Burlish Meadows: Objection

Subject: Formal objection to the proposed disposal of land at Burlish Meadows

Dear Ms Sloan,

I am writing on behalf of West Midlands Butterfly and Moth Society to formally object to Wyre Forest District Council's proposed disposal of approximately eight hectares of public open space at Burlish Meadows to Kidderminster Harriers Football Club. We are a regional voluntary organisation which works with other partners to conserve the butterflies and moths of the West Midlands (www.wmbutterfliesandmoths.org)

Our objection is based on the following grounds:

Loss of valuable wildlife habitat

Burlish Meadows contains rare, flower-rich acidic grassland and supports threatened and protected wildlife. This includes a population of the nationally declining White-letter Hairstreak butterfly at its only known site in the Wyre Forest district and the nationally scarce Six-belted Clearwing moth as well as many other uncommon species. The White-letter Hairstreak has been severely affected by Dutch Elm disease which has killed off millions of elm trees across the country on which this butterfly depends. Other insects occur which are scarce nationally and, in Worcestershire, are only found in areas of acid grassland like Burlish Meadows. Selling approximately 21% of the country park for development is a significant portion of the site (21 acres) would cause direct habitat loss and fragment the wider network of connected natural areas between Stourport, Kidderminster and Bewdley. No ecological assessment has been undertaken of the site in advance of this proposal being brought forward and mitigation elsewhere as part of biodiversity net gain cannot fully replace an established and locally distinctive ecosystem. In a country which is so nature deplete, a loss on this scale cannot be supported.

Damage to ecological connectivity

Wildlife, especially butterflies and moths, depends on connected habitats for feeding, breeding and movement. Reducing and dividing this site could affect many other species such as grass snakes, slow worms, nesting birds and a range of other butterflies and moths, while placing greater pressure on the remaining conservation area. Burlish Meadows is part of a wider ecosystem which is very vulnerable to habitat fragmentation and isolation. Attempts by some supporters of the scheme to make distinctions between the Burlish Top LNR and the Burlish Meadows Country Park have no foundation in fact. The Lawson Report commissioned by the UK Government concluded that the way forward for nature conservation was 'bigger, better and more joined up areas where nature is a priority' and the proposed sale contradicts this important principle. National research undertaken by Butterfly Conservation and others has shown that isolation and fragmentation is one of the major factors behind declines in many species.

Loss of accessible public open space

Burlish Meadows is a valued green space used for walking, recreation and access to nature and is bringing significant gains to community well-being. As the petition submitted on behalf of the Friends of Burlish Meadows indicates, usage of the site is high and it is well valued within the local community. Easy access from the car park and the level ground means that it is popular with those who have mobility problems and their needs should be considered. The development of the football pitches would deny people access to what is widely regarded as a community asset. Its existing environmental and public-health benefits should be protected and enhanced for current residents and future generations. It is part of the established green belt which separates Stourport from Kidderminster. Once public land is sold and developed, that loss is permanent.

Conflict with nature recovery objectives

Public bodies should be restoring and expanding habitats in response to the biodiversity and climate crises, not disposing of successfully restored land. Considerable public resources and effort have already gone into improving Burlish Meadows, and the proposed sale would undermine that work. This includes the District Council's own ranger service who have worked hard to create the ecologically diverse and valuable wildlife habitat that exists today, supported by external grants and efforts by volunteers. Volunteers from our own Society have worked with the Ranger Service to plant disease resistant elm trees to provide additional habitat for White-letter Hairstreak whose caterpillars feed exclusively on elm trees. We have also supported the development of information boards on site illustrating the wide range of butterflies and moths that occur. Previous statements and policies of the District Council make it clear that sites like Burlish Meadows are part of a wider biodiversity strategy and will receive protection. Any sale of part of the Country Park for other purposes conflicts with clearly stated policies and represents a major departure from previous work which had rightly attracted praise for the District Council. Accepting the current proposals undoes much of what has been achieved and is harmful to the reputation of Wyre Forest Council.

Availability of less damaging alternatives

While recognising the role Kidderminster Harriers plays in the community and supporting its ambition to improve youth, educational and community facilities, this does not justify destroying existing wildlife-rich public open space. There is no evidence that other alternatives have been examined by the Club and the Council should insist that this be demonstrated before any decision is made about this land. We can have nature and football but it is wrong to allow artificial football pitches to be developed on land important for nature conservation which is the case here. Without any investigation of alternative sites having taken place, this proposal can be seen to be premature. The current proposal should be rejected and the Council and Kidderminster Harriers should now work together to undertake a proper study of other options elsewhere in the district on previously developed land or another site of lower ecological and recreational value.

Precedent and public interest

Selling part of a conservation area risks setting a damaging precedent for the disposal of other public green spaces. Once permission is given on part of the site in contradiction of Council policies, it encourages future proposals on this and other sites within the green belt. The council should give substantial weight to the site's long-term ecological, recreational and community value rather than treating it primarily as an asset available for development. It is not in the public interest to allow the development of such an important site for wildlife and for the wider community. For all these reasons we therefore ask the council to reject the proposed disposal, retain the land in public ownership and protect the whole of Burlish Meadows as accessible, well connected wildlife habitat.

Yours sincerely,

Mike Williams

pp West Midlands Butterfly and Moth Society