Destruction of Doxey Marshes.

tek-monkey said:

Yeah, but think of the houses you can put on their current plot.

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I knew the Rugby Club had sold the 2nd pitch to TW, however I had no idea that all of the land had been sold and the club would be relocating to Doxey Marshes.

1JKz said:

I can't see any names, addresses, email and telephone numbers!

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If you look through the documents associated with the case (20+ pages of attachments) none of them are redacted. There are dozens labelled 'neighbour consultation response' (if I remember correctly, I'm not on the website right now) which include the personal info.

markpa12003 said:

I had no idea the Rugby Club were proposing to relocate. I thought there were looking to improve their existing facilities.

The inconsistencies shown by the BC in dealing with this application and the SCHC is absolutely shocking. If this application is approved and SCHC refused serious questions should be asked and a complaint made to the ombudsman. Ideally, there would be a judicial review. However, you need to have deep pockets to go down that route!

Stafford Rugby Club are getting funding from TW and have the backing of a major landowner, as such why do need to relocate to an area so environmentally sensitive....surely Riverway or Beaconside would be a better option.

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Yep - I mentioned in the Hockey thread that the position of the council towards these applications does seem to fly in the face of logic and public demand.
And unfortunately by the time it unravels the decisions will have already been made and a complaint to an ombudsman will be fruitless in overturning it.

When is the march? Already done one protest in the hot sun this week, but sure I can come out for another!

I've been having another look at some of the documents.

The response from Natural England, dated 15 April 2015, urges Stafford Borough Council to

have strong regard to the comments of the local wildlife trust in relation to wider biodiversity impacts.

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The response from Staffordshire Wildlife Trust details many reasons why the application should be rejected.

Should Stafford Borough Council go against the advice, of Natural England, to take on board the Wildlife Trust's objection, and approve the application then it would leave the door open for a judicial review as, under Section 28 of the Wildlife and Countryside Act 1981 as inserted by section 75 and schedule 9 of the Countryside and Rights of Way Act 2000, the Borough Council has various duties, including to conserve and enhance Sites of Special Scientific Interest. This includes the duty to consult with and take on board comments by Natural England.

Therefore, as Natural England have advised Stafford Borough Council to have strong regard to the comments of Staffordshire Wildlife Trust, the Borough Council would, if it went against such advice/comments, leave itself wide open to a legal challenge.

tek-monkey said:

Jesus, I had no idea that much land was being grabbed!

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Land and subsequently construction companies nibble away at land you would never have thought would cease to be green belt, look at the developments behind the rugby club started small, and now the fields across from Parkside, only a matter of years until Stone will become part of Stafford.

I'm out of the country on the 5th.

Can someone grab a complete stranger and convince them to go on the march, to make up my number?

Had a look at the plans for North Stafford last night which includes Sports Pitches, perhaps a better home for the Rugby Club?

markpa12003 said:

I had no idea the Rugby Club were proposing to relocate. I thought there were looking to improve their existing facilities.

The inconsistencies shown by the BC in dealing with this application and the SCHC is absolutely shocking. If this application is approved and SCHC refused serious questions should be asked and a complaint made to the ombudsman. Ideally, there would be a judicial review. However, you need to have deep pockets to go down that route!

Stafford Rugby Club are getting funding from TW and have the backing of a major landowner, as such why do need to relocate to an area so environmentally sensitive....surely Riverway or Beaconside would be a better option.

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Ombudsman a waste of time. All they do is push paper around for six months or so, then suggest some sort of damage-limitation excuse for the council, which it can choose to ignore, anyway. By that time it's too late. Judicial Review only costs about a hundred quid in the initial stage. If the council knows it will lose, they might back down, but not if it would offend a rich applicant, of course. If they fight it they have huge resources (ie. millions of our money) at their disposal.

The BC is pulling a similar stunt with the old Brooklands school site at the other side of the Marshes. What we need is an action group that can go through all the dodgy planning decisions and hit the council with a load of JRs (insert Larry Hagman jokes here).

