Representation by Mr. Geoffrey Carpenter and Mr. Peter Carpenter (Mr. Geoffrey Carpenter and Mr. Peter Carpenter)
- Date submitted
- 25 January 2021
- Submitted by
- Members of the public/businesses
Deadline 7a Submission - In relation to the Applicant's Change Request 2 The Applicant is seeking a development consent order within Order Limits identified by red line showing their maximum extent. The Limit area overlaps the Carpenters land. It excluded Stoneacre Copse ("SC") identifiable from Schedule 4 of the Carpenters Deadline 1 Written Representations. The Applicant now identifies ‘ash dieback’ ("ADB") that affects ash in SC but didn't include the area in the Limits necessary for its Application. The Applicant identified in September 2020 rapid ADB spread and its consequence for landscape and visual mitigation of its development as “significant”. It seeks, at this exceptionally late stage, to change its plans to ensure the future baseline upon which its environmental statement ("ES") was based doesn't change as a result of an actual likely significant effect on the environment that it cannot rule out. The Applicant knew of ADB at the time of the original ES. The Arboriculture Report mentions ADB but not in this location. Whilst the first infection was confirmed in 2014, no further account is made of ADB in relevant LVIA documents. The assertion that ADB impact was more than "anticipated" accepts the potential for impact but indicates ADB was not adequately appraised. By contrast, National Grid's Sub-Station Extension ES (May 2013) immediately north of the Affected Land considered ADB before the first confirmed infection. ADB can be highly destructive to ash trees through leaf loss and canopy decline to basal trunk lesions. Decline rates vary. Some ash may have genetic tolerance. Owners should protect trees with limited signs of ADB. The key is monitoring and management. It cannot be said that the visual impact future baseline could not degrade rapidly (nor slowly). Such uncertainty undermines the validity of the Applicant's VIA and photomontages because its ES contains no reasonable worst-case scenario assessment of the proposals' impacts on visual receptors due to actual likely effects of ADB on canopies. The ADB survey (using Tree Council classification but without visualisations showing the reasonable worst-case scenario in the short to medium term) concludes on visual impact on certain residential receptors but excludes the Carpenters' properties. The ADB survey plan indicates high ADB progression at the western end of SC immediately north-east of those properties and adjudges, "losing ash in this woodland would have a significant impact on visual amenity". This judgement cannot coherently align with the assertion that ADB "will have one effect which is more adverse… only in relation to one receptor" and results in real doubt as to the robustness of the appraisal of ADB on visual impact and the ES's present and future baselines. To identify and seek to increase the Order Limits (and the extent of compulsory land take by inference asserted as being required) reflects underlying appraisal inadequacies and existence of a likely significant effect on the environment resulting from ABD. SC holds personal value for the Owners as the site of their father's ashes and, noting high sensitives to sustainably manage this woodland, they are exploring ABD management of their land as a real alternative.