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Representation by David Attwood (David Attwood)

Date submitted
21 February 2023
Submitted by
Members of the public/businesses

Representations submitted on behalf of David Attwood – Farm Business Impact ? The loss of land at Harp Farm for compensatory habitat creation, approximately 81.9 hectares, challenges the financial viability of the farming business, N&D Attwood. Fixed overheads will not reduce but be spread over a smaller area, severely impacting profitability. ? The profitability of N&D Attwood relies on the return from the arable enterprise. Disregarding land that is rented in, it offering no long term security of tenure, the land included in the DCO application amounts to approximately 20% of the arable area farmed. ? Approximately 72.3 hectares of the 81.9 hectares is at Harp Farm, one of two main holdings that are together ring fenced. The economic impact felt as a consequence of the loss of land at Harp Farm is exponentially worse than if the same applied to outlying farms. ? Modern farm buildings and grain stores will be made redundant with no prospect of alternative planning uses due to their size, specialist design and location in a rural setting, and other planning policy constraints, including the AONB designation, highways constraints and the proximity to the SSSI. ? The two main farms, Harp Farm and Boxley Grange Farm, are residential farms, each equipped with a range of modern and traditional farm buildings. David Attwood has two children and his succession plans are presently to leave each child with a viable farming unit. The proposed reduces Harp Farm to a productive arable area of approximately 147.7 hectares, resulting in a non-viable farm business. Attwood Family Impact ? David Attwood’s immediate family are all employed on the farm and their livelihoods will therefore be impacted by the loss of the subject land. Ecology ? The subject land is included in a Higher Tier Stewardship Scheme. The habitats managed by David Attwood under this Scheme support protected species. The habitats enhance the existing biodiversity and ecological value of the land, which will be lost. ? The proposed compensatory habitat will be new woodland. To align the new habitat with that of the neighbouring designated assets, it is assumed, in the absence of detail in the DCO application, that National Highways will create ‘Lowland Mixed Deciduous Woodland’, in accordance with the UKHab Habitat Definitions Guide. Using Defra’s Biodiversity Metric 3.1, the creation of this habitat would result in a loss of biodiversity from the existing mixed arable/stewardship habitat. A strategy that results in a reduction of biodiversity cannot be said to effectively mitigate harm. Alternative sites ? Alternative sites of open land that adjoin the SSSI and other designated assets, and in the same locality as David Attwood’s land, would be able to provide the same connectivity between habitats, create new habitats at a landscape scale and therefore be suitable as compensatory habitat.