SAVE HALGAVOR MOOR

This story has hit the headlines and rightly so. Plans to massively urbanise around Bodmin have gone largely unopposed but the intention to consume the beautiful Halgavor Moor is a bridge too far…

The CPRE, Environmentalists, Bodmin Town Council, the local MP and the Residents are united in their opposition to this blatant destruction.

Currently awaiting a decision is planning application PA20/10618 for 540 new houses to be built on West Halgavor Moor. Cornwall CPRE, Natural England and the Environment Agency, have all sent in objections to this. 

  • This massive project threatens nature across the board. Whilst the allocation of this land for building was deplorable, such safeguards as were built into the allocation need to be properly fulfilled by the developer, to mitigate the brutal treatment being metered out on our wildlife and ecosystem.
  • Our support the Environment Agency’s objection and concerns is based on the lack of sufficient information or adequate answers to the serious environmental consequences of this proposal.
  • There appears to be no adequate plan to responsibly accommodate building houses on this site, much of which is wetland, where elsewhere there are a substantial number of mature trees and Cornish hedgerows.

At an emotional public meeting in Bodmin last year, attended by over 400 people, including the campaign coordinator Christine Howard, Cornwall Council Planners were left in no doubt about the strength of opposition to building on Halgavor Moor.  People departed however with the distinct impression they were simply not being listened to.

CPRE National Chief Executive, Crispin Truman, commented during a recent visit to Cornwall, “There is an absence of grass roots democracy in Planning which needs to be restored”.

Cornwall CPRE Chairman Richard Stubbs commented: “We are being asked to submit to an urban wasteland of unemployment and second homes. This will do nothing for Cornwall except pollute our rivers, increase CO2 emissions and destroy yet more of our natural world, the balance of which is so essential for our well-being.  For the sake of decency and common sense, now is the time for Cornwall Council to listen to the wishes of local people and environmentalists alike.  If not, we will fight this for the months and if necessary, years to come”

‘Wildlife habitat is in catastrophic decline’  Chris Packham, Springwatch

Please email us to support our campaign – admin@cprecornwall.org

DETAILS OF THE PLANNING OBJECTION WE HAVE SUBMITTED – MARCH 2021

PA20/10618 | Outline planning for proposed residential development of up to 540 dwellings with associated car parking, public open space, landscaping and infrastructure (access considered all other matters reserved) | Land Off Halgavor Road Bodmin Cornwall

Whilst we regret Cornwall Council’s decision to allocate the pristine Halgavor Moor as building land, they did so subject to a proper environmental impact report. This report or reports would include consideration for Halgavor Moor’s many mature trees, its role as a significant area of wildlife habitat and how suitable this largely wetland site would be for housing, along with the implications for its drainage polluting the River Camel.

The independent reports that the developer has been required to commission clearly show the futility and in fact the sham, of this site’s suitability for building houses. Additional reports have also been produced, from the Environment Agency and from Natural England both of which express concern at the Developer’s Planning Application’s lack of answers or apparent commitment to the substantial environmental challenges involved.  In Cornwall CPRE’s opinion, for the developer to say ‘We are going to put together an action plan’ is simply not good enough.

In addition, the developers have put through a plan which would involve some land not even allocated for building. If this was agreed it would discredit the whole allocation process and the public consultation that went with it.

We are therefore asking the elected councillors who are entitled to vote on this ill-considered planning application, to do so with their conscience and turn this application down – outright.

Cornwall CPRE has already demonstrated that the Council is over-providing for the building of new houses and Halgavor Moor is a perfect example of this.  No mitigating plans by the developers can conceal the transformation of this ancient Cornish moor into a suburban housing estate.  Anyone can work out that if you concrete over 27 hectares of green fields and cut down hundreds of trees, that the destruction of our declining wildlife and the environmental damage, including the generation of CO2, will be huge.

Even in the two years since this land allocation, public awareness and support for the value of nature and our Cornish landscapes has gone from strength to strength.  Cornwall Council is deeply committed to this project, too deeply in our opinion but in light of the new thinking on the environment, they have a clearly justified route to rejecting this planning application.  This is because the over provision of housing on such a site would clearly be in breach of their own high profile policy on Climate Change.

