Objection!

So, Yorkshire Wildlife Trust have decided to resubmit their controversial plan for a visitor centre at Spurn, despite the East Riding Planning Committee refusing it last time on landscape impacts and flood risk grounds.
I will say again I am not against a centre at Spurn, but the location is wrong, very wrong in my opinion. So I've put together yet another objection. As my objection will be published on the East Riding Planning Portal, I guess there's no harm putting it on here either. Its rushed this time, as every time I have been on the East Riding planning portal something has gone wrong and I've not been able to see the documents until tonight. Still, it will still register my objection even if I haven't quite managed to bottom out all the nitty gritty of the facts and figures.

I guess there's also a risk my interpretation of some of the detail might be a bit out (so bear that in mind when you read it), but its not like I'm a statutory consultee, and this is where a planner comes in - its their job to sort the wheat from the chaff. And, ultimately it shouldn't matter whether I have it all there or not. If the proposals are not in line with the East Riding planning policies it shouldn't be approved. Whether the planner and the committee agree with my interpretation of their policies and the application only time will tell.

Anyway, here it is



I am writing to object to the proposed visitor centre at Spurn, Kilnsea, as proposed by the Yorkshire Wildlife Trust (YWT). I am not a resident of Kilnsea, but have visited regularly (twice a year or more) over the last twenty years.

 My objection and the reasons behind this objection are outlined below. Given that the new proposals do not differ dramatically from the previous plans, I have listed Landscape and Flood Risk as my first reasons for objection as these where the reasons the plans were refused previously. However, all other aspects of my objection still stand.

Landscape: I object to the impact that the proposed centre will have on the visual and aesthetic quality of the area. The proposed visitor centre will be located in an area that YWT believe will have no visual impact on the landscape. However it is quite clear from the YWT Visual Impact Assessment that the centre will be visible from most directions, and is only really screened when looking north from the area of the current ‘Spurn gate’. The associated Radar tower appears to have been removed from these proposals however this does not considerably reduce the visual impact. Not only is the proposed centre visible it is not in keeping with the style of building(s) frequently encountered along this area of coast, or indeed in the wider coastal environment. The council have clearly stated their approach to impacts on landscape on the coast around Spurn in Policy ENV10 of the Local Plan which states that development must “…not adversely affect heritage features, natural coastal processes, flora and fauna, the coast or access to it by reason of scale, siting, design, noise disturbance or traffic. Proposals involving other land uses are covered by other policies in this Plan”. This policy also states that “Proposals for development in the estuarine coastal area will only be approved if Policy Env5 is satisfied.” This latter point is addressed below.

The policy document also specifies that Aim 1 of the council is to “…preserve and enhance those features of the environment that make a positive contribution to the character and appearance of Holderness….”. In addition, whilst the council clearly states its position on tourist facilities in Policy TM1 this policy is clear that these facilities must “…fall within the established centres of population where they, meet the needs of residents and visitors, do not adversely effect the character and amenity of the area or place unnecessary burden on the established services and infrastructure.” I understand that other consultations have raised the issue that roads would need to be widened to accommodate the additional traffic, and the potential for double yellow lines to be needed has also been raised. Both would be a clear breach of this policy. Section 2.4.15 of the local plan also states that “Holderness has experienced the recent development of Environmental or "Green" tourism reflecting national trends and societies increasing concern for the protection of landscape and nature conservation interests. Particular attractions in Holderness include the Spurn Heritage Coast…The Council will encourage the development of tourism in association with the areas environmental resources however, at the same time will ensure that new development does not harm the environmental resources themselves through the removal of their nature conservation or scenic value.” Section 2.1.24 states that the council “…wishes to discourage the encroachment of development into the open countryside.” and under the coastal zone policies the Council identify the value of the coastal landscape and the need to protect and value this area.

 I believe that given the information provided in this application, the current proposals clearly conflict with current policy due to the size, design and location of the proposed centre and car park. There are clear alternatives that provide viable options if not necessarily the applicant’s first choice.

