The saga of Croudace Homes’ Upper Cufaude Farm housing estate continues to rumble on in the planning process. A new planning incarnation – Planning Application 24/02846/FUL – has been submitted to the Local Planning Authority, Basingstoke & Deane Borough Council. You now have an opportunity to influence the outcome of the development for existing biodiversity and the future of the natural world. To follow is my letter of objection and comment, which focuses on inadequate on-site mitigation and off-site compensation for wildlife and the absence of an adequate environmental plan of works. Feel free to use arguments and comments it contains to write your own letter of objection.

You can submit your comments via the council’s planning portal, making sure you tick the box that says ‘object’ if that’s how you feel.

Alternatively, you can send an email to planning.comments@basingstoke.gov.uk making sure you have provided your name and address and clearly identified the planning reference number. Upper Cufaude Farm is the subject of a past NPL Second Nature blog regarding a previous application for the site.

Here’s my letter:

To: Planning Department, Basingstoke & Deane Borough Council, Civic Offices, Basingstoke, Hants RG21 4AH. Email: planning.comments@basingstoke.gov.uk

Planning Application 24/02846/FUL

I wish to object to the above application because of concerns I have regarding the environmental impact of the housing estate on the existing wildlife of Upper Cufaude Farm. These concerns relate both to the building stage and to the ecological consequences of the development upon completion. They are summarised as follows:

  • The ecological reports submitted on behalf of developers Croudace Homes are overly optimistic regarding the biodiversity outcome for existing onsite wildlife and incomplete regarding detail. They are also woefully out of date.
  • It is 5 years or so since the ecological reports that accompanied the Outline Planning application for Upper Cufaude Farm were compiled. Since that time, there has been a suspension of routine farming activities on the site, on land that already harboured a rich array of wildlife associated with farmland habitats. Upper Cufaude Farm has undergone nature restoration and recovery under its own steam. 5 years of rewilding means the land is now far richer in wildlife than it was when the ecological surveys were undertaken and reports compiled, and it now hosts significantly more biodiversity. The ecological reports submitted on behalf of the original application are no longer valid and relevant.
  • Croudace Homes’ Upper Cufaude Farm site plans do not provide adequate onsite mitigation for Protected Species and Species of Principal Importance; indeed, some aspects of the plans have the potential to harm these species in the future, above and beyond the direct destruction and loss of habitat that will result from the development itself.
  • A biodiversity and ecology plan of works for the development needs to be created and approved by the council in advance of planning permission being granted. Only by creating such a plan and ensuring that Croudace Homes stick to it (with consequences if they fail), do remnants of existing wildlife stand a remote chance of surviving beyond the first weeks of commencement of works.
  • As part of such a plan, the council should, for example, require a secure site/haven be allocated prior to development commencing, protected by impenetrable (to wildlife) barriers. Field ecologists should be required to search for and collect Protected Species and Species of Principal Importance (along with as much other biodiversity as it is possible to save) from the rest of the site, these to be relocated to the protected haven. In association with wildlife removal from the main site, exclusion fencing should be installed to prevent recolonisation during the building phase. Fencing should also be installed to safeguard existing hedgerows, woodlands and tree belts and ensure that meaningful environmental buffer zones for these habitats are respected and not degraded.
  • Onsite mitigation can never address the wholesale loss of habitat and existing native biodiversity that will result from the development; in particular, but not exclusively, with regard to the consequences for Protected Species and Species of Principal Importance. Nor can it alter the Zones of Influence consequences (for those few animals that survive the construction phase) that will inevitably result following completion of the project and occupation of houses.
  • Therefore, additional offsite environmental compensation should be required of Croudace Home to address the calamitous ecological impact of development on Upper Cufaude Farm’s current residents.

Cufaude Lane’s Amphibians

The area is well known in naturalist circles for its amphibians, as has been the case for decades. Of particular note are the area’s Common Toads, a Species of Principal Importance (Section 41, NERC Act 2006). The population is of national significance and represents the most important one in the borough of Basingstoke & Deane. Also present are Common Frog, Common Newt and Great Crested Newt (schedule 1, Wildlife and Countryside Act). For the last 10 years, the Cufaude Lane Amphibian Rescue Group/CLARG (the area’s ‘Toad Patrol’, registered as Froglife 314) has been operating on the road in response to the increased amphibian deaths occurring during migration in spring. Year on year, the carnage and need for rescue increases as road traffic numbers rise, as a predictable and inevitable consequence of building more and more houses at either end of Cufaude Lane.

It was in this context that a so-called Toad Tunnel was mooted by Croudace Homes as mitigation for increased amphibian road mortality that would result from cars associated with 350 homes being built on Upper Cufaude Farm.

CLARG considers Croudace Homes’ toad tunnel proposal to be entirely inappropriate and potentially harmful to the area’s amphibians. The whole idea of a toad tunnel needs to be reconsidered. Furthermore, the natural world is a dynamic system and a lot has changed over the 5 years since the proposal was advanced. Today, ecological compensation and not just mitigation needs to feature in the environmental equation with regards to Common Toads in particular: CLARG road-crossing/migration records indicate that the northern section of the Upper Cufaude Farm development has now become important terrestrial habitat for amphibians. The same applies to Common Frogs, Common Newts and Great Crested Newts, all of which are now recorded at migration times on the stretch of Cufaude Lane adjacent to the northern part of the Upper Cufaude Farm development.

