 2020 Hillside grassland Square-stemmed St John's Wort 2020 Hillside grassland Field Rose 2020 Crab Hill Lane Common: Hop 2020 Hillside grassland Water Mint 2020 Hillside grassland Fleabane 2020 Hillside grassland Brooklime 2020 Hillside grassland Water-cress 2020 Hillside grassland Storksbill 2020 Hillside grassland Meadowsweet 2020 Hillside grassland Water Figwort 2020 Hillside grassland Viper’s Bugloss 2019 Arable area, TowerHill
Fauna (except birds) Location (latest record)
Mammals Water Shrew 2010 Woodland Rise Area Water Vole 2019 Crab Hill garden stream Common Pipistrelle 2013 Woodland Rise Area Soprano Pipistrelle 2013 Woodland Rise Area Noctule Bat 2013Woodland Rise Area Bat species 2020, regular, Davidson Close Area Badger 2020 lower Prospect Hill, Crab Hill Lane Hedgehog 2020 many sightings, bordering gardens Hare 2020 Tower Hill Field Roe Deer 2019 lower Prospect Hill, Tower Hill Fox 2020 frequent whole area Reptiles Viviparous Lizard 2019 Davidson Close, Prospect Hill Invertebrates Signal Crayfish 2015 Black Brook Freshwater Shrimp 2019 Black Brook Glow worm 2019 Prospect Hill verges
BIODIVERSITY REPORT PAGE 11
Appendix 3
Summary of Selected Bird, Fauna and Flora Records: East End of Corridor- Newton Rd to Sheepshead Hill incl. Abbas Hall Wood, Woodland Rise Area, Shawlands and Joe's Road
Cons. Mig. BIRD SPECIES Status Frequency Status Latest Records / Notes Sch.1 Barn Owl Species * R Regular Breeding (latest 2019) Black headed Gull Amber ** R Regular flyover small groups Blackbird Green *** R Abundant breeder Blackcap Green *** S Abundant summer breeder Blue tit Green *** R Abundant resident breeder Bullfinch Amber * R Breeds in old orchards Buzzard Green ** R Regular, probable breeding near Abbas Hall Carrion Crow Green *** R Resident breeder Chaffinch Green *** R Resident breeder Chiffchaff Green *** S Summer breeder Collared Dove Green ** R Resident breeder Common Gull Amber * R Regular flyover small groups Corn Bunting Red * R Occsional in winter (latest 2017) Cuckoo Red * S Regular summer Dunnock Amber *** R Resident breeder in field hedgerows and scrub Fieldfare Red ** W Variable nos. Winter in fields and orchards, 100s-1000s (2019/20) Goldcrest Green * R resident in woods Goldfinch Green *** R Resident breeder Great spotted woodpecker Green ** R Resident breeder in woods Great tit Green *** R Resident breeder Greenfinch Green *** R Resident breeder Green Woodpecker Green * R Regularly passing between woods Herring Gull Red ** R Regular flyover small groups House Martin Amber *** S Good numbers in summer House Sparrow Red ** R Resident breeder Jackdaw Green *** R Resident breeder Jay Green ** R Resident breeder Kestrel Amber ** R Resident breeder near Abbas Hall area Lapwing Red * R Occasional in winter fields Greys Hall (latest 2019) Lesser Whitethroat Green * S Summer breeder in hedhes/ scrub (latest 2020) Linnet Red *** R Resident breeder in scrub/ hedges widespread over area(2020) Little Owl Green * R Resident breeder several locations (2019) Long tailed tit Green *** R Resident breeder Magpie Green *** R Resident breeder Mallard Amber * R Resident Meadow Pipit Amber ** R.W Mainly winter visitor in flocks over fields often with skylarks Mistle Thrush Red ** R Resident breeder (latest 2020) Pheasant Green *** R Resident breeder Pied Wagtail Green ** R Resident, numbers increase in winter Red Kite Green * R Regular and increasing (latest 2020) Red legged Partridge Green *** R Breeding in arable fields Redwing Red ** W Winter visitor in fields, orchards and hedges, 100s-1000s (2019/20) Robin Green *** R Resident breeder Rook Green ** R Resident breeder nearby Resident breeder in several arable fields and rough meadows, large winter Skylark Red *** R flocks ) Song Thrush Red ** R Resident breeder (latest 2020) Sparrowhawk Green * R Resident breeder Starling Green ** R Resident breeder Stock Dove Amber * R Resident breeder Swallow Green ** S Summer visitor Swift Green * S Summer flyover Tawny owl Amber * R Resident breeder Treecreeper Green * R resident breeder Whitethroat Green *** S Abundant summer breeder in field hedges and scrub (latest 2020) Willow Warbler Amber * S Summer visitor (latest 2020 south of Joes Rd) Wood Pigeon Green *** R Abundant resident and winters in v large flocks Yellowhammer Red *** R Resident breeder in most field hedges
Fauna and Flora (except Birds) Location (latest record) Mammals: Harvest Mouse Shawlands Brown Hare 2020 near Abbas Hall Reptiles and Amphibians Slow-worm 2015 Shawlands, 2019 Wheldons fruit farm Common Lizard 2019 Shawlands (20+), Wheldons fruit farm Grass Snake 2019 Wheldons fruit farm **Common Toad 2020 Over 500 crossed Joe's Road (exceptional : site given Butterflies and Cricket 'Froglife' designation Scarce: Brown Argus 2019 Shawlands White-letter Hairstreak 2019 Shawlands Purple Hairstreak 2018 Shawlands Green Hairstreak 2019 Shawlands Marbled White 2019 Shawlands Silver-washed Fritillary 2013 Pot Kilns Small Heath 2019 Shawlands Large Skipper 2019 Shawlands(annual,max 12), 2015 Pot Kilns Small Skipper 2018 Shawlands (annual, max 50 2015) Essex Skipper 2018 Shawlands (annual, max 7 (2008) Long-winged Conehead Bush Cricket 2019 Shawlands (now annual and increasing) Less Scarce: Small Copper 2019 Shawlands Painted Lady 2017 Shawlands (max 6 in 2009) Speckled Wood 2020 Shawlands (regular, max 6 2013) Gatekeeper 2020 Shawlands (regular, max 40 2008) Ringlet 2017 Shawlands (regular, max 66 2013) Common Blue 2017 Shawlands (max 4 2015) Dragonflies: Brown Hawker 2017 Shawlands Migrant Hawker 2017 Shawlands Southern Hawker 2017 Shawlands Common Hawker 2017 Shawlands Ruddy Darter 2017 Shawlands Common Blue Damsel 2017 Shawlands Flowering Plants Common Spotted Orchid 2019 Shawlands Pyramidal Orchid 2019 Shawlands Bee Orchid 2019 Shawlands Ploughman’s Spikenard 2006 Newton Rd
BIODIVERSITY REPORT PAGE 13
Appendix 4
Summary of Selected Bird, Fauna and Flora Records: West End of Corridor, Country Park and Blackhouse Lane
Cons. Mig. BIRD SPECIES Status Frequency Status Recent Records/ Notes Sched. 1 Barn Owl sp. * R Pair hunts most eves and roosts and breeds - 2020 Blackbird Green *** R Common breeder Black headed gull Amber *** R Feeds on fields Blackcap Green ** S (W) Common breeder Blue Tit Green *** R Common breeder Bullfinch Amber ** R Breed Country Park (2020) and beside Blackhouse Lane Buzzard Green ** R Regular, breed C. Mere (2020) Carrion Crow Green *** R Common breeder Coal tit Green ** R Breeds Chaffinch Green *** R Common breeder Collared Dove Green *** R Common breeder Common Gull Amber ** R Feeds on Fields Cuckoo Red * S Annual, often commutes betweenCP and Mere, 2 in 2020 Dunnock Amber *** R Common breeder Fieldfare Red * W Winter, occasionally feed on fields and in hedges (2020) Garden Warbler Green * S Scarce breeder Goldcrest Green ** R Common breeder Goldfinch Green *** R Regular breeder, groups feed on thistles and teasles Great spotted woodpecker Green *** R Breeds inthe fragment woodland Great Tit Green *** R Common breeder Green woodpecker Green ** R Breeds in the fragment woodland Greenfinch Green *** R Common breeder Hobby Green * S Occasional over House Martin Amber *** S Common over feeding on insects House Sparrow Red *** R Good breeding colonies in CP and B'house lane hedge (2020) Jackdaw Green *** R Common breeder Jay Green *** R Common breeder Kestrel Amber *** R Pair breeds annually Kingfisher Amber * R Feeds occasionally in Black Brook (B'house La) 2018 Lapwing Red * R Annually, occasional (2019) Lesser Redpoll Red * W Present winter in variable numbers Lesser Whitethroat Green * S 3 territories in 2020 Linnet Red ** R Several pairs breed top of Danes Hole Little Owl * R Breeds annually (2020) Long tailed tit Green *** R Common breeder Magpie Green *** R Marsh tit Red ** R Breeds most years (2019) Mistle thrush Red ** R Breeds annually (2020) Pheasant ** R Common breeder Pied wagtail Green ** R Breeds nearby Red legged partridge * R Occasional from nearby fields Red Kite Green * R Regular now (2020) Redwing Red * W Winter flocks in variable numbers (2020) Reed Bunting Amber * R Few in winter top of Danes Hole (2019) Robin Green *** R Common breeder Rook Green *** R Common, breeds nearby Sand Martin Green * S Feeds over on migration Siskin Green * W Winter visitor in small numbers Snipe Red * W Occasional in Black Brook (b'house La) in winter Breed in adjacent field (between CP and Mere), winter flocks Skylark Red ** R (2020) Song thrush Red *** R Several pairs breed Sparrowhawk Green ** R Breeds (2019) Spotted Flycatcher Red * S Passage, breeds in adjacent large gardens (2020) Stock Dove Amber ** R Several pairs breed Starling Red ** R Breeds and feeds on fields near allotments Swallow Green ** S Feeds over Tawny Owl Amber * R Heard regularly, probable annual breeder (2020) Swift Amber * S Feeds over Treecreeper Green ** R Breeds in fragment woodland Turtle Dove Red (*) S No longer recorded Whitethroat Green ** S several pairs breed annually (approx 12 pairs 2020) Willow warbler Amber * S Annual (2020) Woodpigeon Green *** R Very common breeder Wren Green *** R Common breeder Yellowhammer Red ** R Several breeding pairs in hedge boundaries (2020)
Fauna and Flora (except birds) Location (latest Record) Mammals Badger 2020 Country Park active sett Long-eared bat 2020 Country Park Pipstrelle bat 2020 Country Park Soprano Pipistrelle bat 2020 Country Park Reptiles and Amphibians Common Lizard 2019 CP widespread, increasing, some intro to refuge area Grass Snake 2019 CPark and Allotments, increasing Slow Worm 2019 CPark increasing, some intro into refuge area Smooth Newt 2007 Allotments Butterflies Scarce: Brown Argus 2018 CP population of hundreds Large Skipper 2019 Country Park Small Skipper 2019 Country Park Essex Skipper 2019 Country Park Purple Hairstreak 2018 Country Park Small Heath 2020 Country Park White Admiral 2010 CP Danes Hole Less Scarce: Common Blue 2018 CP prolific, 2020 Small Copper 2020 Country Park Small Tortoiseshell 2020 Country Park Ringlet Country 2018 Country Park Common: Holly Blue 2020 Country Park Orange-tip 2020 Country Park Green-veined White 2020 Country Park Brimstone 2020 Country Park Gatekeeper 2020 Country Park Moths Cinnabar moth 2020 Country Park Burnet moth 2020 Country park Dragonflies Scarce: Scarce Chaser 2018 Country Park Broad-bodied Chaser 2018 Country Park Black-tailed Skimmer 2018 Country Park Ruddy Darter 2018 Country Park Less Scarce: Brown Hawker 2018 Country Park Southern Hawker 2018 Country Park Migrant Hawker 2018 Country Park Common: Azure damselfly 2018 Country Park Common Blue damsel 2018 Country Park Common Darter 2018 Country Park Other Invertebrates Orange Tailed Mining Bee 2019 Country Park Snail Hunter Beetle 2019 Country Park Micro Ladybird Soymnus montalis 2019 Country Park Hornets 2018 CP ancient woodland fragment Flowering Plants Scarce: Moschatel 2020 Country Park plantation, increasing Bluebell 2020 Country Park, increasing Nettle-leaved Bellflower 2019 Country Park, increasing Pignut 2020 CPancient woodland fragment, increasing Sulphur Clover 2020 CP top rough meadow, increasing Ploughman's Spikenard 2019 CP Danes Hole Bee Orchid 2020 CP top rough meadow, good numbers Grass Vetchling 2014 Country Park wildflower meadow Vervain 2002 Country Park Lesser Calamint 2020 CP (Danes Hole) and bottom of Prospect Hill Less Scarce: Marsh Bedstraw 2015 Country Park Wild Marjoram 2020 CP - important food source for invertebrates
BIODIVERSITY REPORT PAGE 16
Appendix 5
Summary of Bird, Flora and Fauna Records: West End of Corridor, Cornard Mere
Cons. BIRD SPECIES Status Frequency Mig.Status Most recent records / Notes Barn Owl Sched. 1 * R Breeding 2020 Bearded Tit Green (r) Three birds March 2011
Blackbird Green *** R Common breeder Blackcap Green *** S Common breeder Black-headed Gull Amber ** R Feeds on adjacent field Blue Tit Green *** R Common breeder Bullfinch Amber ** R Few breeding pairs Buzzard Green *** R Now breeds (2020) Canada Goose Green *** R Common breeder Carrion Crow Green *** R Common breeder Cettis Warbler Green * R 1-2-pairs breed annually (2020) Chaffinch Green ** R Common breeder Chiffchaff Green *** S Common breeder Common Gull Amber ** R Feeds on adjacent field Coot Green *** R Common breeder Cormorant Green ** R Regular visitor Corn bunting Red * R Occasional mainly in winter Cuckoo Red ** S Annual. 2020: 2 males and female Dunnock Amber *** R Common breeder Garden Warbler Green * S Scarce breeder Goldcrest Green ** R Common breeder Goldfinch Green *** R Common breeder Great Spotted Woodpecker Green ** R Pair breeds Great Tit Green *** R Common breeder Green Sandpiper Green * P Regular passage migrant (2019) Green Woodpecker Green * R Regular Greenfinch Green ** R Common breeder Grey Heron Green ** R Regular Grey Wagtail Red * R Annual; 2020 Greylag Goose Green *** R Common breeder, large numbers in winter Herring Gull Red ** R Frequent over Hobby Green * S regular in summer feeding on dragonflies (2020) House Martin Amber *** S Feeds over water in summer, large numbers, autumn roost Jack Snipe Green * W occasional in winter Jackdaw Green ** R Common Jay Green *** R Common breeder Kestrel Amber ** R Regular, breeds nearby Kingfisher Amber * R regular, breeds nearby Lapwing Red * R occasional visitor (2020) Lesser black-backed gull Green * R Occasional over Lesser Redpoll Red * W regular winter, variable numbers (2019) Lesser Whitethroat Green * S Occasional breeder Linnet Red ** R Present in nearby hedges Little Grebe Green *** R At least 4 pairs breed (2020) Little Owl * R Occasional
Long tailed tit Green *** R Common breeder Magpie Green *** R Common breeder Mallard Amber *** R Common breeder Mandarin Duck Green * R occasional visitor (2018) Marsh Harrier Green * (r) occasional visitor (2019) Meadow pipit Green * R Few pairs mainly winter Mistle Thrush Red ** R Pair regular Moorhen Green *** R Common breeder Mute Swan Green ** R Pair breeds annually Nightingale Red * S Returned to breed 2019 and 2020 after several years absence Pied Wagtail Green ** R Large winter roost Pintail Green * R Occasional visitor (2018) Raven Green * R Pair regular 2020 (rare for Suffolk) Red Kite Green * R Breeds nearby, now regular (2020) Redwing Red *** W Winter roost site Reed Bunting Amber *** R Several pairs breed annually (2020) Reed Warbler Green *** S Good numbers breed annually (2020) Robin Green *** R Common breeder Rook Green ** R Nearby rookery (2020) Sand Martin Green * S Pass through in variable numbers Sedge Warbler Green ** S Few pairs breed annually (2020) Shoveler Green * R Present most years small numbers Skylark Red *** R 3-4-pairs breed field between Mere and CP, winter flocks (2020) Snipe Amber * W Winter visitor in small numbers (2020) Song Thrush Red *** R Few pairs breed Sparrowhawk Green ** R Breeds nearby Spotted flycatcher Red * S Regular on passage Stock Dove Amber *** R Breeds Summer visitor and roost in lrge numbers on autumn passage Swallow Green *** S (2020) Swift Green * S Feeds high over Teal Green *** R Large winter numbers Treecreeper Green ** R Breeds Tufted Duck Green *** R Few pairs year round Turtle Dove Red * S Annual in past, no longer recorded Water Rail Green ** R Few pairs breed, winter in variable numbers (2020) Whitethroat Green ** S Breeds in scrub Wigeon Green * R Winter visitor Willow Warbler Amber * S Scarce breeder Woodcock Red * W Winter visitor Woodpigeon Green *** R Common breeder Wren Green *** R Common breeder Yellow-browed Warbler Green Occasional (2016)
Yellowhammer Red ** R Breed in adjacent hedges (2020)
BIODIVERSITY REPORT PAGE 18 Fauna (except birds) Latest Record Flowering Plants Latest Record
Mammals: Scarcest: Harvest Mouse 2019 Trifid Bur Marigold 2020 Otter 2018 Greater Spearwort 2007 Stoat 2018 Lesser Spearwort 2008 Weasel 2020 Brookweed 2009 Badger 2015 Fen Bedstraw 2006 Leisler’s Bat 2009 Great Yellow-Cress 2019 Water Shrew 2020 (good numbers) Wild Strawberry 2016 Field Vole 2020 Blunt-flowered Rush 2017 Common Shrew 2020 Tufted Sedge 2008 Wood-mouse 2020 Bottle Sedge 2020 Hedgehog 2019 Cyperus Sedge 2020 Reptiles and Amphibians Marsh Pennywort 2009 Slow Worm 2020 Marsh Marigold 2011 Common Lizard 2019 Mousetail 2007 Grass Snake 2020 (good numbers) Water-Crowfoot 2013 Smooth Newt 2018 Common Meadow-Rue 2019 Butterflies Water Violet 2008 Scarcest: Skullcap 2018 Brown Argus 2017 Small Heath 2017 Great Water Dock 2020 Less Scarce: Golden Dock 2020 Small Copper 2016 Bogbean 2008 Small Skipper 2017 Rough Hawksbeard 2007 Essex Skipper 2017 Tubular Water-Dropwort 2008 Dragonflies Yellow Loosestrife 2018 Scarcest: Common Valerian 2010 Hairy Dragonfly 2020 Water Chickweed 2019 Red-eyed Damselfly 2009 Celery-leaved Buttercup 2019 Small Red-eyed Damselfly 2009 Non-Flowering Plants 2015 Common Emerald 2019 Lady Fern (Non Flowering Willow Emerald Damselfly 2019 Plant) Broad-bodied Chaser 2020 Less Scarce: Four-spotted Chaser 2019 Marsh Woundwort 2019 Scarce Chaser 2020 Rigid Hornwort 2014 White-legged Damselfly 2005 Amphibious Bistort 2019 Black-tailed Skimmer 2019 Brown Sedge 2008 Ruddy Darter 2019 Watercress 2019 Less Scarce: Small-leaved Fluellen 2017 Banded Demoiselle 2019 Creeping Jenny 2020 Large Red Damselfly 2019 Common Fumitory 2018 Southern Hawker 2019 Lady’s-smock 2020 Migrant Hawker 2016 Blue Water-Speedwell 2016 Brown Hawker 2019 Pink Water-Speedwell 2016 Emperor 2019 Green Field Speedwell 2012 Common: Vervain 2002 Azure Damselfly 2020 Tufted Forget-Me-Not 2007 Common Blue Damselfly 2019 Marsh Yellow-Cress 2019 Blue-tailed Damselfly 2019 Migrant Hawker 2019 Common Darter 2019
BIODIVERSITY REPORT PAGE 19
Appendix 6.
