Impact of the Proposed Development on the Ashdown Forest SAC Author: Zoe L Wangler Bsc (Hons) Ecological Land Limited
Total Page：16
File Type：pdf, Size：1020Kb
Proof of Evidence: Impact of the Proposed Development on the Ashdown Forest SAC Author: Zoe L Wangler BSc (Hons) Ecological Land Limited Planning appeal: Wealden District Council, non-determination planning application WD/2017/0340/F Description: Siting of three temporary agricultural workers’ dwellings for a period of 5 years together with an agricultural barn with PV array and alterations to existing highway access to provide three affordable smallholdings to new entrants to ecological agriculture Location: Field south of Copyhold Cottages, Arlington, Hailsham, BN26 6RU June 2018 CONTENTS Qualifications And Experience .......................................................................... 2 1 Summary .................................................................................................... 4 2 The Threat to the Ashdown Forest SAC .................................................... 8 3 Overview of Existing Traffic Through the AFSAC ..................................... 14 4 Projected Trip Generation & Traffic Flow from the Proposed Development ....... 16 5 Vehicle Trips Removed ............................................................................ 30 6 Overall Impact on the AFSAC of the Proposed Development ................. 34 Acronyms and Abbreviations .......................................................................... 37 Appendix 1: Details of the Traffic Counter at Greenham Reach Smallholdings ......... 38 Appendix 2: Calculations for Trip Generation and Traffic Generation ............. 39 Appendix 3: Survey of Greenham Reach Residents ....................................... 40 Appendix 4: Description of Greenham Reach Residents and Farm Businesses ....... 41 Appendix 5: Mileage Reported at Greenham Reach and Mileage Calculations ......... 42 Appendix 6: Calculations for Trips Avoided .................................................... 43 Figures and Tables Figure 1: Map of Ashdown Forest showing SAC and SPA ............................... 9 Figure 2: Relative Contributions of Nitrogen Deposition at AFSAC away from Roadsides ....................................................................................................... 11 Table 1: Measured Traffic Flows at Points Across the AFSAC from WDC ..... 14 Figure 3: Map Showing Locations of Traffic Counters .................................... 15 Table 2: Average Annual Mileage of LID Projects against National Averages 17 Table 3: Ecological Footprints of LID Projects against National Averages ..... 18 Table 4: Distance Between Appeal Site and Select Towns and Villages. ....... 21 Figure 4: Map Showing Proximity of Appeal Site to the Nearest Point within the AFSAC ............................................................................................................ 22 Figure 5: Maps Showing Road Links from Appeal Site to Nearest Primary, Secondary, District and Service Settlements: Eastbourne, Lewes, Hailsham and Polegate................................................................................................... 23 Table 5: Journey Times from the Appeal Site to Points in London 6pm, weekday ......................................................................................................... 24 Table 6: Summary of Projected Total Trip Numbers and Trips through the AFSAC Based on Greenham Reach (per Year) ............................................. 28 Zoe Wangler Proof of Evidence 1 of 2 | Page i QUALIFICATIONS AND EXPERIENCE My name is Zoe Lelah Wangler. I hold an honors Degree of Bachelor of Science in Development Studies. In 2007 I co-founded the Ecological Land Co-operative (ELC), taking the role of Managing Director in 2009. I stayed in this post until 2015 at which point I became my mother’s carer. I currently work part-time for the ELC. I was responsible for the planning application for the appeal site including co- ordinating public and stakeholder consultations. I prepared the planning applications and appeal documentation for an ELC site with a similar scheme of affordable starter agricultural holdings in Mid Devon District and gave evidence at the public inquiry in 2013. I have also been responsible for monitoring, amongst other indicators of sustainability, the traffic generated by the ELC holdings in Mid Devon. My work, education and training prior to the ELC is relevant to this proof of evidence, as follows. Whilst an independent environmental researcher and consultant I carried out the following: a. a report and briefing for Department for International Development (DFID) providing staff with baseline information and data relating to the scale and significance of horticulture production and exports from Sub-Saharan African