Area of Outstanding Natural Beauty
The proposed route is within an area of Outstanding Natural Beauty, which is one grade below a Nation Park.
The High Weald, in which the proposed route is situated, is one of Europe's very few Medieval Landscapes that has been mainly unchanged since that time. It is "a medieval landscape of wooded, rolling hills studded with sandstone outcrops; small, irregular-shaped fields; scattered farmsteads; and ancient routeways."
There are many sites of archaeological importance close to the route, along with pristine habitats for native flora and fauna.
The Rother Valley is home to many native species, some of which are endangered.
The proposed extension of the railway will destroy the habitats of these flora and fauna.
- Great crested newts
- Water voles
- Grass snakes
There will be an extensive loss of habitat including 1.5ha of mature woodland, 0.46ha of scrub, 100m of hedgerows, 3 ponds and 0.4ha of flood plain marsh.
A typical steam locomotive uses 50lb of coal per mile or 45kg each time a train runs one way along the proposed 3.4km extension.
Each kg of coal produces 2.9kg of CO2 when it's burnt so that's 125kg of CO2 released on each pass.
If we compare this to an average diesel car putting out aroung 0.12kg of CO2 per km, each time a train passes along the proposed extension, it's equivalent to a car driving 1000km / 650 miles.
This doesn't take into account the CO2 released in transporting the coal in by ship / road to the Rother Valley.
At a time when the government is committed to reducing CO2 emissions to reduce the effects of global warming, this level of extra pollution is unacceptable.
Statement from the Sussex Wildlife Trust on the impact of the proposed development:
The following comments are made on behalf of the Sussex Wildlife Trust in relation to the planning application RR/2014/1608/P. The Wildlife Trust feels strongly that the ecological information submitted with this application is currently insufficient to enable Rother District Council to make an informed decision, and we therefore suggest that the planning application is not granted until RDC are satisfied that the necessary legislative procedures have been adhered to.
In particular, paragraph 9.2.25 of the Environmental Statement (ES) states that 'Due to lack of access there are significant gaps in knowledge of the ecological receptors on the site. This lack of data could alter the process of impact assessment and the conclusions of this report'. We agree that this lack of data for the proposed development site could have a significant impact on the way that the Council proceeds with the application. Paragraph 9.2.27 also states that 'The assumptions are provided on the understanding that the ecology chapter will be re-drafted once 100% land access is allowed and all of the ecology surveys have been completed'. We fully recommend that no planning permission is given until full survey of the land has been undertaken by neutral experts.
The ES admits that a number of European protected species are likely to be present on the site and therefore impacted by the proposed development. This is a material consideration and it is vital that 'the presence or otherwise of protected species, and the extent that they may be affected by the proposed development is established before the planning permission is granted' as per paragraphs 98 and 99 of ODPM Circular 06/05: Biodiversity and Geological Conservation - Statutory obligations and their impact within the planning system. We are aware of a large number of nationally and internationally protected avian, amphibian, reptilian, mammalian, invertebrate and plant fauna which are present along the proposed development route, but which are unrecorded in the desktop site survey, including grass snakes, barn owls, dormice, bats and butterflies. There are also a range of BAP and protected habitats present along the proposed route including, and in particular, ancient woodland, orchards and species rich floodplain meadow.
The circular is clear that this is not something that can be conditioned when permission is granted. This extreme lack of up to date ecological evidence is also contrary to BS 42020 Biodiversity - Code of practice for planning and development particularly section 8.1: 'Making decisions based on adequate information' and paragraph 165 of the National Planning Policy Framework: 'Planning policies and decisions should be based on up-todate information about the natural environment and other characteristics of the area...'
The limited information provided in the ES also make the scheme contrary to Policy EN5 of the Rother Core Strategy:
'Biodiversity, geodiversity and green space will be protected and enhanced, by multi-agency working where appropriate, to:...
(viii) ensure that development retains, protects and enhances habitats of ecological interest, including ancient woodland, water features and hedgerows, and provides for appropriate management of these features;
(ix) require developers to integrate biodiversity into development schemes by avoiding adverse impacts from development on biodiversity or habitat, or where wholly unavoidable, provide appropriate mitigation against or compensation for any losses. In any event, developers will also be expected to consider and promote opportunities for the creation and/or restoration of habitats appropriate to local context.'
We take this opportunity to remind Rother District Council (RDC) that the planning system should 'contribute to and enhance the natural and local environment by: minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government's commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures' (NPPF, para 109).
RDC has a duty as a public body, under section 40 of the NERC Act 2006, 'in exercising its functions, (to) have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity'. We ask RDC to consider whether the information provided is adequate to assess this application to be sure it is properly determined. If it is deficient, as we believe it to be, then we would recommend that the application is rejected until deficiencies have been remedied.
We are very grateful for your consideration of these points, and we look forward to receiving your full and considered response.
Fran Southgate on behalf of Sussex Wildlife Trust