Friday, 8 October 2021

Proposed Development at Linford Lakes

I'm sure by now many of you will have heard that yet another planning application (21/02533/OUT Linford Lakes) been submitted in respect of the land adjacent to the Nature Reserve. You can find all the details relating to the proposal by clicking on the link below.

The new proposal seeks to provide 584 units of accommodation, far more than in the previously refused application, of up to 250 units of accommodation, and more than the adjacent Redhouse Park housing.


If you have or are thinking about writing in objection then a massive THANK YOU.

If you are not sure or wonder if it will really do any good, I can promise you (and I have been here a few times before) every voice counts

Profit driven developers and ill-informed planners rely on apathy to get away with - what to some wild life - will literally be murder.

I have pasted below a copy of FoLLNRs letter of objection to MKC Planning Dept. Please feel free to copy from this or use your own words to make your feelings known.


Please also do email your local councillors and ask them to support your objection - their e mail addresses can be found on the MK Council website, you may be surprised how helpful some of them can be.

You can either lodge your objections to the new planning applications by e mail to :

dcadmin@milton-keynes.gov.uk

Or if you can’t see that your objection has been logged you can email Jonathan.Palmer@milton-keynes.gov.uk who is the head planning officer.

(1) Full application for the change of use of 68.65ha of agricultural land to a linear park and a new access road to the Linford Lakes Study Centre with associated works including the stopping up of the public road in Stanton Low and demolition of the Marle Inn; and (2) Outline application (matter of access to be considered, with matters of layout, scale, appearance and landscaping reserved) for up to 277 extra care apartments (Use Class C2); a care home providing up to 70 bedrooms (Use Class C2); up to 41 retirement bungalows (Use Class C3) and up to 196 homes (Use Class C3) with communal amenity space and other associated works. 

If you are going to email please include your name and address otherwise it may not be accepted.

Kindest regards

Tony


 

To: Milton Keynes Council Planning Department

 

Re: Planning Application 21/02533/OUTEIS | (1) Full application for the change of use of 68.65ha of agricultural land to a linear park and a new access road to the Linford Lakes Study Centre with associated works including the stopping up of the public road in Stanton Low and demolition of the Marle Inn; and (2) Outline application (matter of access to be considered, with matters of layout, scale, appearance and landscaping reserved) for up to 277 extra care apartments (Use Class C2); a care home providing up to 70 bedrooms (Use Class C2); up to 41 retirement bungalows (Use Class C3) and up to 196 homes (Use Class C3) with communal amenity space and other associated works. | Linford Lakes Nature Reserve Wolverton Road Great Linford Milton Keynes MK14 5AH

Dear Sirs

We are writing to voice our strongest opposition to the above planning application in respect of the Land at Linford Lakes. 

Our reasons are as follow. 

1.     The proposed development is contrary to the following local policies:

Policy DS5 Open Countryside

 

A. The Council defines Open Countryside as all land outside the development boundaries defined on the Policies Map. Planning permission within the open countryside will only be granted for development which is essential for agriculture, forestry, countryside recreation, highway infrastructure or other development, which is wholly appropriate to a rural area and cannot be located within a settlement, or where other policies within this plan indicate development would be appropriate. 

 

Policy DS6 Linear Parks 

 

C. The Ouse Valley between Haversham and the M1 motorway, known as "Linford Lakes", is part of the Linear Park system.

 

Policy DS6 restricts any development in Linear Parks to leisure and recreation  activities and these should be consistent with the objectives set out in Policy NE3 and Policy NE4

 

Policy DS6 states: The wildfowl reserve - Linford Lakes Nature Reserve, based on Stantonbury Lake, and the surrounding lakes and land that fall within the Great Linford Gravel Pits Biological Notification Site (BNS), should be retained as an important ecological resource. 

 

Policy L1 Facilities Acceptable In The Parks 

 

Planning permission will only be granted for leisure and recreation uses, or proposals that are ancillary to and directly support such uses.

 

Policy NE3 Biodiversity and Geological Enhancement 

 

Development proposals will be required to maintain and protect biodiversity and geological resources, and wherever possible result in a measurable net gain in biodiversity, enhance the structure and function of ecological networks and the ecological status of water bodies in accordance with the vision and principles set out by the Buckinghamshire and Milton Keynes NEP. 

