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Text of submission by Judy Webb to Oxford City Council in relation to the Consultation on the Northern Gateway Area Action Plan Proposed Submission Policy NG 8 Oxford Meadows SAC (Consultation closed 15 September 2014)
Text of submission by Judy Webb to Oxford City Council in relation to the Consultation on the Northern Gateway Area Action Plan Proposed Submission Policy NG 8 Oxford Meadows SAC (Consultation closed 15 September 2014)
Q5.
What change(s) do you consider necessary to make the document sound or
legally compliant?
--- A more detailed, accurate assessment of the potential recreational pressure generated by the Northern Gateway development (human/dog impact) on the Oxford Meadows SAC haymeadows in particular. --- A full hydrological survey, including complete data on the Green Belt meadows north-east of Joe White’s Lane and including the proposed SUDS area to the north of the A40 that is currently outside the NG AAP limit and in Cherwell District. --- A detailed Air Quality Assessment, including calculations based on a full year’s baseline N deposition data from the Oxford Meadows SAC hay and other meadows from spring 2014-spring 2015. --- Appropriate biodiversity surveys for protected species throughout the AAP site, especially the meadows proposed for removal from green belt and including areas under the proposed Strategic Link Road and the Proposed SUDS area, both north of the A40 and outside the current AAP boundary. Q4 Please tell us why you consider the document to be unsound The Submission AAP is unsound as it does not provide appropriate evidence to justify the development. I am a local ecologist who has studied the Oxford Meadows SAC for many years and have first-hand knowledge of them and the issues they currently face. I have also recently surveyed the green belt meadows north-east of Joe White’s Lane that are proposed for removal from the green belt. Recreational Pressure Assessment of the possible human/dog impact on the sensitive haymeadows is inadequate therefore it is unsound to assume there will be no harm from the Northern Gateway development. Even limited public recreational impact is unacceptable during the hay growing season (March to July) when the meadows are particularly vulnerable. The meadows will be a honey pot for walkers because they are so beautiful – has no one considered this? Even after the hay cut, the aftermath grazing (currently done by sheep, but should be done by cows) can be compromised by much dog walking pressure. Already the farmer involved (FAI farms, Wytham) reports dog attacks on sheep in those meadows are a problem. Increased dog walking and stock attacks may compromise the ESSENTIAL aftermath grazing management the haymeadows need. Nesting curlews in the meadows are now already regularly disturbed by public pressure, especially from dogs, now that there are a number of canal boats illegally moored next to Oxey mead and Yarnton West Mead. A foot path from Joe White’s Lane leads up past the canal, along Duke’s Cut and past Oxey Mead and through the middle of Yarnton West mead. Pixey Mead has a foot path through it that is regularly accessed by people from Godstow Road. Public pressure on haymeadows can be very destructive – not just trampling at flowering time but arson in the form of barbeque fires might be a consequence, as well as dog pressure on ground-nesting birds. The Northern Gateway must be expected to bring huge extra public pressure on these sensitive haymeadows. |
Hydrology
Inadequate evidence has been provided in relation to hydrological impacts. A full hydrological assessment is required at this stage, not just an ‘Interim Hydrogeological Summary Note’. Therefore any conclusion of ‘no harm’ to the meadows from hydrological impacts is unsound and unjustified. Within the Ashmolean Natural History Society of Oxfordshire (ANHSO) I am part of the Oxfordshire Flora Group, where I am voluntary ‘Flora Guardian’ for the rare Creeping Marshwort. This is the plant species for which Port Meadow is included within Oxford Meadows SAC and I have been involved in voluntary monitoring this species for years and supplying the information on it to Natural England and Oxford City Council. This is a species requiring flooding in the winter months but also requiring NO prolonged flooding into the summer months. This species has recently been doing very badly on Port Meadow exactly because of prolonged flooding into the summer months causing the death of many plants. The Northern Gateway development must therefore not produce any less flooding in the winter on Port Meadow and also not produce any increase the degree of flooding on Port Meadow from spring into summer. The hydrology of the whole area is