 

ENVIRONMENTAL IMPACT REPORT – Key Points

Access   Cornwall Site Allocations Development Plan DPD states that the main vehicular access should be onto Lostwithiel Road, where the junction should be appropriately located to enable the delivery of a continued highway route into the Halgavor Urban Extension East allocation (Bd-UE2b); this new junction will enable early phases of this allocation to proceed. A highway contribution will be required from this development towards the delivery of a new junction from Carminnow Road, over the railway line, into the Bd-UE2b allocation. Delivery of this entire site will not be permitted until the new Carminnow Road junction and route through the Bd-UE2b site on to Lostwithiel Road is in place.

The Development Proposals incorporate an alternative access location and arrangement, in the form of a roundabout, approximately 300m further to the south from the signalised junction option. This is 48m beyond the southern extent of the allocation boundary. Accordingly, the red line boundary of the Proposed Development extends beyond the allocation boundary into open countryside to include a field that has not been allocated for development. We believe that this conflicts with the aims of the Local Plan to protect the open countryside from inappropriate development and is not a feasible alternative.

There are also unresolved issues with Cornwall Council’s preferred access route.  These include gradient challenges, made ground, potentially contaminated, removal of woodland covered by TPO, is a Habitat of Principal Importance (HPI) and Cornwall Biodiversity Action Plan (CBAP) habitat. It is considered this loss would have a permanent Significant Adverse ecological effect at a local level for which there is no mitigation possible. Furthermore, there is also the risk of degradation to retained woodland as the result of accidental damage or construction activities within root zones, and through effects of contaminated run-off. We believe that this access proposal is also unfeasible.

River Camel – Special Area of Conservation  Special Areas of Conservation (SAC): Subject to the legal tests of the Habitats Regulations development will not be permitted unless it can show it will not have an adverse effect on the integrity of the designated site, whether direct or indirect, having regard to avoidance or mitigation

The application could have potential significant effects on the River Camel Special Area of Conservation (SAC). The Environment Agency, a consultee, raises concerns in its response dated 04 February 2021 regarding the impact of nutrients from the develop on the Camel River SAC and calls for an Appropriate Assessment to be carried out to identify the scope and scale of mitigation measures required to ensure that the development will not increase nutrient loading to the estuary. Natural England are the competent authority for reviewing the Appropriate Assessment and we recommend that the application is not determined until Natural England are satisfied that the development will not have any adverse impacts on the River Camel SAC.

The River Camel SAC qualifying features, bullhead and Atlantic salmon, are particularly vulnerable to increases in phosphate levels which can arise in the final effluent which is discharged from Sewage Treatment Works (STW) to water courses. Elevated phosphorus levels can result in enhanced plant growth leading to a drop in dissolved oxygen levels, affecting fish survival, and can have negative impacts on food supply, the state of spawning gravels and egg survival. Therefore, an increase in phosphorus and point source pollution incidents could result in adverse impacts on these two qualifying features of the SAC.

Ecology and Biodiversity   The assessment identified several significant effects to ecologically important features, both on and close to the Application Site. This includes significant adverse effects during construction and operation on The River Camel SAC, Bodmin Beacon LNR, hedgerows, mature trees, grassland, waterbodies, amphibians, bats, breeding birds, dormice, European eel, invertebrates, reptiles, otter and hedgehog.

There are a number of limitations and constraints affecting the outputs from this work. Data collected during the field surveys is non-exhaustive and provides a snapshot of the habitats/ species present at the time. Therefore, the possibility of important ecological features being missed due to survey timings, lack of evidence or absence during surveys cannot be ruled out.

Livestock (cattle) presence meant that the extent of the reptile survey was limited to certain fields and therefore a full survey for reptile presence across the Application Site could not be undertaken.

 Access was not possible to areas of the watercourse up- and downstream of the Application Site to undertake a full survey for otters.

 The Biodiversity Net Gain assessment is based on a number of assumptions on the amount of habitat loss/ degradation. A detailed assessment will be required at Reserved Matters Stage.

