Download Elton Reservoir Housing Allocation

Elton Reservoir Housing Allocation – objection. DP Bentley ecological Consultant.
The open land between Bury and Radcliffe to be destroyed
Lack of consultation
The lack of consultation has been breath-taking. The process is contrary to Bury Council’s own
guidelines thus:
“How will the Council involve you?
3.16 The following table lists some of the activities and methods the Council will consider using
when undertaking consultation exercises in connection with the Local Plan. The methods used will
be tailored to suit the scale and nature of impact of the decisions to be made and the particular
needs of people being consulted:
Material made available on the Council’s web site, in Council offices at Knowsley Place Reception,
Town Hall Reception and selected local libraries (see our Statement of Community Involvement web
page on http://www.bury.gov/10738 for a list). The ALLOCATIONS AND NOTES ARE NOT FREELY
AVAILABLE ON THE COUNCIL WEBSITE.
Send letters and emails to database contacts, including targeted consultation letters for key
community groups. The Council may consider more targeted consultation where residents may be
more directly affected by proposals. NOT DONE.
Advertise via social media on Facebook & Twitter. NOT DONE.
Where possible, place articles in:
local newspapers;
‘Planzine’ - the department’s e-newsletter sent to a database of contacts and
Using other online news sources as appropriate.
Use posters on notice boards in prominent locations including town centres, civic suites, markets,
leisure centres and public open spaces. NOT DONE.
Council held a public consultation on the wettest, windiest day of the year and told few people.
Never told me. This consultation is contrary to Bury Council's Statement of Community Involvement,
and thus may not be legal. http://www.bury.gov.uk/index.aspx?articleid=10738
The importance of the Habitat Mosaic
The open space around Elton Reservoir contains 10 different council-designated Sites of Biological
Importance and a river. This is the most concentrated and diverse group of wildlife sites in Greater
Manchester. Present are large open waterbodies, small ponds formed in marlpits, brickpits, coal
shafts and inundation areas, lowland streams - with cut off sections, a canal, a river and riverside
habitats, mill goits, marshland, reedbed, berry-rich hedgerows, shrubland, woodland, hedgerow
trees, vegetated industrial mineral workings, working farmland of improved dairy grazing land, and
semi-improved grassland with for example hay-rattle flower, old farmsteads supporting bats and
owls and other nesting birds. There is a network of well-used public footpaths allowing people to see
a working countryside with Highland Cattle, milk cattle, beef cattle, sheep and free range poultry as
well as horses, and of course the abundance of wildlife. The area draws bird watchers from not just
Bury, but the whole of Greater Manchester and indeed the North West. The canal towpaths and
footpaths attract cyclists and long distance path users, and Elton Reservoir hosts a Sailing Club.
Industrial heritage is represented by the reservoirs, the canal, the embankment of an ancient horsepulled railway connecting with the canal, railwaylines -active and closed, the goits, and the ponds
formed in old workings. There is a Bronze-age burial site in the field next to Radcliffe cemetery and
crematorium - this is a landscape which our ancestors have cherished as a final resting place for
thousands of years. Metrolink passes the area and shows people entering the main town of Bury
what a lovely green place the town is.
If you draw a line from the southern parts of Stockport across Greater Manchester to the north of
Bury across a solidly built up conurbation there is only one substantial area of open water in a
setting of grassland, woodland and hedgerows. That is this proposed Housing Allocation of Elton
Reservoir. Gorton Reservoir is a large waterbody but it sits in a well-manicured golf course. The
importance of the Elton Reservoir Housing Allocation for migratory wildlife, local wildlife and
informal recreation cannot be over-stated. And Bury’s Labour Council seeks to trash it all to pursue
Labour’s choice of ACCELERATED GROWTH, which lies on top of faulty population growth statistics.
To object send an email to [email protected] by 23.59 on 16th January 2017 citing the area you
want to protect and giving your full name and address.
The importance of Mammals in the Elton Reservoir Allocation Area and the undesignated Wildlife
Corridor across Pilkington Fold/Spen Moor.
The area supports a wealth of mammals including Roe Deer, Brown Hare, Rabbit, Badger (tracks
seen and photographed), Red Fox, Stoat seen on hinds lane between Elton Reservoir and Withins
Reservoir, Weasel, Mink, Brown Rat, Short-tailed Field Vole, Wood Mouse, Grey Squirrel, Hedgehog,
Common Shrew between Elton and Withins, Mole, and Otter, which is known from the adjacent
River Irwell and also Roch in recent years. Seven species of bats have been recorded.
