Action for the River Kennet is a charitable organization dedicated to the conservation of the ecology of the River Kennet. We have over 500 members. Our members are people interested in the preservation of the Kennet against the threats posed by over abstraction, pollution, and riverside development. Our members include, but are not limited to, most of the riparian owners of fishing interests on the upper Kennet. We also have many members who regularly give up their time an energy to take part in conservation activities on the river.
The River Kennet has one of the greatest biodiversities of any English chalkstream. The English chalkstreams are globally environmentally special. There are few other temperate chalkstreams in the world, two in France and three in an area of Russia. We can firmly state a little considered point " that this makes the River Kennet as important to global bio diversity as the Brazilian rain forest and any threats to this must be considered with extreme care.
In summary we believe that this proposed development of 24 houses to be a significant and entirely unnecessary threat to the ecology of the Kennet and would have serious effects both up and down stream. We are strongly of the opinion that absolutely no development should be allowed on or near the riverbank outside of an existing urban area. Even within urban areas measures to prevent any form of run off or additional light pollution should be highly developed.
We do acknowledge the importance of the Chilton Estate to the environment of the area and we commend the Estate for many of the works they have undertaken. We do not accept that this development is critical to the future strategy of the Estate.
We are therefore writing to lodge a formal objection to Planning Application 9/02451/OUTMAJ submitted to West Berkshire Council by Southern Management Ltd on 7th December 2009.
We request that the application be called in for an Environmental Impact Assessment. The environmental studies included in the application are highly flawed.
We also understand that the application pre-empts the work being carried out through the Local Development Framework. We are not qualified to comment further on this other than to state that we cannot believe urban development out side of existing town boundaries and so far from shops and schools is remotely justified and should be barred on any measure of sustainability.
Where ARK is more qualified to comment concerns the likely impact on the fishery and on invertebrate populations, with inevitable consequential damage to birds and mammals, such as the kingfisher and the otter. We have looked at this proposal with two of our members, Hungerford Town and Manor Fishery and the Eddington Fishery and we have been informed by their knowledge. The brown trout is a signature species of a chalkstream and it is fishing interests that are primarily responsible for the preservation of the river environment.
Water Framework Directive
Under the terms of the the European Water Framework Directive we have an obligation to bring our water bodies to ‘good’ ecological status or good ecological potential by 2015. The River Kennet in Hungerford is already failing to meet this target and the proposed development will severely limit the likelihood of it ever improving.
We would like to make the following observations:
1. Threat to viability of Eddington fishery
The proposed development threatens the viability of the Eddington Fishery. No recognition of the value of this is noted in the developer’s proposal.
2. Inadequate ecology survey area and methodology
The developers have employed surveyors who seemed to have surveyed a river in a completely different universe. We are confident that this section of the river and the margins and fields alongside would have the normal profile of many other similar sections of the Kennet despite the poor environmental management of the field in question. This is unrecognized in the developer’s surveys.
3. Impact on aquatic invertebrates
It is highly likely that the development proposals would also lead to a degradation of the aquatic environment, which would impact upon the aquatic invertebrates. These species’ are extremetly vulnerable to to incidental and minor pollution and increases in sediment loads.. Although there are still a number of species in abundance it is known that populations of many invertebrates have crashed in the past 50 years and the river’s hidden creatures can ill afford any further development along its banks.
4. Threats to the SSSI river corridor
It cannot be stressed enough the value of a river corridor to a wide cross section of wildlife. This is threatened by
a) re-siting of footpath alongside the river where the disturbance from humans and dogs would totally change the environment
b) buffer zone breaches " once houses were sited close to the river occupants would soon come to think of the river as their own and humans can often fail to understand the importance of wildernesses " even those as small as a few metres square are priceless - and the strimmers would soon be out tidying these up.
c) domestic pet damage " cats and watervoles do not mix well " cats do more destruction than any other species in the country.
d) destruction of bankside habitat
Unsurprisingly, as we see such ignorance regularly, the developers’ river corridor survey suggests clearing the north river bank of bankside 'scrub' and that a revetment may be required to protect the bank and prevent further erosion. In fact, the north bank of the river is a natural mix of emergent vegetation, relatively dense undergrowth and trees, including a mature oak and is a rich habitat for wildlife, in particular for songbirds of conservation concern.
e) urbanisation of the river corridor
The proposed development would create a break in the open land currently free from encroachment, which is a feature of this section of river for several miles, even where passing through Hungerford. This open land allows wildlife to commute and forage along the river without undue disturbance. A development of 24 houses with associated street lighting so close to the river bank would urbanise the River Kennet corridor at this point and would create a break in this important wildlife corridor.
Finally, although of less direct concern to Action for the River Kennet, and as it is currently protected by the AONB status of the area we feel that the proposed development would be in full view of an historic and SSSI protected river setting and the AONB watermeadows and would damage the setting.
Conclusions
Summary of planning objections
The planning application submitted by Southern Management is in breach of the statutory Local Development Framework process. Building on AONB land is not a sustainable solution to any planning issue or housing shortage in Hungerford.
The site scores low on sustainability relative to other potential development sites in and around Hungerford and its visual impact on the SSSI River Kennet setting and watermeadows would be severe.
The site also threatens the viability of the Eddington Fishery and threatens the ecology of the SSSI River Kennet corridor. The Environmental Impact Assessment Screening Report is based on the ecology reports commissioned by the developer which are incomplete in their scope and content.
Environment Impact Assessment is essential
The Environmental Screening opinion was sought by the developers from the planning authority without consideration of one of our member’s survey reports. Thus their request as to whether a full Environmental Statement was required with the application, was based only on their own surveys. The developers’ ecology report has not considered the potential impact on fish, which are mentioned within the SSSI citation. Failure to adequately consider all the wildlife information that is available undermines the adequacy of the EIA screening and the conclusions about the environmental impact of the development.
We therefore request that the Council’s response, which indicated that an EIA was not required be reviewed and that the application should be called in for a full Environmental Impact Assessment.