Flood Risk: The applicant does not sufficiently demonstrate how they will mitigate for the risks associated with visitor safety on the site. The proposed centre would be extremely isolated should tidal flooding occur, whereas other sites, eg Southfield Farm are located closer to evacuation routes. Similarly, the applicant’s assertion that it is “difficult” to flood proof existing buildings is not exactly true and there is no indication that the applicant has investigated what flood proofing these other buildings would require in order to come to that decision. The site at Southfield Farm opposite the Bluebell did not flood during the recent tidal surge and so may require less flood protection than that suggested by the applicant and I understand this has been offered to the applicant.

 The sequential test used by the applicant with regards to flood risk points out that other sites would conflict with current planning policies, however they fail to mention that their chosen site also conflicts with the majority of these policies, plus additional ones.

 The applicant states that Kilnsea Wetlands would be unsuitable due to land being allocated to mitigation for the loss of Beacon Lagoons. From information here http://www.tide-toolbox.eu/measures/kilnsea_wetlands/habitat_creation_area_discription/ the plans suggest that area X is not allocated for any habitat creation other than a pond dipping pond. They also state that this site would have visual impacts, which can equally be said of their preferred location. Although YWT only lease land at Kilnsea Wetlands, there is no indication they have spoken to the Environment Agency to establish whether construction of a centre here would be feasible.

Nature Conservation: I object to the development due to the impacts on nature conservation. The council clearly sets out its stance regarding nature conservation in Policies ENV1 to ENV40. This section of the plan also establishes that the Council recognises that it has a major role to play in conserving the landscape. In section 2.1.14 the local plan states that issues needing to be addressed by the plan include: “The sea and estuary coasts need to be protected from unnecessary and inappropriate development, Identification of natural features which are important and irreplaceable and to protect them against development, and identification and protection of features of archaeological, historic and architectural importance from the effects of inappropriate development, and ensure that new development where it is appropriate is designed to have a minimal adverse impact on such features and to enhance them wherever this is appropriate”. The plans for the visitor centre and associated car parking and mitigation do not appear to comply with the policies outlined in the Local Plan, nor is it clear how the YWT plan to ensure that these policies are met, or how they will deliver a number of actions.

 With regards the Biodiversity Report, whilst the authors have clearly followed the standard approach to establishing the value of the site, they have paid little attention to the main biodiversity value of the site in question - its value to migratory birds. Whilst these impacts may be hard to establish, the report does not even attempt to describe the value of the site, the numbers of birds passing through or using the habitat or the potential impacts of the development on these. Much of the data needed would probably be available from the Spurn Bird Observatory, or if not it should have formed at least part of the monitoring of the site. The proposed site provides a valuable stopping off point for significant numbers of migrant bird species and habitat loss and increased disturbance will be detrimental to these species. Whilst I accept that migratory birds have limited protection compared to breeding species, to largely ignore these at a site that is arguably the most important migration route in the UK is inexcusable.

 Once again the figures quoted in the biodiversity enhancement plan do not add up and, given the lack of detailed drawings it is impossible to include conditions to ensure the proposals are met. It appears that most of the mitigation would be delivered in Clubleys field, however most of this habitat is already present and therefore the proposals do not appear to match with the figures quoted in the Biodiversity enhancement plan. The landscape enhancement plan for Clubleys field suggests that there would be scrub planting, however scrub is already present where the trust are proposing this measure, meaning this should not be considered as mitigation or an enhancement. In addition, many of the other proposed enhancements have already been carried out, or relate to proposals such as fencing. These are not suitable or appropriate mitigation measures.

 Any habitat created in the Clubleys field and Warren area could only be considered as temporary. The YWT Flood Risk Assessment establishes that coastal erosion at the proposed centre location will reach the set-back defence line within 40 years. This line would see the current Warren area lost well before 40 years as the area is already much closer to the sea. This would render the majority of the mitigation irrelevant much sooner than the visitor centre life expectancy.

