Appraisal of Lowood housing site showed potential risk of pollution

EXCLUSIVE by EWAN LAMB

A screening exercise to ascertain whether 29 Borders housing sites could be developed without threatening protected habitats acknowledged the construction of hundreds of new homes at Lowood, close to the River Tweed "could increase discharge of pollutants from waste water treatment works".

The Habitat Appraisal Record (HAR) was compiled by Scottish Borders Council in 2017, but the findings from the study have only now been made public following a Freedom of Information request. It says: "There is a chance of housing allocations in the Housing Supplementary Guidance (SG) causing LSEs (Likely Significant Effects) to this site."

Despite the apparent potential threat to the River Tweed Special Area of Conservation [SAC] the screening assessment concluded "all 16 of the sites screened into the process either were not found to have effects on the SAC, or had possible minor effects that could be sufficiently avoided or mitigated."

The land at Lowood - recently purchased by the council for £11 million inclusive of fees and tax - is expected to be the largest new greenfield housing site in the region's second Local Development Plan (LDP), due to be finalised in 2020. SBC clearly believes the scale of proposed development will not pose a risk to the delicate habitats associated with the Tweed river system.

But at least one of the riparian owners is convinced the Lowood housing proposals being promoted by the council could inflict unwanted damage on salmon stocks and the environment in general. As previously reported in these columns Middlemede Properties, proprietors of the mile-long Upper Pavilion salmon beat right next to Lowood is calling on the council to remove the estate land from its list of housing sites.

The local authority's 2017 HAR says: "Any housing development taking place on this site (Tweedbank/Lowood) would still require to be acceptable under LDP Policy EP15, which confirms that development that would adversely affect the water environment would be refused.

"Furthermore, the development requirements for this site include a flood risk assessment, mitigation required to ensure that there will be no significant adverse effects on integrity of the River Tweed SAC, possibly an environmental impact assessment, a drainage impact assessment, contact with Scottish Water in respect of water treatment works, and the assessment of ecology impacts and the provision of mitigation. The above is considered sufficient mitigation for any potential minor effects on the SAC."

However, Middlemede's representatives claim the proposed mitigation measures are vague and non-specific. The potential threats to the SAC have been under-played, they maintain.

The entire Tweed river system was designated a SAC - of European importance - in 2005. It is also referred to as a Natura site. A range of conservation objectives are included in the designation to safeguard key species including Atlantic salmon, otter and lamprey.

Those objectives are listed as follows: "To avoid deterioration of the habitats of the qualifying species  or significant disturbance to the qualifying species, thus ensuring that the integrity of the site is maintained and the site makes an appropriate contribution to achieving favourable conservation status for each of the qualifying features; and  to ensure for the qualifying species that the following are maintained in the long term: Population of the species, including range of genetic types for salmon, as a viable component of the site; Distribution of the species within site; Distribution and extent of habitats supporting the species; Structure, function and supporting processes of habitats supporting the species; No significant disturbance of the species."

The threats, pressure and activities with impacts on the River Tweed SAC according to the record of the Joint Nature Conservation Committee are: Pollution to groundwater; Human induced changes in hydraulic conditions; Invasive non-native species; Modification of cultivation practices; Grazing; Annual and perennial non-timber crops.

JNCC's record also states: "Substantial housing development within close proximity of the River Tweed SAC may increase recreational disturbance and could increase discharge of pollutants from waste water treatment works."

It is a formidable and robust designation, underlining the importance of keeping the river system safe from risky development projects and other activities which might upset the delicate balance.of the SAC's habitats.

However, the council's HAR overall conclusion appears to dismiss any potential threats from any or all of the proposed housing development sites.

The document states: "Ultimately, all 16 of the sites screened into the process either were not found to have effects on the SAC, or had possible minor effects that could be sufficiently avoided or mitigated. 

"These findings were confirmed following the relevant steps which were: screening out allocations for which a link to a Natura site cannot be established; screening out allocations where a previous HRA or appropriate assessment have concluded that there is no LSE on the conservation objectives of a Natura site or that there is LSE that can be avoided; screening out sites where Local Development Plan policy and site specific requirement means LSE on the conservation objectives of a relevant Natura site can be avoided; and confirming that any potential effects on the SAC are so minor there would be no cumulative effects."