If cost rings a bell it must only be cost of land, they are building from scratch? What about the uni, why not build it there? Bit of a slope granted but they could be on different levels, and the land will be up for sale. Somehow, cos I thought we owned it? Sure it was a state run institute, do they get to steal all the assets?

tek-monkey said:

What about the uni, why not build it there? Bit of a slope granted but they could be on different levels, and the land will be up for sale. Somehow, cos I thought we owned it? Sure it was a state run institute, do they get to steal all the assets?

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The Polytechnic was built, owned and run by the County Council when I was there. I have asked many times if any money changed hands when it was passed into the ownership of the University "Trust"*, but I've never got an answer.

* I use the word "trust" in its legal sense, I do not imply any actual trust being involved anywhere.

Thought as much, guessing they got it free then realised half of Stafford campus was worth 5x the stoke one. Laughing really, free land and now they're farking off

The Hawk said:

I've been having another look at some of the documents.

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I have done the same - apologies if this turns out to be a bit mahoosive but is a precis of the positions of those that matter. There may turn out to be formatting issues that i will try and address if necessary. Here goes...

Natural England 09/01/15

...we do not believe at present that sufficient information has been demonstrated that the development clearly outweighs nature conservation value or that measures to mitigate / compensate impacts are appropriate as proposed.

SWT 16/01/15

Staffordshire Wildlife Trust objects to the application due to the impacts to Doxey and Tillington Marshes Site of Special Scientific Interest (SSSI) and support the comments made by Natural England in their letter of 9 January 2015.

Biodiversity Officer (Bill Waller) 16/01/15

... In short I don’t think there should be any further development of any kind that close to the SSSI...

13/02/15

(Case Officer: I would inform you that I have received additional information on the above proposals. I would be obliged to have your further observations by 27 February 2015.)

There is no change to my comments

SWT 18/03/15

At this point we are still minded to object to the plans for a number of reasons, including that the design still does not minimise impacts to the SSSI, the loss of habitats and the overall function of the site in its own right is not adequately mitigated or compensated, and the current compensation proposed within the SSSI is not appropriate as stated by Natural England.

SWT 26/03/15

This application would appear not to comply with the NPPF in terms of minimising impacts to biodiversity, providing net gains in biodiversity or establishing coherent ecological networks that are more resilient to current and future pressures...

... The proposal does not comply with local policy in terms of the reasons for it clearly outweighing the nature conservation value of the site itself and the national policy to safeguard the national network of such sites...

... The proposal does not comply with the Green Infrastructure Strategy for Stafford, as it does not involve managing land adjacent to Doxey Marshes in sympathy, promote wildlife and sensitive access, or include net biodiversity enhancement or flood mitigation...

... We feel the role of the application site as a buffer and valuable habitat in its own right, protecting and aiding the SSSI's function while providing habitat diversity within the overall ecological unit, has not been fully reflected in the information provided. We feel that further information on the site’s status as a potential addition to the SSSI needs to be sought...

... The application site was within the original SSSI boundary, along with other areas of land, when it was first designated in 1977. It was excluded when the SSSI was renotified in 1989 under the Wildlife and Countryside Act 1981. We understand this was due to the site having a planning application active at that time, hence the rather irregular boundary. This is no longer the case, as all former permissions have lapsed...

... Overall, the value and status of the site needs to be clarified and understood before a decision is taken, and we strongly advise the LPA to obtain information from Natural England on the site’s potential status and the current SSSI review situation...

... SWT notes the amended layout which now avoids taking any land within the SSSI. However there would still be indirect impacts to the SSSI due to the removal of most of the site’s habitats and the alteration of its role as a link between the SSSI areas on each side and a buffer adjacent to existing housing...