The Brown Hare has already been expelled from Spen Moor where records of it were unlawfully
ignored in the planning process by Bury MBC. The Brown Hare is listed by the UK Government as a
United Kingdom Biodiversity Action Plan Priority Species, given a 49% decline recorded between
1995 and 2002. This is now succeeded by the UK Post-2010 Biodiversity Framework (or “Biodiversity
2020”) and Priority Species are termed Section 41 species i.e. species “of principal importance for
the purpose of conserving biodiversity” covered under section 41 (England) of the NERC Act (2006)
and therefore needing to be taken into consideration by a public body when performing any of its
functions with a view to conserving biodiversity. Concerns cited are the loss of roughs in farmland
and the loss of mixed farmland and an increase in predation. The housing allocation seeks to
effectively wipe out the farmland of this area, which mixed and non intensive, as well as increase the
population of dogs and cats in the area many-fold.
The site supports Hedgehogs – which is listed by the UK Government as a United Kingdom
Biodiversity Action Plan Priority Species, given a 20% decline recorded over 4 years prior to listing as
a UKBAP species. Concerns cited are traffic density, fragmentation of habitats, need for hibernation
sites, need for hedgerows and wide field margins.
The importance of the undesignated wildlife corridor for mammals across Pilkington Fold between
the wider countryside and Elton Reservoir allocation cannot be over-stated. It that area is closed
then there is no other linkage. An earlier linkage was lost when Peel Estates closed the old
railwayline in order to progress the building on land at Black Lane, Radcliffe. A corridor must be
maintained across Pilkington Fold. A Wildlife Corridor must be designated.
Seven protected Bat species have been recorded in the affected area. The South Lancashire Bat
Group, in a 1.5km radius circle centred just north of Dofferfold Farm at Elton Reservoir, have
recorded in recent times UK and European Law protected bat species Daubentons, Common
Pipistrelle, Soprano Pipistrelle, Noctule and the Eurobat Priority species Nathusius Pipistrelle. Angela
Graham has provided records of Brown Long-eared and Whiskered/Brandts Bat. The Noctule, the
Brown Long-eared and the Soprano Pipistrelle are UK Biodiversity Action Plan Priority Species, i.e.
“Species of principal importance for the purpose of conserving biodiversity” covered under section
41 (England) of the NERC Act (2006) and thus they need to be “taken into consideration by a public
body when performing any of its functions with a view to conserving biodiversity.” For Noctules,
which had a 21% decline over 6 years prior to UKBAP listing, the JNCC website shows a requirement
to protect mature trees, wetlands, stream sides and other insect rich areas and boosting water
quality – developing by streams and in the reservoirs and canal catchments of the allocation site will
not help water quality. For Brown Long-eareds, which had a 20% decline over 7 years prior to
UKBAP listing, the JNCC website shows a need to protect countryside buildings with roost potential
as well as a landscape of woodland edges, hedgerows, small farm woodlands, deciduous and mixed
woodland, and connectivity between these – the site is dotted with hedgerow trees and those
associated with farmsteads. The advice specifically says this: “Ensure the retention and protection of
older trees for roosts is included in land-use policies.” For Soprano Pipistrelles, which had a 42%
decline prior to UKBAP listing, the JNCC website requires that the needs of the Soprano Pipistrelle
are considered in agri-environment, planning, water quality, wetland creation …..policies. The
Turley Peel Masterplan specifically shows they intend to destroy or encourage the destruction of
the Elton Goit Site of Biological Importance in order to remove the wildlife value and remove the
reasons preventing development – this is the largest area of marsh in the vicinity. The JNCC urges
the creation, expansion and improvement of key habitats including wetland and features such as
hedgerows and woodland edges. “Ensure adequate consideration of a landscape approach to the
conservation of Soprano Pipistrelle.” Alas the housing allocation does quite the opposite - a
landscape approach to the destruction of wildlife habitat and wildlife corridors.
Recent data shows that Nathusius' Pipistrelle may be widespread but rare in Britain and Ireland.
Nathusius' pipistrelle is considered to be vulnerable in the European context and is protected under
the ‘EU Habitats Directive.’ Furthermore, this species is listed in the United Nations convention on
the ‘Conservation of Migratory Species of Wild Animals’ (Bonn, 1979) via the EUROBATS agreement
(London, 1991). At present, threats to the species include: Habitat Loss – all of which will happen
due to the Elton Reservoir Housing Allocation; Maternity roost sites in buildings and trees can be
disturbed, damaged or destroyed by inappropriate land management or development; Loss of
hibernation roost sites in buildings, trees and underground sites can occur for similar reasons to
those above; Destruction of habitats such as riparian, wetland, woodland and unimproved grassland
has resulted in the loss of insect-rich feeding habitats; Land use Changes; Loss and decline of linear
landscape features (e.g. tree lines, hedgerows, ditches) remove important flyways and flight line
features along which bats hunt for insect prey; The trend for opening up land to produce large
uniform fields has led to a decrease in habitat diversity, and consequently a loss of feeding habitat
and decline of insect prey; May be effected by badly sited windfarms due to its migratory behaviour;
Use of Pesticides and other chemicals - The widespread use of pesticides in both the garden and the
wider countryside has led to a decline in the presence of insect prey; The use of inappropriate
timber treatment chemicals at roost sites (i.e. those that are toxic and persistent) can be directly
harmful to bats, and decrease the availability of roost sites. Elton Reservoir area contains a mosaic of
habitats including 10 different Sites of Biological Importance, streamsides, hedgerows, and semiimproved grassland (with e.g. Hay Rattle) as well as improved pastureland.
