The Long Ashton Nature, Community & Environment Trust (LANCE Trust) has objected to the recent planning application submitted by EPIC.
In order to explain some of the principle issues raised by the proposed, huge and complex development, we have broken our response into sections and explained below.
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Summary of our objection comment
EPIC wants to build its ‘Forever Home’ by creating its European Headquarters on high quality Green Belt lying on the eastern edge of Long Ashton. The development will take a minimum of fourteen years to complete. In that time, significant changes will take place within the accelerating crisis of climate change and biodiversity loss (aka the planet’s life support systems) yet this problem appears not to be addressed. Yet, as the National Trust’s audit in late December 2023 shows “the disappearance of reliable seasonal patterns is causing chaos for the flora and fauna of the UK, a long-running annual audit of the impact of weather on nature has found. Extreme weather events, from storms and pounding rain to searing heat and drought are putting huge pressure on animals, plants and the environment.”
The Trust urges politicians to prioritise “urgent action” to protect nature and people from future climate shocks and says parties should commit to making changes in their manifestos for the next UK general election.
The LANCE Trust believes, as do many of the other comments, that the proposal from EPIC and its consultants represents a real and significant threat to the concept and integrity of the Green Belt. It may also has an adverse impact on the Local Nature Recovery Networks (LNRNs proposed and identified by the West of England Nature Partnership (WENP) and referred to in the draft Biodiversity Supplementary Planning Document recently produced by North Somerset Council.
In addition, the development may pose specific threats to red-listed species ie. those of a high conservation concern, despite the recognition from EPIC that Long Ashton is an important stepping-stone for such species utilising nationally important wildlife sanctuaries such as the Avon Gorge & Leigh Woods, the Mendips, Chew Valley, Tyntesfield/Belmont Estate and Tickenham/Kenn Moors.
Readily available data reveals well-founded concerns about the potential lack of due process during and after building developments such as these. In this case, with a particular focus on enforcement measures designed to protect the ecology of an important area, potential proposals for future changes in use of the site by EPIC and the prospect of a hostile take-over, plus the Government’s refusal to implement Environmental Net Gain as outlined in its 25 Year Environment Plan, make the acceptance of this application a high-risk strategy.
The ever-increasing severity of the impacts of climate change and biodiversity loss leads the LANCE Trust to believe that leaving and enhancing an intact Green Belt offers a multitude of short term and long term benefits locally and nationally. At present, the current application seeks to facilitate the economic growth of a multi-billion dollar US corporation in order to retain or enhance its market share in an increasingly competitive market. So far, EPIC has shown little desire to reshape its method of 20th century working which depends on centralisation of a big work force combined with an auditorium, large training facility and office blocks. This means EPIC appears to display little commitment to tackling the real-world problems of the 21st century.
After pre-application discussions with North Somerset Council, the Biodiversity Net Gain (BNG) document produced by Buro Happold reveals that a minimum of 10% BNG should be the target figure. However, due to the long timescale, impact and importance to EPIC of this development, it’s worth drawing attention to the shortfall of the BNG policy as the Chartered Institute of Ecology and Environmental Management stated in 2021 to the House of Commons Environmental Audit Committee, “the biodiversity net gain policy, in its current form, does not go far enough in contributing to the transformative change necessary to address biodiversity loss in the UK.”
The Committee concludes that, “The failure to move towards a system of net environmental gain risks undermining the government’s plans for a green recovery and allows developers to focus entirely on biodiversity, rather than treat the environment as a system. This could lead to severe habitat fragmentation.”
Scientists investigating the current impact of BNG policy went further to state, “The safest mechanism for reducing the biodiversity impact of infrastructure is to avoid impacts to biodiversity initially. In practice, this means redirecting development to previously degraded sites wherever possible.”
The UK is one of the most nature-depleted countries in the world and ranks lowest in the G7. Long Ashton has no nature reserves and, apart from the small area of Peel Park, all it’s Green Open Spaces are privately owned giving the Parish very little security in terms of future, long-term access to high quality green and blue space bursting with wildlife so the loss of 90 acres that, potentially, could be used much for wisely is a matter for concern. Once Green Belt has been developed, it’s gone forever.
A 2023 report revealed the UK’s biodiversity levels continue to plummet with one of the main drivers being increasing urbanisation such as this proposed development.