countries in driving climate change compared to production in other countries1. This was prepared to inform DFID staff in developing their public statements on the issue of Sub-Saharan exports, and to support them in discussions on future research and on policy formation; b. working with the Food Commission, assessed for the National Consumer Council (NCC) the practicality of benchmarking food retailers’ practices and policies to help consumers to shop more sustainably2. The report for the NCC 1 Wangler, Zoe (2006) Sub-Saharan African Horticultural Exports To The UK And Climate Change: A Literature Review Fresh Insights Number 2, International Institute for Environment and Development, available at: http://www.sustainweb.org/pdf/SSA-airfreight.pdf 2 Dalneny Kath, and Wangler, Zoe (2005) Greening Supermarkets: Do Supermarkets Help Consumers Buy Sustainable Food?, the Food Commission, available at: https://www.sustainweb.org/publications/greening_supermarkets/ Zoe Wangler Proof of Evidence 1 of 2 | Page 2 led to multiple surveys and reports from the NCC which I also contributed to, including their 2006 publication “Greening Supermarkets”; From 2001-2004 I worked as Project Analyst, and a member of the management team at the Tenderloin Neighbourhood Development Corporation. This well- established non-profit organisation builds and manages affordable housing and provides social services to tenants in San Francisco’s Tenderloin district. The evidence which I have prepared and provide for this appeal in this proof of evidence is true and I confirm that the opinions expressed are my true and honest opinions. Zoe Wangler Proof of Evidence 1 of 2 | Page 3 1 SUMMARY 1.2 This proof of evidence relates to a planning appeal made pursuant to Section 78 of the Town and Country Planning Act 1990 in respect of a field to the south of Copyhold Cottages, formerly part of Wilbees Farm, Arlington, Hailsham, BN26 6RU (the Appeal Site). 1.3 The planning application the subject of this appeal sought permission for: ‘the siting of three temporary agricultural workers' dwellings for a period of 5 years together with an agricultural barn with PV array and alterations to existing highway access to provide three affordable smallholdings to new entrants to ecological agriculture’ (the Proposed Development). 1.4 The application was validated in March 2017 and has not been determined by the LPA, Wealden District Council (WDC). An appeal was lodged October 2017. The appeal was given the reference APP/C1435/W/17/3189734. 1.5 WDC’s view is that the application should be refused for two reasons: a. The Proposed Development “in combination with other plans and proposals would be likely to result in adverse effects on the integrity of the Ashdown Forest Special Area of Conservation (AFSAC)”. b. That there is “no clearly established essential agricultural need has been demonstrated as required by Saved Policy DC2 and paragraph 55 of the NPPF” and that the “scale and nature of the operation does not suggest strong functional requirements to be on the site, nor a sustainable financial case for the business”. This proof of evidence addresses the first of WDC’s reasons. 1.6 The Ashdown Forest has been designated as a Special Area of Conservation primarily in order to protect its Northern Atlantic wet heaths and European dry heaths. This heathland is vulnerable to gaseous ammonia and oxides of nitrogen, both from atmospheric pollution and vehicle exhaust emissions. The Zoe Wangler Proof of Evidence 1 of 2 | Page 4 most significant sources of these pollutants are emissions from fossil fuel combustion and ammonia (NH3) emissions from agriculture. 1.7 Air Quality Consultants (AQC) for WDC have found that the levels of NH3 and oxides of nitrogen (NOx) considered to be safe for healthland vegetation are being exceeded at the upper bounds of the critical levels at some roadsides within the AFSAC and adversely affecting 14 areas within 250m of the roads, representing 0.63 ha of the 1,630 ha of AFSAC. These pollutants they report are also being exceeded at the lower bounds of the critical levels at points across the heathland within the SAC. 1.8 WDC have taken the position that no new development should be allowed in any part of Wealden District or near the Ashdown Forest if the development generates additional vehicle trips or parts thereof. The council’s position is that applicants cannot guarantee that none of the additional trips will be through the AFSAC, and that any additional trip or part thereof will have an adverse impact on the AFSAC. 1.9 The author knows of no other authority which agrees with WDC’s position. This includes Rother District Council (RDC) and Tunbridge Wells Borough Council (TWBC). TWBC’s air quality consultants AECOM concluded that the TWBC Local Plan would have negligible or no adverse effect on the AFSAC even