... The LPA firstly needs to be sure that impacts cannot be reduced via Avoidance – can significant harm to wildlife species and habitats be avoided for example through locating on an alternative site with less harmful impacts? We feel this site is not appropriate for any development, and certainly not the best site amongst all other available land in the Stafford area for a rugby club...

... Doxey Marshes is very much an urban SSSI and has suffered, and continues to suffer, from development pressures on all sides. We feel that suitable alternative sites do exist for this development, that the Plan for Stafford Borough appears to have allocated ample space for new green space, and that affordability of land, although an understandable and unfortunate constraint, should not be a reason to compromise the future protection and enhancement of this sensitive area.

... Staffordshire Wildlife Trust submits an objection to the proposals, due to:

· Lack of information on the status of the site in terms of its potential inclusion in the SSSI and therefore broader impact on the national network of Sites of Special Scientific Interest.
· The site being inappropriate for development compared to other land available
· Likely impacts to the SSSI's notified features namely Snipe, as well as other birds that use the SSSI and the site itself.
· Lack of assessment of other developments regarding cumulative impacts
· The proposals being contrary to policies in The Plan for Stafford Borough 2011- 2031 and the Green Infrastructure Strategy for Stafford.
· The need to clarify in more detail the value of the grassland on site particularly for fungi.
· Lack of figures for the loss and gain of each habitat on the site, the value of these habitats and the net impact to biodiversity.
· Inadequate avoidance of impacts through the design of the layout. · Inadequate provision of habitat and species compensation.

Biodiversity Officer 27/03/15 – re “The Wildlife Trust’s full and comprehensive comments on the application”

...this degree of uncertainty and lack of information must lead to serious questions over the appropriateness of this application in its current location. It is my opinion that the questions asked above will not and cannot be answered satisfactorily and therefore we should refuse this application.

Natural England 02/04/15

The withdrawal of Natural England’s objection to this application does not necessarily mean that all natural environment issues have been adequately addressed, but that we are satisfied that the specific issues that we have raised in previous correspondence relating to this development has been met. Natural England, as stated in previous correspondence, is not in a position to give a view on issues such as local sites, local landscape character or the impacts of the development on species or habitats of biodiversity importance in a local context. We would therefore urge you to have strong regard to the comments of the local wildlife trust in relation to wider biodiversity impacts.

Case Officer (Mark Alford) 08/04/15

For clarification, the club do not need to justify why they want to move, but why this site is suitable when considered against other possible alternatives...

...However, it is noted that Natural England is not objecting to the proposals...

...Both Staffordshire Wildlife Trust and the Biodiversity Officer object to the proposals. The Wildlife Trust has been consulted as a neighbour given its role in the management of Doxey Marshes SSSI. It should be noted that their response does include an indication of their own aspirations for the application site in addition to the technical advice offered, thereby suggesting a potential conflict of interests...

... The recommendation is therefore to grant permission, subject to conditions...

... The reasons for the Council’s decision to grant permission for the development subject to the above conditions are:
...
6. To safeguard the character of the area, enhance biodiversity...
...
15. To minimise disturbance to wildlife of the Doxey Marshes Site of Special Scientific Interest
...
22. To enhance biodiversity (Policy N4 of The Plan for Stafford Borough)

23. To enhance biodiversity (Policy N4 of The Plan for Stafford Borough) (sic)
...
29. To minimise disturbance to wildlife of the Doxey Marshes Site of Special Scientific Interest





...

... cont...

SWT 15 (sic)/04/15

There are a number of inaccuracies in the Officer’s Report which we wish to address, as well as further comments on biodiversity we wish to make...

...Staffordshire Wildlife Trust (SWT) has commented on this application not solely as a neighbour, but as a nature conservation body... Our comments are related to impacts to the SSSI as a protected site and to biodiversity impacts generally... Staffordshire Wildlife Trust as an organisation does not have any ‘aspirations’ for the site and there is no conflict of interest bearing on our comments. We request this sentence be removed from the report, and would welcome an explanation as to which part of our response has indicated this impression...

