I feel compelled to respond to Councillor Richard Lewis’s response this week to the West Leeds Dispatch about lack of consultation for the Leeds Flood Alleviation Scheme Phase 2 (LFAS2).
Having worked on the creation of the Kirkstall Valley Nature Reserve and associated environmental projects throughout the 1990s and more recently working on the development and funding of the central and East Leeds flood alleviation scheme (FAS 1) and as an environmental volunteer in Kirkstall Valley I have taken a keen interest in the development of the FAS 2.
Sadly, along with many local people, colleagues at Urban Wildlife Leeds and the Friends of Burley Mills and St Ann’s woods and other local community organisations working to improve and protect the Valley and its wildlife, I am dismayed at the lack of genuine consultation for the scheme.
The planning application was submitted in December just before the Christmas period when people are very busy and may be away from home and entailed around 100 documents some hundreds of pages long. My strong impression is that very few local people actually even knew that a planning application had been submitted for the scheme.
Even if they did, gaining some understanding of the scheme is very time consuming, because of the confusing presentation across multiple lengthy documents which are not always consistent. Other places, for instance York and Calderdale, have approached their flood defence schemes with much clearer and accessible public information.
It’s not even clear which elements of the scheme are funded and which are aspirational as currently there is only an in principle agreement for funding of £65million whilst the cost of the complete FAS 2 scheme is estimated to cost £112million!
This is particularly worrying in regard to environmental mitigation and any enhancements to help repair the damage to the natural environment and or improve public realm and access as these elements are often seen as ‘nice to haves’.
I must question Councillor Lewis’ claim of ‘significant consultation’. From the consultation period starting in Autumn 2017 up to the December 2018 planning application submission I am aware of very few consultation events taking place and where they did the information offered was very limited. For instance I attended one of the few events in October 2017 and although the staff were very welcoming I was disappointed to come away learning virtually nothing about the proposals.
I was the only person at the event just before it closed and on my way home from work. However when I signed the register of attendees noticed that only two other people had signed. I still haven’t had a newsletter that I requested.
This limited approach is not good enough nor is it in line with the National Planning Policy Framework or Leeds City Council Policy for Inclusive Design which require early community involvement in the development of public design projects.
Although the FAS team were at the Kirkstall Festival in July 2018, which was welcome, in reality there was still very limited information available about the design of the scheme, and later some local groups were offered a meeting to update them on the scheme before it was submitted for planning but evidently that meeting didn’t take place.
The environmental surveys accompanying the scheme also present a very unrepresentative and unflattering description of the ecological value of the Kirkstall Valley and its remarkable green infrastructure.
Local knowledge from naturalists living in the area and biological records they have helped compile have not been used to help inform any environmental mitigation and enhancement strategy, due to no consultation with them.
The few environmental enhancements that are included are extremely limited in ambition and scale when compared to the very significant investment proposed and the damage to the natural environment that will be caused.
For instance the creation of a 2.4 hectare wetland and flood storage area – Kirkstall Meadows – includes the preservation of three Rugby pitches within the so-called meadows area where no landscape intervention is proposed to take place, effectively reducing by over 50% the actual area for enhancement such as tree planting and wetland creation.
And it is now clear that it’s not just the local communities who have concerns about the design and limited time for consultation. Statutory organisations such as Historic England, the Coal Authority and the Canal and Rivers Trust have all raised serious concerns about the scheme.
The development of a major, linear infrastructure project such as FAS 2 is not only challenging, it is an opportunity for multiple environmental improvements. The Council is aiming to invest £112million in the delivery of FAS 2 mainly to defend commercial areas but what are we the actual local communities getting for this massive investment?
These flood defences are going to create massive destruction to the local landscape including felling of hundreds of trees affecting bats and the many other species that rely on woodland. Also, river bank habitat will be destroyed affecting protected bird species who nest in river banks including dipper, grey wagtail and kingfisher.
Severe ecological impacts will also damage watercourses, including the Kirkstall Goit, that forms part of the medieval modification of the River Aire and the setting of the Abbey and is an important aquatic habitat for dragonflies and damselflies.
Successive road schemes and retail developments have already eroded the integrity of the beautiful green setting of the river and now the FAS2 will potentially undermine the potential for ecosystem services including mature trees which not only promote biodiversity but also slow surface water runoff into watercourses and improve the air quality in one of the most polluted areas in Leeds.
In response to all of these concerns there should be a significant extension to the planning application consultation period and opportunities for the local communities and statutory consultees to be engaged in genuine consultation on the proposals.
– Johanna Mawson, by e-mail
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