The importance of Birds in the Elton Reservoir Allocation Area and of the area for bird migration,
both regional and international.
Following is a list of birds from the Elton Reservoir housing allocation area. In this list are UK and EU
Protected Species, Biodiversity Action Plan Priority Species, and species requiring conservation
measures via the UK’s international obligations – the Bern Convention, the Convention on Migratory
Species and the African-Eurasian Waterbirds Agreement. There are Birds of Conservation Concern
Red List species, the most threatened UK bird species, whose conservation is of most concern, and
BoCC Amber List species, whose conservation is also of concern. Four species are globally threatened
and are listed by the IUCN. The remaining species are of Least Concern but are valuable part of this
wonderful and vital ecosystem.
Total birds species recorded by contributors to this list
186 species
Bird species fully protected by UK Law (W&CA Sch 1.1)
39 species
Bird species fully protected in EU Birds Directive (Annex 1)
27 species
Bird species designated UK BAP Priority Species
27 species
Bird species recommended for protection by Bern Convention Appendix 2
71 species
Migratory bird species with unfavourable conservation status requiring
international conservation agreements via Convention on Migratory Species App 2
66 species
Migratory waterbird species that are endangered or with unfavourable
conservation status.CMS African-Eurasian Waterbirds Agreement - Annex II
75 species
BoCC Red List species with severe population/range declines
42 species
BoCC Amber List species with moderate population/range declines
64 species
Bird species listed by the IUCN as Globally Vunerable i.e.considered
to be “facing a high risk of extinction in the wild.“
1species
Bird species listed by the IUCN as Globally Near Threatened i.e.
which may become vulnerable to extinction threats in the future
3 species
Bird species listed by OSPAR Convention - seabirds birds which are
vulnerable to the threats posed by the many competing human uses of the sea.
2 species
There are 42 Red List species, 64 Amber List species, and 80 other species. 39 of the bird species are
specially protected birds under the Wildlife and Countryside Side Schedule 1.1. 27 of the bird species
are UK Biodiversity Action Plan Priority Species, i.e. “Species of principal importance for the purpose
of conserving biodiversity” covered under section 41 (England) of the NERC Act (2006) and thus they
need to be “taken into consideration by a public body when performing any of its functions with a
view to conserving biodiversity.” Patently the housing allocation devised by Bury MBC has ignored
these species. This area is truly remarkable for birdlife. If you draw a line from the southern limits of
Stockport to the northern part of the town of Bury there is only one single area of large waterbody
set in a farmland landscape – the Elton reservoir area, with its mosaic of water, marsh, reedbed,
streams, ponds, shrubs, hedgerows, grasslands, both improved and semi-improved, tall herbs, canal,
river and vegetated mineral workings. The only comparable area of water with grassland is Gorton
Reservoirs which is situated in an active golf course. I need to stress this list is important due to the
whole habitat mosaic and not just one large waterbody.
The list of birds is not included in this draft. It will be submitted to GMSF in due course.
Key to notes– R – resident; B - breeds; S – Summer visitor; W – Winter visitor; P – passage migrant;
V – vagrant (very rarely seen). (PB) – from Peter Baron’s Elton Bird Report 10 years to 2016; (SJ) –
Simon Johnson; SH – year of latest records from Steven Higginbottom; Some dates gleaned from
Manchester Birding. This is not intended to be an exhaustive list of records. It is a list of bird species
recorded over the proposed Elton Reservoir housing allocation in the last 10 years, with most recent
years seen by one bird recorder; there may be more recent records. Farmland birds are still a major
concern according to the British Trust for Ornithology. The list is what people have seen and should
not be taken in any other way. Birds do not have to be seen by people to be present and visiting or
migrating through.
Codes to protected/conservation status:
WCA1.1
Bird species fully protected by the UK’s Wildlife and Countryside Act Section 1.1.
BD1
Bird species fully protected by the European Union’s Bird Directive Annex 1. Birds
which are the subject of special conservation measures concerning their habitat in order to ensure
their survival and reproduction in their area of distribution.
UKBPS
UK BAP priority species were those that were identified as being the most
threatened and requiring conservation action under the UK Biodiversity Action Plan (UK BAP) – Now
termed Section 41 species.