... although the site received planning permission 25 years ago, the officer should clarify the relevance of this and the weight to be given, as legislation and planning guidance have changed vastly in this time...

...The summary given of Natural England's comments is over-simplistic... they are not commenting on aspects of local biodiversity importance, and urge the council to “have strong regard to the comments of the local wildlife trust in relation to wider biodiversity impacts.”...

...Additional proposed usage from April to September ...have not been assessed in terms of impacts to ecology... This information is required pre-determination...

... We question how the conclusion that the benefits of the development outweigh the impact to the SSSI when the final design of the site has not been submitted and impacts have not been fully quantified or accurately assessed...

... We would appreciate a response to our points, particularly with regard to the incorrect statements made within the officer’s report...

Natural England 15/04/15

I would reiterate that Natural England was able to remove our objection only after the applicants suggested no works within the SSSI would take place and only subject to the imposition of the specific conditions we requested. Additionally I would agree with your point 7 in the attached -

“The summary given of Natural England's comments is over-simplistic...”

- Unfortunately we aren’t resourced to comment those aspects but we would again urge regard to those who are better placed to comment on such issues.

Biodiversity Officer 13/05/15

Natural England has withdrawn its objection but states that it is not in a position to judge... The Wildlife Trust has made a number of comments on the application concerning the biodiversity impacts therefore we should be minded to take account of this. The Wildlife Trust have summarised their concerns below. The developer needs to be able to answer these questions before a decision is made...

...We are of the view that the proposals, from what can be seen of them, would not adequately mitigate or compensate for impacts to habitats and species on the site, or result in a net gain for biodiversity...

...It is not clear how the proposal will contribute to the priorities for habitats and species in the plan, and it would appear that currently the proposal would not contribute positively...

... Green Infrastructure Strategy for Stafford November 2009

The proposals are contrary to policies for Strategic Open Space Action Area ‘A’ – Doxey and Tillington Marshes, and also the Biodiversity Intervention Zone for Wetland Management Expansion.

The Plan for Stafford Borough 2011-2031

The application site is marked as Green Infrastructure in the Stafford Inset Map. Approximately 1 hectare of green land would be lost to hard infrastructure, without compensation...

Ecological Report 03/07/15

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Same old story of LPA selecting 'evidence' and parts of policies to suit their agenda, while ignoring or trying to keep other relevant info secret. The case officer's comments are total twaddle.

Below is a list of bird species recorded on Doxey Marshes, as per Staffordshire Wildlife Trust's Doxey Marshes Bird Report for 2009. I make no apologies for the length of the list, as it highlights the wide range of species that would be threatened by this development.

