More about WHSAP’s Further Main Modifications
On page 20 of the Schedule of Further Main Modifications (which you can find on the WHSAP Examination page, under Consultation Documents), FMM 25 proposes that at the Church Lane site, H2.4:
[t]he Lambrok Stream should be enhanced as a local amenity feature of the site in conjunction with development proposed at Southwick Court and Upper Studley
Nobody seems to know what a Local Amenity Feature actually is; we fear these are just weasel words, calculated to sound as impressive as possible while containing no real meaning. A Local Amenity Feature could be anything: a boating lake, a lido, a goldfish pond.
The development plans already submitted to the council for the sites at Church Lane and Upper Studley both showed landscaped open spaces, play areas and footpaths running alongside the Lambrok. These may be Local Amenity Features but neither will buffer the stream and its wildlife against the dangers of surface run-off from residential sites on steep slopes.
There is no limit to the number of Local Amenity Features that an ecologically important waterway could be turned into when it lacks statutory protection. The phrase is discouraging, particularly after FMM23’s proposal that all the allocated sites along the Lambrok plan together for the stream’s benefit.
Wiltshire Council signed up to the Bristol Avon Catchment Partnership in 2012;
The partnership, under the aegis of Wessex Water, has seven aims, three of which are to:
• improve public understanding about the value and services provided to society and the local economy by the river catchment and its wildlife;
• improve land management and sustainable agriculture to reduce soil erosion and nutrient and pesticide loss, and to provide better links between habitats for wildlife.
• improve river management to increase connectivity between habitats. . .
How will any of these aims be met by a Local Amenity Feature?
Among its highest priorities Bristol Avon Catchment Partnership has identified:
reduced natural habitat and wildlife associated with:
• poor riparian habitat
• highly modified channels
• in-stream barriers to prevent fish migrating
• increase of invasive non-native species.
How will a Local Amenity Feature address the problem of poor riparian habitat or an invasive non-native species?
Surely Inspector Stephen Lee’s intention in requiring policies to be written for each allocated site was that there would be clarity for planners and developers. In his post hearing findings and advice he says:
The policies should [. . . ] include reference to any constraints to development that will require mitigation or affect the form and layout of development, any specific assessments that might be needed and any specific infrastructure requirements or contributions.
Local Amenity Feature is not specific; the policy needs clarity in which the requirement to protect the Lambrok’s water quality and biodiversity, in line with the commitments Wiltshire Council has made to the Bristol Avon Catchment Partnership, is clear and specific.
We are in the middle of a world-wide ecological emergency. Wiltshire Council should be protecting our assets, not creating loopholes for developers to wriggle through.
Please join us in assessing the WHSAP Schedule of Further Main Modifications. Add your comment to the public consultation:
+ online via the council’s consultation portal;
+ by email using this representation form and returned to firstname.lastname@example.org (a word version of the representation form can be found on the council’s consultation portal);
+ or by post in writing to: Spatial Planning, Economic Development and Planning, Wiltshire Council, County Hall, Bythesea Road, Trowbridge, Wiltshire, BA14 8JN
Not all bad news, though: