Biodiversity - Flora Objection
Submitted to Wealden District Council by Sue McRae on behalf of the Horstedpond Farm Action Group (HFAG)
16 December 2022
Castlefort Homes proposes to build 400 homes on the 27.3 acres of Horstedpond Farm at the southeastern end of Uckfield where the A22 and Lewes Road meet at the Little Horsted roundabout. At the centre of Horstedpond Farm is a small complex of five existing residences, including Horstedpond House, a Grade II-listed building, and three converted agricultural buildings also of historical value. This enclave would be completely surrounded by the proposed 400 dwellings.
When the proposed housing project was announced, four of the Horstedpond Farm residences established the Horstedpond Farm Action Group (HFAG) to object to the development. HFAG was immediately successful in drumming up widespread support from neighbours in Uckfield and the surrounding parishes who were similarly vehemently opposed to the Castlefort Homes proposal.
All the objectors feel that ‘Enough is enough’, that the 1,000 homes that have been permitted for Ridgewood Place, just across Lewes Road from Horstedpond Farm, will more than meet any conceivable need for new homes in Uckfield. The objectors do not want to see any more of East Sussex’s precious green countryside obliterated and with it the habitats of our region’s wide variety of flora and fauna.
HFAG has followed up its initial group objection to Wealden District Council on the proposed project with over a dozen targeted objections by individual HFAG team members. These objections focus on specific key issues and, following submission to Wealden, are also posted on the HFAG website: horstedpondfarm.org.
Because biodiversity, and the potentially adverse impact of housing developments on biodiversity, are such a key consideration, we’ve split our biodiversity objections into three, i.e. Biodiversity – Fauna, Biodiversity – Flora and Biodiversity – Ancient Woodland.
This particular objection focuses on Flora. The Horstedpond Farm site is situated within a highly rural landscape and is home to a rich diversity of plant, tree and hedge life. The wider landscape is dominated by a complex mosaic of farmland and scattered woodland parcels connected by a complex network of hedgerows and treelines.
The Preliminary Ecological Appraisal (PEA) carried out by PJC Consultancy on behalf of Castlefort Homes in April 2019 states that the proposed site has the potential to support protected, notable and rare plant species, and recommends that a National Vegetation Community (NVC) survey be undertaken to determine the presence/likely absence of such species.
However, the Interim Ecological Impact Assessment (EcIA), which was completed by Hone Ecology Ltd, again for Castlefort Homes, states that the habitats on the proposed site are dominated by arable and pastureland and are, therefore, sub-optimal for such flora. As a result, no NVC survey was carried out.
Our Horstedpond Farm Action Group (HFAG) commissioned an ecological data search from Sussex Biodiversity Record Centre (SxBRC) on 4 November 2022, covering both flora and fauna.
The SxBRC databank shows that over the last 10 years a total of 12 “protected and designated species” of flowering plants and mosses were recorded within a 1 km radius of the Horstedpond Farm complex. Whereas the SxBRC data was collected over a period of 10 years, Hone Technology was satisfied with the results of a sincle survey, carried out in April 2020 as part of its EcIA. Hone considered that, for the purposes of a Phase 1 Habitat Survey, the information gathered within the PEA was sufficient – “species observed is limited to those present at the time of the survey”.
The wet woodlands of not only the adjacent Horstedpond and Park Woods but also the treeline slices of ancient woodland within the Horstedpond Farm site are important habitats for fungi, mosses, liverworts and lichens.
The Arboricultural Survey carried out by GRS on behalf of Castlefort Homes in August 2020 identified 44 individual trees at the site, comprising mostly common oak but also sycamore, horse chestnut, ash and hornbeam. The arboriculturist also surveyed eight groups of trees, four woodlands and seven hedges in and around the Horstedpond Farm site.
According to his Arboricultural Survey report, “the tree stock comprises early mature to mature specimens that are indicative of the local landscape”. Several trees at the site, all common oak, were ‘significant specimens’.
When the Council tree officer visited the proposed site to assess the quality of the trees, he concluded that “Whilst I do not consider the trees to be of veteran status at present, they are magnificent, mature, mostly open grown, landscape trees and each one has the capacity to become a veteran. Therefore, any future (housing) scheme design should be built to respect their full root protection allowance (RPA) and (the need for) sufficient space for future growth and maintenance requirements. It is essential that they are retained within the scheme and even those with minor defects should be retained for both landscape and habitat value as well as their role as ‘veterans in waiting’.”
Paragraph 2 of Section 7.2 in the Interim Ecological Impact Assessment (EcIA) points out that mature trees are an ecologically valuable habitat and are likely to provide a variety of roosting and nesting features for birds and bats as well as foraging opportunities for a diversity of species.