 

Policy NE4 Green Infrastructure 

 

E. The existing network of linear parks and linked parks and green spaces will be extended into the urban extensions and along the Ouse and Ouzel Valleys to the north to provide a well-connected network of green infrastructure that: 

1. Is strategically planned. 

2. Is attractive and enhances the surrounding landscape. 

3. Is safe and well used for recreation. 

4. Meets the needs of existing and future residents. 

5. Is designed to provide a range of ecosystem services e.g. manage flood risk or provide flower rich habitats that supports a diverse range of pollinators. 

6. Is designed to support mitigation and adaptation to climate change e.g. through vegetation for carbon uptake (carbon sequestration). 

7. Achieves a net gain in biodiversity. 

8. Is managed into the long-term. 

9. Where possible improves connectivity with other green infrastructure networks e.g. by linkages to the urban parks. 

10. Where appropriate explores economic opportunities that will support the network’s sustainability – for example in conservation, agriculture, renewable energy or outdoor environmental education or recreation; such activity must not result in a negative impact to the integrity of the network, the ecosystem services provided or on biodiversity. 

Previous decisions in respect of development proposals relating to this land

MKC DCC have reviewed and unanimously rejected all previous applications for the development of the land at Linford Lakes for the reasons that: 

"the proposed development(s), by virtue of its location outside the settlement boundary of Milton Keynes would represent an intrusive form of development in the open countryside which is identified as an Area of Attractive Landscape in the Milton Keynes Local Plan, which would be detrimental to the open, rural character of the locality. The proposal would result in the loss of a substantial area of varied habitat and appearance and would harm the special landscape character of the area in this regard, providing an urbanised character and appearance to the land." 

On 27th March 2018 The Planning Inspectorate ruled that development of this site:

 “would intrude into the countryside, and into a designated AAL and Wildlife Corridor. It would cause substantial and irreversible harm to the Ouse Valley’s valued landscape. It would permanently destroy priority habitats, threaten important wildlife, and weaken ecological networks. It would also take 15 ha of land from the Linear Park, reducing the scope for informal and passive recreation uses in the future”. 

2.     The Proposed Development will result in serious ecological damage and will negatively impact Linford Lakes Nature Reserve

This proposed development flies in the face of the 2020 Environment Bill by which the Government has strengthened its commitment to protect the environment for future generations.

This Bill introduces statutory guidance for local planning authorities to explain how they should take into account Local Nature Recovery Strategies, to embed strategies for the environment and nature’s recovery into their planning systems.

The Government has committed to leave a richer, more biodiverse environment for future generations with a clear need for action: between 1932 and 1984, we lost 97% of our species-rich grassland, five species of butterfly have disappeared from England in the last 150 years, and indicators showing the state of birds dependent on farmland stand at less than half their value compared to 1970.

The Applicants own Independent Preliminary Ecological Appraisal has identified the following types of habitat within the proposed development area, all of which they rate as having a high protected species potential.

Dense Scrub, Scattered Scrub, Broad-leaved Scattered Trees, Mixed Scattered Trees, Recently Felled Woodland, Tall Ruderal, Swamp/Reedbeds, Running water, Species-poor Hedge with Trees 


Most of the above habitats would be destroyed if this application were allowed to proceed.

The land which the applicant suggest could be used to replace the above habitats, lies directly within the River Great Ouse Flood Zone. This land floods significantly and regularly (photographs are available to substantiate this), it is very different in nature to the area being proposed for building, it cannot be regarded as a similar habitat and could not support the same range of flora and fauna. It would be almost impossible to replicate the types of habitat identified above and any attempts to do so would be washed away or submerged in the winter floods. Even if it were possible to replicate the lost habitat, it would take many years to establish, during which time most of the current species would be lost to the area, probably for ever.


The EIA report which accompanied 17/01937/OUTEIS in 2017 for development of the same area of land concluded: 

"There would be an irreversible loss of habitat and fragmentation of habitat within Linford Lakes Biological Notification Site and Wildlife Corridor during construction" and "a significant negative effect at COUNTY level was classified as certain." The EIA report also indicated that the Zone of Impact that construction work could have, would be up to 2Km and could severely impact Linford Lakes Nature Reserve. 

