Cemex Planning Application
Hound Parish Council members have objected to the Cemex planning application HCC/2021/0787 which refers to the proposed gravel extraction site on Hamble Airfield.
The objection has been raised regarding traffic, air quality and ecology.
I do not feel that Cemex’s reply has adequately addressed my previous concerns regarding air pollution and dust created by the proposed development, so my previous concerns below still stand.
Ecology currently onsite -
Currently lowland acid grassland with widespread shrubbery across the entire site, with scattered trees (semi-mature oak, english elm, silver birch, ash, whitebeam) mostly in the southern half of the site.
Grassland and scrub mosaic, hedgerows and woodland noted in Ecology survey to be suitable habitat for protected species including slow worm and common lizard. Most recent survey reports a good population of slow-worm and low population of common lizards, but assumes populations of both could potentially be exceptional. Noted to provide a very substantial area of grassland and scrub mosaic highly suitable for these species.
Grassland management following restoration is intended to enhance foraging opportunities and basking sites for reptiles. Site considered to be of Regional Value for slow worm and common lizard.
Hazel Dormouse - ecology survey noted no dormouse records within 2km of site - However, recent dormouse nests have been found in Westwood last year.
Hedgehogs - known to be classified as Vulnerable to extinction and subject of significant conservation efforts, reports that desk study shows 19 records of hedgehog within 2km of site - anecdotally, we all know there are many sightings of hedgehogs within Hamble and Netley, so it is extremely likely to be many hedgehogs on site.
3 x S41 Priority Species, 1 Nationally Rare species, 9 Nationally Scarce species, 1 Vulnerable species, 1 Rare species, and 7 Nationally Scarce - Notable species. Ecology survey noted favourable site habitat for these species was Scrub edge, Scrub heath and moorland, and Open short sward.
17 species confirmed as breeding onsite, including bird species of national conservation concern - skylark, linnet, song thrush (all Red listed), dunnock, common whitethroat (both Amber listed). Further species breeding on-site include Amber-listed Willow Warbler and Stock Dove. Protected species Dartford Warbler recorded on site 2017, and seen and photographed nearby in 2021. Site identified as being of value for species of conservation concern including kestrel, green woodpecker, mistle thrush, dunnock, bullfinch, house sparrow, starling, song thrush, redwing and marsh tit. Site identified as being of ornithological interest and value. Site identified to be of substantial value for overwintering flocks of nationally declining farmland bird species - skylark, linnet and meadow pipit.
Red listed Spotted Flycatcher and amber listed Green Woodpecker, House Martin, Swallow and Long-eared Owl were recorded during 2020 surveys.
Flocks of starling, meadow pipit, as well as linnet and skylarks were recorded within the more open grassland sections of the site, indicating the importance of maintaining and protecting these areas of open grassland for these Red listed birds which are known to be declining in Hampshire and nationally.
From Outline Landscape restoration - planning on using Glycosulphate to spray areas to reduce weeds prior to replanting. Glycosulphate is a non-selective herbicide noted by the International Agency for Research on Cancer to be “probably carcinogenic” in 2015. Some research suggests it may persist in the soil for up to a year, with some residues up to 3 years. . It has been found to potentially destroy beneficial soil microorganisms and affect earthworms. It is only approved for use for another 2 years in the UK.
Following restoration, planned to have community area in very north of site with 20 year management plan, area of woodland and grassed area with 10 year management plan in north of site (coincidentally the area highlighted as a “Countryside Gap”), with grassed area only in south half of site with 5 year management plan which will be managed with grazing or mowing. 39.019Ha rough acid grassland to be recreated (previously ?64Ha) - “re-establishing existing rough grassland with new field edge woodlands and scrub blocks habitat for reptiles and ground nesting birds, managed by regular grazing” - this appears to take up the larger part of the total area of the plot, and the claim is that this area will be
contributing to a large part of improving the biodiversity following extraction - “to provide a valuable habitat resource for the important fauna, including badger, foraging and commuting bats, ground-nesting birds, wintering birds, hedgehog, invertebrates and reptiles”. Therefore, this contribution to the improvement in biodiversity needs to be guaranteed and protected for longer than the proposed 5 years.
Biodiversity net gain calculated as being at 10.56%. Environment Act 2021 - all planning permissions need to deliver at least 10% net gain. This net gain across the entire site needs to be protected - Natural England states that this net gain should be secured for at least 30 years via obligations/conservation covenants (as stated in Cemex’s no 10 Ecology survey).
There are species on site that are covered by Biodiversity Action Plans (BAPs) - policy for protecting and restoring priority species and habitats - important for Skylark (open habitat, currently 19 territories mostly recorded in the north of the site - planned to become more woodland habitat), Linnet (less dense scrub, currently 4 territories mostly in north of site, designed to become more woodland habitat), House Sparrow, Dunnock (scrub), Bullfinch, Starling, Song Thrush. As most of the territories of the Skylark and Linnet are in the north park of the site, by changing this north part of the site into a more wooded area, this is likely to adversely affect these Red listed bird species of national conservation concern. The current restoration plan does not appear to adequately protect these species under BAPs as the replacement habitats does not match the habitats and territories currently established by these species - ie territories in open grassland are being replaced by broadleaved woodland, and there will be a permanent loss of approx 15.3Ha of existing scrub habitat on site, with the ecology survey suggesting that the magnitude of effect of losing this scrub will be “Moderate”.
Planned to be a loss of approx 0.026 Ha of broadleaved woodland.
Loss of 14 existing trees (0.51Ha of scattered tree habitat). Loss of 3 trees off-site. 21 new trees are proposed (0.7692Ha), but small young trees will not replace the habitat of large mature trees. Ecology report suggests these trees will take a number of decades to mature into more established woodland habitat.
Currently, the site is mainly lowland acid grassland. Proposal for redevelopment is that part of the existing acid grassland will be replaced by broadleaved woodland habitat, all in the Northeastern area rather than spread throughout the site which is the current state.
Trees to be felled
Includes Cat B2 Oaks, 1x Cat C Oak amongst others - important in biodiversity of local area.
Another Cat B Oak will be at risk of having its RPA damaged by the access.
There are many species living, breeding and feeding on-site, which are Red-Listed, classed as vulnerable to extinction, are species of national conservation concern, and species which are covered by policies to protect and restore the species and their habitats, with the current plan being to destroy their habitat over many years.
There have been found to be potentially exceptional populations of protected species.
The site is currently considered to be of regional value for some species found there.
The current plan for restoration will be permanently altering and destroying the type of habitat available for the most vulnerable of these species by significantly reducing the lowland acid grassland available to these species, and changing a large percentage of the site into broad-leafed woodland, possibly in order to be able to increase the total biodiversity of the site. What lowland acid grassland is proposed to be left, is only proposed to be protected for 5 years, leaving the remaining most vulnerable, nationally declining and highly protected of species (which includes the skylarks, linnets, meadow pipits) that require the open grassland to potentially losing their remaining habitat once this protection finishes. The Environmental Act 2021 asks for protection of the increase in biodiversity to be protected for at least 30 years.
I recommend we object on impact to Traffic, Air Quality, and Ecology, and ask that any restoration of the site respects the habitat and territory of the protected and vulnerable species, with retention of open acid grassland across the site, maintaining the scattered trees and scrubland which currently exist on the site, and that the entire site is protected following restoration for at least the 30 years as per the Environmental Act 2021.
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