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Response of the Friends of Moor Pond Woods to the Inspector's Matters

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Response of the Friends of Moor Pond Woods to the Inspector's Matters Enquiry into the Greater Nottingham - Broxtowe Borough, Gedling Borough and Nottingham City Aligned Core Strategies Publication Version June 2012 Response of the Friends of Moor Pond Woods to the Inspector’s Matters, Issues and Questions This information is relevant to the session : In week 2, Tuesday 5 th November: Day 4 (10am) Word count : 2,080 Created 18 th September 2013 THE FOLLOWING OBSERVATIONS RELATE TO MATTER 5: THE ENVIRONMENT Background 1. The representations made here build upon earlier representations made to the Gedling Borough Aligned Core Strategy (ACS) on behalf of the Friends of Moor Pond Woods (“the Friends”). They are made specifically in respect of the policies and proposals relating to Gedling Borough. 2. Reference in this section is made to English Heritage (2006),” Environmental quality and spatial planning ” [EQSP] (which is best-practice advice issued jointly by English Heritage, Natural England and The Environment Agency). This does not seem to be in the examination library. 3. In the absence or paucity of information in ACS about heritage landscapes in general, and in particular in the section relating to ‘Land North of Papplewick Lane’ [LNPL], “The Friends” have commissioned a report which has been presented as appendix 1 with our response to the site specific issues. Response to question 6 4. Section 2.2.26 of the ACS refers specifically to the risk of flooding from fluvial sources, and draws attention to the situation in the Trent Valley and at Lambley. In the area around Linby and Papplewick, the risk of pluvial and groundwater flooding are also a significant threat. On several occasions in the last 5 years, overland flow following heavy rain has brought about road closures at Linby Lane and on Papplewick Lane, most recently in July 2013. These problems would be exacerbated by more extensive building, for example at Top Wighay or North of Papplewick Lane because the impermeable surfaces would speed overland flow. 5. The ACS does not seem to take account of the potential for flooding within the Leen Valley. There is no evidence that the flood risk has been reassessed following completion of the portions of the Papplewick Green / Papplewick Grange estate in neighbouring Ashfield District, nor what impact of building the remaining portions of that development. There is no evidence of assessment being made of the possible combined effects of development of Top Wighay and North of Papplewick Lane on surface water flow into the Leen, and how that may compound problems arising from the other Friends of Moor Pond Wood, submission to matter 5 extensive development in the Leen Valley. It is a fact that the B683 from Papplewick to Nottingham via Bestwood Village has been closed twice in the last year owing to accumulated floodwater. 6. In Appendix A of the ACS, referring to Land North of Papplewick Lane GBC suggest that the ’site has overall low flood risk ’. That may well be true within the site, but have they considered the accumulated effect of all the new or proposed development within the upper Leen catchment ? 7. In this area, the underlying geology increases the risk of groundwater flooding, The 18 th century water system was constructed so that the ponds in the Moor Pond Wood Project Area (“The project area”) were as much spring fed as fed from the river Leen; Even today, when the Leen no longer refreshes the water system, the leats and ponds are replenished by groundwater after periods of heavy rain. For example, In October 2001 Moor Pond rose 1.5m in a weekend. 8. It is the opinion of “The Friends” that paragraph 2.2.26 should refer to pluvial and groundwater flooding. 9. “The Friends” also suggest that within this section, and embedded appropriately thereafter, the ACS should present more detailed policies and strategies for sustainable water management. EQSP, on p5, suggests that to be effective “we would like to see genuinely visionary plans and strategies that are meaningful and not just vague aspirations. The vision should be at the forefront of the plan or strategy and shape all aspects of it. Objectives, policies and proposals should flow from the vision and contribute to it.” 10. In our view, paragraph 2.2.26 is too bland and recognises a threat without presenting any vision about how that risk should be minimised. As a result, the section is not consistent with best practice. Response to question 8 11. “The Friends” feel that ACS does not present a coherent vision or spatial vision towards either the natural or heritage environments. In 2.3.10 the ACS states that the vision is that “the area’s unique built and natural environment has been improved through the sensitive and high quality design of new development, whilst the historic environment, both urban and rural is valued and protected .”, this is in contrast to the best-practice advice of EQSP, p6, which suggests that “ Plans and strategies should be more ambitious about what can be done to enhance and manage the environment ” 12. NPPF, in sections 11 and 12, is concerned with ‘conserving and enhancing’ both the natural and heritage landscapes of places. We would suggest that there is a world of difference between ‘valued and protected’ and ‘enhanced’, ‘conserved’ or ‘managed’. 