Angela
Rayner - Housing & Communities Secretary of State
Dear
Minister's,
FAO:
The Rt Hon Angela Rayner MP (Deputy Prime
Minister)
Secretary of State for Housing, Communities and Local Government
House
of Commons
London
SW1A 0AA
&
FAO:
The Rt Hon Steve Reed OBE MP
Secretary of State Department for the Environment, Food and Rural
Affairs DEFRA.
Seacole
Building
2
Marsham Street
London
SW1P
4DF
Re: Urgent Action Required to Protect Wildlife and Natural Habitat
from Housing Development: WD/2024/2257/MAJ
I hope this letter finds you well.
I am writing to draw your urgent
attention to a pressing conservation issue in Lime Park, Herstmonceux,
where housing development company's are planning to divert the natural
surface water supply from two mature ponds that are critical habitats
for several species, including the legally protected Great Crested Newt
(Triturus cristatus) and Common
Toads (Bufo bufo).
The proposed development would redirect all rainfall from the adjacent
fields at Lime Cross, away from these ponds, risking the drying up of
these vital aquatic ecosystems. As you are aware, Great Crested Newts
are listed as a Priority Species under the UK Biodiversity Action Plan
and are protected under the Conservation of Habitats and Species
Regulations 2017. The disruption of their habitat, especially in light
of ongoing climate
change-induced water level drops, poses a severe threat to their
survival.
Key Arguments for Conservation:
Legal Protections: The Great Crested Newt is protected under both UK and
European
legislation, making it illegal to disturb, harm, or destroy their
habitats. Any action that jeopardizes their habitat would be in direct
violation of these laws.
Ecological Importance: These ponds support a rich diversity of wildlife,
including ducks, moorhens, and various amphibians, playing a crucial
role in the local ecosystem. The loss of these ponds would have a
cascading negative impact on biodiversity.
Climate Change Considerations: With climate change already affecting water
levels, it is imperative to conserve natural water bodies that serve as
crucial habitats for wildlife. Disrupting these ecosystems would
exacerbate the negative effects of climate change on local biodiversity.
Sustainable Development: While development is essential, it must be
balanced with environmental conservation. There are sustainable
alternatives that can be explored to ensure the protection of these
habitats while meeting development needs.
Given the above points, I urge you to intervene and recover the planning
application submitted by the housing development company. It is
essential that an Environmental Impact Assessment (EIA) be conducted to
fully understand the consequences of this project on the local wildlife
and habitats. Additionally, alternative solutions that do not harm these
vital ecosystems should be considered. Such
as alternative sites for genuinely affordable house building, including
the field at Lime End Farm, that the surface water from Lime Cross, it
is proposed should be diverted towards, together with a Bypass, so as
not to exacerbate the pothole
situation in the Village of Herstmonceux, any further. And so avoiding
use of the proposed junction near a brow of a hill on the A271.
Your prompt attention to this matter would be greatly appreciated by the
local community and conservationists who are committed to protecting our
natural heritage. I am confident that with your support, we can find a
balanced solution that upholds our environmental responsibilities while
supporting sustainable development.
Thank you for your time and consideration.
Yours sincerely,
[Your Name and Address]
Not
too much about potholes, and green belt is something to be careful
about, unless for Net Zero homes, but then protected species are also
under threat, if the alleged destruction of Badger sets in Chapel Row
are anything to go by.
The Conservative house building boom has been continued by the Deputy Prime Minister, Angela Rayner, with some slight variations in direction, more toward affordable homes. Hurrah! But, there is a marked lack of policy change as to recurring
potholes in over-developed regions, and little improvement in the transport infrastructure to support the proposed new homes in a little village in
East
Sussex. In one case detailed
above, passed by a Conservative council, with support from a Conservative government, even though
James Brokenshire was invited to call in the proposed application in 2015, as being totally contrary to local and national policies, but has since been increased in number from 70 to 140 additional houses - also under the previous Conservative
council, with Parish council (alleged) fingers in pies and
non-declarations of interest. Easy to check by the Register of
Interests, but no easy to cross reference with who was in the committee
chambers, since they deliberately do not record this information, to
continue to rule the roost - regardless as to the law.
The concern is that the CIL (Community Infrastructure Levy) that is supposed to go toward improving the local amenity, will be, or maybe even, has already been squandered by the local authority on
Pension
plans, or other investments, robbing and detracting from the human rights of this particular village, as being less important than other areas, in discrimination of the right to peaceful enjoyment of property, of those living in and around the village.
