Hello again
New documents and comments from Forest Holidays(FH) were lodged on the ENC website on 18th August. If you had already sent an objection you will (probably) have had a letter from East Northants Council listing the new documents and pointing out that NEW objections are welcome. There's loads of new stuff to read and we really hope you may feel able to make further objections to their responses.
Below are some suggestions for possible areas that you may feel able to comment on before 17th September. Please don't try to tackle them all. Best to choose just one (or two?) points... something that you feel you can express strongly in your own words. If everyone says the same thing these objections will be ignored.
Yes, it's very complicated!.... but well worth the effort, so please do something if you can.
Best wishes
Barrie Galpin
On behalf of a group of Fineshade Residents Email: fineshade.wood@zen.co.uk
1) How to object
The reference number for the application is 14/00195/FUL and it can be found online at
Objections can be made online, or simply emailed to planning@east-
Or by letter to Planning comments, East Northamptonshire Council, Cedar Drive, Thrapston NN14 4LZ.
All comments must include your name and address and the reference 14/01156/FUL. The consultation period ends on 17th September.
We suggest you also put at the top: Objection relating to documents published 18th August
1) Comments/objections on Road Access
New stuff is mainly contained in the document called Forest Holidays response to Transport Assessment review and objections 18.8.14
This documents is headed: Response to Transport Assessment review and objections
Key objection: Timing of survey
Our previous objections highlighted that they had surveyed the road before Easter and not during the holiday period. This response seems ludicrous:
"By their nature traffic flows are variable on an hourly, daily, weekly and seasonal basis. The traffic surveys were commissioned at a time of very good weather in Spring and evidence of the sunshine hours for March was included in the Transport Assessment. The traffic survey on the Fineshade access road was completed over a period of 2 weeks to learn about flows.Traffic flows may be higher in the summer months but this means that the impact of the known traffic generation to the cabins will make up a lower proportion of the overall flows and therefore have a lesser impact."
Key objection: Sunday traffic
Page 3 lists revised estimates for weekend traffic movements (again based on survey data from early March, before the main holiday period started and the caravan site was fully open) However, figures are produced only for Saturday, while the applicant's own survey, conducted in March, shows that Sunday traffic was much heavier. (see Appendix E of their original document)
Key objection: Construction vehicles
The document provides some new details of the type of construction vehicles, but crucially only in relation to “the construction of the cabins”. These vehicles will include low loaders, long wheelbase 7.5 tonne tracks, occasional articulated trucks, bulk delivery on 10 ton trucks and transit vans. What this list does not include is the type and number of vehicles needed for the construction of the additional 2 miles of vehicle tracks, parking and passing places. How many lorry-loads of roadstone is this?
Key objection: Cyclists and caravans
The document, which purports to deal with our objections, makes no reference to use of the lane and A43 junction by cyclists or to the special problems faced and caused by caravans. There is no reference to our concerns about winter conditions.
Key objection: No offer of funds
The documents states that FH will not be providing funds to improve the A43 junction, even with skid resistant patches since "such improvements are not justified".
Key objection: Recent traffic problems
Some of us experienced the total gridlock caused by FC mismanagement of a nationally publicised Gruffalo event on 5th August. We can certainly mention this in comments about current over-use of the road. (We have some photos if you want to use them) The FH covering letter concludes that at the A43 junction "the risk of a queue remains very small and the junction will continue to operate safely" . If you have recently experienced a queue at that junction or have recent evidence of it not operating safely please include this information
2) Some new wildlife surveys
Details are contained in the document called Final Ecological Report 18.8.14
Key objection: Surveys not complete or inadequate
It appears that even this "Final" report is still incomplete. Second sentence of Executive Summary: “Some of these surveys are still to be completed”
Bats
Survey has now been carried out by means of walking around the edge of the site (so-called transects) and just 4 remote bat detectors in the interior.
"The assemblage of bats recorded indicates that Fineshade Forest is likely to be of at least local value for roosting and foraging bats, and the presence of Myotis species and barbastelle bats suggests that the Forest may be of county value for bats."