At the EPIC development, with 2,500 staff plus a 3,000 seater auditorium, there will be increased human pressure across the site with walking & cycling trails, public rights of way, permissive paths, playful art installations and fitness trails. Frequent traffic including cars, coaches and delivery vans from the South Bristol Link Road will take place day and night bringing in supplies, staff and visitors.
This development is on a flood plain and the increased traffic will result in pollutants from tyre particles created during accelerating and braking dispersing from road surfaces by rainfall and wind. Since the main environmental pathway is identified as road run-off into storm drains, where they empty into rivers and the sea so it’s likely that unseen and increased pollution will happen downriver in the Severn Estuary, a RAMSAR site, Site of Special Scientific Interest and Special Protection Area.
The increased pressure could be problematic for some key species that currently use the site for foraging or breeding. Others that are more reclusive may simply not be able to cope with such a busy site. In addition, two busy roads (the A370 and the South Bristol Link Road/Colliter’s Way) border the site that, together with a fast railway line on it’s third border, may make the transfer of many species such as amphibians and hedgehogs to and from adjacent land such as the wetland in Ashton Vale extremely hazardous.
It is notable that EPIC after considering a number of sites in and around Bristol seems to show a lack of interest in either compromise or reacting to Britain’s undeniable problems by identifying a high value Green Belt site, as it’s only ‘Forever Home’.
Finally, the style of buildings have no architectural ambition to complement the landscape or provide habitats with the use of green roofs or living walls, instead there seems to be is a simplistic architectural reference to the dominant architecture of the early-mid 19th century rather than an inspiring response to the over-arching problems of the 21st century. And rather than an imaginative use of solar panels within the build itself, there is a proposal for a large solar park.
Add to this, the application for one of the largest Auditoriums in the country that , alongside the Culinary Area, Training Facility and Office Blocks – some over ten stories high in line with the highest point of Ashton Gate Stadium- this development will not mesh with the landscape but dominate it. In so doing, it will increase the feeling of ‘urbanisation’ merging the semi-rural aspect of Long Ashton village and the distinctive suburb of South Bristol into one homogenous unit with EPIC as the epicentre.
More information on topics raised in the summary follows including an Introduction to the Trust and it’s concerns plus comments on Green Belt Protection & Enhancement, Biodiversity Net Gain v Environmental Net Gain and Human Pressure.
An introduction to LANCE: who we are
The Long Ashton Nature, Community & Environment Trust (LANCE Trust) is a charity whose overall remit is to maintain and enhance biodiversity within Long Ashton and beyond.
As shown by EPIC’s ‘Statement of Community Involvement’ produced by Community PR in August 2023, the Trust notes a lack of engagement from EPIC since none of the consultants involved in submitting EPIC’s planning application has reached out to the Trust despite the application having a profound effect on our local habitats and species protection – areas that, of course, the LANCE Trust is specifically interested in.
The Trust understands that EPIC is relying on proving ‘Very Special Circumstances’ in order to bypass the current protection of this Green Belt site from development for either residential or employment purposes. Although there are several arguments that can be made to dispute the VSC claims, the charity’s focus is on assessing the impact on biodiversity within the parish and beyond from several documents submitted on behalf of EPIC.
The Trust has read and responded to the Biodiversity Supplementary Planning Document produced by North Somerset Council in November 2023. We also draw on October 2023 report from the Office for Environmental Protection and the State of Nature Report released late in September 2023 that shows the on-going devastating decline of British wildlife.
We also note the West of England Nature Partnership (WENP) “is working to develop a regional Nature Recovery Network (NRN) for the West of England, aligning with shared principles developed across the South West (by the South West Local Nature Partnerships) to ensure coherence and strengthened networks across the wider region.
This means protecting and enhancing our existing natural habitats, but also making them bigger, creating new areas of species-rich habitat, and, critically, ensuring they join up to create functional and resilient ecological networks that enable nature and people to thrive.
The Government’s 25 Year Environment Plan, published in January 2018, includes a commitment to “develop a Nature Recovery Network to protect and restore wildlife, and provide opportunities to re-introduce species that we have lost from our countryside.” “
The comments below refer to general principles rather than picking up on specific ecological points such as the realignment of Ashton Brook and other proposals.