Whereas, there are literally hundreds of other potential sites that are far more suitable, if
national planning policy is to be discarded (as was in this case) in any event. And that being the case why overload villages that do not and cannot possibly benefit from infrastructure improvements, the roads being too narrow, where there are other far more suitable locations that are better served by roads that may be improved, or that are already served by dual carriageways, etc.
Put simply, the planners in this council (and many others) do not appear to know very much about sustainable
development, hence forward planning, but rather just looked to infill in villages, without taking in the bigger picture. In some case feathering the nests of certain
landowners, in this case Tim Watson (now deceased), who it appears may have had connections with Area Plans committee members, that were un-declared. Such impropriety undoing any grant of permission, so
obtained, should that be shown to be true. (Sharland v Sharland)
But all of this background does not detract and should not draw fire from the underlying potential to destroy the habitat of a protected species.
Ponds
are frequently endangered by developers of housing estates, as is this
one near Herstmonceux
in East
Sussex,
England. In this case, Latimer Homes and the Clarion Housing group are
proposing drainage that is sure to dry out the ponds and cause major
upset to the wildlife in this location that depends on the water from
adjacent fields to survive. This is a whole ecosystem, including ducks,
toads, fish, herons, and great crested newts. The houses are more over
development of executive homes for renting landlords, where in the UK
there is an acute shortage of genuinely affordable housing, so
perpetuating the rent trap that young families cannot escape in their
lifetime. The A271
is already
overloaded with traffic that routinely causes dangerous potholes in the
village high street every year. And the proposed access is so dangerous
that it has been named locally: Suicide
Junction. It is
unclear if the local farmer at Lime End Farm is agreeable to the
proposal, or if the local
Wealden
District Council will
be exercising their compulsory purchase powers. The initial application
in 2015 came as a shock to local residents, with over 300 people
attending the village hall to object to yet more inappropriate local
development. In addition, the location is home to the only
electricity
generating station
in the world, featuring battery load levelling from C. 1896. Hence, a
potential UNESCO
world
heritage site.
This
network of ponds has been sustained for over 40 years by surface water
runoff from the adjacent field. This established flow of water has
become a prescriptive right under the Prescription Act 1832, meaning
that the continued flow of water cannot be legally obstructed after such
a long period of uninterrupted use.
Diverting this water source will have a devastating impact on the ponds,
likely leading to their desiccation and the destruction of the
established ecosystem.
Critically, the pond network is an integral part of the setting of the
unique local heritage asset: the only surviving early electricity
generating station in Europe. This building is a significant historical
landmark, and its setting, including the ponds and surrounding
landscape, contributes significantly to its historical and architectural
significance. The rural setting and surrounding countryside are part of
the charm of the technology that nestles in this estate, as a time
capsule. This historical and environmental context may well be protected
by other conservation law, and that is now under threat. The proposed
land drainage diversion would severely compromise this historical
setting and diminish the heritage value of the site.
CLIMATE
CHANGE
Species are already being impacted by anthropogenic
climate
change, and its rapid onset is limiting the ability of many species to adapt to their environments. Climate change currently affects at least 10,967 species on the IUCN Red List of Threatened Species™, increasing the likelihood of their extinction. The Bramble Cay melomys (Melomys rubicola) is the first mammal reported to have gone extinct as a direct result of climate change. Previously found only on the island of Bramble Cay in
Great Barrier
Reef, its habitat was destroyed by rising sea
levels.
Corals form one of the most biodiverse ecosystems, yet they are among the most rapidly declining species groups due to mass bleaching, disease and die-offs caused by rising ocean temperatures, as well
ocean
acidification. Meeting the Paris Agreement’s target of less than 2°C rise in global temperatures is essential for the survival of
coral
reefs.
In addition to increased rates of disease and degraded habitats, climate change is also causing changes in species themselves, which threaten their survival. Rising temperatures have led to ecological changes including the migration of Chinook salmon (Oncorhynchus tshawytscha) to Arctic rivers, while behavioural changes in species include earlier breeding times for North American tree swallows (Tachycineta bicolor). Climate change is also causing significant physiological changes. Warmer temperatures during egg incubation are causing imbalanced female to male sex ratios among Endangered green sea turtles (Chelonia mydas), with females accounting for 99% of newly hatched turtles on some nesting beaches. Genetic changes attributed to climate change include hybridisation – interbreeding as species’ habitats change – affecting species such as the common toad (Bufo bufo) and green toad (Bufotes balearicus) in southern Italy.
Here
in the UK, we have a number of protected species on the Red List, or,
such as the Great Crested Newt, or just undervalued, such as the Common
Toad.