Notable invertebrates recorded for the described wildlife corridor (from Cornard Mere in the west to Shawlands in the east) in recent years (Stuart Read)
Species National status Species National Status
Odonata Wood Carpet Local
Willow Emerald Damselfly Colonising Pine Carpet Rare away from Brecks/Sandlings
Hairy Dragonfly Local Sloe Pug Scarce in Suffolk
In Suffolk confined to parts of the Scarce Chaser Stour & Waveney Valleys Haworth's Pug Local
Slender Pug Locally scarce
Dermaptera Maple Pug Local
Short-winged Earwig Nb Toadflax Pug Locally scarce
Marsh Pug Local
Orthoptera Pimpinel Pug Only modern record in Suffolk
Roesel's Bush-cricket Local Plain Pug Local
Long-winged Conehead Na Ochreous Pug Only record for the Stour valley
Freyer's Pug Only records in West suffolk
Heteroptera Satyr Pug Locally scarce
Eurygaster testudinaria Local Yarrow Pug Nb
Pied Shieldbug Orange Moth Local
Bordered Shieldbug Lilac Beauty Local
Forget-me-not Shieldbug Local Small Emerald Local
Podops inuncta Nb Buttoned Snout Nb
Bisop's Mitre Shieldbug Local White Satin Local
Crucifer hieldbug Local Black Arches Local
Blue Shieldbug Local Gypsy Moth Colonising
Box Bug RDB Shaded Fan-foot RDB3
Syromastes rhombeus Local Beautiful Hook-tip Local
Coriomeris denticulatus Dewick's Plusia Colonising
Corius hyoscyami Local Coronet Local
Stictopleurus punctatonervosus Colonising Small Yellow Underwing Local
Rhopalus subrufus Local Toadflax Brocade RDB3
Rhopalus parumpunctatus Local Tree Lichen beauty Colonising
Orsillus depressus Colonising Clancy's Rustic Colonising
Peritrechus lundii Local Silky Wainscot Local
Reduvius personatus Synanthropic Bird's Wing Local
Ledra aurita Local Old Lady Local
Asiraca clavicornis Nb Fen Wainscot Local Nb, 2nd Suffolk record since Saldula opacula 1990 Twin-spotted Wainscot Local
Double Lobed Local
Coleoptera Dusky Lemon Sallow Local
Bembidion obliquum Nb Dotted Chestnut Nb
Bembidion quadripustulatum Nb Pale Pinion Local
Bembidion clarkii Nb Lesser-spotted Pinion Local
Demetrias imperialis Nb Lunar-spotted Pinion Local
Badister collaris RDB1 Minor Shoulder-knot Locally scarce
Summer Chafer Local Dingy Shears Local
Anthocomus rufus Local Deep-brown Dart Local
Nephus quadrimaculatus Vulnerable Black Rustic Local
Scymnus frontalis Local Large Ranunculus Local
18-spot Ladybird Rare away from Brecks/Sandlings Feathered Gothic Locally scarce
Larch Ladybird Rare away from Brecks/Sandlings Small Ranunculus RDBK
Adonis Ladybird Rare away from Brecks/Sandlings Varied Coronet Locally scarce
Cream-streaked Ladybird Rare away from Brecks/Sandlings Southern Wainscot Local
Tenebrio molitor Nb L-album Wainscot Nb
Phymatodes testaceus Nb Lunar Yellow Underwing Nb
Frosted Green Local
Dptera Small Elephant Hawkmoth Local
Chrysotoxum festivum Local Dasycera oliviella Na
Leucozona laternaria Scarce in East Anglia Agonopterix purpurea Local
Meligramma trianguliferum Scarce Anarsia innoxiella Rare
Meligramma euchromum RDB3 Dicromeris marginella Local
Epistrophe melanostoma Rare Mompha propinquella Local
Epistrophe nitidicollis Local Marasmarcha lunaedactyla Local
Rhingia rostrata RDB3 Epermenia falciformis Local
Brachyopa scutellaris Local Aethes tesserana Local
Anasimyia interpuncta RDB3 Cochylis molliculana Local
Pipiza luteitarsis Local Apotomis lineana Na
Volucella inanis Scarce Lobesia littoralis Local
Volucella inflata Scarce Endothenia nigrocostana Local
Volucella zonaria Scarce Nemophora metallica Nb
Brachypalpoides lentus Local Argyresthia cupressella Local
Conops quadrifasciatus Nb Argyresthia trifasciata Local
Phania funesta Nb Donacaula forficella Local
Phasia hemiptera Local Evergestis extimalis Local
Gymnocheta viridis Local Pediasia contaminella Nb
Norwickia ferox Nb Ypsolopha mucronella Local
Lepidoptera Hymenoptera
Green Hairstreak Locally scarce Cerceris rubyensis Rare away from Brecks/Sandlings
Purple Hairstreak Locally scarce Ivy Bee
White-letter Hairstreak Locally scarce Andrena flavipes Local
Small Copper Locally scarce Andrena hattorfiana RDB2
Brown Argus Locally scarce Andrena labiata Na
Andrena marginata Na RDB3, 1st & only W Suffolk Hornet Clearwing Nb Andrena florea Record
Currant Clearwing Nb Andrena praecox Local
Red-belted Clearwing Nb Chelostoma campanularum Local
Red-tipped Clearwing Nb Osmia caerulescens Local
Festoon Nb Osmia leaiana Local
Emperor Moth Nomada ferruginata RDB1
Least carpet Local Nomada fucata Na
Maiden's Blush Local Nomada zonata colonising
Ruddy Carpet Nb Anthophora furcata Local
BIODIVERSITY REPORT PAGE 21 Appendix 7.
Table of Barn Owl breeding evidence (boxes monitored under Schedule 1 licence and chicks ringed annually as part of Suffolk Community Barn Owl Project
(4-6 pairs breed in the area covered by the report annually - details confidential)
Appendix 8.
Data Sources and Acknowledgements
All of the bird, fauna and flora records were taken from the following sources:
1) Suffolk Biological Information Service www.suffolkbis.org.uk
2) BTO (British Trust for Ornithology) BirdTrack www.bto.org
3) Breeding Bird Survey:
"The BTO/JNCC/RSPB Breeding Bird Survey is a partnership jointly funded by the British Trust for Ornithology (BTO), Royal Society for the Protection of Birds (RSPB) and the Joint Nature Conservation Committee (JNCC), with fieldwork conducted by volunteers."
4) Suffolk Community Barn Owl Project,
SW region manager D. Ping
BIODIVERSITY REPORT PAGE 22
Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
BIODIVERSITY POLICY REPORT
We regard this as a key biological site for the Sudbury area.
This site is exceptional as a wildlife corridor, and as a survival of unimproved grassland habitat with natural wetlands. The land is too important biologically to be lost. It should be left as green space, and shouldn’t be drained, nor left ungrazed, nor undergo tree-planting.
This statement is attached to our Biodiversity Report, which shows the importance here of the species, habitats, and value as a wildlife corridor. Development here would fragment the network that includes the Country Park and Shawlands. This land is exemplary of the Stour Valley habitats, with its dry grassland and marshes, and for Lowland England it is comparable with the “irreplaceable habitats” referred to in paragraph 175c and Glossary of the NPPF.
REQUIREMENTS UNDER NATIONAL PLANNING POLICY FRAMEWORK, AND POLICY STATEMENT ON THE ENVIRONMENT BILL
A1. Babergh’s Duty to Biodiversity
Paragraph 170 of the NPPF presents two distinct courses for progress, it states “a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan) …. d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures”.
It is necessary to achieve both (a) and (d) since the former refers to protecting a select number of distantly spaced habitat fragments, but the latter calls for establishing a coherent network. Therefore we advise against any Land Allocations on sites that have not had any assessment for their importance in a local network of potential habitat corridors (especially near towns).
B2 Mitigation and Avoidance
170(d) above goes on to refer to two distinct courses, and our survey shows the correct course would be “minimising impacts” not merely “providing net gains” (the latter being epitomised by arbitrary tree-planting).
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
BIODIVERSITY POLICY REPORT
Paragraph 175 of the NPPF stipulates that “if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused”.
Our survey indicates the correct course would be “avoid”. We find that to “mitigate” development here would not be achievable, because of the biological and other value of the whole site; nor equally to “compensate for” since the wet hillside land could not be re-created.
The “mitigation” proposed by the developer’s representation in the 2019 Local Plan consultation, should be a “last resort” - not a first resort. It would be substitution of an inferior arrangement, and the only acceptable response to a planning application would therefore be refusal.
Building on a large proportion of the habitat of the habitat, and replacing the remainder with planted trees, could never support much biodiversity beyond what the adjacent woodland and ponds provide; it’s appropriate to development of arable land, but not in a wildlife corridor or on natural grassland.
B3 Scope for “enhancements” and “mitigation” on this land
Although it is usual for developments to include enhancements by way of “net gain”, we put it that the biological quality of land at this site would not be enhanced by such measures. We believe this land could not benefit from the “mitigation” set out in the NPPF paragraph 175, and that the correct option is “avoidance” - particularly given the availability of a better option at Chilton Woods in Sudbury.
- We don’t believe such biodiversity as damp meadows and an established Barn Owl corridor can be mitigated, nor any changes to the Brook, which is Sudbury area’s only remaining natural watercourse this side of the Stour. Cutting the area up with fences etc would be harmful. - The two adjacent new balancing ponds at Woodland Rise may in future provide some useful additional habitat.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
BIODIVERSITY POLICY REPORT
- Extensive tree-planting on the grassland, would be to substitute an inferior option, and it is increasingly becoming clear to planning authorities (and organisations like the Woodland Trust), that trees are not a substitute for natural grassland. To quote David Hill, Chair of the Environment Bank and Plantlife “there’s a great difference between planting trees and creating woodland, as I’m sure you know”. - Natural grassland is a very scarce resource in modern lowland Britain, and can also be a greater carbon sink than the same area of planted trees. - Planting along the watercourses on the hillside would harm their biological quality. - There are few places where gapping up hedges is necessary.
B3. Nature Recovery Network
Paragraph 174a & b of the NPPF require Local Authorities to “identify, map and safeguard …. wildlife areas and stepping stones ... ”
The Government’s January 2020 Policy Statement on the Environment Bill states “The case for tackling biodiversity loss, climate change and environmental risks to public health is clear. The accelerating impact of climate change in this country and around the world is of profound public concern, as is the damage to nature with species loss, habitat erosion and the disappearance of cherished wildlife …. Despite recent positive action, we have not been able to reverse this long-term decline in nature and this government is determined to take urgent action, creating the step change required for its recovery”.
Babergh’s planning authority will be aware the new direction that this step change will require in the Local Plan and Land Allocation policy, over and above maintenance of existing protected sites.
The partnership for Suffolk Ecological Networking advises “Suffolk has many sites and features of high ecological quality and value, but many of its habitats are highly fragmented and isolated within a largely intensive agricultural landscape. There are examples where conservation and enhancement of habitats and species is being successfully combined with commercial agriculture, but this is not generally happening at the landscape scale required to restore the wider functional ecological networks envisaged by the Lawton Review as being critical to enabling nature recover and respond to a changing climate.”
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
BIODIVERSITY POLICY REPORT
Babergh’s partnership organisation for mapping ecological networks, advise us that their tool for evaluating potential elements in a Nature Recovery Network will take another two years to develop, but that “We are aiming to have some results available by the end of this year”.
However the obligation on planning authorities already exists: the NPPF paragraph 170d refers to "establishing coherent ecological networks”, paragraph 171 sets out that plans should “take a strategic approach to maintaining and enhancing networks of habitat and green infrastructure”, and paragraph 174 requires Local Authorities to “identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks …. wildlife corridors and stepping stones that connect them; and areas identified by …. partnerships”.
Since this paragraph 174 obligation pre-dates any future Land Allocations, we assume the local authority should without delay draw up and consult on an interim map, for areas which border on Sudbury, Hadleigh and Ipswich.
We can immediately identify that the fringes of Great Cornard all form an important link from the riverside meadows, to the line of Babergh’s “Green Arc”. A recent e-mail to us from Babergh’s key partnership organisation tells us “It should be possible to give different weighting to green space in urban areas if that is needed.”
B4. Net Gain
Under the Environment Bill’s plans for 10% Biodiversity Net Gain, natural grassland would count very high in the metric, including when costing any payment required from a developer.
The ecology and sustainability consultant Sue Everett, who is nationally known for her news pages, in “British Wildlife” has written to our group that “I suggest a motion goes to the Council to engage with the Environment Bank, and develop a partnership that will assist in progressing Biodiversity Net Gain in preparation for the en-action of the Environment Bill, likely to be later this year. There is a 10 minute presentation on this issue, presented by David Hill of the Environment Bank, which explains - I recommend all members of the Planning Board, and planning officers, watch this. For planning officers it will count towards CPD.”
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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C1. Land Allocation Process
We object that Babergh’s 2019 SHELAA document, only identifies the “constraints that would require further investigation” as: Highways, Heritage, Contaminated land and Flood. This site is evidently a key landscape and wildlife corridor for the Sudbury area, and an Environmental Impact Assessment is indicated in advance of any Land Allocation.
As paragraph 171of the NPPF states "Plans should …. allocate land with the least environmental or amenity value, where consistent with other policies in this Framework; take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure ….” we point out that a less harmful alternative exists at Chilton Woods. Also, that fair comparison with Tye Farm is hindered by the LA042 document not indicating what parts of that big land area might be proposed for development.