As a bit of background, the Toad Mitigation Report compiled by Aspect Ecology for Croudace Homes contains no original survey work as far as CLARG is aware. The data, and the ‘migration’ maps, are based on information provided in a spirit of openness by CLARG. When the report was compiled 5 years ago, the data was already a year out of date. A representative of Aspect Ecology met two members of the CLARG for roughly 1 hour and spent a further hour shadowing the toad patrollers on a single migration night. To put this in perspective, over a typical season CLARG team members devote roughly 500 volunteer hours during spring amphibian migration. Many years ago, a meeting took place in council offices at which CLARG members, Aspect Ecology and Croudace Homes were present, the aim being to discuss amphibian mitigation. Neither Aspect Ecology nor Croudace Homes have made any attempt to contact CLARG since those brief encounters.

Reasons why the proposed Croudace Homes toad tunnel would not function as intended are various and include:

  • Profoundly, at the site of the proposed tunnel, ditches on both sides of the road routinely flood at amphibian migration times (late winter/early spring) meaning that the tunnel entrances and the tunnel itself would likely be underwater and hence useless, at a time when it might conceivably have helped the situation.
  • For amphibian tunnels to work there need to be barriers installed that guide migrating animals towards the mouths of the tunnel, in the manner of a funnel. In the case of the Croudace Homes proposal, the placement of the barriers is likely to guide amphibians away from the mouth of the tunnel along much of its length and prevent them from migrating at all.
  • The situation regarding flooding is exacerbated because one of the properties on the western side of Cufaude Lane adjacent to the proposed toad tunnel location operates an electrical pump that drains water into the ditch.
  • For a toad tunnel to provide any meaningful benefit, the engineering of the project requires cooperation and involvement of landowners at both ends of the tunnel. This has not been possible.
  • Perhaps most significantly, last spring the owners of a property on the east side of Cufuade Lane adjacent to the proposed toad tunnel installed fencing along roughly 200 metres of lane. From an amphibian perspective the fencing represents an impenetrable barrier and is likely to hinder, if not prevent entirely, migration along this stretch of Cufaude Lane. Given this development, over time there is likely to be an increase in the number of animals using the land adjacent to the northern part of the Upper Cufaude Farm as a migration route.

The Croudace Homes plans for Upper Cufaude Farm show an array of SuDS ponds. Although this will not be the intended use for these flood mitigation installations, they will inevitably be colonised by amphibians as breeding sites. Seasonally drying and ephemeral bodies of water are ideal for spawning, in part because predatory fish cannot become established. From an amphibian perspective, placing SuDS ponds right next to Cufaude Lane is absolutely the worst thing you could do because it virtually guarantees carnage on the road at migration times. These SuDS ponds need to be relocated, as far away from Cufaude Lane and internal roads on the housing estate as possible.

Skylarks

The evidence of my own ears (walking the margins of Upper Cufaude Farm) tells me that the Skylark data provided 5 years ago is out of date. I would estimate that in 2023 for example the land supported a minimum of 12 territories. It is inconceivable that on-site mitigation could compensate for the complete loss of breeding and feeding habitat for 12 territories – stating the obvious, Skylarks are birds of open countryside not housing estates. Since Croudace Homes have introduced Skylarks into the planning equation through their submissions, it follows that off-site environmental compensation is the only solution that can address the loss of habitat.

Skylarks are included in Croudace Homes’ planning equation because they are a Species of Principal Importance. It should be noted that a number of other avian Species of Principal Importance are also present on Upper Cufaude Farm. These include Linnet, Yellowhammer, Grey Partridge, Marsh Tit, Bullfinch, Dunnock and Song Thrush. In addition, there are regular sightings on the land of hunting Barn Owls. The destruction of breeding and feeding habitat and the inevitable Zone of Influence adverse impact on nesting potential means that offsite environmental compensation should also be applied to these species as well as to Skylarks.

Bats

All species of bats are protected by schedule 1 of the Wildlife and Countyside Act. It is a statutory requirement placed on local authorities that anything that affects their survival needs to be considered as part of the planning process. Bat species depend for food primarily on nocturnal flying insects. To varying degrees (seasonally for example) they are reliant on adult insects whose larval stages are soil-dwelling and subterranean (craneflies and many moth species for example), which are undoubtedly present in good numbers on Upper Cufaude Farm land. Covering the land in concrete, bricks and tarmac will mean that the majority of the current feeding habitat for bats is destroyed. Off-site environmental compensation should be required of Croudace Homes.

Hazel Dormouse

The dormouse mitigation proposals suggested by Croudace Homes are most unlikely to achieve the goal of protecting the species, either during the development phase or following occupation of the housing estate. Apart from the catastrophic disturbance caused by the building phase, of greatest significance is what happens after the housing estate is built and occupied. Specifically, predation by domestic cats is likely to result in extinction of the species and nothing short of impenetrable predator-proof fencing will make a difference. Offsite environmental compensation for the species should be required of Croudace Homes.

Interestingly, along with Hazel Dormouse, other mammals present on Upper Cufaude Farm that are Species of Principal Importance (NERC Act 2006) include Harvest Mouse, Hedgehog and Brown Hare. Off-site environmental compensation should be required for them.