Dormice
Not surveyed for spurious reasons
Birds
No specific bird surveys have been carried out - which, in itself, is an appalling omission. But FH surveyors have incidentally recorded Nightjars in both April and June. This constitutes sufficient evidence to claim Probable Breeding and would make the wood of at least county if not regional importance. There is also confirmation of breeding Woodcock, Tree Pipits, Grasshopper Warblers and recent records of Turtle Dove and Willow Tit. 9 Red list species and 9 Amber list species. Avoidance measures are proposed (no vegetation clearance will take place in the nesting bird season etc) 30 bird boxes to be erected
Badgers
No specific survey - they think all active setts are to the west of the site. Foraging paths present on the site.
Reptiles and Amphibians
All four species of reptile found throughout the site. Further surveys of ponds for amphibians confirm presence of Great Crested Newts and the locally uncommon, Palmate Newt. Measures to "displace" reptiles are proposed (reducing height of tall vegetation etc)
Flora
A second survey was undertaken on 20th July 2014 to identify certain species that would be evident at this time due to their flowering period, such as species of sedge. This survey brings the total of Axiophytes (worthy plants in need of protection) to 50 and
Ancient Woodland Indicators to 21.
Invertebrates
No invertebrate surveys were considered necessary despite strong objections from Butterfly Conservation etc.. Glow-worms recorded in many location
Area of access road
Surveys here confined only to a walkover survey on a single day. This was "limited to the route of the road i.e not the full area within the red line boundary"
Key objection: Refer to (and perhaps quote) expert objections
A strong objection has been published from RSPB joining those from the Wildlife Trust and many other conservation groups and individual experts. These can be found on the ENC website under External Documents and then Application - Consultation or Request
3) Mitigation and Enhancement Area
The amended planning application includes "an area of woodland measuring approx 3.7 Ha to the south west of the the application site for the purposes of a Mitigation and Enhancement Area and "inclusion of forest rides within the red line area to provide a link between the development Site Area and the mitigation and Enhancement Area".
Key objection: Failure to provide environmental enhancement.
Ecological mitigation in the broadest sense involves: Avoidance (e.g. avoid area or particular times of year), Mitigation (reduce adverse impacts. Eg tunnels under roads), Compensation (offset damage that’s unavoidable by creating new habitat)
Ecological enhancement involves improving the ecological condition of the development site (or an alternative site) after the development is complete. Ecological enhancement measures must, therefore, be over and above any avoidance, mitigation and compensation measures required to neutralise the impacts of the development on wildlife.
(More detail in a useful Natural England Document on their website)
The new documents fail to show that Fineshade Wood will be a better place for wildlife after the development
Key objection: The new area is too small and, since restoration is already under way, it cannot count as compensation.
Where is it? Approximately 1 km SW of the site of the nearest cabin! It is the first cleared bit of wood on the left as one walks south from Top Lodge along the bridleway towards KIngs Cliffe. It was cleared of conifer in 2010 and is regenerating nicely. FH claim that ""in the absence of development it is likely this area would be allowed to regenerate to broadleaved woodland." This seems to denigrate aims and successes of the Forestry Commissions own "Ancient Woodland Project" - of which this area is a part.
FH are trying to claim that this small area which is already being restored by the FC can in some ways compensate for the very large undisturbed areas where they plan to create 2 miles of new roads and accommodation for 350 people.
Why are they doing it?
The newly published "Habitat Management Plan", section A6 gives details of what management is proposed here and why. The section starts
The development will affect areas of open grassland with scattered trees, an uncommon habitat within the wood. The areas retained around the lodges will be subject to increased disturbance, therefore reducing their potential for some of the bird species which have been recorded, including nightjar, grasshopper warbler and tree pipit. Compensatory measures require that suitable habitat is created and maintained in perpetuity outside the boundary of the development.
The areas of "open grassland with scattered trees" which are referred to here comprise a total of 15.5 Ha, according to the FH "Woodland Management Plan"
Key objection: How will reptiles and other wildlife get to the new area?
FH covering letter refers to forest rides and there are red lines drawn showing these linking the new area and the development area (see thick red lines drawn on site plan 47A). The only detail about this is on page 10 of the Habitat Management Plan which refers vaguely to maintenance of ride margins. Once again existing FC plans, drawn up before the FH application, show that these rides are to be opened up, so this cannot be counted as part of the enhancement and mitigation package.
Can anyone produce a cartoon showing an adder looking at a signpost that says"mitigation area this way"? !
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