NATURE CONSERVATION
The conservation of species depends on the maintenance of their habitats. Habitat classifications can be founded on structural or abiotic features, but they are often based on syntaxa, conveying a summary of ecosystem properties that are difficult to measure or model. Preserving the diversity of extant plant communities is thought to safeguard the survival of typical species not only of plants, but also of animals, fungi, and microorganisms, and the maintenance of current ecosystem processes.
In Europe, phytosociological units were important in defining habitats (biotopes) in the CORINE and EUNIS systems, which contain a comprehensive classification of European habitats. The CORINE classification provided the basis for inclusion of habitat types under the Habitats Directive of the European Union, the most powerful legislative instrument for nature conservation in Europe. In the Union-wide conservation network Natura 2000, phytosociologically defined habitat types are crucial for the delimitation, inventory, monitoring, and management of protected areas.
In landscape planning and policy making, phytosociological units are used to underpin normative judgments and set conservation priorities by evaluating their naturalness and endangerment. Naturalness, or its reciprocal concept, hemeroby, ranks communities by the strength of human influence and consequent alterations of species composition, structure, and ecological processes. Methodologies range from assigning community types to classes of naturalness to complex evaluation schemes taking detailed account of community features.
Reporting the degree of threat to the habitats of a region, red lists of plant communities are another potentially powerful policy tool in nature conservation. Compilation of red lists presupposes a comprehensive and well-established phytosociological classification for the target region, including detailed knowledge about distribution, commonness, and temporal trends of syntaxa. With the advent of phytosociological databanks and GIS, red list compilation is moving from pure expert judgment to a process driven by relevé data and rule-based decisions on the vulnerability and conservation value of plant communities. While vulnerability considers current distribution, quantitative development in the past, and foreseeable threats in the future, conservation value may be based on the frequency and status of component red-listed plant species, naturalness of the inhabited sites, and responsibility of the target region for the global preservation of a syntaxon.
WHY IS IT IMPORTANT
In addition to their intrinsic value, species play essential roles in ecosystems, which in turn provide vital services to humans. Climate change interacts with threats such as habitat loss and overharvesting to further exacerbate species declines. The decline of species and ecosystems can then accelerate climate change, creating a feedback loop that further exacerbates the situation.
ALTERED FOOD CHAINS
The effects of climate change on even the smallest species can threaten ecosystems and other species across the food chain. For example, increased sea-ice melt and
ocean acidification in the
Arctic Ocean is reducing krill populations, threatening the survival of whales, penguins and seals that depend on krill as a primary food source. Because species lowest in the food chain are often among the first impacted by climate change, the full impacts of species loss may not be seen for decades.
The types and severity of diseases that affect crops are also changing. For example, incidences of Fusarium ear blight on wheat are increasing due to a rise in temperature and rainfall. These can produce mycotoxins that make wheat inedible and cause crop losses of up to 60%.
WHAT CAN BE DONE
Efforts to conserve species and mitigate the impacts of climate change require an approach that includes meeting climate targets, conserving and securing habitats, and helping species adapt.
Reduce CO2 emissions. Long-term and cohesive actions to meet Paris Agreement targets for emissions reductions can prevent temperature increases from exceeding the critical 2° threshold. This will have greatest impact on reducing the impacts of climate change on species and ensuring ecosystems continue to provide habitats for species and their wide-ranging services to people.
Help nature to help people. By functioning as carbon sinks, ecosystems like forests, wetlands and tundra combat climate change and play a key role in helping countries meet their
Paris Agreement targets. Restoring ecosystems and reforesting in biodiversity-friendly ways with climate-change resilient species can further increase their effectiveness. Nature can also help people adapt. For example, conserving coastal species such as mangroves and coral provides an ongoing source of food and supports livelihoods, while also providing protection from tsunamis, storm surges, and other extreme weather caused by climate change.
Help species cope. Species are the building blocks of ecosystems, and reducing the risks to species posed by climate change is critical. Sound conservation responses include helping species adapt to shifting climates and preparing strategies for coping with extreme weather events such as heat waves, floods and droughts. Minimising non-climate stressors is essential for increasing species’ future resilience to climate change. Humans’ responses to climate change, including changing land use (e.g. planting biofuels) and building hard infrastructure (e.g. wind turbines and dams), may have negative impacts on species if biodiversity is not considered.
Make use of conservation tools. A variety of useful conservation tools is available. The
IUCN Red List provides up-to-date information on species’ threat statuses, while the IUCN Species Survival Commission offers guidelines for assessing species’ vulnerability to climate change. The Integrated Biodiversity Assessment Tool (IBAT) provides basic risk screening on biodiversity, enabling governments and businesses to mitigate their impacts on species and biodiversity. The
US Army, for example, uses IBAT to better understand how potential bases might affect biodiversity.