The proposed development fails to minimise impacts on biodiversity or provide a net gain in biodiversity and/or contribute to the Government's commitment to halt the overall decline in biodiversity, nor does it establish a coherent ecological network that is more resilient to current and future pressures, as required by the NPPF. 

In the last three years over 20 cuckoos have been ringed by the local BTO team on LLNR land adjacent to the development area. This indicates just how vitally important this area is as a breeding site for this "red list" species, which is in severe decline - the UK has lost over half of its breeding cuckoos during the last twenty-five years. Linford Lakes is locally and nationally important to the survival of this and many other "red list" species and any form of disruption should be avoided. (A list of Red List and BAP Species recorded at LLNR since 2012 is included as Appendix 1).

Osprey have become annual visitors to Linford Lakes and use the site as a ‘refuelling point’ as they arrive in Spring and leave in Autumn. Last year one bird remained at LLNR for nearly two weeks and this year birds visited in April and August. This spectacular fish-eating bird of prey is an Amber List species because of its historical decline (due to illegal killing) and low breeding numbers. They are listed as a Schedule 1 species on The Wildlife and Countryside Act.

Linford Lakes are immensely rich in Dragonflies, 11 species of dragonfly have been recorded along with 9 species of damselfly. Dragonflies in the UK are in decline. The loss of wetland habitat due to development, together with run-off and the effects of insecticides are having a devastating effect on dragonfly numbers. The high risk of run-off contaminates during the construction process and then from the housing estate into the lake system along with the loss of habitat and increased human activity, will inevitably lead to a further decline in these species. 

During the last ten years, the Friends of Linford Lakes, along with specialists such as the County Bird Recorder, Moth Recorder, the Parks Trust Biodiversity Officer and the local BTO Bird Ringing Group have built up a great deal of information and data about the wildlife to be found on and around the Nature Reserve. This information clearly demonstrates that for its size, LLNR is probably the richest habitat and most species diverse site in the County. 

The applicants Ecological Desktop Survey (Bird Report) whilst indicating the presence of well over a hundred species appears to consist of only old records with nothing later than 2016. By not including records for the Nature Reserve it has missed many of the rare and priority species which are regularly seen at LLNR. It therefore fails to fully recognise the exceptionally high ecological value of the Linford Lakes complex. The applicants survey team do not appear to have referenced the species records for LLNR which would have helped give a better indication of the true importance of this area for biodiversity and priority species. Records for LLNR maintained by FoLLNR can be found at https://fohescnews.blogspot.com

The applicants own Environmental Impact Assessment Predicts “Significant Effects”. “During the construction phase, the effects will be high. A number of protected and rare species are present. The proposed scheme of works is likely to kill, injure and harm species and habitats at the site should no mitigation and compensation be installed.” As can be seen above it is unlikely that effective mitigation and compensation can be achieved.

The report goes on to say “The site is likely to have a significant impact on species during its operational phase. The increase in traffic levels will ultimately lead to higher road collisions between vehicles and species”.

 Such loss of habitat and disruption to wildlife is not acceptable.  

3.     There is no justification for the proposed development

The applicant has failed to consider the impact of the new Milton Keynes East Strategic Urban Extension which lies around 2 miles from Linford Lakes within the development boundary and which is set to deliver 5000 new homes. This development will according to MKC provide:

“A wide range of dwelling type, size and tenure should be provided creating choice, a varied building form and meeting community needs. 31% of housing should be affordable.”

 “In accordance with Plan: MK policy HN3, the development will be expected to provide an element of supported or specialist housing to help contribute towards meeting the needs of older persons and households with specific needs.”

The MK East Strategic Urban Extension will provide all and much more than this piecemeal proposal can ever achieve, furthermore, it includes all the infrastructure (shops, medical facilities, schools, leisure facilities and parks) that a sustainable development requires. The proposed development at Linford Lakes has no supporting infrastructure and by comparison is unsustainable.

We therefore request that this proposal be refused.

Yours faithfully

A C Bedford

Chair Friends of Linford Lakes

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