C2. Babergh’s Core Policies
CS5 dealing with strategic growth in Great Cornard seems applicable to this site: “Ensure development incorporates a green infrastructure framework connecting, adding or extending …. wildlife areas ….”
CS14 - The introduction to CS14 reads: ”3.3.9.2 A good network of multi-functional green infrastructure within and between urban and rural areas should aim to achieve the following; …. ii) Contribute to habitat connectivity and to habitat creation, protection and enhancement …. greenfield sites and those within or close to sensitive landscapes will be particularly important”.
CS15 - “Proposals for development should …. vii) protect and enhance biodiversity …. increase the connectivity of habitats and the enhancement of biodiversity…. in particular proposals should protect and where possible enhance …. habitats and features of …. biological interest”.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
BIODIVERSITY POLICY REPORT
Babergh Development Framework August 2012 - A Green Infrastructure Framework for Babergh District sets out the Green Infrastructure Vision for Babergh District: “Introduction: Future provision, enhancement and management of green infrastructure will seek to maximise the connectivity and potential of the wealth of multi-functional green infrastructure throughout the district. Green Infrastructure will be enhanced and managed to ensure there is a well- connected green infrastructure network for the benefit of all interests and communities that the spaces intend to serve, throughout the district …. Broad Principles: Enhance biodiversity by linking, extending and creating important BAP habitats, including opportunities to reverse habitat fragmentation and promotion of sustainable landscape management practices”. We regret that the Open Spaces map which has so far resulted, includes only land owned or managed by the local authorities.
C3. The Dedham Vale AONB
The site is within the proposed AONB extension. The Dedham Vale AONB, in addition to its purpose of conserving and enhancing the natural beauty of the area, is now working to meet the Colchester Declaration (an AONB network pledge to meet the wildlife and climate crises), and the Glover Review of nationally designated landscapes, which sets out that “national landscapes should have a renewed mission to recover and enhance nature …. the state of nature and natural capital in our national landscapes should be regularly and robustly assessed, informing the priorities for action; set clear priorities and actions for nature recovery …. and should form the backbone of Nature Recovery Networks”.
This site is given prominence in the Alison Farmer report to the AONB (referred to in the Landscape section of our report).
DEVELOPER’S DOCUMENT
We quote from the Landscape Statement (Appendix 2) from Huntstowe Land’s representation to the 2019 Local Plan consultation, in the “Great Cornard” section. We must conclude at the least there is much “unconscious bias” in Huntstowe’s statement.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
BIODIVERSITY POLICY REPORT
6.1.1 “Woodland structure including ancient woodlands: The site boundaries include some strong tree belts in places. These features should be retained, enhanced and reinforced through a strategic evaluation of green infrastructure locally, with the potential for introduction of new woodland structure, improving the connectivity between existing features”
Our comment - We explain in B1 above that the features here don’t require “re-inforcement” and such planting would harm the biodiversity of the streams and marshes on the site.
6.2.3 Appropriate ecological surveys should be undertaken to confirm the presence of important habitats and/or protected species. Where required appropriate mitigation will be incorporated during the design development phase, with appropriate enhancements to biodiversity included within any landscape strategy.
Our comment - We don’t believe such biodiversity as damp meadows and an established Barn Owl corridor can be “mitigated”, nor any changes to the Brook, which is the Sudbury area’s only remaining natural watercourse this side of the Stour.
6.2.5 …. the strategy plan makes an allowance for a buffer of approximately 10-15m to the perimeter of all existing woodland areas.
Our comment - Such buffer areas could be too overshaded unless nearer 30 metres wide, as at Moreton Hall, Bury St Edmunds.
6.3.1 “Given the limited site constraints and potential for mitigation/enhancement planting the Site is considered to be a suitable location in landscape and visual terms for development.”
Our comment - This indicates the excessive reliance of the whole proposal, on “mitigation by tree-planting”.
Page 27 Illustrative Landscape Strategy: “To establish green corridors / landscape dominated streets that permeate the built form (north-south and west-east), connecting the site and established residential areas via a series of linked open spaces to the wider countryside in order to ensure permeability for people and wildlife.”
Our comment - We challenge a statement like this: it may be a pleasant feature for those living on the site but does it provide any permeability for wildlife, particularly as the main effect is destruction of natural grassland.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
FLOOD RISK REPORT
1. REFERENCE DOCUMENTS USED IN THIS REPORT
Sudbury and Great Cornard Surface Water Management Plan (SWAMP) February 2019 produced by BMT Ltd, Flood Consultants
NPPF (2019)
Government Surface Water Management Plan
Surface Water Management Conference October 2018 – Speech delivered by Sir James Bevan KCMG CEO of EA
Suffolk Local Flood Risk Management Strategy
Babergh Water Cycle Study June 2011 – produced by Water Industry Consultants
Environment Agency Flood Maps and Survey information
Witness statement of Mr R J Barry dated 20 October 2017, produced in response to the Babergh & Mid Suffolk Joint Local Plan published in August 2017.
2. FLOOD RISK ON THE PROPOSED SITE
2A. In the desktop study produced by your consultants in the Land Availability Assessment published as part of the 2019 Preferred Options Joint Local Plan, the site is assessed has having no flood exposure. THIS IS UTTERLY INCORRECT.
Not only does the main drainage channel for the Critical Drainage Area (CDA), known locally as the Cornard Black Brook, run adjacent to the proposed site and forms the site boundary for a significant part, but also runs through the centre of the proposed development for about 30% of its entirety.
However, other flooding issues arise. The Brook itself has a long recorded history of flood events. Indeed your own consultant reports refer to these issues going back to1968 and prior. We attempt to flesh out the specifics:-
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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The immediate area is also known for its high levels of ground water retention. This is witnessed by reference to the SWAMP and other publically available geological publications and maps. Furthermore, the site area is within an EA ground water protection zone. Indeed, two Anglian Water bore holes feed directly from this aquifer and are in close proximity of the proposed site. The high levels of ground water produced a number of issues after prolonged winter rains, as was the case in 2000, 2014 and 2019/2020. A number of natural springs appeared on the slopes of the proposed site discharging significant volumes of water to flood the lower ground as it made its way to join Black Brook.
2B. In heavy rainfall events, a culvert that runs diagonally across the site surcharges and produces a diagonal flood flow path across the proposed site/field known as Tower Field as water travels down the incline to join Black Brook.
2C. New evidence is emerging from the new Persimmon Homes development known as Woodlands Rise, of a number of properties suffering from ground water flooding after prolonged rainfall events. The Woodlands Rise development is immediately adjacent and on somewhat higher ground than the proposed site.
2D. The SWAMP produced for SCC as LLFA contains many caveats and a number of very serious omissions. The most material and important of these omissions relate to the fact that no account whatsoever has being taken of the impact of the new Woodlands Rise development in the flood modeling utilized within the report. This omission could prove most significant given that the Woodlands Rise estate sits on higher ground overlooking the proposed site and the impact on any further new builds at a lower level, and the wider community for that matter, is a dangerous unknown risk factor.
2E. An investigation is currently underway as a result of the EA suggesting that all the flood prevention planning requirements may have not been fully complied with on the Woodlands Rise estate. Whilst this investigation is work in progress and any likely impact on flood risk unknown at this stage, it begs the question of how much surface water drainage can Black Brook physically take?
This issue is proving extremely difficult to bottom out as a result of the planning approval B/14/00804 for Woodland Rise being issued in 2014 containing the EA conditions, but surface water flood responsibility was transferred to SCC as LLFA in 2015 and building works not commencing until 2017. If site SS0220 is approved for development and surface water is allowed to drain into Black Brook, not only will the risk to any development onsite rise exponentially, but also throughout the CDA.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
FLOOD RISK REPORT
2F. An additional layer of risk has been recently identified that could have a materially detrimental effect on the site flood risk and properties lower down the catchment. During the winter of 2019 which was exceedingly wet, a large number of flood events occurred immediately below the proposed site, one of significant note on 20th December 2019.
Upon investigation (which to some extent are still ongoing), it emerged that not only was the Woodlands Rise attenuation pond discharging large volumes of water, but simultaneous and in addition to this was the natural discharge from field drains into Black Brook, but also Anglian Water was discharging large volumes of water from their water tower at Cornard Tye.
The dynamics of the flood risk has changed dramatically as a result of the Woodlands Rise development. These cumulative factors create a material uncertainty of the flood risk on the proposed site.
Even by engineering a SUDS into any development to take surface water drainage, it will not remove the risks. In fact, in conversation with the SCC flood team as LLFA following publication of SWAMP in 2019, it became apparent that they had considered mitigation measures for CDA 5 including a SUDS in the area of Kiln Field but had to abandon the idea as their modeling indicated it actually increased the flood risk!
Given these issues, the only way surface water drainage can be safely managed in the area is by discharge into dedicated surface water drains/sewers but of course that is not possible as various reports including the water cycle study indicate no capacity is available.
A matter of very real concern that flows from these issues; if planning is approved for Site SS0220 incorporating a SUDS, as it would seem inevitable given the status of the ground water protection zone, what would happen onsite and to the immediate locality, if we had simultaneous discharge into Black brook from;
• A new site SUDS • The Woodlands Rise SUDS • Natural drainage and the diagonal discharge across Tower field as a result of culvert surcharge • Anglian Water Tower discharge
2G. Furthermore, Prospect Hill is a deeply sunken lane on a steep incline. This means in times of extreme rainfall, it acts as a land drain as water drains off the surrounding fields and the alluvial gully that runs from the top of the hill and joins Prospect Hill just below Woodlands and forms a river of water running downhill to join Black Brook.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
FLOOD RISK REPORT
One of the proposed access routes into site SS0220 is directly on this flood flow path and the consequence of an entry road at this point would probably divert the flood flow path to an unknown location. The EA Surface Water Flood Risk map for CO10 0GY confirms this, as does the written testimony of Mr R J Barry in his witness statement.
3. FLOOD RISK TO THE WIDER COMMUNITY
The NPPF (2019) clearly states; “Ensure flood risk to others is not increased”.
“The Government is on the side of householders at risk of surface water flooding”. Ministerial Forward from the Surface Water Management Plan.
3A. SURFACE WATER FLOODING
The proposed site is less that 40m distant from the recognized flood risk zone incorporating Eldred Drive, Horse Pond Close, Blackhouse Lane and Wells Hall Road (in the main CO10 0GY and surrounding area).
SWAMP classified this area ‘as being Medium to High risk of surface water flooding’.
The EA surface water flood map for this area is a mix of low to high risks.
However, it must be remembered that SWAMP, although deficient in many respects, is a more detailed piece of work and more specific to local flood risk. In addition, it includes many important caveats about unknown risk factors and takes no account whatsoever of the likely impact that the Woodlands Rise development may have. Although, it does draw out a number of key issues; Quote:
• ‘Areas that intersect with historic watercourses are at particular risk’.- Being CO10 0GY Prospect Hill and Blackhouse Lane.
• ‘Areas adjacent to obstructions to flow (raised road, embankment etc)’.- Again being CO10 0GY Prospect Hill and Blackhouse Lane. This particular issue is a very material risk factor as can be demonstrated by a simple visual inspection.
The immediate upstream culvert running under Eldred by TWO 600mm culverts but only 100 meters down stream flows into ONE 400mm culvert running under Prospect Hill. Being only some 40m from the proposed development site.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
FLOOD RISK REPORT
Furthermore, the culvert downstream running under Blackhouse Lane although having TWO 400mm has always proved to be inadequate as a result of the flood flow path of water running down Prospect Hill and joining joining Black Brook immediately below the Prospect Hill culvert. These flow impediments create back flows and ponding upstream of these constrictions. This includes the rear of Horse Pond Close, Eldred Drive, Davidson Close and indeed the new proposed site itself.
Further aggravating issues that exacerbate the constriction of flow in the area of the Blackhouse Lane culvert and downstream:-
• The exceedingly poor design of the trash screen that regularly blocks.
• Accumulation of siltation in this culvert and those downstream. A recent survey, conducted by EDI Surveys on behalf of the EA, confirms serious siltation impeding flow and reducing flood flow volumes.
• Inadequate size of culverts.
• Lack of riparian owner maintenance, there being many flow obstructions.
• Continued verge collapse as a result of Highways failure to q“bite the bullet” and install sheet metal piling to prevent vehicles entering into the brook and collapsing the verge and causing additional flow retardation.
• Outfall blockages in Cornard Mere (SSSI), into which all flow from Black Brook is received.
Whilst the above issues have severely exacerbated the difficulties experienced locally from flooding and add to the cumulative impact of the overall risk factors pertaining to any development of site SS0220, they represent only one aspect of a much greater and significant risk that any development on this site would generate to the wider community. Mitigation of these much increased exposures are likely to prove exceedingly difficult if not impossible to achieve.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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3B. GROUNDWATER FLOODING
‘The potential ground water flooding events arises when groundwater levels increase to the point where the water table meets the groundwater level and inundates low lying land. The resultant flood impacts may be distant from groundwater discharging locations through developed overland flow paths and increased stream discharges resulting in downstream flooding.’ Page 28 paragraph 3.5 of SWAMP. On two occasions, in 2000 and 2014, elements of the flooding in the area of CO10 0GY can be attributed to these issues. On both occasions water was escaping from the deeply sunken sides of Prospect Hill, which form the boundary of the proposed site, and materially increasing the volume flow along Prospect Hill on its downward journey to join Black Brook.
SWAMP quotes on page 28. ‘Areas most susceptible to groundwater flooding are in locations close to river corridors where groundwater level is likely to remain high’. Black Brook is a head water of the Suffolk Stourand is classed as a main river below the culvert outfall of Prospect Hill.
3C. OTHER ISSUES
Much of Great Cornard has been declared a Critical Drainage Area (CDA). In fact, you could reasonable argue that Great Cornard is one big CDA broken down into smaller zones. This to a large extent is due to the Topography of its location, sitting in the main at the bottom or close to the valley floor. You cannot therefore continue to relentlessly build up the valley sides without the consequence of flooding affecting those buildings on the flood flow paths as water makes its way down the slopes and onto those at the lowest points.
This situation is greatly exacerbated by infrastructure issues. In particular as SWAMP and the Water Cycle study demonstrate, there is no spare capacity locally for extra surface water drainage into sewers or surface water pipes. Indeed, the Anglian Water assets are poorly recorded and in some respects are a complete mystery. BMT within SWAMP have had to make some far reaching assumptions on the local drainage assets. These assumptions may not be appropriate given the paucity of available information and create dangerous reassurance for decision makers who do not know the locality.
Many local residents, with knowledge going back prior to the building of the council estate in Great Cornard, have made statements to the effect that many properties in the general vicinity of the council estate are not served by surface water drainage of any description whatsoever but rely on soakaways. Soakaways degrade over time and are not as effective as dedicated surface water drains. Furthermore, in incidents of area water saturation and high water tables during wet winters, this water must invariably find other means of escape!
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
FLOOD RISK REPORT
Another concerning matter, of huge significance, relates to the Wells Hall Road attenuation basin. This is is a large Anglian Water asset that was intended to hold surface water drainage from the surrounding estate, safely hold it and discharge it over time into Black Brook and prevent local flooding. There is just one problem, it does not work as intended! Despite there having been numerous flood events including the Head Lane, Canhams Road, Nursery Road and Wells Hall Road area and on some occasions, water up to threshold level in Nursery Road and Horse Pond Close, this facility has remained almost dry with no volumes of water observed. We have evidence to this effect from a number of local residents whom have resided in the area for up to 40 plus years. We also refer to the witness statement of Mr R J Barry in this regard.
The cumulative impact of all these issues is of the utmost importance in determining the flood risk this proposal will greatly exacerbate and the impact on the local community. Any decision to include this site in the local plan must not only take all the above points into account but also the following:-
3C1. The numerous infill developments that have been granted planning approval in recent years and their impact on surface water drainage and assets. In one case, development taking up lower catchment flood water capacity. This has taken place since the publication of SWAMP.
3C2. The various material caveats and limitations contained in SWAMP, for ease of reference we append below:-
• Page 15/16. ‘In Great Cornard, a combined stormwater and drainage network has been ASSUMED, except at Pot Kiln Road and the South Eastern corner of the town. Sewer asset information is sparse, of poor quality and the impact of foul flows on the combined system unknown’.
• Page 16. ‘In Great Cornard a lack of data precludes a full (IUD) (fully integrated urban drainage model) model being developed. Instead a VIRTUAL PIPES approach will be used where the surface water drainage is determined solely by highway gullies and does not require pipe assets’.
• Page 19. ‘Very little information is available on the probability, hazard or consequence of local flooding incidents’.
‘Therefore, it is very difficult to use this information to validate claims of flooding or the predictive capabilities of any hydraulic modeling’.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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‘Additionally, a lack of comprehensive groundwater information makes it difficult to predict the location, timing and extent of groundwater flooding’.
• Page 23. ‘Consequently, the designed storm approach tends to UNDERESTIMATE FLOOD PROBABILITIES’.
• Page 30. ‘IT SHOULD ALSO BE NOTED THAT THE ANTECEDENT CONDITIONS OF THE CATCHMENT WERE CONSIDERED TO BE DRY IN ALL MODELLED RETURN PERIOD EVENTS’.
Further significant observations arise from the modelling and historical evidence available from local residents;-
• Page 32. One exceedingly alarming aspect of the flood risk modeling contained on this page arises from the 0.10% AEP (Annual Exceedance Probability) example, (once in one thousand years return period). On two occasions, Mr R J Barry of Horse Pond Close has personally witnessed material elements of this modelled scenario occurring. In Winter 2000 and again in winter 2014. To have witnessed two such events taking place during an elapsed period of only 14 years is testament to the grave underestimation of the flood probabilities utilised within the modelling criteria. These events should not have been witnessed in more than 10 life-times if the modelling results bear any relevant relationship to reality! This graphically demonstrates the under-estimation of the flood risk in this locality. Furthermore, this is supported by the EA flood maps, where again direct evidence confirms that areas indicated as low risk have been repeatedly flooded in Mr R J Barry’s 22 years residence at Horse Pond Close.
• Page 35. This increase is most obvious in topographic low points that have flow obstructions (raised ground downstream) and along valleys due to the ability for flood depths to be greater and/or experience an increase in flood depth and velocity’. (This is exactly the topography that pertains to the immediate area below the proposed site in Prospect Hill, Horse Pond Close and the road junction of Blackhouse Lane and Wells Hall Road).
• It should be remembered that during the flood event of 2014, the water velocity was so great in Wells Hall Road that a significant part of the road on the Western side close to the junction with Blackhouse Lane and Prospect Hill was washed out and remained closed for a long period. The repairs entailed the road to be piled with sheet metal next to the Moat.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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• Page 60. Recommendations. Extensive recommendations for all CDA’s have been made in this report. To our knowledge no material progress has been made on executing any of the recommendations contained within SWAMP.
However, even with the execution of all the specific recommendations that pertain to the locality contained within SWAMP, one overarching point is absolutely fundamental and indisputable - no account whatsoever has been taken of the impact the Woodlands Rise development and the proposed new site SS0220 will have on the already very significant local flood risk. Mitigation of risk means reduction of risk, not complete removal. Therefore, whatever works are completed to mitigate the impact of this new proposed development, a residual risk will always persist that must be considered as cumulative to that what already exists and cannot be removed from the locality, with the possibility of unintended and dangerous consequences.
4. CONCLUSION
Even the most uninformed reader of SWAMP and this document must conclude that the flood risk on the proposed site and the surrounding area (CO10 0GY) is not what has been portrayed within the Land Availability Assessment utilised for the purposes of the production of the Draft Local Plan.
Indeed, any rational analysis of SWAMP must likewise conclude it materially and dangerously underestimates the actual flood risk in the area. This is particularly so given the uncertainty of rapidly accelerating climate change. Building on this proposed site very seriously risks the creation of a devastating exposure of an unacceptable flood risk, not only to private dwelling houses and their residents, but also to a number of critical community infrastructures.
Councillors should remember that the Thomas Gainsborough School and several other child facilities sit on the junction of CDA4 and CDA5 with perhaps as many as 1,500 persons in attendance at peak times, creating a large accumulation of human risk.
We therefore fail to understand how any rational decision can allow the inclusion of site SS0220 in the Local Plan based upon the flood risk alone.
This site must therefore remain outside the final version of the Local Plan due to be published in Summer 2020.
FLOOD RISK REPORT Page 9
Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
FLOOD RISK REPORT
Photograph – Flooding on corner of Wells Hall Road and Blackhouse Lane
Photograph – Flooding on corner of Prospect Hill and footpath, by proposed access point
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
FLOOD RISK REPORT
Photograph – Flooding on corner of Prospect Hill and footpath, by proposed access point
Photograph – Flooding opposite Horse Pond Close, bottom of Prospect Hill.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
FLOOD RISK REPORT
Photograph – Flooding of gardens at Moat Cottage
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
OPEN SPACE REPORT
A. DESCRIPTION
The area proposed for development, listed by Babergh as Site SS0220 and known locally as Kiln Meadows, is valued by walkers, and people are to be seen there at all times.
The area comprises three fields. It is crossed by footpaths affording five access points and is on the route of numerous circular walks of all distances.
We conclude that this area in its present state is truly outstanding in its attractiveness, extent, naturalness, lack of urban clutter, tranquillity and connectedness. It is a beauty spot immediately adjacent to Babergh’s largest populated area and can be accessed without crossing busy roads.
The site has attractive rolling topography, mainly natural grassland, with both level ground and steep slopes; a scene which is varied at every turn. Numerous features including streams, natural hedges and intimate valley settings combine with some wider vistas.
B. REQUIREMENTS OF PLANNING POLICY
“Green infrastructure: A network of multifunctional green space, urban and rural, which is capable of delivering a wide range of environmental and quality of life benefits for local communities.” - The National Planning Policy Framework July 2018, Annex 2, Glossary.
“Access to high quality open spaces and opportunities for sport and recreation can make an important contribution to the health and wellbeing of communities.” - The National Planning Policy Framework July 2018 Paragraph 96 (Quoted in Para 1.1 of the Babergh and Mid Suffolk Open Space Assessment May 2019).
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
OPEN SPACE REPORT
C. PLANNING FOR SUDBURY AND GREAT CORNARD
1. THE PROBLEM
Throughout living memory, sprawling development in Sudbury area has been at the constant expense of the former ready nearby access from houses to green space, school fields and open countryside, and this loss of access land both within the town and on its edges is continuing.
As housing sprawls, most people live further and further away from the riverside meadows and development has swallowed up all the open spaces.
Open spaces: “Scrub, grasslands, wetlands, open and running water, quarries and pits, accessible countryside in urban fringe areas, green corridors.” - typology list of “open spaces that may be of public value” from Planning Policy Guidance Note 17 Planning for Open Space, Sport and Recreation” Para 33.2.
2. BABERGH’S STRATEGY
Para 33.2 of PPG17 above, concludes: “This typology, or variations of it, should be used by local authorities when preparing assessments of need and audits of existing open space and recreational facilities.”
Para 33.3 clearly does not intend those audits to be limited to publicly-owned land. Prior to Babergh’s recent audit, we repeatedly asked for all land meeting the typology to be included around towns, despite which only certain local authority land designated access land was included.
The land figuring in the audit includes a lot of straggles between houses, cemeteries, small steep greens, slopes above roads and amenity areas far from any habitation. This does not meet the definition of Green Infrastructure in the Glossary of the NPPF. Even including these, Babergh’s report admits there is a shortfall, especially in the urban areas.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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Babergh’s Draft Joint Local Plan advises that the only opportunities for creating open spaces are likely to be within housing developments. However, we put it that this wrongly excludes the government requirement for substantial natural land and should not be the default position for Babergh’s largest urban area. We argue that taking this as a default position would be to preclude the requirement to implement the NPPF, so that a Land Allocation at this site before creating a plan for Green Infrastructure would be premature.
An accepted formulation of land needed for urban populations has been produced by Natural England:
- no person should live more than 300m from their nearest area of natural greenspace; - there should be at least one accessible 20ha site within 2km from home; - there should be one accessible 100ha site within 5km; - there should be one accessible 500ha site within 10km.
However, the 2010 Landscape Partnership report for Natural England “Analysis of Accessible Natural Greenspace (ANG) Provision for Suffolk” tells us:
- Table 1: Forest Heath has the largest proportion of its area made up by ANG at 13.5%, Babergh and Mid Suffolk have the lowest at 1% - Table 2: Suffolk has a lower proportion of its population meeting all the ANG standards in comparison to Hertfordshire and Essex, and the highest proportion meeting none of the ANG standards when compared to the other counties. - Table 3: In Suffolk, At 51.2% Babergh has the second highest proportion of households meeting none of the ANG standards.
This examination calls into question the statement in 1.6.1 of the 2019 “Babergh & Mid-Suffolk Open Space Assessment”, that “the [Babergh] district is also recognised for its value with a wealth of designated areas from SSSIs, AONBs to listed buildings and conservation areas to name a few.”
We put it that Babergh’s approach is negligent and not strategic; “achieving open space” by just allocating a set proportion of new developments. It may cater for people living on that development, but it deprives the wider community who previously enjoyed that land.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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In 2019 Babergh commissioned the Ethos Environmental Planning “Open Space Study”, which states in Para 8.2 “Existing provision to be protected: The starting point of any policy adopted by the Council should be that all open space should be afforded protection unless it can be proved it is not required. Even where open spaces are in sufficient supply within a Parish, this does not necessarily mean there is a ‘surplus’ in provision of open space, as additional factors such as the supply of other typologies of open space, the quality of open space and where new development is planned, needs to be taken into account.” The total figures for open spaces in this Study count all accessible land - not just officially designated Open Space - even where it is only visible from a footpath.
In 2012, Babergh stated it’s “vision” in “A Green Infrastructure Framework for Babergh District”: “Future provision, enhancement and management of green infrastructure will seek to maximise the connectivity and potential of the wealth of multi-functional green infrastructure throughout the district. Green Infrastructure will be enhanced and managed to ensure there is a well- connected green infrastructure network for the benefit of all interests and communities that the spaces intend to serve, throughout the district….. Promote health and well-being by encouraging active exercise, enhancing recreation and amenity opportunities and encourage contact with nature.”
However, note that the document went on to reject the established principle of setting any standards (e.g. the ANG standards) and principles like “linking, extending and creating important BAP habitats” were in reality unambitious, and the result would have been negligible. The document proposed a “Green Arc” for Sudbury area - which development at SS0220 would cut across - but it was a narrow strip mostly far out in the arable hinterland.
3. NEED FOR A PLAN
Present policy is, to wait and see what planning applications come in, and then reserve bits of those sites.
However, we ask Babergh to follow a more proactive policy and be more precise about how it intends to meet its Core Policies. Will the future be tokenistic small straggles with a pastiche of engineered paths, mown grass and planted trees, or will it genuinely preserve the last and best of Great Cornard’s countryside? With those questions in mind, we invite a reading of Babergh’s Core Strategies, and ask whether they are simply too vague and meaningless:
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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- CS5 - dealing with strategic growth in Great Cornard: “Ensure development incorporates a green infrastructure framework connecting, adding or extending formal and informal green spaces ….” - CS14 - The introduction to CS14: “3.3.9.2 A good network of multi-functional green infrastructure within and between urban and rural areas should aim to achieve the following; • i) Create links which connect existing spaces to each other especially close to areas where people live and work …. • iv) Promote healthy living by providing opportunities for exercise; • v) Improve access and recreation opportunities …. • vi) Enhance links from urban areas to the countryside …. • viii) Make a positive contribution to creating a sense of place …. Greenfield sites and those within or close to sensitive landscapes will be particularly important”. - CS15 - “Proposals for development should …. • ii) make a positive contribution to the local character, shape and scale of the area …. • ix) make provision for open space, amenity, leisure and play through providing, enhancing and contributing to the green infrastructure of the district; • x) create green spaces and / or extend existing green infrastructure to provide opportunities for exercise and access to shady outdoor space within new developments”.
We respond to the question “will Babergh truly meet the aims of its Core Policies?” by reference to Chilton Woods at Sudbury, which we are constantly told is “50% green space” - but this space includes extensive sports pitches and car parking, and is mostly bare flat arable land devoid of interest.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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4. ASSESSMENT OF SITE SS0220
We object that Babergh’s 2019 SHELAA document identifies the “constraints that would require further investigation” only as: Highways, Heritage - potential impact, Contaminated land, and Flood. As this site we believe presents one of the best assets in the Sudbury area, adjacent to the main urban area and where people live, an assessment of the spatial value of this land will certainly be needed.
In October 2019, knocking on doors revealed only two people out of about 70 adjacent residents were aware of even the possibility of a development and none knew that a plan had been submitted and even one who had found SS0220 and objected in the consultation. Despite the Local Plan consultations since 2017, some believed the intention was still to create a nature reserve.
One resident later wrote to say "Yesterday we heard from a neighbour that the land adjacent to our house has been included in the Local Plan. I have since spoken to the Parish Council Manager who informed me that even the Parish Council were not aware of this as it was represented under Chilton (falsely). My husband and I went to the open day about the Local Plan, but no mention of this so we could not have the correct information to give our views."
D. VALUE OF THE SITE
The attributes of this land are key for the quality of:
- Great Cornard Parish Council’s aspirations for a Green Arc connecting the Country Park, Woodland Rise Natural Area and Linear Park, and Shawlands Local Nature Reserve; - Sudbury Town Council’s remit for completing the Gainsborough Trail; - The Dedham Vale AONB’s application for an extension, on landscape, public enjoyment and biodiversity.
The land here is important as access for local people to unspoilt countryside, evidenced by:
- its use by walkers at all times; - comments and photos of local people, shown in this statement and Annex 1 below; - record public attendances at meetings to oppose development here, of the Parish Council and the Cornards Residents Association;
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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- the official path between the houses at the west end to Prospect Hill, as opposed to the other paths here, provides a chilling foretaste of the landscape loss this development would constitute. Such metalled paths would be a sorry, suburban feature.
The urban area has a large and growing population - Great Cornard 8,908 and Sudbury 13,063.
The site is served from the adjacent housing areas via three public footpaths.
The site has the advantage of car parking, at the allotments.
With the nearby Country Park, Woodland Rise access land, and Shawlands Local Nature Reserve, the area is relatively well served by open green space. However that has to be set against the general deficiency of open space in the Sudbury and Cornard built up areas and of accessible natural green space in Babergh generally.
The 2019 Ethos Environmental Planning goes on to say: “Existing open space or sport and recreation facilities which should be given the highest level of protection by the planning system are those which are either:
- Critically important in avoiding deficiencies in accessibility, quality or quantity and scored highly in the value assessment; or - Of particular nature conservation, historical or cultural value ….
Sites which have significant nature conservation, historical or cultural value should be afforded protection, even if there is an identified surplus in quality, quantity or access in that local area.
Factors/criteria which may make a space locally distinctive include the presence of:
- natural features of ecological value (such as ponds and streams); - protected and rare species; - Tree Preservation Orders; - archaeological features; - a connection with a historic event or person of historic significance; and its importance to the setting of Listed buildings or a Conservation Area(s).
We are clear that the reports which we are submitting for Site SS0220, give abundant reasons for giving this “highest level of protection”.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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ANNEX 1
Comments from some local residents:
“As for the three fields this proposal would destroy, it would be a tragedy for the local wildlife. Being retired, I see the amount of people that use the proposed access area to walk their dogs and families all gaining access to the walks around and through the fields. We should preserve the last remaining area around Cornard Wood, being an area of outstanding natural beauty.” - Brian Nutt
“This is the view we wake up to every morning, although not always with this amazing sunrise. I think from this you will completely understand why we feel so passionately about this area.” - Andy Broomfield
“The area seems to be a very important spot for wildlife. We regularly see the barn owls hunting over the fields at the back and almost every night we also hear a tawny owl somewhere in the fields out there. We have hedgehogs visit our garden regularly and have caught foxes and deer on our CCTV camera's which look out onto the field. There are skylarks, bats, sparrow hawks, buzzards and kestrels. It seems such an important area for wildlife, not to mention the fact that it is a beautiful spot that is very widely used by walkers from all around the village. You can imagine how devastated we are that it could all be ruined. I don't think there are many areas around here which are not farmed and have been left so natural and you can see by doing this, how it has had a huge positive effect on wildlife. I grew up on a farm in the 1970s and when I moved to Chaplin Walk three years ago, for the first time I saw species which I had not seen since my childhood.” - Sarah Gage
“We are absolutely gutted at the thought of losing our beautiful countryside.” - Sara Edwards
“I am saddened and greatly annoyed that the 'onward march of progress' appears to be compromising yet another fragment of our dwindling wildlife habitat.” - Adrian Walters
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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Photographs – Open space on the proposed development site.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
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Photographs – Open space on the proposed development site.
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RESEARCH NOTES FOR CORNARD/ABBAS HALL LANDSCAPE
Introduction These notes have been prepared on a voluntary basis by a retired Landscape Architect with a special interest in historic landscapes in order to provide background information to aid the understanding and correct evaluation of the area of land proposed for development as SHELAA SS0220: facts and opinions expressed are extra-professional and not subject to liability.
The information given is based on a short, curtailed desk-top study, including two visits to the Suffolk Record Office at Bury St Edmunds, plus four site visits in which access was limited to public footpaths and the gardens of Abbas Hall. Both the desk-top study and the site survey must therefore be regarded as incomplete.
(The notes consist of general information on the physical characteristics and landscape history of the wider Cornard area in order to set the proposed development site in context, followed by more detailed comments on the individual areas of the SHELAA site. Finally, a section is included on certain aspects of the Gainsborough connection.
