Fighting Development at Linford Lakes



Pro-forma letter you can use when objecting to MK Council

Please remember to put your name and address on the bottom then just cut and paste and send to:

paul.keen@milton-keynes.gov.uk

or you can object via the MKC website

www.milton-keynes.gov.uk/publicaccess


Dear Sirs

Application 17/01937/OUT – Outline Planning for 250 Houses at Linford Lakes

I am writing to voice my strongest opposition to the latest planning application from Templeview Developments in respect of the Land at Linford Lakes.

My reasons are as follow.

1.     On 30th March this year the DCC reviewed and unanimously rejected Templeview’s previous application for the above development for the reasons that:

“the proposed development, by virtue of its location outside the settlement boundary of Milton Keynes the proposed development 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 2001-2011 (adopted 2005), 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.”
and
“No evidence has been presented to demonstrate that the proposed housing is essential for agriculture, forestry, countryside recreation, and is not considered to be an appropriate form of development in a rural area. The proposal is therefore contrary to Saved Policies S10 (Open Countryside) and S11 (Areas of Attractive Landscape) of the Milton Keynes Local Plan 2001-2011 (adopted 2005), Policy CS9 (Strategy for the Rural Area) of the Core Strategy (adopted 2013), and the aims and objectives of the National Planning Policy Framework 2012.”

I wish to state that I totally agree with the above reasons and believe they are still valid and the original decision to refuse must be adhered to.

2.     At the meeting dated 30th March 2017, the applicants’ agents contended that the application should be passed because the Council could not demonstrate a 5 years housing supply in line with the NPPF. I understand that this latest application contends the same.

This reason cannot be valid because we have the following public statement put forward at the DCC Meeting dated 30th March.

The Senior Planning Officer – Development Plans told the Committee that “he was confident that the calculations (regarding the 5 years housing supply) were robust and made on an acceptable basis and could be defended if required”. The Head of Development Management assured the Committee that “he would not expose the Council to risk unless confident in the figures presented”.

Nothing material has changed in this new application, the decision to refuse should therefore be the same.

3.     I do not believe that ecological concerns and in particular the effects on Linford Lakes Nature Reserve have been properly considered.

The Environmental Impact Assessment accompanying the application takes no account of the wildlife to be found on the Nature Reserve and surrounding areas not covered by the planning application.

The EIA makes a number of assumptions that loss of habitat in the building area could be replaced by alternative management of the land in the proposed linear park extension, this theory is flawed. The land which is shown as parkland lies directly within the River Great Ouse Flood Zone - it is of no use to the developer.  Historically this land floods significantly and regularly, it is very different in nature to the dry area being proposed for building, it cannot be regarded as a similar habitat and could not support the same range of flora and fauna.

As part of its conclusions the EIA report confirms:

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 indicates that the Zone of Impact that construction work could have, would be up to 2Km. This means most of the Nature Reserve area will be affected.

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.


The EIA also fails to consider birds protected by the Wildlife and Countryside Act 1981, e.g. Barn Owls currently nest within the Zone of Impact and would be affected by noisy development work.

Pochard, which are on the UK “Critically endangered UK species list” are regularly recorded in good numbers at LLNR, habitat destruction, such as is being proposed, is blamed for the reduction in population.

This year (2017) five cuckoos were ringed by the local BTO team in one small part of LLNR alone. The number of birds captured for ringing normally represents a small fraction of the population in any given area.  Statistically this would suggest around fifty Cuckoos could be visiting and breeding in the Linford Lakes area and Wildlife Corridor. Cuckoos are a “red list” species and according to the BTO are in severe decline - the UK has lost over half of its breeding cuckoos during the last twenty-five years. Linford Lakes is therefore locally and nationally important to the survival of this and many other “red list” species and any form of disruption should be avoided.

LLNR is immensely rich in Dragonflies, 11 species of dragonfly (including the Scarce Chaser seen for the first time this year) have been recorded along with 9 species of damselfly. This closely rivals Wicken Fen which is recognised as one of the best sites for dragonflies in the UK. 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.


