by Sue Sullivan
On average, we’ve seen an astonishing 60 per cent decline in the size of populations of mammals, birds, fish, reptiles, and amphibians in just over 40 years … We’re facing a rapidly closing window for action and the urgent need for everyone — everyone — to collectively rethink and redefine how we value, protect, and restore nature.WWF’s introduction to its Living Planet Report 2018
This is not just happening in the Amazon or in places far away, it is also happening right here, in the UK, right now in east Kent. Piece by piece, corner by corner, field by field, we are losing wildlife habitat at an unprecedented rate. The State of Nature Report 2019 showed that populations of the UK’s most important wildlife have plummeted by an average of 60 per cent since the 1970s. A quarter of UK mammals and nearly half of the birds assessed in the report are at risk of extinction. So this is the backdrop to the plans for Betteshanger, where Quinn Estates now proposes to build a development comprising over two hundred houses together with commercial and retail units.
I know the site, it is close to where I live. We walk there often. It is the old pit-head area of the now-defunct Betteshanger coalmine. Much of it has been rewilding for 30 years and the rest is full of shrubs and trees planted at the beginning of the 2000s. It is a wild green space much used and appreciated by local people, and it’s full of wildlife.
A few of us locals got together and decided we would fight the Quinn Estates planning application on the grounds of the site’s biodiversity value. The Friends of Betteshanger was born.
It seems to me that unless the protest and the pressure comes from ordinary people demanding that nature is properly protected, the unrelenting declines that we see in habitats and species are set to continue.
But what was the site’s biodiversity value? We were told by Quinn Estates when they held their public consultation that the proposed development platforms were of “low ecological value”. This was based on a minimal survey carried out in November 2018. We decided we needed a second opinion, so after contacting everyone we knew who might have an interest in what was being proposed — environmental non-governmental organisations, the RSPB, Buglife, CPRE, Kent Wildlife Trust, local Green groups, individuals etc — we asked Sue Buckingham of the Kent Plant Recording Group if she would come and look at the site.
What she found made it quite clear that, far from being of low ecological value, the development platforms supported a range of unusual plants, some rare and endangered — such as the grass-poly, found nowhere else in Kent — and a number of others on the Kent Rare Plant Register. Altogether she identified over 180 vascular plants on the site.
Pete Findley of the East Kent Wildlife Group came and helped us by doing a bird survey. He identified over 100 bird species that used the site, including turtle doves — the UK’s fastest-declining bird and in danger of becoming extinct in the UK — and the grey partridge, one of Europe’s fastest-declining birds.
We sent the results to Dover District Council as part of our analysis of the original ecological appraisal carried out by Aspect Ecology and paid for by Quinn Estates. Due to the efforts of many people and organisations, including the the council’s senior natural environment officer, a full suite of surveys was eventually carried out by Aspect Ecology. They revealed a site not just of significance in east Kent but of significance at a county and national level. In fact the biodiversity value of the site was such that when we contacted Kent Wildlife Trust, assistant conservation officer Lucy Carden told us that with its mix of bird, reptile and rare plant species, the site sounded like “a particularly good habitat for a variety of species and could potentially be considered as a Local Wildlife Site”. Local Wildlife Sites are some of the UK’s most important places for wildlife but have no legal protection.
Aspect Ecology is claiming that the measures it has put in place will prevent significant harm to the site’s population of turtle doves. But nesting habitat for the birds would diminish under the proposals, as would the foraging opportunities provided by the seed-bearing plants on the development platforms. Moreover, they are very shy, wary birds, likely to abandon the site anyway when it has over 200 houses, and disturbance from people, pets, and all their activities. The fate of the turtle doves hangs in the balance. They are a target species in the Kent Biodiversity Strategy for 2020-2045, singled out for action to maintain their numbers in east Kent, where they are still — just — hanging on. Will Dover District Council be implementing this target at the local level? Will it take the action necessary to maintain the turtle dove population on the proposed development site?
The site also supports numbers of other red-listed birds such as grey partridge, cuckoo and linnet. They are all red-listed because they are of the highest conservation concern.
Six different species of bat were identified on the site. All are protected species under the European Habitats Directive. However, at Betteshanger it is proposed to remove a soprano pipistrelle bat roost that is located in an old boiler unit that will be demolished. Although it is against the law for you and I, if you are a developer, you can apply to Natural England for a licence: then you can remove the bats. Like the turtle doves, the bats are not likely to thrive when 200 houses and maybe 500 people are living in their midst. All the light can disrupt their feeding, and it has been shown that urbanisation has a negative effect even on the more common species of bat. So the fate of the bats is uncertain.
All of the grass-poly, one of the most important plants found at Betteshanger, was found growing on one of the development platforms. Under the current proposals, the areas where the notable plants were found will disappear under housing.
