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