13. We do not feel that this is an issue of semantics. We feel that the language of the vision laid out by a planning authority is fundamental to the way in which the natural and heritage landscapes that characterise local areas are perceived and (through the policies and procedures that flow from the vision) are treated. 14. We feel that this section would be more effective if the wording were changed to include “ ...conserve and enhance the historic, architectural and archaeological features of the district.” 15. We suggest that, in its present form, this section of ACS is not consistent with best practice. 2 Friends of Moor Pond Wood, submission to matter 5 Response to question 9 16. Relating to the LNPL site to “The Friends” feel that Appendix A of the ACS does not take enough account of either the natural or the historic heritage. 17. Our responses in this section are informed by the assessment that we commissioned, which is submitted as Appendix 1 with our responses to site-specific issues. Responses relating to natural heritage 18. This site is within the Landscape Description Unit [LDU] ML017 identified in the Greater Nottingham Character Landscape Assessment [GNCLA], but GBC seem to have disregarded the classification. It also borders the LDU ML018 but that has also been ignored. 19. As a consequence, the recommendations of the of the GNLCA for LDU ML017, to ‘conserve and enhance the landscape vegetation which filters views to Hucknall urban fringe as it contributes to separation between Hucknall urban area and the draft policy zone ’ have been discounted, as have the recommendations for LDU ML018, to ‘conserve the nucleated character of the settlements by placement of any new development in existing villages and settlements ’. 20. By promoting development of this site we feel that the separation of Hucknall and the ML017 LDU will be further eroded, and the green buffer that is supposed to prevent the coalescence of Papplewick, Linby and Hucknall will also be considerably reduced. 21. Section 11, para 109 of NPPF states that the planning system should ‘ contribute to and enhance the natural environment by protecting and enhancing valued landscapes ... and recognising wider benefits of ecosystem services ’. It is our view that by failing to reference the recommendations of the GNLCA, GBC have not fulfilled their duty as laid down in NPPF, and therefore that this section of the ACS does not comply with national policy. Responses relating to historic heritage 22. Section 12, para 129 of NPPF states that Local planning authorities should ‘identify and assess the particular significance of any heritage asset that may be affected by a proposal (including by development affecting the setting of a heritage asset) taking account of the available evidence and any necessary expertise. They should take this assessment into account when considering the impact of a proposal on a heritage asset, to avoid or minimise conflict between the heritage asset’s conservation and any aspect of the proposal.’ 23. There seems to be no evidence that GBC have undertaken or commissioned such an assessment, or taken any account of the effect that developing this site would have upon the heritage assets of the middle Leen valley. We feel that the landscape setting of the 18 th century water system, bleach fields and the surviving mills are integral to understanding the heritage of the valley, and should be protected from development of this scale. See Site-related issues, Appendix 1. 3 Friends of Moor Pond Wood, submission to matter 5 24. Referring to section 12, para 126 of NPPF, local plans are supposed to take ‘ opportunities to draw on the contribution made by the historic environment to the character of a place’ . We do not consider that GBC have heeded this obligation 25. In view of the above, we feel that this section of the ACS is neither positively prepared nor consistent with national policy. 26. With reference to section 9 of the ACS, we believe that it is short-sighted to regard contributions to ‘culture, tourism and sport’ to be solely concerned with providing large facilities. We would suggest that the culture and tourism policy should be more closely associated with recognition and development of heritage assets and heritage landscapes. 27. We also feel that culture and tourism lend themselves to development of networks, maximising the cumulative cultural and tourist value of several small sites, rather than concentrating resources (and incoming visitors) to single sites.
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