Dormice distribution in Cornwall is patchy and mainly understood to be focused in east and central Cornwall. The species is declining in the UK. Therefore, the Application Site is considered to be of County importance for Dormice.

European Eel. A record of European eel (SPI, Cornwall RDB) from 2006 was provided by ERCCIS adjacent to the Application Site within the watercourse that runs along the southern boundary. The watercourse and potentially some of the ditches provide suitable habitat for European eel. European eel numbers have declined markedly and they are considered to be critically endangered on the IUCN Red List. The Application Site is therefore considered to be of at least County importance for eel.

Riparian Mammals 7.91 Evidence of otter (EPS, SPI, CBAP) was recorded along the stream adjacent to the southern Application Site boundary, including spraint and potential resting places/ hovers. Otters are widespread in Cornwall’s river catchments and the River Camel downstream of the Application Site supports a strong population. It is likely that the Application Site’s stream forms part of a wider home range for otter and is considered to be of County importance.

Given the presence of the watercourses within and adjacent to the Application Site, which enter the River Camel downstream, it is considered that construction risks could include run-off of land-based sediments, pollution incidents (e.g., chemical or fuel spills), increased water run-off rates and contaminated water run-off. Whilst these impacts would be temporary, they could result in longer-term impacts on food resources for the SAC qualifying features such as otter and bullhead. In the absence of mitigation, these impacts are predicted to be Significant at the European level.

Policy 28 (Infrastructure) states: ‘Development will be permitted where: It would be supported by appropriate infrastructure provided in a timely manner.’ This implies that the provision of new development will only be permitted provided suitable infrastructure (such as a suitable capacity of a Sewage Treatment Works) is in place to ensure no likely significant effects arise. Until this is established, it can be predicted that the development could have an adverse effect on the SAC at a European level.

Flooding   Cornwall CPRE support the Environment Agency’s objection to this application on the grounds that insufficient information has been submitted to demonstrate that the proposed development will be safe from flooding over its lifetime.

We believe that the development is contrary to The National Planning Policy Framework Section 14 paragraph 155 which states that inappropriate development in areas of risk of flooding should be avoided by directing development away from areas at highest risk.

We believe that the development is contrary to Policy 26 of the Cornwall Local Plan – Flood risk management in relation to flood resilience, potential contamination of ground and surface water, increased surface water runoff, reduced groundwater recharge increased water usage demand and increased foul drainage.

Heritage  The HEP Team have consulted the Cornwall & Isles of Scilly Historic Environment Record and note that a heritage asset, MC041408 HALGAVOR MOOR Medieval field system, is within the proposed development area. In addition, there is potential for paleo-environmental archaeological deposits within Halgavor Moor to be contained within the development area. These known heritage assets provide an archaeological potential for the proposed development and the likelihood for further archaeological discoveries. Any groundworks may therefore disturb buried archaeological features, or paleo-environmental deposits and/or artefacts present.

It has been found that the construction of the Proposed Development would result in damage to three of the four identified buried archaeological remains to the point where their archaeological interest would be lost, resulting in a Minor to Moderate Adverse significance of effect, depending on the significance of the remains affected.  The proposed actions could not completely mitigate for all the loss, and so a Minor Adverse residual significance of effect would remain.

Need   The sites allocated for Bodmin, in the Plan as submitted, provide for approximately 2,350 dwellings. Added to the existing supply of 2,252 homes, the total forecast supply would amount to 4,602 dwellings, 48% greater than the LPSP requirement of 3,100 dwellings. These allocations, Bd-UE2, Halgavor Urban Extension and Bd-UE4, Callywith Urban Village, are reliant on significant highways upgrades which will lengthen the time for their delivery until beyond the Plan period.

The Housing Delivery Test states that for 2019/2020 only 2423 houses were required but 3103 were delivered.

It is our assertion that the need for this development has not been established and that it would be contrary to Cornwall Council’s action plan to address the Climate Emergency declared on 22 January 2019 which focuses on how we live, how we travel how we reduce waste and how we enhance our environment.