When an invertebrate survey was carried out in the summer, nationally rare and threatened invertebrates were found, also on the development platforms. If the development goes ahead as planned, their habitat will be removed. The two most important were a spider: Phlegra fasciata, and a ground bug: Ortholomus punctipennis.
paying to trash nature
Slow worm, common lizard, smooth newt and great crested newt have been found on site: all “priority species” of the highest conservation importance and, in the case of the great crested newt, given additional protection under the European Habitats Directive and the Wildlife & Countryside Act: it is unlawful to kill or remove them.
However, if you are a developer in Kent, there is a nifty scheme whereby, for the payment of a fee into the district’s great crested newt licensing scheme, you can ignore the protection. The money will be used elsewhere for the benefit of newts, but as far as the Betteshanger population is concerned, it is probably goodbye, as the pond they were found in is due to be altered. Some people call this ‘“paying to trash nature”.
Then there are the badgers — protected by their own act of Parliament. To start with, there was a Quinn proposal to “close” one of the setts and then dig them out, under licence from Natural England, as they were in the way of six housing units proposed for the A258 end of the site. This was also going to involve removing deciduous woodland.
We protested on several occasions as this was also the part of the site that butts up against the protected Sandwich Bay and Hacklinge Marshes site of special scientific interest (SSSI) and is where turtle dove territories were found. Eventually Quinn Estates agreed to drop the plan at this end of the site.
We found it extraordinary that Dover District Council was even prepared to consider a development this close to a SSSI, particularly as its own policies do not allow development within 500 metres of such a site. However, as a developer you can bypass this inconvenient policy by paying into the Dover district mitigation fund, a strategy suggested by developers and approved by Natural England. The fund is used for “monitoring” and for benefits elsewhere. It does not prevent recreational pressure on the SSSI nor does it prevent domestic pets disturbing the birds and other wildlife. Once again: “paying to trash nature”.
Have I mentioned hedgehogs, hares and harvest mice? No? Well, these were not considered important enough to even be surveyed, even though they are all priority species, although it was acknowledged that they were likely to be present. The hedgehog is another Kent Biodiversity Strategy target species because of alarming declines in its numbers,.
So as you can see, in the world of planning and biodiversity, “protection” doesn’t always mean protection. If you are a developer, there are exceptions made so that your plans can be implemented and housing targets can be reached. And Natural England appears to help facilitate this despite its professed aim “to help conserve, enhance and manage the natural environment for the benefit of present and future generations”.
We believe a form of regulatory capture is going on whereby the very protections originally put in place to protect wildlife have now been skewed to the advantage of the developer and to the great disadvantage of the species and habitats they were meant to protect. Even the ecologists who do the surveys are paid by the developer. There is a consultation on biodiversity within the planning system by the Department for the Environment beginning soon. Contributing to this will be important in the face of changes to the planning system that may well water down protections for wildlife even further.
But back to Betteshanger. What will happen now? Aspect Ecology on behalf of Quinn Estates has designed a compensation package to make up for destroying the Betteshanger site. They plan to enhance and create open-mosaic habitat at Betteshanger Country Park, on the other side of the A258 from the development site. The area in question is already valuable habitat and supports a large population of lizard orchids: a rare (schedule-eight) plant protected under the Wildlife & Countryside Act. This habitat doesn’t need changing and no full-scale survey has been done to assess its current value.
Aspect Ecology is claiming a large biodiversity net gain as a result of this package — a claim that is disputed by the senior natural-environment officer at Dover District Council and the Kent Wildlife Trust.
The important issue here is: will the planning committee at Dover District Council, who will make the ultimate decision, be persuaded that this package is a satisfactory solution? Will the committee be convinced that it makes up for the destruction of the site on the other side of the A258 and approve the application? Will they think that housing targets are more important than protecting the wildlife? This is all very likely.
Our view is that developing the site at Betteshanger, with its wealth of species and habitats, is tantamount to ecological vandalism, particularly at this time of ecological crisis, and we are looking to Dover District Council to fulfil its statutory duty to conserve biodiversity and refuse planning permission.
If you have read to the end of this, thank you for staying the course. If you feel you would like to help, then thank you for that, too. Here are the details for making an objection to the planning application. Please go to: https://publicaccess.dover.gov.uk/online-applications/applicationDetails.do?activeTab=makeComment&keyVal=Q93DSHFZIVA00 and click on “make a comment”. Thank you so much.
Sue Sullivan: Friends of Betteshanger
Sue Sullivan is part of the campaign group, the Friends of Betteshanger, which was set up to try and protect the wildlife on the Betteshanger site. She is a retired teacher, has a lifelong interest in ecology and the natural world, and has been involved in environmental campaigning for many years.
For more information on the background to this development please read Betteshanger v Mark Quinn: by Julie Wassmer
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