BTF Comments – 31 March 2024

2

managed to their target condition (as specified in the BNGA). It should also show how

management of the site will be resourced and monitored.

Reason: Ecological enhancement is needed to meet the requirements of the revised

National Planning Policy Framework (NPPF, 2023). The NPPF states in paragraph 174 (d)

on page 50 that "Planning policies and decisions should contribute to and enhance the

natural and local environment by... minimising impacts on and providing net gains for

biodiversity..". And, the Environment Act (2021) requires habitats to be maintained for

30 years after development is completed.

This is the LEMP Land – edged in blue and coloured green - to the south of the redline boundary:

As we pointed out in our recent email dated 25 March 2024, this site is clearly contaminated:

Dear Development Management and xxxx,

You will be aware that, for some time now, we have been unsuccessfully attempting

to have sight of the proposed LEMP (Landscape and Ecological Management Plan)

BTF Comments – 31 March 2024

3

referred to at paragraph 11 of the attached Grant and in the Unilateral Undertaking

(also attached). May we please see a copy of the current draft.

In the meantime, we have been collating photographs of the offsite area which you

can view here - https://photos.app.goo.gl/tmRL4Lj3sqUmRQFm6.

These comprise a series of stills taken from drone footage made on 23 September 2023

published on Youtube - https://www.youtube.com/watch?v=igy1I_S6_FY&t=36s. The

other images were made today, 25 March 2024.

If you compare these, you will see that the site has been substantially degraded

between these two dates so that it is unlikely that it would now be described as 'Other

woodland; broadleaved' habitat under BNG 4.0. From what we have seen, it appears

that the site has been used by the club as a dumping ground during the recent stand

construction.

There is also evidence of historic flytipping. Given this, it is perhaps surprising that

the applicant's ecologists, Wardell Armstrong, omitted to mention this when they

surveyed the site on 07 September 2023 - see section 3.6 w1g – Other Broadleaved

Woodland of the attached report.

We sincerely hope that the final LEMP, when it is presented, will take account of this

and make proposals to restore (as far as possible, the site back to its pre-degradation

state before work is undertaken to enhance the offsite area condition from Poor to

Moderate.

In the meantime, we have submitted this Freedom of Information Request

- https://www.whatdotheyknow.com/request/request_for_information_about_pl_2.

In light of this, the applicant has failed to comply with Condition 2 which was imposed ‘to

ensure that risks from land contamination to the future users of the land and neighbouring

land are minimised, together with those to controlled waters, property and ecological systems,

and to ensure that the development can be carried out safely without unacceptable risks to

workers, neighbours and other offsite receptors.’