No firm evidence has been presented as to why it is necessary, justified or reasonable to remove the Local Nature Reserve designation to accommodate the SDA. It is stated that the site has been identified to help meet future housing needs and that the LNR forms part of the Scraptoft North Strategic Development Area. However the LNR itself forms only a small part of the overall site. Whilst it may mean reducing the number of houses it has not been demonstrated that the LNR cannot remain in the event of the golf course being developed.
The proposed de-declaration appears initially to have been largely justified on a consultant's report submitted by the site promoters dated May 16. This alleged the LNR was generally of poor quality with little formal access or interpretation of the site. However, Natural England (NE), the Government's statutory advisor, say that local authorities should explain why the impacts on an LNR cannot be avoided or mitigated and why all or part of the LNR cannot continue to be managed for its statutory purpose. NE also draws attention to the NPPF which gives some strong steers that the Council should be helping to achieve the Government's aims for biodiversity. This raises a key question whether de-declaration of the LNR meets the objectives of sustainable development and whether this is in line with the core principle for planning that it should contribute to conserving and enhancing the natural environment and reducing pollution. NE advise that local authorities should consider partial de-declarations where it is possible to bring about improvements in the quality of the remaining LNR to counteract the loss in land area.
Contrary to the conclusions of the promoters report, a site visit undertaken by ecologists from Leicestershire County Council reached rather different conclusions. Their report in May 17 states that little of the site has changed significantly in quality since the previous survey in 1999 that led to the LNR declaration in 2002. Apart from the north eastern part of the site the rest of the grassland is not over-grazed and has similar species composition and habitat description to that recorded in 1999. The report goes onto to say that with the exception of the north-eastern part, the site meets current Local Wildlife Site criteria for scrub- grassland habitat mosaics. In July 17 the promoters commissioned a further survey of the LNR by Ecological Planning and Research Ltd. This report seems to reach similar conclusions to those of the County ecologists and recommends that any development should be focused on habitat polygons that are of lower biodiversity interest.
The Council are proposing to designate part of the site as a LWS however, my concern is that this is not a statutory process and does not provide the same level of protection as LNR status. LWS status does not preclude development and the landowner's consent is required. It is not known if this would be forthcoming.
The supporting evidence for the SDA includes a note on a Green Infrastructure Strategy for the SDA. This mentions the creation of a new park to the north of Scraptoft Brook partly on the site of the LNR. The note states the park would be around 100 mm deep extending to the north providing a range of natural habitats. However an accompanying infrastructure plan dated May 17 provides an indicative layout showing GI / open space. The area set aside for the park on this plan appears significantly smaller than the existing LNR. In fact it appears to fall well short of the 100m stated in the note on GI. I have measured the LNR field from Beeby Road and it is approximately 130m to the field gate. I estimate that the depth of the area shown on the GI plan to be less than half that and this would result in a significant reduction in the area currently designated as LNR. Furthermore the report prepared by the County Council ecologists includes a map at appendix 5. This proposes a much larger area for the Local Wildlife Site than put forward by the promoters in their note and accompanying GI Plan. The lack of clarity on the area that would remain undeveloped and protected as a site for nature conservation is of great concern to the local community and is not helping the plan making process.
The proposed SDA is also in conflict with the Scraptoft Neighbourhood Plan. Policy S11 on Biodiversity highlights the diversity of habitats within the Parish which includes the Local Nature Reserve forming part of the Green Wedge with the City of Leicester, five wildlife corridors and other landscape features. The Plan seeks to protect these and to retain and enhance the Local Nature Reserve. The examining Inspector did not propose any changes to this policy.