Elton Reservoir Housing Allocation Objection. DP Bentley Ecological Consultant

Elton Reservoir Housing Allocation – objection. DP Bentley ecological Consultant.

The open land between Bury and Radcliffe to be destroyed

Lack of consultation

The lack of consultation has been breath-taking. The process is contrary to Bury Council’s own guidelines thus:

“How will the Council involve you?

3.16 The following table lists some of the activities and methods the Council will consider using when undertaking consultation exercises in connection with the Local Plan. The methods used will be tailored to suit the scale and nature of impact of the decisions to be made and the particular needs of people being consulted:

Material made available on the Council’s web site, in Council offices at Knowsley Place Reception, Town Hall Reception and selected local libraries (see our Statement of Community Involvement web page on for a list). The ALLOCATIONS AND NOTES ARE NOT FREELY AVAILABLE ON THE COUNCIL WEBSITE.

Send letters and emails to database contacts, including targeted consultation letters for key community groups. The Council may consider more targeted consultation where residents may be more directly affected by proposals. NOT DONE.

Advertise via social media on Facebook & Twitter. NOT DONE.

Where possible, place articles in:

local newspapers;

‘Planzine’ - the department’s e-newsletter sent to a database of contacts and

Using other online news sources as appropriate.

Use posters on notice boards in prominent locations including town centres, civic suites, markets, leisure centres and public open spaces. NOT DONE.

Council held a public consultation on the wettest, windiest day of the year and told few people. Never told me. This consultation is contrary to Bury Council's Statement of Community Involvement, and thus may not be legal.

The importance of the Habitat Mosaic

The open space around Elton Reservoir contains 10 different council-designated Sites of Biological Importance and a river. This is the most concentrated and diverse group of wildlife sites in Greater Manchester. Present are large open waterbodies, small ponds formed in marlpits, brickpits, coal shafts and inundation areas, lowland streams - with cut off sections, a canal, a river and riverside habitats, mill goits, marshland, reedbed, berry-rich hedgerows, shrubland, woodland, hedgerow trees, vegetated industrial mineral workings, working farmland of improved dairy grazing land, and semi-improved grassland with for example hay-rattle flower, old farmsteads supporting bats and owls and other nesting birds. There is a network of well-used public footpaths allowing people to see a working countryside with Highland Cattle, milk cattle, beef cattle, sheep and free range poultry as well as horses, and of course the abundance of wildlife. The area draws bird watchers from not just Bury, but the whole of Greater Manchester and indeed the North West. The canal towpaths and footpaths attract cyclists and long distance path users, and Elton Reservoir hosts a Sailing Club. Industrial heritage is represented by the reservoirs, the canal, the embankment of an ancient horse-pulled railway connecting with the canal, railwaylines -active and closed, the goits, and the ponds formed in old workings. There is a Bronze-age burial site in the field next to Radcliffe cemetery and crematorium - this is a landscape which our ancestors have cherished as a final resting place for thousands of years. Metrolink passes the area and shows people entering the main town of Bury what a lovely green place the town is.

If you draw a line from the southern parts of Stockport across Greater Manchester to the north of Bury across a solidly built up conurbation there is only one substantial area of open water in a setting of grassland, woodland and hedgerows. That is this proposed Housing Allocation of Elton Reservoir. Gorton Reservoir is a large waterbody but it sits in a well-manicured golf course. The importance of the Elton Reservoir Housing Allocation for migratory wildlife, local wildlife and informal recreation cannot be over-stated. And Bury’s Labour Council seeks to trash it all to pursue Labour’s choice of ACCELERATED GROWTH, which lies on top of faulty population growth statistics. To object send an email to by 23.59 on 16th January 2017 citing the area you want to protect and giving your full name and address.

The importance of Mammals in the Elton Reservoir Allocation Area and the undesignated Wildlife Corridor across Pilkington Fold/Spen Moor.

The area supports a wealth of mammals including Roe Deer, Brown Hare, Rabbit, Badger (tracks seen and photographed), Red Fox, Stoat seen on hinds lane between Elton Reservoir and Withins Reservoir, Weasel, Mink, Brown Rat, Short-tailed Field Vole, Wood Mouse, Grey Squirrel, Hedgehog, Common Shrew between Elton and Withins, Mole, and Otter, which is known from the adjacent River Irwell and also Roch in recent years. Seven species of bats have been recorded.

The Brown Hare has already been expelled from Spen Moor where records of it were unlawfully ignored in the planning process by Bury MBC. The Brown Hare is listed by the UK Government as a United Kingdom Biodiversity Action Plan Priority Species, given a 49% decline recorded between 1995 and 2002. This is now succeeded by the UK Post-2010 Biodiversity Framework (or “Biodiversity 2020”) and Priority Species are termed Section 41 species i.e. species “of principal importance for the purpose of conserving biodiversity” covered under section 41 (England) of the NERC Act (2006) and therefore needing to be taken into consideration by a public body when performing any of its functions with a view to conserving biodiversity. Concerns cited are the loss of roughs in farmland and the loss of mixed farmland and an increase in predation. The housing allocation seeks to effectively wipe out the farmland of this area, which mixed and non intensive, as well as increase the population of dogs and cats in the area many-fold.

