A Commonsense Neighbourhood Development Plan for Burghill Parish

Note: this is NOT the 'official' Burghill Parish Council website.




According to an article in October in the journal EndsReport, in July 2019, wildlife regulator Natural England notified Herefordshire Council that it had updated its legal advice and would no longer be able to support planning applications that could detrimentally affect the River Lugg catchment – a Site of Special Scientific Interest (SSSI) and part of the River Wye Special Area of Conservation (SAC) – unless it was certain that the level of phosphates in the river could be brought into compliance. The Lugg is currently failing its conservation targets of phosphate levels as a result of water pollution from both ‘point’ source (e.g. sewage outlets) and ‘diffuse’ source (e.g. agricultural run-off).

(High levels of phosphates in the Lugg catchment, can lead to algal blooms starving the water of oxygen and killing aquatic species in a process known as eutrophication.)


Herefordshire Council has now issued a Position Statement dated 15 October which we have only been able to find and share because Kinnersley Group Parish Council - clearly one of the more transparent parish councils - posted it on their website. It has yet to appear on Herefordshire Councl's website** ! Or indeed on the website of Burghill Parish Council. Here is that Position Statement.pdf (opens in new window).

(**miracle of miracles - it has been discovered on Herefordshire Councl's website on 17 November! It is buried under "About Planning Services". Click on the link https://www.herefordshire.gov.uk/info/200142/planning_services/66/planning_services, then look in the panel on the right hand side under "In this Section", scroll down to " Guidance for developers - current development in the River Lugg catchment area" and click on it. When the next page appears, click on the yellow bar which has the text "Current development in the River Lugg catchment area position statement".)

It contains a map of the whole Lugg Catchment (in Red), which covers most of North Herefordshire.

The whole Catchment is shown on the map on the left below, the part which affects Burghill Parish is shown enlarged on the extract on the right below:



Broadly speaking, the south of Burghill Parish (including Burghill) is in the Wye Catchment, and the north ofBurghill Parish (including Tillington) is in the Lugg Catchment:

(this map extract is from the Environment Agency's Catchment Data Explorer https://environment.data.gov.uk/catchment-planning/WaterBody/GB109055037180. Note that it shows 3 year old (2016) data because the EA reduced their Wye & Lugg sampling points from 45 to 38 in 2017!)












Referring to the Herefordshire Council Position Statement it states that subject to an "Appropriate Assessment", within the Lugg Catchment drainage fields (i.e. spreaders from septic tanks) may be acceptable if the drainage field is more than 50m from the designated site boundary or sensitive interest feature (includes Habitats of Principal Importance). Habitats of Principal Importance include Priority Habitat Inventories of Deciduous Woodland, Traditional Orchards, and Woodpasture & Parkland. The Lugg Catchment boundary is shown in the left-hand map below (which is from the Environment Agency's Catchment Data Explorer); and the Habitats of Principal Importance are shown in green on the right-hand map below (which is from Natural England's Magic Map). Given the plethora of Habitats of Principal Importance and the Natural England requirement of a 50m buffer around them and from the Catchment Boundary, it is obvious that development in Tillington will be severely constrained. Tillington, along with dozens of other off-sewer villages was targetted for housing development by Herefordshire Council as a main growth settlement in the 2015 Core Strategy and Burghill Parish Council then obediently supported that by including it in its 2019 Neighbourhood Devel;opment Plan) .



There will of course be those who will call for mains sewerage to be installed to solve this phosphates problem. Good luck with that. The phosphates problem extends across most of North Herefordshire. Do the lobbyists for mains sewerage really think that there is a magic money tree to fund mains sewerage installation right across the north of the county, for the benefit primarily of developers of mini-housing estates? Do they really think that owners of existing properties with cheaper private drainage will see any benefits for themselves from more expensive mains sewerage? It is the legal duty of existing private foul drainage owners to maintain their septic tanks to avoid ground contamination, and for that care they benefit from private sewerage which is usually cheaper than mains sewerage, so it is hard to see that there might be a genuine spin-off benefit for them even if mains sewerage were affordable. And although properies very near a mains sewer might be able to afford connection, the majority will be too distant from the sewer.

Finally, one should note that Herefordshire Council's Core Strategy is starting to be reviewed. In fact there is a Core Strategy and Neighbourhood Planning review workshop at 4:30PM on Wednesday 6th November 2019 at the Shire Hall, Hereford. That is tomorrow! (This is being written on 5 November). Presumably this is for Parish Councils and not for the likes of parishioners and citizens! It is hard to comprehend how citizens can be informed about these reviews if (a) they are not told about the reviews and (b) they are not informed about a new constraint as significant as Natural England's decision not to support planning applications which detrimentally affect the Lugg. All residents in Herefordshire should be very concerned, because while the phosphates problem remains unresolved, the planning constraints in the Lugg Catchment will inevitably displace and concentrate the housing development emphasis towards other areas which are within other river catchments not so far affected.

The planning answer to this latest Lugg phosphates problem (apart from obviously reducing agricultural run-off) is not to make repeated attempts at locating excessive new development in off-sewer "zones" which have poor soil infiltration characteristics, but to scale down the amount of development which the land can absorb. This was suggested by concerned parishioners during the NDP process but was of course completely ignored.

CommonSense 5th November 2019