 Regarding the impacts on the SPA and associated bird species. The YWT have identified a number of wader roost sites, none of which appear to be in front of the proposed centre. This is in conflict with the results of other recent documentation, namely the Associated British Ports MER document from the ABP road application in 2013, which clearly indicates a wader roost directly out from the proposed visitor centre site. There are several possibilities, however all point to only one outcome. If the roost has been missed by the report author or appointed surveyors, the fact it is present in another recent document suggests that there is at the very least, uncertainty as to the presence of the roost site. If the roost site has moved, it suggests that the roost sites used by wading birds of the estuary, and associated with the SPA, are not fixed and therefore prevention of disturbance cannot be guaranteed as the location of the roost cannot be guaranteed. However the information is interpreted it raises doubts over the impacts on the roosting waders, and therefore potential impacts on an interest feature of the SPA. Under the Habitats Regulations, where adverse effects cannot be ruled out, a plan must not proceed.

 Policy ENV 5 states that Nature Conservation policies must be satisfied, whilst policy Env11 states “Proposals for development in the estuarine coastal area must accord with Env5 and the other nature conservation policies of this plan. The Council will require a comprehensive scheme to accompany significant estuary related proposals, including environmental measures to safeguard environmental features of importance”. I do not believe that these requirements have been met, or at the very least there is sufficient doubt over their compliance with Habitats Regulations and the delivery of mitigation that the scheme should be refused.

 Policy ENV 9 also references the need to protect the Heritage Coast, of which Spurn is a part. This policy specifically states that the the Heritage Coast Policy is to “…..to conserve, protect and enhance the natural beauty of the Spurn Heritage Coast, including its terrestrial, littoral and marine flora and fauna, and its heritage features of architectural, historical and archaeological interest…” I do not believe that the construction of a permanent 6m high visitor centre and pay and display car park is in keeping with that policy.

 Access: There is a significant risk of disturbance to wildlife and local communities by increasing visitor numbers. The YWT Access document provides as much argument for not building the centre as it does supporting its construction. As the document states, visitor numbers have dwindled dramatically since the breach of the peninsula. However, the YWT state that activity is now focussed around the Warren area. Whilst this is true there are several things to consider. Firstly, as the YWT control access to this area from the ‘Spurn Gate’ they have the ability to control this access by simply closing a gate. Similarly, they could use YWT staff to control the parking etc at the Warren. They have done neither. The majority of people park at the Warren and then move off into the Triangle area, the area that the YWT propose to move their centre to. If the current 20,000 visitors are providing significant disturbance then how, by constructing a centre in the middle of the area they wish to protect, and increasing visitor numbers to in excess of 50,000, do YWT propose to protect the area? Arguably they would be better trying to accommodate the current visitors to the site. Many of the things that the YWT state that they will do ‘if’ they are given permission should have been done years ago if they were a problem. Most could be done with limited investment. For example, the proposed viewing screen at the Warren to prevent disturbance. Since I began visiting the site in 1996 there has been no screen. A screen is relatively cheap and simple so why has one not been provided before now?  

 Essentially the access documents simply demonstrate that the YWT believe that they could attract more visitors if they had a new centre, whilst at the same time arguing that the current visitor numbers are unmanageable. Considering spurn and the YWT proposed centre are at the ‘end of the road’ exactly how is this a ‘Gateway Centre’ so desired by the trust. If the site is so sensitive, why make it into a gateway site?

Aside from the counter arguments within the documents, the statements do not provide any confidence that YWT would be able to deal with increased visitor numbers. Apart from a bit of signage and restricting some access there is no indication that they would have increased staff presence other than, presumably, visitor centre staff. There is therefore a considerable risk of disturbance to both the wildlife of the area and local communities.

The access statements also suggest that the plan is to make Spurn more like a Fairburn Ings or Blacktoft Sands. They want to make it a visitor destination with guided paths and restricted access. Whilst I can appreciate that some restricted access may be beneficial, in 20 years of visiting the site I have never witnessed anyone trespassing or wandering off rights of way. This approach would, in itself, detract from the whole Heritage Coast ethos and result in the area becoming anything but the environment that it is now.

Finally, I am not against the provision of visitor facilities at Spurn. There are however other, better alternative locations or options.

 

Sorry about the small font - for some reason the blog didn't like me copying and pasting from another programme.