BC2
Bird recommended for protection as a result of the Bern Convention Appendix 2 to
which the UK is a signatory. Special protection (`appropriate and necessary legislative and
administrative measures`) for the animal taxa listed, including all forms of deliberate capture and
keeping and deliberate killing; the deliberate damage to or destruction of breeding or resting sites;
the deliberate disturbance of wild fauna, particularly during the period of breeding, rearing and
hibernation, insofar as disturbance would be significant in relation to the objectives of this
Convention.
CMS2
Convention on Migratory Species Appendix 2, to which the UK is a signatory.
Migratory species having an unfavourable conservation status for which Range States are
encouraged to conclude international agreements for their benefit.
AEAW2
Convention on Migratory Species, African-Eurasian Waterbirds Agreement - Annex
II, to which the UK is a signatory. Conservation of migratory waterbirds, giving special attention to
endangered species as well as to those with an unfavourable conservation status.
RED
Status given by Birds of Conservation Concern 4. Uses several criteria - IUCN: Global
conservation status. Species that are Globally Threatened (Critically Endangered, Endangered and
Vulnerable, but not Near Threatened) under IUCN guidelines, as assessed by BirdLife International,
the IUCN Red List Authority for birds, in2015; Historical decline in breeding populations. Species
judged to have declined severely between 1800 and 1995, from an assessment conducted by
Gibbons et al. (1996a), and which have not recovered subsequently; Breeding population decline.
Severe decline in the UK breeding population size (>50%) over 25 years or the longer term; Nonbreeding population decline. Severe decline in the UK non-breeding population size (>50%) over 25
years or the longer-term; Breeding range decline. Severe decline in UK range (>50%) between the
breeding bird atlases in 1988–91 and 2007–11 or 1968–71 and 2007–11 , as measured by the
calculated change in the number of occupied 10-km squares; Non-breeding range decline. Severe
decline in UK range (>50%) between the wintering bird atlases in 1981–84 and 2007–11, as
measured by the calculated change in the number of occupied 10-km squares.
AMBER
Status given by Birds of Conservation Concern 4. Uses several criteria - European
Red List status; Historical decline – recovery. As described above, previously Red-listed for historical
decline, followed by an increase of at least 100% over 25 years or the longer term period; Breeding
population decline. As for Red-list criterion, but with moderate decline (>25% but <50%) over 25
years or the longer-term period; Non-breeding population decline. As for Red-list criterion, but with
moderate decline (>25% but <50%) over 25 years or the longer-term period; Breeding range decline.
As for Red list criterion, but with moderate decline (>25% but <50%) between 1988–91 and 2007–11
or 1968–71 and 2007–11; Non-breeding range decline. As for Red-list criterion, but with moderate
decline (>25% but <50%) between 1981–84 and 2007–11; Breeding and non-breeding rarity; Species
qualified as rare breeders if the UK breeding population was <300 pairs, and as rare non-breeders
(WR) if the UK nonbreeding population was <900 individuals; Breeding and non-breeding
localisation. Species were considered localised if more than 50% of the UK population was found at
ten or fewer sites in either the breeding the non-breeding season. Sites were defined as either
Special Protection Areas or Important Bird Areas; Breeding and non-breeding international
importance. Species were considered of international importance if the UK holds at least 20% of the
European population in either the breeding or the non-breeding season.
(V)
Globally Vulnerable to extinction threats per IUCN Threatened i.e.considered
to be “facing a high risk of extinction in the wild.“
(NT)
Globally Near Threatened per IUCN i.e. which may become vulnerable to extinction
threats in the future.
(O)
OSPAR Convention conserved seabirds birds are vulnerable to the threats posed by
the many competing human uses of the sea.
The importance of Amphibians in the Elton Reservoir Allocation Area
The Proposed Housing Allocation has ponds and land habitats that support 5 species of amphibians –
Common Frog, Common Toad, Great Crested Newt, Smooth Newt and Palmate Newt. Some of the
ponds are centred on coal shafts, as can be seen by looking at the maps on the Coal Authority
website. In my time other ponds have appeared meaning that the area is actively producing new
ponds as the underground workings subside. Other ponds are appearing via impeded drainage. The
amphibian breeding sites include field ponds, reservoirs, goits, the canal, marshland, cut-off sections
of the River Irwell, quarry ponds and conservation ponds.
Many of the ponds contain marshy habitats and swamps that may not have much open water in
some years – they do however support interesting plants of conservation value – such as Bottle
Sedge, White Sedge, Lesser Pond Sedge, Marsh Pennywort and Sphagnum Bog-moss species, and for
example the mollusc Twisted Ramshorn, which likes late successional ponds.
The importance of the grassland and hedgerows in the Elton Reservoir Area
Lots of Yellow Rattle marks some of these meadows as semi-improved grasslands. The improved
pastureland used for dairy cattle contains the worms eaten by Great Crested Newts.
More to follow.