Response to the Wimpey Planning Application

Wildlife and Conservation Issues

The QED Allotment Group in the document ‘Making Biodiversity Happen’ (1998) stated that:

The Tilehurst Poor’s Allotment land has been an open space for at least 200 years and has developed a range of flora and fauna that reflects this. Although some sections have been cultivated, others have fallen into disuse presenting opportunities for wildlife to flourish undisturbed. The construction of 61 dwellings will put pressure on the habitats outside the development zone resulting in a decrease in the area’s value to wildlife.

Habitats present (See list of flora and fauna and map references A,B,C)

1. A long strip of woodland (2.5 acres) encompassing a steep wooded valley and a stream known as the Withies. This area comprises mixed woodland with bird cherry, white willow and ash with large hawthorn trees bordering the copse. Understorey trees include spindle, holly and yew and two specimens of box were found in 1998.The wide range of ground flora included 2 ancient woodland indicator species. There are fox earths and an active badger sett here.
2. Site A (1 acre). This is on a steep slope with sporadic streams or springs near the Armour Hill boundary. Within the last decade the land has been well cultivated and watercress was grown. Pigs were once kept in the buildings that were recently demolished. Until very recently some of this land was let and used for growing garden crops and raising poultry. It is bounded on one side by woodland owned and used as an educational and play area by the 79^th Scout Group. Badgers have excavated a small sett here that extends into the Scout Group land and part of which is currently (September 2001) occupied by a fox.
3. Site B (1.5 acres) contains some derelict buildings at its northern corner, but most of it has been well cultivated until recently. There are 14 marked out plots with potential for three more. There is one building currently let to a non-conforming user. The edge of this site, which has a common boundary with Site C, appears in the Planning for the Future document to be at the brow of Kentwood Hill. All the southern half of this area commands fine views over the Thames Valley to the Chilterns.
4. Site C (2 acres) is relatively level land and is divided into about 12 plots. There are two compounds containing non-conforming users. Several of the plots are used for poultry. This site shares boundaries with Kentwood Hill and the Recreation Ground. .
5. Remaining allotments (4.5 acres). Most of the 75 or so allotments on the remaining site are well cultivated. Nearly all are currently let.

In 1998 Dr Neil Gale identified a rare plant, Babington’s poppy, on site C.

Site in context of local natural areas

The site is part of a green link between McIlroy Park, Gypsy Lane and Arthur Newbery Park. Green links are relatively continuous areas of green space joining areas of similar habitat through the built environment. They are formed by the combination of parks, open spaces, playing fields, railway cuttings and embankments, footpaths, even tree-lined roads and roadside verges. Green links may not be areas of high nature conservation value themselves, but provide a corridor between such areas to form a network of sites. (freely quoted from Friends of the Earth publication Planning for the Planet). Reading’s Local Plan policy NE 3 refers to those already identified and the Council will seek opportunities to consolidate, extend and enhance the network.

When the West Reading Woodlands Plan survey was carried out in 1997/98 by Henrietta Westergaard this site was not included. The first map in the final report shows this site as a substantial area of open space surrounded by Blundells Copse, McIlroy Park, Arthur Newbery Park and Lousehill Park. It should be the subject of a detailed survey for flora and fauna before any important decisions are made involving alteration of use.

Wildlife present (species list in Appendix)

The Landscape and Ecology Report presented by Wimpey Homes is totally inadequate in this respect. Section 4.2 and 4.3 admit that the fieldwork was carried out in December, hardly the best time for vegetation, breeding birds or reptiles. No habitats were mapped or described and no target notes given only ‘casual records’ of flora and fauna were made. This falls well short of a Phase 1 habitat survey, the minimum required for this level of development. The badger survey did not attempt to penetrate the dense bramble scrub adjacent to Armour Hill or to look at the land owned by the Scout Group. If it had, the presence of other setts would have been apparent. Although currently occupied by a fox, the one on land proposed for the housing in Armour Hill could well be re-occupied in the future. As a result, the picture presented of the current use of the site by the badger clan is incomplete and the mitigation suggested is therefore insufficient. A single 1m wide corridor along the edge of the site and not following existing routes is not sufficient. The report admits that ‘the entire allotment area displays well-worn badger paths and snuffle holes’ then suggests confining the badgers to fenced-off section with a single narrow track out. This may look neat on a plan, but is hardly adequate to safeguard the future of this badger clan.

Appendix 3 gives a preliminary list of flora and fauna. This is by no means comprehensive as access to large sections of the area is now prohibited. Reference to this list will show that a number of protected and scheduled species are present. Besides the badgers, protected by the Protection of Badgers Act 1992, slow-worm, grass snake, at least three bat species and stag beetle have been recorded. All these species receive protection under the Wildlife and Countryside Act 1981 and Subsequent Amendments. In the Protected Species section of PPG 9 Nature Conservation, paragraph 47 states

There is a wide variety of garden and woodland birds including song thrush, a National Biodiversity Action Plan (BAP) and Red Data Book species. Proposals for extensive housing will inevitably result in loss of breeding and foraging resources for all these animals.

The local BAP draft list includes bluebell, stag beetle, song thrush, nightingale, grass snake, pipistrelle and noctule bats all of which have been recorded from the allotment site. These animals and plants all have Action Plans for their protection and some have activities designed to enhance and extend their habitats.

The local policy NE 5: TREES, HEDGES AND WOODLANDS is relevant:

There is a range of trees, and important hedges along Armour Hill and Kentwood Hill that also merit assessment. A list of plants has already been made and the hedges appear to have been present for at least 200 years making them even more important as established habitat.