The site supports Hedgehogs – which is listed by the UK Government as a United Kingdom Biodiversity Action Plan Priority Species, given a 20% decline recorded over 4 years prior to listing as a UKBAP species. Concerns cited are traffic density, fragmentation of habitats, need for hibernation sites, need for hedgerows and wide field margins.

The importance of the undesignated wildlife corridor for mammals across Pilkington Fold between the wider countryside and Elton Reservoir allocation cannot be over-stated. It that area is closed then there is no other linkage. An earlier linkage was lost when Peel Estates closed the old railwayline in order to progress the building on land at Black Lane, Radcliffe. A corridor must be maintained across Pilkington Fold. A Wildlife Corridor must be designated.

Seven protected Bat species have been recorded in the affected area. The South Lancashire Bat Group, in a 1.5km radius circle centred just north of Dofferfold Farm at Elton Reservoir, have recorded in recent times UK and European Law protected bat species Daubentons, Common Pipistrelle, Soprano Pipistrelle, Noctule and the Eurobat Priority species Nathusius Pipistrelle. Angela Graham has provided records of Brown Long-eared and Whiskered/Brandts Bat. The Noctule, the Brown Long-eared and the Soprano Pipistrelle are UK Biodiversity Action Plan Priority Species, i.e. “Species of principal importance for the purpose of conserving biodiversity” covered under section 41 (England) of the NERC Act (2006) and thus they need to be “taken into consideration by a public body when performing any of its functions with a view to conserving biodiversity.” For Noctules, which had a 21% decline over 6 years prior to UKBAP listing, the JNCC website shows a requirement to protect mature trees, wetlands, stream sides and other insect rich areas and boosting water quality – developing by streams and in the reservoirs and canal catchments of the allocation site will not help water quality. For Brown Long-eareds, which had a 20% decline over 7 years prior to UKBAP listing, the JNCC website shows a need to protect countryside buildings with roost potential as well as a landscape of woodland edges, hedgerows, small farm woodlands, deciduous and mixed woodland, and connectivity between these – the site is dotted with hedgerow trees and those associated with farmsteads. The advice specifically says this: “Ensure the retention and protection of older trees for roosts is included in land-use policies.” For Soprano Pipistrelles, which had a 42% decline prior to UKBAP listing, the JNCC website requires that the needs of the Soprano Pipistrelle are considered in agri-environment, planning, water quality, wetland creation …..policies. The Turley Peel Masterplan specifically shows they intend to destroy or encourage the destruction of the Elton Goit Site of Biological Importance in order to remove the wildlife value and remove the reasons preventing development – this is the largest area of marsh in the vicinity. The JNCC urges the creation, expansion and improvement of key habitats including wetland and features such as hedgerows and woodland edges. “Ensure adequate consideration of a landscape approach to the conservation of Soprano Pipistrelle.” Alas the housing allocation does quite the opposite - a landscape approach to the destruction of wildlife habitat and wildlife corridors.

Recent data shows that Nathusius' Pipistrelle may be widespread but rare in Britain and Ireland. Nathusius' pipistrelle is considered to be vulnerable in the European context and is protected under the ‘EU Habitats Directive.’ Furthermore, this species is listed in the United Nations convention on the ‘Conservation of Migratory Species of Wild Animals’ (Bonn, 1979) via the EUROBATS agreement (London, 1991). At present, threats to the species include: Habitat Loss – all of which will happen due to the Elton Reservoir Housing Allocation; Maternity roost sites in buildings and trees can be disturbed, damaged or destroyed by inappropriate land management or development; Loss of hibernation roost sites in buildings, trees and underground sites can occur for similar reasons to those above; Destruction of habitats such as riparian, wetland, woodland and unimproved grassland has resulted in the loss of insect-rich feeding habitats; Land use Changes; Loss and decline of linear landscape features (e.g. tree lines, hedgerows, ditches) remove important flyways and flight line features along which bats hunt for insect prey; The trend for opening up land to produce large uniform fields has led to a decrease in habitat diversity, and consequently a loss of feeding habitat and decline of insect prey; May be effected by badly sited windfarms due to its migratory behaviour; Use of Pesticides and other chemicals - The widespread use of pesticides in both the garden and the wider countryside has led to a decline in the presence of insect prey; The use of inappropriate timber treatment chemicals at roost sites (i.e. those that are toxic and persistent) can be directly harmful to bats, and decrease the availability of roost sites. Elton Reservoir area contains a mosaic of habitats including 10 different Sites of Biological Importance, streamsides, hedgerows, and semi-improved grassland (with e.g. Hay Rattle) as well as improved pastureland.