1. Red-throated Diver
2. Little Grebe
3. Great Crested Grebe
4. Red-necked Grebe
5. Manx Shearwater
6. Gannet
7. Cormorant
8. Bittern
9. Little Egret
10. Cattle Egret
11. Great White Egret
12. Grey Heron
13. Purple Heron
14. White Stork
15. Spoonbill
16. Mute Swan
17. Whooper Swan
18. Bewick’s Swan
19. Snow Goose
20. White-fronted Goose
21. Bean Goose
22. Pink-footed Goose
23. Greylag Goose
24. Canada Goose
25. Barnacle Goose
26. Brent Goose
27. Shelduck
28. Ruddy Shelduck
29. Egyptian Goose
30. Mandarin Duck
31. Mallard
32. Gadwall
33. Pintail
34. Shoveler
35. Wigeon
36. Teal
37. Garganey
38. Pochard
39. Scaup
40. Tufted Duck
41. Common Scoter
42. Goldeneye
43. Smew
44. Ruddy Duck
45. Red-breasted Merganser
46. Goosander
47. Osprey
48. Marsh Harrier
49. Hen Harrier
50. Montagu’s Harrier
51. Buzzard
52. Honey Buzzard
53. Sparrowhawk
54. Goshawk
55. Kestrel
56. Hobby
57. Peregrine Falcon
58. Merlin
59. Red-legged Partridge
60. Grey Partridge
61. Quail
62. Corn Crake
63. Pheasant
64. Water Rail
65. Spotted Crake
66. Coot
67. Moorhen
68. Common Crane
69. Oystercatcher
70. Little Ringed Plover
71. Ringed Plover
72. Grey Plover
73. Golden Plover
74. Lapwing
75. Knot
76. Sanderling
77. Turnstone
78. Dunlin
79. Curlew Sandpiper
80. Little Stint
81. Temminck’s Stint
82. Wood Sandpiper
83. Green Sandpiper
84. Common Sandpiper
85. Redshank
86. Spotted Redshank
87. Greenshank
88. Black-tailed Godwit
89. Bar-tailed Godwit
90. Curlew
91. Whimbrel
92. Woodcock
93. Snipe
94. Jack Snipe
95. Red-necked Phalarope
96. Ruff
97. Pectoral Sandpiper
98. Arctic Skua
99. Mediterranean Gull
100. Little Gull
101. Common Gull
102. Lesser Black-backed Gull
103. Black-headed Gull
104. Herring Gull
105. Great Black-backed Gull
106. Caspian Gull
107. Yellow-legged Gull
108. Glaucous Gull
109. Kittiwake
110. Little Tern
111. Common Tern
112. Arctic Tern
113. Black Tern
114. Stock Dove
115. Wood Pigeon
116. Collared Dove
117. Turtle Dove
118. Cuckoo
119. Tawny Owl
120. Long-eared Owl
121. Short-eared Owl
122. Barn Owl
123. Little Owl
124. Swift
125. Bee-eater
     
126. Kingfisher
127. Green Woodpecker
128. Great Spotted Woodpecker
129. Lesser Spotted Woodpecker
130. Skylark
131. Swallow
132. Sand Martin
133. House Martin
134. Meadow Pipit
135. Rock Pipit
136. Water Pipit
137. Tree Pipit
138. Yellow Wagtail
139. Blue-headed Wagtail
140. Pied Wagtail
141. White Wagtail
142. Grey Wagtail
143. Great Grey Shrike
144. Waxwing
145. Wren
146. Dunnock
147. Robin
148. Redstart
149. Black Redstart
150. Whinchat
151. Stonechat
152. Ring Ouzel
153. Wheatear
154. Blackbird
155. Fieldfare
156. Redwing
157. Song Thrush
158. Mistle Thrush
159. River Warbler
160. Cetti’s Warbler
161. Grasshopper Warbler
162. Sedge Warbler
163. Reed Warbler
164. Marsh Warbler
165. Lesser Whitethroat
166. Whitethroat
167. Blackcap
168. Garden Warbler
169. Wood Warbler
170. Chiffchaff
171. Willow Warbler
172. Goldcrest
173. Firecrest
174. Spotted Flycatcher
175. Pied Flycatcher
176. Marsh Tit
177. Willow Tit
178. Blue Tit
179. Great Tit
180. Coal Tit
181. Long-tailed Tit
182. Bearded Tit
183. Treecreeper
184. Nuthatch
185. Jay
186. Magpie
187. Jackdaw
188. Rook
189. Carrion Crow
190. Raven
191. Starling
192. Tree Sparrow
193. House Sparrow
194. Chaffinch
195. Greenfinch
196. Goldfinch
197. Brambling
198. Siskin
199. Linnet
200. Twite
201. Lesser Redpoll
202. (Mealy) Redpoll
203. Crossbill
204. Bullfinch
205. Hawfinch
206. Yellowhammer
207. Snow Bunting
208. Reed Bunting
209. Corn Bunting

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Since 2009 a few additional species have been recorded, including Red Kite and Bluethroat.

A number of "exotic" (escapes/feral) species have also been recorded, including Aylesbury Duck, Muscovy Duck and Black Swan.