Representation by Gloucestershire Wildlife Trust (Gloucestershire Wildlife Trust)
- Date submitted
- 21 March 2024
- Submitted by
- Members of the public/businesses
Dear Sir/Madam, Please see below Gloucestershire Wildlife Trusts response to the DCO application for the M5 junction 10 improvements scheme. Coombe Hill SSSI and nature reserve As per our response to the previous consultation held in 2022 (please see our previous response titled ‘GWT M5 J10 statutory consultation 2022’ for context), our main concern is the impact the road scheme will have on Coombe Hill Canal Site of Specific Scientific Interest (SSSI) and nature reserve. We are disappointed to see that the HRA screening (4.2.43) rules out any impact from the scheme to Coombe Hill. The reasoning given is that the large developments in North-West and West Cheltenham, which the project will support, will be delivering the required mitigation to counteract the additional recreational pressure. The proposals for these developments include suitable alternative green spaces, integrated into the sites, to help mitigate recreational pressure. The report states that NE are content with this approach, which we acknowledge. However, the scheme doesn’t only support development in the area. It also makes Coombe Hill more accessible via the M5, which is a separate matter and isn’t considered. There also remains uncertainty and concern over the approach to mitigation for the proposed North-West Cheltenham development (Elms Farm), and until this is resolved we are not content with the approach taken for this scheme. The shadow HRA for the Elms Farm outline application (16/02000/OUT) quoted the Planning inspectors report for a nearby, previous development (Planning Inspectorate APPG1630W203257625), suggesting that the mitigation paid to GWT for that development (of only 140 homes) covers all required mitigation, which is simply not the case. The inspectors report for that development clearly stated that “the sum of £100,000 which is offered through the Unilateral Undertaking meets all the requests which the GWT has made and so I conclude that it represents a proportionate contribution to be made from this development.” This makes clear that this contribution does not apply to any subsequent development. We raised this point in our response to the Elms Farm outline application. A decision on Elms Farm has not yet been made and there are no guarantees around the delivery of the Green Infrastructure (GI) proposed for that scheme. Even if the Elms Park and Golden Valley developments deliver the most effective, attractive, multi-functional GI possible, the addition of thousands of extra people (over 10,000 at Elms Farm alone) will see additional recreational pressure at Coombe Hill. Large expanses of effective GI at development sites will help to lessen the pressures faced, but the level of development in the area will still create an impact on the site, which needs to be managed and where possible mitigated, to avoid irreversible damage. This scheme needs to acknowledge the role it has in this. Our response to 16/02000/OUT also stated that, without sufficient mitigation in place, Coombe Hill might need to have restricted access to the public going forward, which is not an ideal outcome as we want to connect people with nature, not limit access to it, but we need to protect this valuable habitat. Nature recovery and compensation We are disappointed to see the loss of very high distinctiveness habitats as part of this scheme, including lowland meadow and native species rich hedgerow with trees, valuable, core areas of habitat and an important part of Gloucestershire’s nature recovery network. When looking at the plans, the compensatory habitat proposed for the loss of lowland meadow, which is species-rich road verge that would need to reach good target condition, could be difficult to achieve. It will depend on the strategy and management plan for the verges. Although road verges can support high levels of biodiversity, poor management and nutrient pollution can lead to deterioration. We note that a Road Verge Compensation strategy is not yet available for comment and will be produced at the detailed design stage. Until we have seen the content of this, there is no evidence that the loss can be ‘compensated’ which will be a requirement of the scheme gaining permission as per 186(a) of the NPPF. Biodiversity Net Gain We note a BNG% of 11.59% has been stated in the Environmental Impact Assessment. As the neutral grassland that will form the road verge is a substantial contributor to habitat units in the BNG metric, failure to deliver it to a ‘good’ standard would likely mean failure to deliver 10% BNG. We understand that 10% BNG won’t apply to NSIPs until late 2025, however, given that this project is being delivered by local government, we would expect to see a strong commitment to achieving at least 10%. We also note that an older version of the BNG metric (3.0) was used, when a newer version (4.0) is now available. We would be happy to discuss any of the comments made above further. Regards, Laura Chester Planning and Green Infrastructure Lead On behalf of Gloucestershire Wildlife Trust