1. GREEN BELT PROTECTION & ENHANCEMENT
Some corporations, developers, councils and MPs see Green Belt protection as a threat to economic growth.
From the Alternate Sites Assessment document provided by C Squared and Rapleys LLP, we note the company has chosen to put in an application for a proposed development identified as being “inappropriate” in Green Belt. This implies EPIC believes Green Belt protection is an unwelcome impediment to its specific needs in retaining or growing its market share in a increasingly competitive industry.
However, adverse impacts of climate change and plummeting biodiversity losses are increasingly felt around the world. In our global world no one can afford to ignore the obvious effects that a volatile, unpredictable climate will have on human, animal and plant populations.
The Office for Environmental Protection (OEP) helps to protect and improve the environment by holding government and other public authorities to account. OEP is an executive non-departmental public body, sponsored by the Department for Environment, Food & Rural Affairs. In its report (October 2023) it states, “The environment is under serious threat. We continue to see extremely worrying and persistent trends of environmental declines, with some increasingly difficult to arrest".
As a result, economists and strategists are turning to alternate models to linear economic growth in order to live within planetary constraints. As an article within Town & Country Planning by Julia Thrift in 2022 states “Bold ideas to transform the way we live are essential… Transforming local Green Belts into beautiful, accessible places in which to enjoy nature, keep fit, have fun and grow affordable food could be an incredibly attractive idea for voters of all ages.”
The Natural Capital Committee (NCC) chaired by Prof Sir Dieter Helm drew up a roadmap to green economic recovery that included maintaining and enhancing the Green Belt. With the existing Green Belt providing a chain of interlinked sites, it provides an unparalleled opportunity to tackle some of the fundamental aspects of climate change and biodiversity loss for the benefit of all, not the few.
North Somerset Council should be congratulated on tackling some of the key issues within its Biodiversity Supplementary Planning Document but with the support of national government, much more could be achieved. For now, though, we hope that NSC recognises the importance of protecting the remaining portions of Green Belt in the hope of providing a safer future for our children and the wildlife with which we share the planet.
Once Green Belt land is developed by a corporation such as EPIC, it’s gone forever.
2. ENVIRONMENTAL NET GAIN (ENG) v BIODIVERSITY NET GAIN (BNG)
In its 25 Year Environment Plan the Government announced it would embed the principle of “environmental net gain” in the planning system. The existing approach within the National Planning Policy Framework (NPPF) of seeking biodiversity gains where possible would be strengthened and broadened to include wider natural capital benefits, such as flood protection, recreation and improved water and air quality. The NCC has argued that whilst the Government committed to environmental net gain for planning, subsequent Government action and policy documents have only focused on biodiversity net gain.
The NCC is concerned that a focus on biodiversity net gain could lead to increased habitat fragmentation because it did not include a natural capital focus and did not consider the environment as an integrated system. The Chartered Institute of Ecology and Environmental Management supported this, emphasising that as the BNG metric uses habitats as a proxy for biodiversity value, other important elements such as species and ecosystem services are not accounted for.
Bearing in mind the paper published in June 2021 “Exploring the ecological outcomes of mandatory BNG using evidence from early-adopter jurisdictions in England”, we note their summary as follows: “The safest mechanism for reducing the biodiversity impact of infrastructure is to avoid impacts to biodiversity initially. In practice, this means redirecting development to previously degraded sites wherever possible.”
The final advice report provided by the NCC on the Government’s 25 year Environment Plan in October 2020 included this warning: “In looking at these assessment regimes (Environmental Impact Assessment, Strategic Environmental Assessment and Habitats Regulation Assessment), we have found three fundamental root causes impacting on their effectiveness: access to information, the extent of post-decision monitoring, evaluation and reporting and access to expertise.
“These root causes arise less from the law itself, and more from shortcomings in the wider planning system that affect the way assessment laws are implemented. The issues are well recognised, deep-seated and not susceptible to easy, or indeed legislative, fixes." Addressing these issues will be increasingly important, not just to improve assessments, but because these matters underpin so much of the Government’s environmental ambition. Successful implementation of biodiversity net gain and local nature recovery strategies, for example, rests on the same foundations.