(Map reproduced by permission of the Ordnance Survey)
Location, Physical Geography and Geology
Cornard is situated on the eastern bank of the River Stour immediately south of Sudbury (Suffolk). Much of the parish, that nearer the river, lies on low, undulating ground formed by terraces of river gravels plus other sediments, overlying chalk. Further east the land rises suddenly up onto the mainly clay plateau beyond, forming a low but steep escarpment facing west and north-west as it curves first south, then south-west almost to the river. The plateau bedrock is Thames Formation (London Clay, etc) but this is overlain here by glacial moraine deposits (Boulder Clay) giving a fertile but often heavy and slow-draining chalky till.
Along the foot of the scarp runs the Black Brook flowing south and west to the Stour. It collects the water from numerous small streams draining the plateau above and, to a lesser extent, from the lower lands to the north-west. The wisdom of building houses within what must be regarded as the floodplain of this small stream seems questionable especially as future peak flows are now more difficult to predict. The drainage arrangements for the extensive housing developments to the north and west have not been investigated but it is noted that the overflow from the site currently under construction is already entering the Black Brook. There are existing properties downstream which could be vulnerable, and old-fashioned solutions such as culverting or hard containment schemes would be unacceptably damaging to the environment here, both aesthetically and ecologically.
This line along the foot of the scarp marks a geological boundary – due to the abrupt change in level quite different beds are exposed on either side. The geology of this small area is remarkably complex and further detail would probably be confusing here, though relevant comments may be made later in the text in relation to specific parts of the proposed site: visit the British Geological Survey's 'Geology of Britain Viewer' for maps and further information. One point, however, should be noted here: much of the stream valley's bottom and lower slopes are covered by 'Head', ie relatively uncompacted detrital material which has slipped/crept or been washed down from further upslope and which is inherently unstable. This process will have been accelerated by the clearance of trees and shrubs from most of the scarp and by ploughing, and is likely to be on-going. Is building houses in such a location wise?
Landscape History
The area around Cornard was subjected to several phases of glacial/periglacial activity during the ice-ages, and the River Stour would have carried a vast flow of melt-water in the post-glacial period. As the ice retreated and conditions improved prehistoric man would have returned to the area, first on hunting visits, then to stay. For most of England's history rivers and their valleys were the highways of the country, connecting the interior with the surrounding seas and the world beyond. Thus the location of Cornard beside the River Stour would have encouraged early post- glacial access to this area both by water and on foot up the valley. Scattered archaeological finds indicate at least a passing presence of man in prehistoric times, and there are signs of minor settlement from the Iron-Age and Roman times onward. For most of its history the Stour probably carried more water than today and was less under man's control, so earlier routes and settlement may have been further from the river than now. Early settlement might well have focused on riverside activities with forays further inland for hunting/gathering, but with the advent of farming there would have been an increasing reliance on agricultural produce. Cultivation would probably have been initially on the lighter soils on sands and gravels, but was later extended onto the heavier clay soils of the plateau lands once the heavier Iron-Age/Roman ploughs came into use. The piecemeal clearance of the original post-glacial woodland for the first agriculture produced small irregular-shaped fields: later Roman ones were also small but tended to be more planned and regular in shape (local conditions permitting). Astonishingly, quite a few of these small, ancient fields managed to survive in places until the mid-20th century, and although then obliterated at ground level by the wholesale removal of hedgerows to accommodate ever-larger agricultural machinery, their ghostly lines may still sometimes be seen on aerial photography.
From Roman times onwards (and probably earlier) the Stour valley provided an access route for seaborne raiders from the continent, first the Anglo-Saxons who in time became settlers, and later the Vikings. The developing population must frequently have feared for both lives and possessions, with the riverside area being most vulnerable. Countering this risk would have required early warning from a system of watch-towers and beacons plus centralised control based in a fortified manor complex. In Saxon times the main Cornard manor was the one later known as Abbas Hall
Manor. The site of Abbas Hall on high ground in the eastern part of the manor distanced it from the river and gave extensive views of the valley and the surrounding countryside: it's possible therefore that the earliest Cornard Manor could have been defensive in origin. A glance at aerial photography shows that the Abbas Hall area has a distinctive character making it stand out in the landscape: there is a tendency for the lines of field boundaries, roads and paths to wrap around it like enclosures, perhaps reflecting the lines of an early manor demesne. There is, however, also the possibility that some of these lines could be the ghosts of ancient defensive features. One in particular is the curved line on the scarp south-west of Abbas Hall wood, where a sharp drop in level separates Tithe Map plot 169 from the land below: this could be a medieval plough lynchet, or an old path cut into the slope, or maybe geological, relating to selective quarrying, or indeed to any combination of these over time. It could, however, also have had an even earlier origin as the remains of a defensive earth-work. Note that a SEAX reference, so far untraced, mentions a circular earthwork within the present-day Abbas Hall Wood which may now perhaps be confirmed by a clear circle showing on modern LIDAR data. There are also unidentified ground-marks close by in the field called Crab Hill (plot 190) on the Tithe map (above SHELAA Area A) though these may well be due to modern agricultural features.
Sudbury, sited on a hill in a loop of the Stour, was in a strategic position to control movement on the river and up and down both sides of the valley. From a first-known farming settlement in the early Bronze-Age it developed into a fortified centre in the Iron-Age, maintained a presence in Roman times and continued through the Anglo-Saxon period, being first mentioned by name as Sudbury in 797/8 in the Anglo-Saxon Chronicle. During the latter part of the Anglo-Saxon period the raiding Danes had become settlers, taking control of large areas of England (the 'Danelaw'). Sudbury must at times have been close to the war-zone between the Danes and the Anglo-Saxons and by the 10thC it had developed into a substantial fortified town. Meanwhile, nearby Cornard, closely tied to Sudbury economically, had become a significant farming area supplying food to the town's population (and possibly also exporting surplus grain by river). The name Cornard appears in the Domesday Survey (1086) as Cornierda/Cornerda which is Anglo-Saxon for 'corn-earth', corn being a general term for grain crops and earth meaning land. At that time self-sufficient mixed farming was the norm and every farm would grow some grain, so for a place to be singled out as 'corn-land' indicates an unusual degree of specialisation. This in turn implies extensive arable cultivation and therefore wholesale clearance of woodland from much of the land suitable for ploughing. It's possible that by Domesday the only woodland surviving might have been confined to steep slopes which were difficult to plough, plus the manor 'homewoods', ie the woods close to the manor hall which provided shelter, timber/wood and if large enough a food hunting resource. In time the complex local geology probably meant some areas of soil would prove to be unsuitable for sustained arable use and these would be left to revert to secondary woodland and pasture, often combined as 'wood-pasture', a management system that entails certain compromises but offers useful flexibility. At times even good arable land would fall out of cultivation as the price of corn fluctuated through the centuries, or as increases in the value of wool fuelled large-scale conversion to sheep pastures. Periods of population growth led to increased pressure for land, while plagues and wars had the reverse effect, with land reverting to scrub and secondary woodland. The landscape was not static but changing and adjusting throughout the centuries, sometimes only very slowly but at other times abruptly and with perhaps serious consequences for both land and people.
By the time of the Norman invasion, Anglo-Saxon Cornard was divided into one main manor plus several sub-manors/small estates (not unusual in Suffolk) with lands held by both overlords and freemen and, in the case of a single meadow, by the Abbey at Bury St Edmunds. The Normans' 1086 Domesday Book records three Anglo-Saxon landholders whose lands were given to William's followers, though the king did hold on to the main Great Cornard Manor for some time (and the Abbey kept its meadow). In 1086 the main manor comprised a substantial settlement of 44 households (10 villagers, 25 smallholders and 9 slaves); ploughland employing 11 plough-teams (oxen) suggesting at a rough estimate c1320 acres of arable land; 14acres of meadow; woodland for
10 pigs (not much); 1 mill and 1 church. The livestock totalled 18 cattle, 80 pigs, 383 sheep and 4 other (probably horses): the animals (including most of the pigs) would have grazed the commons (called 'waste' but very important in the manor economy) and also, at carefully regulated times the arable fields, their manure being essential to maintain fertility. The large number of sheep would have been supplying wool to the merchants and weavers of the prosperous local textile industries. Note that the small area of woodland listed would have been augmented by trees and scrub on the waste, including common wood-pasture. In Domesday terms 44 households made Great Cornard a large settlement, and in the absence of any evidence of expansion on the Abbas Hall site it must be assumed that the population had dispersed into the countryside, with a small village centre focussed on the riverside and the road to Sudbury. The locations of the church and mill listed in Domesday are unknown. A standard Anglo-Saxon manor would have had its church within the enclosed manor complex on the hill and this may be the one referred to: on the other hand, as there were c150 years of relative peace between the unification of England following the defeat of the Danes, and the Norman invasion, it's possible a new Anglo-Saxon church was built in the settlement developing down by the river and this might be the Domesday church, later to be replaced in the 13/14thC by the present parish church built by the Normans. The mill is, on balance, most likely to have been a riverside watermill.
The other significant manor listed in Domesday Cornard was probably Little Cornard Manor at Peacock Hall: this comprised 17 households (2 freemen, 11 smallholders, and 4 slaves); 3 plough- teams (c360 acres of arable land); 8 acres of meadow; woodland for 30 pigs; 4 cattle, 30 pigs and 110sheep; and 1 church. Note relatively more woodland, and again a good number of sheep.
These two Cornard manors were given by William to different followers, but were soon united by marriage/inheritance and over the centuries probably absorbed many, though not all, of the smaller holdings. Under Norman feudal control, both manors would have been strictly managed in an organised open-field system involving large, common (ie shared) arable fields cultivated in strips, with livestock grazing common pastures, waste and woodland. Great Cornard Manor was known as Abbas Hall Manor after it was gifted to the Convent of West Malling in Kent at the end of the C13th, with the present-day Abbas Hall being built at around the same time, presumably on or near the site of the original Saxon manor. It's possible the new hall was occupied by a bailiff in the convent's employ who would have continued to run the manor in the same way, including controlling every aspect of agriculture and land-use through the manor court. However, it's also possible that the whole Manor was let on a long lease to a tenant who would then have held the powers of the lord of the manor and may or may not have occupied the Hall.
The population of England grew through Saxon and Norman times until the early C14th, eventually putting pressure on land resources: the area of arable land had to be extended, and the common waste and woodland were diminished by squatting and assarting (the clearance of small plots of land for cultivation, often on the margins of the parish). This pressure was relieved, horrifically, by the Black Death which so reduced the population that it took until the end of the Tudor period to recover its former level. Many areas of England experienced problems of labour shortage which caused some land to drop out of cultivation, but it's possible Cornard was cushioned to some extent by its sheep – with the local wool and textile industries thriving, demand for fleeces must have been increasing and sheep husbandry required fewer men than arable cultivation. One of the incidental effects of relatively high numbers of sheep was that the very large open arable fields had to be divided up for proper animal management (they were grazed on common pasture/waste but folded in the arable fields at night when crops allowed, in order to drop their manure).
The Late Medieval feudal landscape of Cornard would have been dominated by very large open- fields, farmed in common. Those up on the clay plateau in the east would probably have been in more or less permanent arable cultivation, while those on the lower land are likely to have included both arable and pastoral farming, the relative areas adjusting as the prices of corn and fleeces varied. Any subdivisions necessary to control animals would have been temporary fences rather than hedges, which were probably confined to the field perimeters and to lining roadsides and some paths (especially 'holloways', where the stability of the sides is dependant on the hedgerow roots). Many old hedgerows were remnants of ancient woodland, which probably also survived as a substantial strip along the escarpment and to an unknown extent on the clay plateau. There would also have been wider belts of hedgerow in places, managed as coppice rows to provide the wood necessary for fencing, building, tools and firewood etc. Other land in the parish, especially marginal land, would have been common 'waste', a mixture of rough grazing and woodland/woodland- pasture, some of which would have shifted in and out of cultivation in response to parish needs and population/market pressures. Meadow was a separate, valuable category of land important for the early spring grazing of ewes and lambs: it lay on wetter land beside streams and on areas of seepage on hillsides, plus in Cornard as larger meadows beside the River Stour.
By the middle of the C16th the wool trade was in decline, while an increasingly sophisticated economy/society was creating new demands to be met and new opportunities to be exploited. Manorial self-sufficiency gave way increasingly to external market forces, which required quicker responses to changing conditions. The rigid controls of common-field agriculture were simply not flexible enough to cope: holders of land began rearranging their scattered open-field strips into clumps which could be fenced if necessary and allowed more farming independence. In some places this turned into a movement for wholesale enclosure but as there were legal rights involved this often required the consent of parliament in a formal enclosure act: this, however, was expensive, and a cheaper alternative was by a legal agreement between all landowners. The amount of newly enclosed land allotted to each person was determined by how much land they already held in the parish: sometimes everyone benefited from enclosure, but the largest landowners had most power, and if they were unscrupulous then the lesser folk suffered. At first it was mainly the open- fields which were enclosed: most commons and wastes were still available for common rights. However, agricultural improvements accelerated, especially in the second half of the C18th, provoking a new wave of enclosures.
It's not clear exactly when Cornard's open-fields were enclosed but it appears it was not early. Surviving Court Books for Abbas Hall Manor record the transfer of rights to land from one generation to the next between 1624 and 1785. Entries as late as the 1770's were still referring to pieces, parcels or acres held in the common fields, and it's clear from the location details given that at least some of these strips were still scattered across an open-field. It may be that some larger landowners had already agreed to enclose some or all of their lands but that those who held only a little land found it more practical to continue farming communally: further research might clarify this.
These manor records of land-holding, when combined with the field names shown on the later Tithe Map, allow some of the open-fields to be identified, including one called Brookfield which appears to have lain in the area SE of Canham Road and NE of Chapel Lane. The 1838 Tithe Map shows three fields named Brook Field (plot nos.212,213,217) within this area, and the old sunken way which separates Areas A and C is named as 'Brooke Field Lane' on the 1813 Enclosure Map. The SE boundary of Brookfield may have been the Black Brook itself, or it could even have extended across the brook to include at least the lower part of Area A (Tower Hill). Brookfield's NE boundary, from Canham Road to the Black Brook, once separated the open-field from a large wedge-shaped area of common waste which at the time of enclosure ran from a narrow base at Area C north-west through the middle of the parish. This boundary probably varied over time as land was taken in and out of cultivation from the waste as required. Brookfield may have been developed later than the earlier open-fields to the north and west: the name itself occurs in documents from 1703 (though research is so far incomplete).
The very first Ordnance Survey of this area was carried out in 1799 at a scale of 2 inches to the mile and the original surveyors' drawings are available online: fields are marked, not necessarily accurately but probably giving a good indication of the land enclosed by that date. Some smallish areas of open common/waste can still be seen among the fields but most striking is a huge area between Canham Road and Cat Lane that is shown as open land, with quarrying apparent at least in the northern section. Brooke Field Lane continues beyond the brook as an unfenced track/road curving north-west across still open land to join Canham Road. A similar track runs beside the brook from Wrongs Farm to Kiln Farm and the eastern corner of Area B (Kiln Field). The map also shows two interesting features in the Abbas Hall landscape at this date which though short-lived are probably correct (within the limitations of the map). The only access shown to Abbas Hall ran north from the Hall to Tye Farm at Cornard Tye, and then on across the A134 to Chilton Hall and church, possibly as an easier route for carriages: there is no sign of the present drive up to the Hall, though there must have been a footpath linking Abbas Hall to the village/church. The 1799 drive is not shown on the 1813 Enclosure Map but is marked, though less prominently, on the 1838 Tithe Map as a track following field edges. The second significant feature is how Abbas Hall Wood is shown in 1799. Compared with Hodkinson's 1783 map the wood is much smaller, square in shape, and lies to the south of the Hall: moreover, it is actually separated from the Hall and its environs by what appears to be an agricultural field.
In many parishes in England the open-fields had been long enclosed but not the commons and waste. The removal of the common rights on which many depended for their living, especially the poorest in the village, was more contentious and complicated: it was also expensive. A cottager with a small plot and the right to graze his animals on the waste could have a degree of independence, but the costs of enclosure might oblige him to sell his tiny share of the waste (his allotment) to a larger landowner and either become a paid farm labourer or leave the village and look for work in the towns. In the early C19th there were many parliamentary acts of enclosure for just the commons and wastes, and Cornard's Enclosure Act of 1813 was one of them. An accurate detailed survey was made of Great Cornard, Chilton and Great Waldingfield, and the three parishes appear together on the same 1813 Enclosure Map. What it shows is an agricultural area with a small population in a dispersed settlement pattern. There is no real village: the church is in no way central and has only a few buildings around it; Mill Tye is a little larger and industry-based; otherwise there is a thin scatter of farms and isolated cottages, and some widely-spaced linear settlement along the Bures road.