very complex. The hydrological evidence submitted with this proposal is totally inadequate. It would appear that the potential SUDS area is outside the limits of the AAP to the northwest of the A40, and falling within Cherwell District Council. No evidence is provided of co-operation with Cherwell DC to ensure that this is viable. It also appears that this may lie in a similar geographical area to the proposed route for the strategic link road and there is no evidence as to how these conflicting uses could be reconciled. The hydrological implications of accumulating water in this potential SUDS area should be fully assessed at this stage, not later. For example, it could be that this water is actually needed to enter the ground to feed the gravel aquifer of the Green Belt area adjacent to the SAC. However, without the detailed information appropriate judgements cannot be made. Meadows south of the A40 proposed for removal from the green belt: the ‘Geoenvironmental Assessment of Ground Conditions report’ does not have complete data on the green belt meadows and is therefore inadequate. In particular, trial pits in some of the meadows north of Joe White’s lane could not be completed because they were flooded at the time of visit! This implies that they are part of the functional floodplain. It would be unsound and unjustified to bring these green belt meadows into the development area without full geological data and hydrological study, therefore knowledge of the hydrological implications for the SAC nearby. |
Air quality
Only a Preliminary Air Quality report is available as evidence based on previous years Nitrogen Oxides concentration data from only the roadside areas near Wolvercote roundabout and the main roads through the proposed NG development site. These are the wrong areas to have monitored to generate information relevant to Oxford Meadows SAC. Extrapolation from this to the situation in the meadows with the NG in place is unjustified and conclusion of no harm from increased Nitrogen deposition is therefore unsound. The hay meadows are at, or very near, the critical aerial N deposition limit for this habitat of 20-25kgN/ha/year already. Aerial deposition of N augments the detrimental increase in N deposition the haymeadows have experienced in recent years from prolonged flooding with nutrient enriched Thames river water. Despite being assessed as in ’Favourable Condition’ in 2010 by Natural England, my own more recent surveys indicate a number of detrimental changes are already happening to the flora – for example that sensitive rare plant species like the green-winged orchids are already down in number from many hundreds to a critically small population of under 30. The in-combination of N impacts from different sources needs accurate assessment. A full year’s air pollution surveying actually in the Oxford Meadows SAC is necessary to get a baseline to predict the effect of the Northern Gateway traffic increase in terms of aerial source Nitrogen deposition (particularly along the A40 to Witney) on the Meadows adjacent with any degree of accuracy. However, I observe that appropriate air quality monitoring in the actual SAC haymeadows only started as recently as Spring 2014, so the earliest reasonable data will be available for such calculations is spring 2015. Not until this full years’ worth of data is gathered and fully assessed can there be any proper, accurate calculation of the impact of the predicted traffic increase generated by Northern Gateway. Biodiversity The APP Submission is unsound in assuming this area can be developed without a full biodiversity survey for protected species that cannot be moved. For example the impact of development on these meadows cannot be fully assessed until an ecological survey of brown hairstreak butterflies is carried out. My own preliminary surveys of the hedgerows in the meadows south of the A40 and north-east of Joe White’s lane (that are proposed for removal from the green belt) reveal large amounts of blackthorn and this suggests that there is good potential habitat for this Red Data listed UKBAP priority species (a Section 41 species), which is already present in the Oxford area, and breeding areas need protection. The protected Great Crested Newt has already been recorded in the railway line ditch to the west of the railway that is currently being upgraded by Network Rail adjacent to the Trap Grounds allotments. This suggests that newt forage/hunting areas are likely to extend north to the Canalside Meadows LWS and into the proposed NG development area that is currently green belt to the north-east of Joe White’s lane. It is urgent that surveys for such important protected species are done at this stage to inform the AAP boundary as appropriate. |