Following on from this, it’s worth exploring the principle of Environmental Net Gain (ENG) to ask why a development backed by such a wealthy corporation with a time-scale of continuous development over many years hasn’t adopted ENG rather than the less effective BNG? ENG follows the same ideas as biodiversity net gain but requires developers to deliver a wider range of environmental benefits over and above the full environmental impact of the proposed development (e.g. air quality, flood risk management).
The Government committed to Environmental Net Gain (ENG) in its 25 year Environment Plan but subsequently watered it down to BNG following an outcry from developers.
We note that, at present, the development proposed by EPIC fails to account for the Woodland Network model as outlined by the West of England Nature Partnership (WENP) in its programme of LNRNs. And, as opposed to the perceived ‘gift’ of the Green Wedge to Long Ashton Parish Council the ‘gift’ can, instead, be seen as part of the minimum statutory requirement instigated albeit slowly by this Government whilst much of the ecological landscaping proposed reflects the Indicative Wetland opportunities identified by the WENP in its LNRNs and contained within the draft Biodiversity Supplementary Planning Document produced by North Somerset Council in November 2023.
3. ENFORCEMENT
How sound is the process both prior to development and afterwards? Taking account of the evidence, the LANCE Trust isn’t confident and these paragraphs from the paper mentioned in item (2) above are relevant: “Most importantly, the current reactive nature of English planning enforcement is poorly suited to guaranteeing the delivery of high-quality habitats within approved developments. Councils can only take action against known planning violations, with little financing currently available for routine monitoring. Failures of habitat types to reach specified condition levels are unlikely to be reported by the public
Leaving such an influential scope for judgments comes with risks, especially if ecological consultants lack sufficient training to conduct the relevant specialised ecological assessments (e.g., grassland assessments), or are implicitly pressurised to report a reduced biodiversity unit obligation by clients (Carver & Sullivan, 2017).
Most importantly, the current reactive nature of English planning enforcement is poorly suited to guaranteeing the delivery of high-quality habitats within approved developments. Councils can only take action against known planning violations, with little financing currently available for routine monitoring. Failures of habitat types to reach specified condition levels are unlikely to be reported by the public.”
In a second paper, we quote“Evidence shortfalls in the recommendations and guidance underpinning ecological mitigation for infrastructure developments”. Whilst there are multiple studies evaluating individual Ecological Mitigation Compensation’ measures (e.g. Nash et al., 2020), there are few comprehensive reviews. Where conducted, they generally point to evidence paucity, exacerbated by limited post-development monitoring, and an inability of EMC measures to compensate for impacts. For example, Lewis et al. (2016) found no published literature supporting the effectiveness of great crested newt mitigation. Stone et al. (2013) identified a significant reduction in post-development bat abundance across 300 derogation licenses, whilst Lintott and Mathews’ (2018) analysis of post-development reports revealed that only 52% of lofts created as licensed compensation contained bats.
4. HUMAN PRESSURE
It is recognised that, while small habitat patches within built environments can have ecological value, high levels of human pressure exerts undue influence on the success of individuals within a species and the numbers of species that can use the site.
EPIC is keen to attract staff, visitors and local residents to its site and to this end is proposing an art trail, fitness trails, walking and cycling trails along with frequent deliveries of staff, visitors and goods along its main access route between two areas of woodland in the north-east corner of the site.
Human disturbance of wildlife is frequently mentioned as one of the principal issues of concern in biodiversity conservation, yet the information required to assess the extent of this threat is rarely available. So it’s hard to work out how many species will be adversely affected by the busy passage of people throughout the EPIC site. However, it’s likely to adversely impact on species such as kestrels and buzzards that currently use the site.
There is no mention of conservation grazing so that will have a negative effect on the foraging success of both lesser and greater horseshoe bats. Increased road traffic especially at night may cause problems to great crested newts and hedgehogs.
It is hard to know whether EPIC will carefully curate the site as opposed to letting it go ‘wild’. Careful curating may be pleasing to the human eye but less successful for wildlife that thrives amongst bramble, ivy and long grasses. The introduction of honeybees, for instance, may sound appealing but may spell disaster for our local, native species.
So far, in its open sessions with the local community, EPIC seem to put more emphasis on the human enjoyment of the site particularly in relation to the productivity of its staff rather than ensuring the protection of both species and habitats for their own sake or as a moral duty to ensure the biodiversity of the planet is respected and protected.