During the last seven years, groups like the Friends of Linford Lakes, along with specialists such as the County Bird Recorder, The County 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. SSSI status should be seriously considered.

Neither the EIA team or the applicant’s agents talked to or consulted with FoLLNR and the report does not take into account the exceptionally high ecological value of the Nature Reserve or the effects the development would have upon it.

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

Yours faithfully

Name
Address




Copy of Letter You can send to your Local Councillor

Dear Councillor

I support the Friends of Linford Lakes Nature Reserve (apprx 400 members) and I am writing to ask that you support us in opposing a second planning application from Templeview Developments (17/01937/OUT) in respect of the Land at Linford Lakes.

MK Council DCC reviewed and unanimously rejected Templeview’s first application in respect of outline planning for 250 houses at Linford Lakes at a meeting dated 30th March 2017.

The applicants’ agents contended that the application should be passed because the Council could not demonstrate a 5 year housing supply in line with NPPF.

The Senior Planning Officer – Development Plans told the Committee that “he was confident that the calculations were robust and made on an acceptable basis and could be defended if required”.

The Head of Development Management assured the Committee that “he would not expose the Council to risk unless confident in the figures presented”. “It was further confirmed that the case referred to by the applicants had been allowed for a number of reasons and it was not his view that the 5 year housing land supply issue had not been the main reason”.

Despite their categorical assurances, it seems the planning officers are now far from confident in their assertions and are preparing to renege on these promises and recommend approval of this new application, so as to extract themselves from public humiliation if MKC lose the appeal lodged against the original decision.

If this were allowed to occur it would make a mockery of the planning review process.

The original application was not rejected because MK Council could demonstrate an adequate housing supply but because :

“the proposed development, by virtue of its location outside the settlement boundary of Milton Keynes the proposed development 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 2001-2011 (adopted 2015), 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.” 
and
“No evidence has been presented to demonstrate that the proposed housing is essential for agriculture, forestry, countryside recreation, and is not considered to be an appropriate form of development in a rural area. The proposal is therefore contrary to Saved Policies S10 (Open Countryside) and S11 (Areas of Attractive Landscape) of the Milton Keynes Local Plan 2001-2011 (adopted 2005), Policy CS9 (Strategy for the Rural Area) of the Core Strategy (adopted 2013), and the aims and objectives of the National Planning Policy Framework 2012.”

We believe ecological arguments have not yet been properly considered by the planning officers.

FoLLNR believe that although the EIA may have been conducted in line with recognised principles, it took no account of the wildlife to be found on the Nature Reserve and land outside the application area.

The EIA makes assumptions that loss of habitat in the building area could possibly be counteracted by alternative management of the land in the proposed linear park extension, we doubt this. The land in question is in the flood plain which dictates, depending on weather conditions, what can and cannot survive there, however crucially as part of it’s conclusions the report did say:

“There would be an irreversible loss of habitat and fragmentation of habitat within Linford Lakes Biological Notification Site and Wildlife Corridor during construction”. “A significant negative effect at COUNTY level was classified as certain.” 

Even more worrying from our point of view: The survey also suggests that the Zone of Impact that construction work could have, could be up to 2Km The Nature Reserve is only about 300m from the edge of the proposed development which means most of the Nature Reserve area could be affected.

During the seven years that the Friends Group has been involved with LLNR (formerly the Hanson Environmental Study Centre) we along with many specialists inc the BTO have built up a great deal of information and data about the wildlife to be found on and around the Nature Reserve. 

This data demonstrates that for it’s size LLNR is probably the richest habitat and most species diverse site in the County.

We can provide details regarding species etc. and believe the site could almost certainly achieve SSSI status.

Please can you help us defend this important site. 

We feel that a terrible injustice is about to be done, which will result in irreversible damage to a fantastic asset that most cities would want, protect and cherish.

Yours sincerely


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