The landscape revealed in 1813 is on the point of change. Much of it is ancient, with features dating back hundreds, or even thousands of years, and was made by people who had never seen a map and had little concept of a 'birds-eye view'. They responded to the land itself, as seen from ground level - the topography, soils, drainage, shelter and sun. The old fields were made in irregular, sometimes strange shapes, whose logic is now often hidden from us, but it was not irrational. The old road system seems bizarre seen on a map but look closely and you will see the lines of earlier roads fallen out of use, and new connections made. It had developed and changed as best it could in response to the needs of each generation. With only manual labour available a rural community does not lightly embark on large-scale road building. The ancient landscape is formed by centuries of history overlain one on top of the other. Here in Cornard there are rare survivals of this past, especially on hilly terrain and towards the margins of the parish. There are wonderful ancient sunken lanes, fragile in nature, and so vulnerable to modern traffic and 'improvements' – their historical value is equal to that of Listed Buildings and they need more protection. In time roads and field boundaries get straightened by people who always use rulers or the computer's equivalent, while modern developments obliterate almost everything. When changes to the landscape were made by men with shovels and carts then destruction was slow and and allowed time for reflection. Today, one man with a large machine can remove a thousand years of history in a days work, and neither he, nor those who gave him orders, will know what they have done.
The Enclosure Map shows the contrast between the irregular ancient fields and the straight lines of the allotments drawn up by surveyors. The common land being enclosed is divided up into allotments of various sizes, each outlined in colour and marked with the name of the recipient and the area of the piece: all other fields are outlined in monochrome and carry just the owner's name. The land being enclosed included any land still held in common, and could be woodland/wood pasture or meadow as well as open grazing. The largest area marked for enclosure is the wedge of land running right through the middle of the parish, widening as it goes from a narrow base at the proposed SHELAA site (Area B) in the south-east, to the parish boundary on Cat Lane (called Kiln Lane on this map) in the north-west. Area B itself is an allotment of 2acres 1rod 38perches (c2.5ac)being made to William Taylor and must therefore have been part of the common waste until 1813. North-west of it is the open-field area of Brookfield with some waste to the east. All this area, and that to the north-west of it, has been divided into good field-sized allotments, mostly made to the owners of adjacent farms. Clusters of the smallest allotments are located towards the edges of the parish, in many cases probably too far from the recipients' homes and animals to be practical in use. Such plots were then often bought up by near-by landowners, or perhaps exchanged for other land: a comparison between the 1813 Enclosure Map and the 1838 Tithe Map shows how the farming landscape had been 'rationalised' .
One of the areas of small allotments lies on the steep southern slopes of Prospect Hill and consists of a number of narrow strips running downhill: these would have been common woodland/wood- pasture and ran downslope to give each holder a share of varying soil types, drainage conditions and possibly minerals (arable strips would have lain at right-angles to the slope). This part of the original map is crumpled and some detail is missing/hidden, but it does look as though two of the strips may still have been tree-covered in 1813 and clearly are on the 1838 Tithe Map. Area C of the proposed SHELAA shows what could be the relics of further strips, on land taken out of the waste at an earlier time. Area A (Tower Field) lies between these two areas and was also probably once wooded but its more gentle lower slopes would have allowed conversion to arable use, perhaps with some meadow beside the brook. The track shown on the 1799 drawings from Wrongs Farm along the north-west edge of Area A is not present on the Enclosure MapThe 1838 Tithe Map shows all land divided into fields and plots, including gardens, each with a number. An accompanying schedule gives details for each piece of land, including the owner, the occupier, the name of the plot, its size and the land-use. Many of the names provide additional information about the land, such as crops grown, the nature of the soil or ground conditions, past history etc: collectively they can tell us a great deal about the rural landscape of the time. The following plot names occur in and around the proposed SHELAA site:-
Area A 276 Tower Hill - possibly an earlier name for Prospect Hill, could refer to a past tower windmill somewhere on the hill above, or even the remains/memory of an ancient watchtower. 277 Middle Hill – the field up-slope from 276, separated from it by what may be an ancient plough lynchet or perhaps an old routeway cut into the side of the slope by long usage.
Area B 206a Kiln Field - one of several fields in the vicinity with 'Kiln' in their name, this field could well have been the site of possibly a succession of small kilns, perhaps early ones, or it could have been used to extract the minerals needed for bricks or pottery (suitable geology): the brook could have supplied the necessary water, and the adjacent woods and wasteland the fuel. 205a Further Kiln Lay (adjacent to Area B, to the north) – a piece of land associated with a kiln, but by then sown with grass: uneven topography/ponds suggest previous excavation for kilns/materials.
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Area C An area of small, mostly irregularly-shaped plots presumed to have been previously taken out of the waste by assarting. The plot names on the Tithe Map show the occupants diversifying activities in response to economic pressures/opportunities. 195 Grays Lane Field - this plot lies alongside the Enclosure Map's 'Brook Field Lane' which must presumably have changed its name once the open-field 'Brookfield' ceased to exist. Grays Lane leads uphill to Greys Hall and estates: the de Grais family were Norman and were associated with Cornard for hundreds of years. 200 First Kiln Field – a plot connected with the kiln activity in the past but by 1838 under arable cultivation. 203 Further Kiln Field – as above. 199 Old Orchard – once producing fruit probably for both domestic and commercial consumption, but in arable cultivation by 1838. 202 Cottage and Garden – this must be the late 16th C building Listed Grade II as 'Kiln Farm' in 1998 and subsequently burnt down. Originally a small cottage, it was extended c1700 and divided into three properties, then converted back into a single house in 1967. 201 Barn and Yards – the barn, which was large, lay beside the brook and track that separate Area C from Area B. It is marked on both the Enclosure and Tithe Maps, and also on the 1799 OS surveyors' drawing. It may have been a substantial building associated with the kiln works (bricks/pottery need large covered storage areas while drying prior to firing) or it could have been an earlier, larger farmhouse downgraded to a barn, or finally, it might even have been an old parish tithe-barn, especially as the Enclosure Map shows nearby land (Tithe Map plots 205a – Further Kiln Lay; 206 – Middle Kiln Lay; and 205 – Upper Kiln Lay) all held by a clergyman, the Rev. J Wallace who also held 'Wrongs Farm' and land, including Area A (Tower Field and Middle Field) and land abutting Area B. In 1838 the same land was held by another clergyman, the Rev. Robert Eden, suggesting it was Glebe land. This merits further investigation, especially as it lies close to the presumed original site of Great Cornard Manor at Abbas Hall. 174 Hop Ground, and 204 Old Hop Ground – legislation in 1710 required beer to be flavoured with real hops, not substitutes, stimulating production: hops became a lucrative but demanding crop which could be intensively farmed on a small plot to supply local brewers, provided conditions were right: it needed a fertile soil, hence the change of plot here. 198 Ash Ground – an area probably planted as a single species coppice of ash, a fast-growing tree producing strong, flexible wood with a multitude of uses on the farm and commercially (including the necessary hop-poles). Coppice trees are cut to near ground level at various intervals of years to give multi-stem poles of varying sizes as required: the coppice stools grow larger and more productive over time and can be extremely long-lived: rare specimens are believed to be as much as three thousand years old and will be the oldest living things in their landscape. Old coppice trees are rarely recognised or protected, and may be denied Tree Preservation Order status. The age of this coppice is so far unknown. 196 Osier Ground – another area of coppice, of shrubby willow such as Salix viminalis, cut early and frequently to yield long, young, flexible shoots (withies) for basket-making, a cottage industry for the poor. 197 Rye Field – implies less good soil/conditions 178 Mesely Field – an interesting name with complex associations. It might mean the field was just of generally poor, unproductive quality, but it could also be used more specifically, to describe land infested by tape-worm lavae which infected pigs making their skins 'measly' with sores and their meat less safe to eat: such land was often heavy, poorly-drained and contaminated by human sewage. The name could also mean land associated with lepers ('measly' was an early word for lepers, derived from Latin 'misere' for misery, and later used for modern measles and other skin diseases with disfiguring sores in humans and animals). However, the more likely, and pleasant, explanation would be that the field was often used to grow 'meslin', a mix of wheat and rye grain sown together as it produced a better crop in marginal conditions: used from at least medieval times to the 20thC.
190 Crab Hill – this field sits immediately uphill from Area C and is the location of some recently noticed ground-marks which might merit investigation. The name suggests the field may at some time have grown wild crab apple trees as root stock for cultivated varieties, or was perhaps an orchard of cider apples.
The 1885 6”OS map (pub.1887) shows a small gravel pit in the NW corner of Kiln Field (Area B) and the big barn on the edge of Area C has gone. Neither 'Osier Ground nor Ash Ground are shown as woods but this could be because they had been recently coppiced rather than cleared. On the 1902 OS map (pub. 1904) the Kiln Field gravel pit is no longer shown and had presumably been filled in. The railway was present, running alongside the river. The Cornard landscape remained sparsely populated and overwhelmingly agricultural, with industrial features largely limited to chalk quarrying in the north, two areas of brick kilns, and milling and associated minor industries by the river.
This 19thC rural landscape continued into the 20thC with little change until after the second world war apart from the tarmacking of roads and some small-scale building along the road from Sudbury south as far as Mill Road. The insertion of large post-war housing estates into such a small settlement in the 1950/60's began to change its character, though only in the north of the parish at first. Built to take London overspill, they were sited close to the south edge of Sudbury as it was thought the new inhabitants would feel more at home near a town. In the later decades of the 20thC these estates were followed by a series of individual private developments, often seemingly little related to each other. Housing has now spread south and east until it has covered all the lower-lying ground, destroying much of the historic rural landscape of Great Cornard.
SHELAA Site 0220 and its Setting
This area of the Cornard landscape is of great interest and value for many reasons – aesthetic, geological, historical/archaeological, as wildlife habitat and as a fine piece of accessible countryside on the edge of the already extensive settlement of Great Cornard. To these qualities may be added the Gainsborough/Cornard Wood connection and the fact that the land is part of the wider setting and historical context of a Grade 1 Listed Building, Abbas Hall.
The proposed development site sits where the lower ground beside the Stour rises sharply up onto the plateau inland. At the foot of this scarp is a stream which marks a geological boundary: the proposed site covers part of the bottom of this stream valley plus the lower and middle slopes of the hillside. There are three distinct areas to this land (A,B and C) and each has its own interest and beauty, but collectively they are a gem, a small, rare piece of surviving ancient landscape, a relic of a fast-disappearing world.
Area A, the arable field to the SW, has probably long been cultivated, at least in the upper part where an abrupt break of slope plus hedgerow remnants has the look of an old plough lynchet separating it from the field above (there are other possible explanations for this feature). At the bottom of the field the remains of old coppice rows line the stream, and in earlier times the lower slopes may well have been meadow/pasture. The chief value in the landscape here, however, lies in the beauty of its landform, in the swelling curve of the hillside and the parallel lines of the plough, all set against a backdrop of trees lining Crab Hill Lane and the wooded hillside of Abbas Hall beyond.
Area B was part of the common land of Cornard until the 1813 Enclosure, when it was allotted to William Taylor. On the 1838 Tithe Map it's called Kiln Field, suggesting the presence of a kiln in the vicinity by that date: however, no buildings are shown in the field (as they are on other kiln sites on the map) and the word 'kiln' also occurs as part of the name of four other plots nearby, three of them in Area C opposite. It's possible that the kiln/kilns were a small, early enterprise and that any structures had gone by 1838 but the field-names survived. The 1885 6” OS map records a gravel pit in Kiln Field but this is not shown on subsequent maps and as the field is flat it was presumably soon filled in. The field is now a wild meadow enclosed by hedges and trees, with a footpath down the SW side and the stream on the SE: it abuts housing on the SW and NW, and is a valuable piece of open land in an increasingly urbanised area.
Area C is the most valuable both historically and visually. It faces Area B across the stream and as B was part of the common land it is almost certain that in the past Area C was too, and was part of the steep wooded slopes on the escarpment. It's very likely it was once wood-pasture, a land- management compromise allowing both grazing and trees (often pollarded for fodder) on the same piece of land: Gainsborough's paintings, including the two versions of Cornard Wood, show this type of landscape, with the emphasis here more on trees than grazing (see next section for the Gainsborough connection). The Enclosure Map, 1813, shows Area C divided into multiple small, irregularly-shaped plots, typical of assarting, the clearing by individuals, often squatters, of patches of land from woodland for cultivation, especially at times of population pressure: such features can be centuries old and their survival is rare and valuable.
There is, however, another possibility here - that the small plots represent encroachment into wood or pasture land in order to quarry useful minerals. The geology of this whole valley is very complex and includes a series of outcrops down the scarp of materials of mainly glacial or fluvial origin. Perhaps most significant are the up-slope Kesgrave Sands and Gravels, a reddish-orange gravel which surely can be seen being dug out by workmen in Gainsborough's paintings of Cornard Wood. In the past, parishes were responsible for maintaining their own roads, and this required constant work and materials, especially on clay soils. Gravel was the main material used if available locally, and the nearer it could be dug to the road in question the better: there would have been a high demand for gravel within the area. The lower slopes of Area C are mainly clays plus some silt and sand, and it's quite possible that some of the lower diggings were for clay and sand for the nearby kiln: clay being heavy to transport it was easier to build a small kiln where the materials were.
It may be that the history of this small piece of land includes all the above – wood-pasture, assarting with multiple occupancy and subsistence farming, a 16thC small farmhouse, periods of excavation for minerals plus a brick/pottery kiln and then crop diversification in response to mainly local market needs. Almost certainly the topography of these slopes has been changed by man, possibly a great deal. Natural erosion by many tiny tributary streams running down the scarp into the Black Brook has cut narrow channels back into the hillside, and some have been enlarged by quarrying, probably mainly for gravel: the changes wrought on the landscape may have been substantial and would explain the slightly odd topography of Area C with its rather sunken appearance and in places, concave slopes. At the time of the Tithe Map (1838) the area was still divided into several plots but by then the bulk of it was held by William Taylor. It is shown as mostly arable land, but previous uses may be read in some field-names – 'Old Orchard' and 'Old Hop Field' etc.
Apart from the overgrown plot where the old farmhouse once stood, most of Area C is now pasture grazed by horses, with one or two mature pollard trees set in the grass slopes that sweep up to the skyline. A scatter of little streams and seepages create small boggy areas on the hillside before making their way downhill to the Black Brook (at least one stream is culverted). A wealth of overgrown hedgerows together with old coppice trees down Crab Hill Lane and along the stream give a wonderful sense of enclosure and seclusion. Landscape of this quality and historic interest is rare: it would not survive development.
Area A looking east towards Area C and Abbas Hall Wood beyond
The Holloway separating Area C from Area A, Brooke Field Lane on the 1813 Enclosure Map
Area C, looking uphill from the gate on the boundary with Area B
Area C, a sense of seclusion, yet behind the viewer is Area B and housing
Area C: North corner looking downhill over Area A and across the Stour Valley
Area C: North corner looking downhill over Area B and across the housing beyond
Conclusion and Potential
Present-day Cornard is the result of decades of cumulative piecemeal development spreading east and south across the rural landscape and it has now gone beyond the point when it should have been checked. It is essential in this landscape to respect the topography, and it was a mistake, in terms of visual impact, to encroach onto even the lowest slopes of the escarpment, as can be seen in the intrusiveness of the adjacent development currently under construction. The extension of building any further in this area would, I believe, be a mistake in strategic planning terms: in the specific case of this SHELAA SS0220 site it would be an appalling decision resulting in the destruction of a piece of high-value Suffolk landscape of great beauty, rare historical interest and ecological variety. Many local authorities are obliged to spend large amounts of money trying to create 'amenity areas' of even one-tenth of the quality of this site for their environmentally-impoverished populations. Suffolk's landscape is its greatest asset – can we afford to be profligate in its destruction?
This site's location on the very edge of Cornard's urban area makes it ideal for low-key rural amenity use by the local population: indeed it is already much used by walkers where access allows, and Area B (Kiln Field) provides open space and wildlife value. In addition the whole of the SHELAA site land has undoubted value as an educational resource and its on-the-doorstep location again makes it ideal for local school study visits. Area C is of exceptional historical interest especially as it relates to the lives of the ordinary people and their land as opposed to the constant emphasis on wars and the more dubious conduct of a few monarchs. Apart from history there is excellent scope for many aspects of environmental teaching, plus geography/geology, outdoor art classes with perhaps some reference to the Gainsborough connection, and why not a reading/story- telling circle for all ages, from fairy tales to nature stories, to the poets of landscape and the anti- enclosure movement?
Gainsborough and the Cornard Connection
One of England's greatest painters, Thomas Gainsborough (1727-1788) was born and brought up in Sudbury. He was famous as a painter of portraits and this brought him financial success, but throughout his life his greatest love was for landscape painting. As a boy he roamed freely through the rural countryside surrounding Sudbury sketching and painting what he saw, and his artistic talents were apparent from a very early age. The landscapes of our youth are imprinted deep in the memory, especially when seen and appreciated with an artist's eye, and it was said of Gainsborough that he had a detailed knowledge of practically every path, tree and shrub in this part of the Stour valley and the surrounding area. Although he was obliged to leave Sudbury for most of his adult life in order to pursue his career he must surely have carried the memory of these landscapes with him always, reinforced by his collection of childhood sketchbooks.