Section 7.3 of the EcIA goes on to state that this project’s design plans should aim to retain the mature trees on the farm and protect them during construction, specifically cautioning that “Both roots and above-ground growth are vulnerable to damage during construction and afterwards.”
According to paragraph 4.3.2 of the Preliminary Ecological Appraisal, several of the treeline woodland parcels within the proposed site (one between field boundaries within the south-west corner of the farm and the other along the northern farm boundary running parallel to Ridgewood Stream and forming a field boundary towards the eastern extent of the farm) are also likely to qualify as Ancient Woodland.
The paragraph specifically states that “Although not listed on Natural England’s Ancient Woodland Inventory (AWI), given the age, structure, quality and condition of the woodland and close proximity and connectivity to existing areas of ancient woodland recognised on the AWI, the woodland within the (proposed) site is considered likely to qualify as ancient woodland.”
In view of this, and the key role of these treeline woodland parcels as wildlife corridors, it is crucial that these areas are protected from any damage or alteration, should the proposed development be approved.
A network of hedgerows intersects Horstedpond Farm, largely forming the arable field boundaries. Woody species recorded within them include hawthorn, blackthorn, elder, hazel, beech and bramble, with occasional mature standard or common oak trees.
Paragraph 5.1.2 of the EcIA survey confirms that hedgerows are a Priority Habitat under the Natural Environment & Rural Communities Act (NERC), 2006 and are one of the most botanically diverse habitats within the farm. They have the potential to provide commuting and dispersing corridors for a wide variety of species, including bats, dormice, great crested newts and reptiles, as well as nesting habitats for birds and dormice.
Following on from the Interim EcIA it completed in September 2020, Hone Ecology carried out a hedge assessment walkover in July 2022. Thirteen hedges were surveyed by the company; all were assessed to be ‘important’ under the Hedgerow Regulations 1997. The latter provisions were introduced to protect important countryside hedges throughout the UK from removal.
While the Castlefort Homes planning application specifies the retention of all existing internal hedgerows at Horstedpond Farm, it proposes to remove a stretch of 48 metres of hedge between the farm and Lewes Road. The hedge to be removed is located at the proposed entry point to the site where a roundabout and a single access road to serve all 400 of the envisaged new homes would be constructed.
It would be an offence to remove this hedge, or any other ‘important’ hedges at the site, without applying to the Local Planning Authority (PLA) for permission. The LPA must then decide whether the reasons for removal justify the loss of an ‘important hedgerow’, with a presumption for retention.
The hedge that Castlefort proposes to remove is of substantial length, and its destruction would certainly affect the use of that route as a wildlife corridor. It is not beyond the bounds of possibility that portions of other similarly protected hedges at the site would need to be removed. One specific such location is where the proposed new access road would intersect with the existing hedgerow-lined farm lane that serves the enclave of existing Horstedpond Farm residents.
While the developer points out that the “species-poor hedges on the farm are to be improved through the planting of additional native species”, that is an easy, sweeping statement to make. The likelihood is that further wildlife corridor links would be lost in the short-to-medium term.
Section 5.3 of the EcIA survey recommends that future management plans for the retained hedgerows and treelines should be based upon the Natural England Entry Level Scheme management prescription EB1 (Hedgerow management (Natural England 2013)). This would ensure that the hedgerows are cut to no less than 1.5 m height and cut on a rotational basis of once every two years. However, if the proposed Horstedpond Farm housing project were to be approved and the development completed, who would be responsible for the hedge and treelines management?
There is conflicting advice in Section 11 of the Interim EcIA survey regarding hedgerow management, where it is stated that “All retained hedgerows should be managed sensitively to avoid harm to dormice and other small mammals and enhance the existing habitat for this species. Hedgerows should be trimmed only every three years and should be maintained at a height of at least 2-3 metres.”
The EcIA report also states that “Where space allows, existing hedgerows and treelines should form the boundaries to long back gardens and not be located immediately adjacent to houses. They should also be protected with wooden fence to give some protection from unsuitable management practices.”
Such a provision acknowledges that some residents would be inclined to cut down/remove the existing vegetation for their own reasons, again inevitably leading to loss of habitat and amenities.
We reiterate that the Horstedpond Farm site is situated within a highly rural landscape and is home to a rich diversity of plant, tree and hedge life which, in turn, offers a wide variety of habitats for a similarly wide variety of wildlife.
We are continually reminded of the massive loss of biodiversity across the Earth during the last century, and the disastrous effects this is likely to have on the future of our planet. The proposed development would only reduce the current range of biodiversity enjoyed by this small piece of anciently settled and farmed landscape, and certainly would not leave it in a better state than it is now.