The importance of Birds in the Elton Reservoir Allocation Area and of the area for bird migration, both regional and international.

Following is a list of birds from the Elton Reservoir housing allocation area. In this list are UK and EU Protected Species, Biodiversity Action Plan Priority Species, and species requiring conservation measures via the UK’s international obligations – the Bern Convention, the Convention on Migratory Species and the African-Eurasian Waterbirds Agreement. There are Birds of Conservation Concern Red List species, the most threatened UK bird species, whose conservation is of most concern, and BoCC Amber List species, whose conservation is also of concern. Four species are globally threatened and are listed by the IUCN. The remaining species are of Least Concern but are valuable part of this wonderful and vital ecosystem.

Total birds species recorded by contributors to this list186 species

Bird species fully protected by UK Law (W&CA Sch 1.1)39 species

Bird species fully protected in EU Birds Directive (Annex 1)27 species

Bird species designated UK BAP Priority Species27 species

Bird species recommended for protection by Bern Convention Appendix 271 species

Migratory bird species with unfavourable conservation status requiring

international conservation agreements via Convention on Migratory Species App 266 species

Migratory waterbird species that are endangered or with unfavourable

conservation status.CMS African-Eurasian Waterbirds Agreement - Annex II75 species

BoCC Red List species with severe population/range declines42 species

BoCC Amber List species with moderate population/range declines64 species

Bird species listed by the IUCN as Globally Vunerable i.e.considered

to be “facing a high risk of extinction in the wild.“ 1species

Bird species listed by the IUCN as Globally Near Threatened i.e.

which may become vulnerable to extinction threats in the future 3 species

Bird species listed by OSPAR Convention - seabirds birds which are

vulnerable to the threats posed by the many competing human uses of the sea. 2 species

There are 42 Red List species, 64 Amber List species, and 80 other species. 39 of the bird species are specially protected birds under the Wildlife and Countryside Side Schedule 1.1. 27 of the bird species are UK Biodiversity Action Plan Priority Species, i.e. “Species of principal importance for the purpose of conserving biodiversity” covered under section 41 (England) of the NERC Act (2006) and thus they need to be “taken into consideration by a public body when performing any of its functions with a view to conserving biodiversity.” Patently the housing allocation devised by Bury MBC has ignored these species. This area is truly remarkable for birdlife. If you draw a line from the southern limits of Stockport to the northern part of the town of Bury there is only one single area of large waterbody set in a farmland landscape – the Elton reservoir area, with its mosaic of water, marsh, reedbed, streams, ponds, shrubs, hedgerows, grasslands, both improved and semi-improved, tall herbs, canal, river and vegetated mineral workings. The only comparable area of water with grassland is Gorton Reservoirs which is situated in an active golf course. I need to stress this list is important due to the whole habitat mosaic and not just one large waterbody.

The list of birds is not included in this draft. It will be submitted to GMSF in due course.

Key to notes– R – resident; B - breeds; S – Summer visitor; W – Winter visitor; P – passage migrant; V – vagrant (very rarely seen). (PB) – from Peter Baron’s Elton Bird Report 10 years to 2016; (SJ) – Simon Johnson; SH – year of latest records from Steven Higginbottom; Some dates gleaned from Manchester Birding. This is not intended to be an exhaustive list of records. It is a list of bird species recorded over the proposed Elton Reservoir housing allocation in the last 10 years, with most recent years seen by one bird recorder; there may be more recent records. Farmland birds are still a major concern according to the British Trust for Ornithology. The list is what people have seen and should not be taken in any other way. Birds do not have to be seen by people to be present and visiting or migrating through.

Codes to protected/conservation status:

WCA1.1Bird species fully protected by the UK’s Wildlife and Countryside Act Section 1.1.

BD1Bird species fully protected by the European Union’s Bird Directive Annex 1. Birds which are the subject of special conservation measures concerning their habitat in order to ensure their survival and reproduction in their area of distribution.

UKBPSUK BAP priority species were those that were identified as being the most threatened and requiring conservation action under the UK Biodiversity Action Plan (UK BAP) – Now termed Section 41 species.

BC2Bird recommended for protection as a result of the Bern Convention Appendix 2 to which the UK is a signatory. Special protection (`appropriate and necessary legislative and administrative measures`) for the animal taxa listed, including all forms of deliberate capture and keeping and deliberate killing; the deliberate damage to or destruction of breeding or resting sites; the deliberate disturbance of wild fauna, particularly during the period of breeding, rearing and hibernation, insofar as disturbance would be significant in relation to the objectives of this Convention.

CMS2Convention on Migratory Species Appendix 2, to which the UK is a signatory. Migratory species having an unfavourable conservation status for which Range States are encouraged to conclude international agreements for their benefit.

AEAW2Convention on Migratory Species, African-Eurasian Waterbirds Agreement - Annex II, to which the UK is a signatory.Conservation of migratory waterbirds, giving special attention to endangered species as well as to those with an unfavourable conservation status.