Many of Gainsborough's landscape paintings contain a number of rather similar elements and it has been suggested that he was re-using them to create new, imaginary landscapes. However, although this may well be true of the sketchy rural backdrops in some of his portraits there is surely little reason to suppose that such an idea should be applied generally to his proper landscape paintings. There was no lack of beautiful scenes to paint in the countryside around Sudbury and the young Gainsborough must have been spoilt for choice. The perceived similarities tend to arise because each landscape type has its own characteristic elements which will naturally recur in any painting made in that general locality. In the context of this document the particular landscape type in question is that of a steep wooded scarp overlooking the Stour valley, formed where the lower land beside the river rises abruptly up onto the clay plateau beyond: such a feature occurs in Great Cornard, close to Sudbury. Easily accessible to Gainsborough from a very young age it must surely have been the site of some of his earliest sketches and paintings, including the two versions of the same scene known as Cornard Wood, the first painted when he was only 12 or 13 years-old and the other in 1748 when he was about twenty.
The use of the name Cornard Wood has been called into question for two reasons. First, because it appears not to have been applied to the two paintings until some forty years after Gainsborough's death. However, the titles of his landscape paintings more often refer to their subject matter rather than to geographical locations, and as the first owners of the paintings were quite likely to have either known or at least asked where they were painted, the name Cornard Wood could easily have become informally attached to either picture. Secondly, I suggest that despite opinions to the contrary there would historically have been a 'Cornard Wood', even though its name doesn't survive in the records as far as we know. It would have been the local name for what remained of the parish's common woodland as distinct from the wood belonging to the demesne of the Manor Hall itself (Abbas Hall Wood). Evidence suggests that most of the original woodland of Great Cornard was cleared early on for agriculture but a certain amount would have been left as 'common woodland' as an essential part of the manor economy, providing common grazing and foraging, and wood for a multitude of purposes. The logical site for this would have been a strip along the escarpment on slopes too steep to plough. The young Gainsborough would have had free access to the common woodland but not necessarily to Abbas Wood. By his time the common woodland had probably already been reduced by assarting and informal enclosures, though to what extent is not known: certainly this process accelerated through the 18thC with common rights finally being extinguished by parliamentary enclosure in 1813. Fragments of this woodland do still survive but are everywhere under threat.
By comparing the Cornard Wood paintings with the topography described above it is possible not only to identify the recurring elements which characterise this landscape type but also to show that if the paintings were indeed of Cornard, then they must surely be of a specific view somewhere along this escarpment.
• The viewpoint is high: the artist is looking down a steeply-sloping hillside into a wide river valley and beyond to the rising slopes on the other side. Short but steep scarp-slopes such as these are characteristic of some parts of the Stour valley but feature particularly in Great Cornard where they form a long arc curving inland from near Sudbury southwards and then south-west back towards the river. This curve creates a wide bay of lower land allowing multiple views in different directions.
• The hillside is wooded: the artist is surrounded by trees, many old and gnarled and picturesque. This is not a plantation of tall, straight trees managed for timber production, nor is there any sign of well-managed coppice within the wood. There are, however, animals grazing the scrubby undergrowth - cows, goats, donkeys and horses; a woodman/wood- turner is working in situ; and just below the artist, near the top of the slope, are labourers digging out what appears to be gravel/sand. This is almost certainly a piece of ancient common woodland, a resource available to the villagers: it is not Abbas Hall Wood, which though possibly nearby would have been fenced off and managed more intensively, probably mainly for timber.
• A track winding away downhill: a common landscape device, leading the viewer's eye into the painting and beyond: it also evokes a significant psychological response in most people whether they are directly aware of it or not. Here the effect is emphasised by the way the wooded shoulders of land on either side narrow the foreground view before allowing it to expand out across the wide, sun-lit valley floor. The higher land on either side of the track is explained by the fact that this is a holloway, a sunken path worn by centuries of use especially where the surface and underlying sediments are relatively soft and unconsolidated, as is likely here. The winding nature of the path gives added interest to the scene, but in this context is entirely valid. It is easier and safer to descend a steep slope via a series of curves running diagonally across the contours, rather than in a straight line
downhill: winding paths will therefore be a recurring element. Oliver Rackham, describing holloways in his book The History of the Countryside, says they take at least 300years to form and are typical of Ancient Countryside: he also lists 'the area south and east of Sudbury (Suffolk)' as one of three examples in England where many of these vulnerable features still survive – but that was in 1986.
• Pools and gravel: to the right of the artist, and almost on the same level, is a natural pool, while to his left and a little below him are men digging out what is probably gravel from the bank of the holloway: both pool and gravel can be related to the geology which forms the upper part of this escarpment. Underlying the plateau and most of the hillside is a bedrock of London Clay laid down 48-56 million years ago: overlying this is a layer of c3 million year old Kesgrave Sand and Gravel (mainly gravel) of river origin, and then on top of that a layer of Boulder Clay of variable thickness deposited by melting glaciers. Here on the edge of the plateau the Boulder Clay is relatively thin so that the Kesgrave Gravel and London Clay are soon exposed on the slopes below. Water draining from the plateau is likely to seep out where the layer of porous gravel meets the less porous London Clay, forming a number of small streams and seepages which find their way down into the Black Brook and thence to the Stour. The streams cut back into into the soft sediments at the top of the scarp, creating narrow gullies: where these are adopted as route-ways erosion is accelerated by human traffic, and this in turn channels more water down the road. Natural pools perched high in the landscape must be underlain by a relatively impervious layer, in this case probably London Clay, and would be fed by water seeping from the surrounding gravel.
Much of the upper part of the higher ground seen on the left of the Cornard Wood painting could be Kesgrave Gravel: the whole appearance of the landscape on the left side of both pictures, topography and vegetation, is characteristic of gravel/sandy ground. In fact, the whole scene depicted in the two paintings, foreground, slope and the views beyond is more or less what one might expect to see in a gulley at the top of this scarp, based on evidence from a geology map and a contour map.
• Churches and location: the church provides an ideal distant focal point in the painting and has been much used in attempts to pin-point the exact location of the scene. A number of churches in the Stour valley can be seen from the top of this ridge, of which two, at Great Henny and Great Cornard, have the depicted broach spire. Cornard church sits rather too low in the landscape, leaving only the higher Great Henny church, which some have dismissed as being too far away (c4 miles) to be seen properly. That, however, takes no account of the greater clarity of the air in those days before the pollution of the industrial revolution and motor traffic: the young eyes of the 13 or 21 year old Gainsborough may well have been able to see a small but clear image of the Great Henny church: it's also quite possible he had access to a spy-glass. In any case, as regards the church Gainsborough must surely be allowed some artistic licence in creating the right eye-catcher in the right position. A church may be moved up or down in the landscape as well as right or left; it may be enlarged if necessary, or given a spire if it lacks one (Middleton church is correctly placed but has only a tower).
The Revised Heritage Statement submitted in support of the Appeal against the refusal of planning permission, B/10/00094 Land east of Carson Drive, contains the following statement:- para 1.2.2 ii(c) Like many other Gainsborough landscapes Cornard Wood is almost certainly an imaginary composition, inspired by views across the Stour valley but not closely representing any particular view or point within it.
Are we to believe that when Gainsborough painted the first Cornard Wood at the age of about 12 (possibly his first proper landscape done in oils) he just stayed at home and invented an imaginary scene to paint? Is it not far more likely that he sought out a favourite view and painted the familiar landscape delighting in the new medium? Then when he returned home to Sudbury after eight years of training in London, now a young man and a professional artist, is it likely that one of his first and finest paintings would be just a reworking of a scene imagined in childhood? He was ambitious to earn his living by painting landscapes, and it's possible the 1748 Cornard Wood may have been intended to show potential clients the quality of paintings he could now produce, painted from life. In addition, although Gainsborough has slightly adjusted the viewpoint in the 1748 version to improve the composition, other details in the two paintings are remarkably similar. The trees are the same trees in the same positions, even the minor ones, and the same is true of other elements in the landscape. Were he indeed painting from imagination the mature artist would surely not have felt constrained to copy slavishly every detail in the 1740 version, but would rather have allowed his adult mind and talent to range more freely.
All the evidence suggests that the two Cornard Wood paintings are accurate representations of a real landscape scene, viewed from a point somewhere near the top of the Cornard escarpment. Lack of access to private land plus the Covid 19 restrictions have so far prevented further on-site investigation which might have identified possible locations more closely. However, it has to be borne in mind that 280 years of natural erosion, quarrying and tree loss have passed since the paintings were done, and the scene may no longer be recognisable. Having said that, there is one location which seems on paper to be particularly suitable and that is the large gulley just S of Abbas Hall Wood. It runs SW downhill from a proposed viewpoint (Grid Ref: TL9025 4016) at a height of around 60m, giving wide views across the Stour valley, including possibly any of the three churches at Great Cornard, Middleton and Great Henny by just minor adjustments to the height/position of the artist's viewpoint. The topography and geology of the gulley appear on paper to match the paintings, although the top of the gulley is now occupied by a reservoir. Below is a photograph of the top of the gulley taken across the ploughted field from footpath no.14 : the spire of Great Cornard church can be seen, with a white house in the new development directly in front of it. There are probably other possible sites along this escarpment, but this particular one is the most obvious fit, and is crucially important in this context in that it is very close to the proposed housing allocation. Indeed, the NE end of the housing area actually extends into the gulley itself at the bottom, and if the view in the paintings is indeed of Great Henny church then it is looking directly over almost the whole of the proposed SHELAA site. The woodland area extending SW from the above grid reference should also be considered for possible viewpoints as there are signs of old tracks through here and some abrupt changes of level.
Moving on from the two Cornard Wood paintings to consider Gainsborough's other landscapes, many of them are immediately recognisable as the Stour valley – the steep slopes, wooded with ancient trees; the intimate foregrounds opening out into wide views across the river valley; the swelling curves of a hillside exposed where the trees give way to a patch of sunlit pasture; a scatter of ponds and an occasional stream. Such scenes as these can still be seen in the more secluded parts of the Stour valley but are sadly increasingly rare in Cornard. The site in question here is a rare survival of a fragment of that ancient Suffolk landscape which Gainsborough so loved and captured for posterity in his paintings.
Above: top of gulley looking towards Great Cornard church and across the Stour.
Below: looking uphill from the Black Brook: pasture, and shrub area on the right slopes, will be lost to housing.
Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
The land here is almost the last part of the natural valley slopes of Sudbury area, and we present evidence that building here would be counter to Babergh Core Strategy CS15: that development “should respect the landscape, landscape features, streetscape / townscape, heritage assets, important spaces and historic views; and make a positive contribution to the local character, shape and scale of the area”. Instead of its former scenic valley slopes in full sun, Sudbury and Cornard would instead border on the plateau of intensively arable land.
This statement is attached to the Landscape and Heritage Report by Sybil Wade, former professional landscape architect. We also quote from the March 2020 report by Alison Farmer Associates in Section A, and the 2019 “Heritage and Settlement Sensitivity Assessment” by Place Services in Section C.
This statement combines Landscape and Heritage topics (in the manner of the District Council’s Landscape Character Assessment), because the site’s appearance so clearly reflects its historic land-use.
A. DESCRIPTION
A1. This site presents as exceptionally charming and pretty countryside and is known to be much valued by local people. It is classic peaceful, unspoilt countryside of high quality. Development on this wet valley and hillside would represent the town sprawling beyond its normal topographic boundaries.
A2. We quote from the report of Alison Farmer Associates “Valued Landscape Assessment, Stour Valley Project Area” March 2020:
“The SVPA to the south of Sudbury, in the vicinity of Prospect Hill and Little Cornard, is visually sensitive to expansion of Sudbury or development on the valley slopes ….. Land within the SVPA adjacent to Sudbury is valued due to:
• Extensive and intact water meadows - Sudbury Common Lands Nature Reserve and Wardman Meadows (County Wildlife Sites).
• Undulating valley slopes around Prospect Hill and Little Cornard which express visually diversity, scenic views and historic interest and form a high-quality setting to the south of the settlement.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
• Cultural associations with Thomas Gainsborough.
• Opportunities to access natural green space and recreational routes into the wider landscape.
• Intact pattern of historic enclosures on the valley sides – medium size fields enclosed by tall hedgerows and hedgerows trees with sunken lanes on valley slopes.
• Wooded skylines which define the upper valley slopes and form a backdrop to Sudbury.
Conserving Special Qualities: ….. Avoid development which extends up the valley slopes resulting in a loss of open fields as a backdrop to the town, especially at Great Cornard and where development may become visible from the SVPA on the skyline.”
A3. Sybil Wade’s report comments: “There are three distinct areas to this land (A, B and C) and each has its own interest and beauty, but collectively they are a gem, a small, rare piece of surviving ancient landscape, a relic of a fast-disappearing world.
Field A: The chief value in the landscape here lies in the beauty of its landform, in the swelling curve of the hillside and the parallel lines of the plough, all set against a backdrop of trees lining Crab Hill Lane and the wooded hillside of Abbas Hall beyond.
Field B: Kiln Field ….. was part of the common land of Cornard until the 1813 Enclosure ….. The field is now a wild meadow enclosed by hedges and trees, with a footpath down the SW side and the stream on the SE: it abuts housing on the SW and NW, and is a valuable piece of open land in an increasingly urbanised area.
Field C: The most valuable historically and visually. It is divided into multiple small, irregularly-shaped plots, typical of assarting ….. such features can be centuries old and their survival is rare and valuable.”
A4. We put it that this site is:
• An exemplary land-form of the Stour Valley area, with characteristic features of ancient countryside;
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
• Very reminiscent of Gainsborough's landscapes, part of the parish where Thomas Gainsborough grew up, and painted settings which seem little altered from today - such as "Cornard Wood", “Wooded Landscape with Peasant Resting, Figures and Distant Village Beyond a Cornfield”, “Landscape with Figures under a Tree” and “Wooded Landscape with a Cottage, Sheep and a Reclining Shepherd”
• Part of the setting of the Grade I listed Abbas Hall and Grade II Kiln Farm, also Grade II Corrie Hall, Grade II Wrongs Farm and Grade II Prospect Hill Farm; and that the rare but similar settings of Abbas Hall and Kiln Farm need to be conserved as a unity;
• The unspoilt valley floor and side of the Black Brook, which is the last remaining natural stream in the Sudbury area, on the Suffolk side of the river, the lane known as Crab Hill, small fields, combination of steep slopes and valley, and natural grassland, which together are a gem.
B. REQUIREMENTS UNDER THE NATIONAL POLICY PLANNING FRAMEWORK
Para 127c “planning policies and decisions should ensure that developments are …. Sympathetic to local character and history …. including landscape setting”.
Para 170 “Planning policies and decisions should contribute to and enhance the natural and local environment by …. Protecting and enhancing valued landscapes …. sites of geological value …. Recognising the intrinsic character and beauty of the countryside”.
Para 190 “should identify and assess the particular significance of any heritage asset ….including ….the setting”.
C. BABERGH POLICIES
C1. The development will cause substantial harm to heritage assets which would be contrary to policies CS14 and CS15 of the Core Strategy 2014, and would require wholly exceptional justification.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
CS14:
The introduction to CS14 reads: "3.3.9.2 A good network of multi-functional green infrastructure within and between urban and rural areas should aim to achieve the following;
vii) Enhance the character and local distinctiveness of the landscape;
viii) Make a positive contribution to creating a sense of place especially within large new developments including the strategic sites …. greenfield sites and those within or close to sensitive landscapes will be particularly important.
CS15:
“Proposals for development should:
i) respect the landscape, landscape features …. heritage assets, important spaces and historic views;
ii) make a positive contribution to the local character, shape and scale of the area; …. ensure adequate protection, enhancement, compensation and/or mitigation, as appropriate are given to distinctive local features which characterise the landscape and heritage assets of Babergh’s built and natural environment within designated sites …. and local designations such as Special Landscape Areas …. and also local features and habitats that fall outside these identified areas. In particular proposals should protect and where possible enhance the landscape and heritage areas including habitats and features of landscape, historic, architectural, archaeological, hydrological and geological interest”.
Our finding is that the “adaptation or mitigation” allowed under CS15 would not be suitable in this case because it would be substitution of an inferior arrangement, and the only solution which would be acceptable would be “avoidance” - given that there is a more suitable site at Chilton Woods.
C2. We believe the 2019 “Heritage and Settlement Sensitivity Assessment” of Place Services, commissioned by Babergh for the emerging Local Plan, should be taken as highly relevant to this site. We advise that development here would add to the concerns identified in the report:
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
“Great Cornard:
1. Emerging views travelling along the road by Grays Hall and Prospect Hill, which allow an understanding of the character and interrelationship of the sequence of historic farm complexes.
2. View from Cornard Tye to Sudbury looking south east towards Abbas Hall. This emphasises the prominent siting of the hall within the landscape, and its isolated location (this site is a part of both views, eg., the fine view from Sheepshead Hill).
…. Great Cornard is made up of a series of historic farmsteads which collectively have historic value. Abbas Hall is located on higher ground at the centre of this landscape, and has exceptional value for its architectural rarity and its corresponding evidential significance, which is reflected in the fact that it is designated Grade I. However, the integration of Great Cornard into the wider settlement conglomeration of Sudbury has harmed the ability to understand it as a separate entity, and has accordingly harmed its overall value.
…. The chain of historic farm complexes contains relatively low level of modern infill. As their inter-relationship makes an important contribution to their significance they are therefore susceptible to infill development or to development which would encircle them. Abbas Hall is also still experienced in an open agricultural landscape albeit particularly intruded upon by the re-landscaping of the surrounding area. This isolation was a deliberate decision, reinforcing the status of the hall’s owner, and makes an important contribution to its significance. It is therefore also susceptible to the encroachment of development.
…. Recommendations: The settlement of Sudbury has expanded considerably to the north and east in the 20th century and has encroached upon the setting of several highly significant heritage assets which are now located just beyond or on the settlement edge. It is recommended that future development sites avoid further encroachment on these assets, in particular Chilton Hall and Church and Abbas Hall.”
C3. The Joint Babergh and Mid Suffolk District Council Landscape Guidance 2015: Though mapped in Suffolk County Council’s landscape typology as part of the Ancient Rolling Farmlands, the site is adjacent to the Rolling Valley Farmlands and actually matches closely the following descriptor of the latter, ie:
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
● Gentle valley sides with some complex and steep slopes ● Deep well drained loamy soils ● Organic pattern of fields smaller than on the plateaux ● Distinct areas of regular field patterns ● A scattering of landscape parks ● Small ancient woodlands on the valley fringes ● Sunken lanes ● Towns and villages with distinctive mediaeval cores and late mediaeval churches ● Industrial activity and manufacture, continuing in the Gipping valley ● Large, often moated, houses
Professor Oliver Rackham’s important definition of Ancient Countryside, refers to such landscape, and the above descriptors might have been drawn from the first chapter of his “History of the Countryside”, where he enumerates its features as: “Hamlets and small towns; ancient isolated farms; hedges mainly mixed, not straight; roads many, not straight, often sunken; many public footpaths; pollard trees, if present, away from habitations; many antiquities of all periods”. His book gives this definition: “Ancient Countryside: Districts whose fields, woods, roads etc date predominantly from before A.D. 1700.”
Chapter 12 of Rackham’s book states "Holloways are especially typical of parts of England …. They are abundant in the Lizard Peninsula (Cornwall), south-west Wiltshire, and the area south and east of Sudbury (Suffolk). Such landscapes of holloways are typical of Ancient Countryside. Well-developed holloways take at least 300 years to form.” The examples here are Sheepshead Hill, Abbas Hall lane, Crab Hill, and Prospect Hill and its parallel hollow path.
The Landscape Guidance refers to features which would amount to constraints, including in 12.15: “To conserve the character of rural/green lanes …….. Any proposal that would adversely affect the physical appearance of a rural lane, or give rise to an unacceptable increase in the amount of traffic using them or an unacceptable level of associated activity, noise or disturbance arising as a result of the development would be inappropriate”. Prospect Hill, Sheepshead Hill, Blackbrook Lane and Wells Hall Road cannot take any increase in traffic volume.
The overall objective stated in the Guidance for this Rolling Valley Farmlands landscape unit is “To maintain and enhance the distinctive landscape and settlement pattern.” In
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
the case of this site, which is in very good condition and matches closely the descriptors, this can only mean avoiding change. We advise that an increase in modern housing and traffic, would detract further from the key adjacent features such as the setting of Abbas Hall, the moat and farmhouse in Wells Hall Road, the Black Brook tributaries, and the Country Park.
C4. Policy CR04 of the Babergh Local Plan 2006 states that development in Special Landscape Areas will only be permitted where it maintains or enhances the special landscape qualities of the area, and is designed and sited so as to harmonise with the landscape setting Special Landscape Area. We consider this site to be a quintessential asset within the SLA.
C5. We consider this site would be a strong candidate for inclusion in the intended AONB extension. The valley slopes of Great Cornard are accorded equal merit with the River Stour Common Lands, in the March 2020 report of Alison Farmer Associates “Valued Landscape Assessment, Stour Valley Project Area” quoted in A above.
C6. Emerging Local Plan: We regret that the Landscape Policy LP18 doesn’t include alongside panoramic views the concept of ‘beauty spots’. Smaller beauty spots are for instance equally central to the character of the Dedham Vale AONB, as are larger ‘panoramas’. Gainsborough’s landscape paintings characteristically combine an intimate valley-slope foreground, with a distant panorama.
We suggest that to be rational, in LP18 the word “landscape” should throughout be followed by “and selected beauty spots”. We do not here try to define beauty spot, but we contend it will be extremely important to recognise and catalogue beauty spots that are close to the district’s urban areas.
C7. Babergh’s 2019 SHELAA document lists this land as Site SS0220. We object that it identifies the “constraints that would require further investigation” only as: Highways, Heritage - potential impact, Contaminated land, and Flood. It is evident that this part of the Black Brook valley presents one of the best assets in the Sudbury area, adjacent to the main urban area and where people live, and before deciding on any Land Allocation it merits an investigation, or possibly environmental impact assessment, of landscape, open space and biodiversity impacts.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
D. LOCAL ISSUES
D1. Development would remove the intended route of two long-standing, partially-completed projects of the local councils and volunteers: the Gainsborough Trail and the Great Cornard Linear Park. These are billed as “offering visitors and residents an opportunity to explore and enjoy the countryside” and linking Cornard Mere SSSI, the Country Park, Woodland Rise Wildlife Area, and Shawlands Wood Local Nature Reserve and are a part of the “green arc” of Babergh’s Green Infrastructure Strategy, 2012.
D2. We refer to the Inspectors’ reports in three planning applications which were the subject of appeal.
Case 1:
Appeal Decision APP/D3505/W/19/3230839, dismissal of plan for eight houses on Prospect Hill, 2019. This proposal was adjacent to the present one and these excerpts show the value which the Inspector placed on the landscape here. We regard development proposals here as likely to fail such examination.
5. A Country Park is located close by, as are various agricultural fields. Notwithstanding the nearby presence of existing clusters and singular examples of residential development, the site and its surroundings are inherently rural in their character and appearance.
7. The site is located within a Special Landscape Area. We have not been provided with full details in this respect. However, it appears that landscape sensitivity is drawn, at least in-part, from the prevailing presence of undeveloped countryside and the area’s attractive mix of wooded land and often undulating agricultural fields.
9. In any event, planting cannot be relied upon to provide a solid and permanent buffer to views. This is because it is ever evolving, is reliant on regular maintenance to retain a consistent form and may be reduced in scale or extent in the future.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
10. Even should the proposed dwellings be brought forward at a single storey, the development would appear discordant with its rural surroundings and landscape setting. Particularly given the site’s standalone location relative to existing clusters of residential development in the locality, the scheme would encroach into the open countryside and have an adverse urbanising effect.
11. For the above reasons, the proposal would cause harm to the character and appearance of the rural area in conflict with Policy CS15 of the Core Strategy, in so far as this policy requires proposals to respect the local context and character of the different parts of the District and to make a positive contribution to the local character, shape and scale of the area.
12. Although not forming part of the reason for refusal, saved Policy CR04 of the Babergh Local Plan Alteration No 2 (June 2006) (the Local Plan) has been referred to in the evidence. The proposal also conflicts with saved Policy CR04 in so far as it requires proposals in Special Landscape Areas to be designed and sited so as to harmonise with the landscape setting.
Case 2:
Appeal Decision APP/Z1510/W/18/3207509 March 2019, Land off Colchester Road, Bures Hamlet, Essex. These excerpts from dismissal of an appeal appear largely to be mirrored by the unsuitability of this site and we regard development proposals here as likely to fail such examination.
19. Unusually, the statutory Management Plan for the Dedham Vale AONB also includes the whole of the Stour Valley Project Area, although only part of that area is recommended in the Farmer Report [2016] for consideration for inclusion in an extension to the AONB. The Project Area lies outside the AONB boundary and does not itself have any statutory landscape or other designation. It is thus not subject to the statutory requirement to prepare a management plan. Nevertheless, the Management Plan is a material consideration. It does not seek to preclude housing development in the AONB or the Stour Valley.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
However, it qualifies support for such development as applying to that which:
• sits well with the patterns of historic villages: contributes to the architectural patterns of the area; and which seeks to meet the needs of the community in terms of affordable housing.
20. Paragraph 127 of the Framework [NPPF] provides amongst other things that planning decisions should ensure that developments are: ‘sympathetic to local character and history including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities)’.
Paragraph 170 of the Framework provides amongst other things that planning decisions should contribute to and enhance the natural and local environment by: ‘a) protecting and enhancing valued landscapes ... (in a manner commensurate with their statutory status or identified quality in the development plan)’ and ‘b) recognising the intrinsic character and beauty of the countryside ....’.
21. We consider that recognition of the intrinsic character and beauty of the countryside would have little practical effect without an assessment of the particular qualities of the countryside and the landscape setting where development is proposed and the effect of that development upon them. Neither, having regard to Paragraph 127, do we consider that the exhortation to protect and enhance ‘valued’ landscapes is necessarily limited to landscapes that have either a statutory designation or a local designation in the development plan.
22. The Framework does not provide a definition of a valued landscape. However, we consider it improbable that the addition of the words in brackets to paragraph 170(a) which occurred in July 2018 was intended to encourage policy makers to revive the practice of creating local ‘Special Landscape Areas’ or similar designations in development plans as a means of identifying a valued landscape. Previous advice had sought to discourage such designations in favour of landscape character assessment which would identify the distinctive and valued qualities of landscapes. That is of particular relevance here where the RLP designations of Special Landscape Areas including in the Stour Valley were superseded in the CS by policies which referred to the use of landscape character assessment.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
23. Had the creation of new local designations been the Government’s intention, then we consider that it would have been highlighted in the public consultation on the changes to the Framework and made explicit in the new text. Moreover, even if that were the intention, there would be a long hiatus whilst all the necessary work was carried out to identify, consult upon, examine, and adopt the necessary policies as part of the statutory development plan framework, during which sensitive landscapes would remain vulnerable to insensitive development. In any event, whether or not the site qualifies as a ‘valued landscape’ in the terms of the Framework, the Framework at Paragraph 127 requires development to be sympathetic to its landscape setting. Such consideration must necessarily have regard to the sensitivity of that landscape.
Landscape Value:
24. In this case we consider that there is ample evidence that the landscape around Bures, including the appeal site, is not ordinary countryside of no value but is of high sensitivity and is locally valued. That evidence encompasses: its inclusion in the Stour Valley Project Area and the Management Plan; the commissioning and conclusions of the Farmer Report [2016]; the submissions to Natural England to review the AONB designation; and the related text of the emerging Local Plan at paragraph 8.27 which highlights the sensitive nature of the upper Stour Valley and supports the aims of the Management Plan whilst also seeking to avoid prejudicing the expressed long term aim to extend the AONB to this area.
25. The appeal site itself displays many of the characteristics of the A2 character area. It is arable farmland on the rolling valley sides. It is visible both from within and across the valley. It contributes positively to the setting of Bures within the valley, notwithstanding that other nearby development may have had an adverse impact in that regard.
Case 3:
Appeal Ref: APP/D3505/A/13/2198853 Land East of Carsons Drive, Great Cornard, Sudbury, Suffolk. We quote para 86 to show the stark comparison, on the site adjacent to this one, between the inspector’s comments with what was built – little reliance can be placed on the ability of local planners to hold a determined developer in check once land has been designated suitable for development in the Local Plan.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
86. The materials proposed to be used in the construction of each house are not individually specified but are generically described on the application form as red/brown facing brick, buff facing brick and render for walls and red roof tiles and slate for roofs. As noted above in the discussion of the context for the site, these generic descriptions would not be inconsistent with the locality, although we emphasise that in our observations of the local vernacular, the clay roof tiles we saw were reddish and weathered, rather than bright red concrete tiles which we only observed on the recent estate developed on the former rugby ground. In any event, the particular specification of each material used could be required by condition to be the subject of approval to ensure consistency with the character and appearance of the area.
We point out our photos of 2019, which show the white buildings actually erected here, stick out like a sore thumb in the countryside.
E. DEVELOPER’S DOCUMENT
We quote excerpts from the Landscape Statement (Appendix 2) of the proposals of Huntstowe Land of September 2019, provided as a representation to the Local Plan consultation, in the “Great Cornard” section. We must conclude at the least there is much “unconscious bias” in Huntstowe’s statement.
Landscape Statement:
3.5.2 “Open, highly prominent and distinctive or intricate and complex landforms with sharp changes in level are more likely to be susceptible to change arising from development than flat and indistinct landforms.”
Our comment - The landform here is the opposite to that alleged, ie., it’s steep, changing and complex.
3.5.2 “Locally, within Great Cornard, and particularly at the emerging Woodland Rise development, new dwellings sit on the valley slopes. Therefore development of the site, particularly moving towards the southern boundary, would not be uncharacteristic of the locality.”
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
Our comment - We regret this approach of appealing to “precedent” whereby one recent radical intrusion is used to justify endless repetition of the same.
3.5.3 “Given the localised extent of woodland cover and the site’s position adjacent to the existing settlement edge, susceptibility in terms of landscape pattern/scale/cover is considered to be low. The impact of parliamentary enclosure is particularly noted within the ‘Special Qualities of the Dedham Vale AONB Evaluation of Area Between Bures and Sudbury’ report [2016] as reducing the sense of tranquillity locally.”
Our comment - Such argument is overstated and the word “low” is totally unjustified. If we look at Thomas Gainsborough’s paintings, they characteristically portray intimate foregrounds on wooded hillsides. The references to parliamentary enclosure do not apply to the valley sides which as here, are typified by smaller, irregular fields. We refer to the Landscape Guidance quoted in C3 above.
3.6.7 Quotes the 2016 report ‘Special Qualities of the Dedham Vale AONB Evaluation of Area Between Bures and Sudbury’ prepared by Alison Farmer Associates: “around Great Cornard the enclosure pattern comprises parliamentary enclosure and this combined with less steep topography and adjoining development reduces the area’s scenic quality.”
Our comment - This has since however been superseded by the report of Alison Farmer Associates “Valued Landscape Assessment, Stour Valley Project Area” March 2020, referred to in A2 above. In relation to Sudbury area, this includes:
“Undulating valley slopes around Prospect Hill and Little Cornard which express visual diversity, scenic views and historic interest and form a high-quality setting to the south of the settlement”. “Conserving Special Qualities: ….. Avoid development which extends up the valley slopes resulting in a loss of open fields as a backdrop to the town especially at Great Cornard and where development may become visible from the SVPA on the skyline.”
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
3.6.8 Also quotes the 2016 Farmer report “the later 20th century expansion of the …. former village of Great Cornard to the southeast has increased visibility of urban development which extends up the valley sides …. changes are likely to result in further localised loss of tranquillity and further urbanising influence on the Stour Valley”, and concludes “Existing development moving up the valley slopes if particularly apparent with the emerging Woodland Rise development to the north-east of the Site. …………… If implemented, these changes are likely to result in further localised loss of tranquillity and further urbanising influence on the Stour Valley’.
Our comment - Here, we agree with the conclusion. In effect, to leave this site undeveloped will be a major step to save the countryside round Great Cornard.
6.1.1 “Tranquillity of the Site: Due to the rural nature of Prospect Hill, there is a sense of tranquillity within the Site and its surroundings. Closer to the settlement edge the sense of tranquillity decreases, as highlighted within the ‘Special Qualities of the Dedham Vale AONB Evaluation of Area Between Bures and Sudbury’ report prepared by Alison Farmer Associates.”
Our comment - In reality, the tranquillity here does not reduce; the site is separated from houses by long gardens and hedges; there is no traffic noise, no street furniture etc, and the entire setting is natural and long-established.
6.3.1 Given the limited site constraints and potential for mitigation/enhancement planting the Site is considered to be a suitable location in landscape and visual terms for development.
Our comment - Here we must again regret the SHELAA document’s failure to identify constraints of landscape and biodiversity. The danger is for Land Allocations by Local Planning Authorities to completely overlook the value of sites, as well as to nod through “developer-speak” with its bias towards development.
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Proposed Land Allocation SS0220 Land off Prospect Hill / South of Davidson Close
LANDSCAPE AND HERITAGE POLICY REPORT
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