Details of the proposed development

The revised application details the erection of 265 dwellings, employment workspaces along with associated parking and access roads.

The Trust’s primary concern is that there would be a greatly increased number of people visiting the Lugg Meadows, an increased number of dogs and cats, noise, light pollution and traffic. This is likely to have a significant impact on the flora and fauna of the meadows. In particular, the increased disturbance would impact the breeding curlew, which are already threatened with local extinction and the subject of a conservation project at the site.

SSSI status is the greatest protection a habitat can have in the UK and should mean it is preserved in perpetuity. Floodplain meadows have become incredibly rare with only around 1,200 hectares of this habitat remaining in the UK. They fulfil natural functions of flood management, pollution reduction and carbon sequestration alongside the provision of fantastic, specialised, wildlife habitat. This habitat is also included in Herefordshire’s Biodiversity Action Plan as one that conservation groups have identified as particularly under threat in the county and in need of preservation. The nature reserve is home to many rare species of plants and animal including the snake’s head fritillary and a small population of breeding curlew.

The Trust also has concerns about the impact on the River Lugg, designated a Special Area of Conservation, already under huge pressure from pollution and described by Natural England as “unfavourable/declining.” The proposals do not guarantee that run-off from the development (which may include a wide range of pollutants e.g. oils, phosphates from car washings, paints, bleach) cannot enter the Lugg Rhea and, from there, the meadows and the River Lugg.

Much of Lugg Meadows is owned by Herefordshire Wildlife Trust with some areas also owned by the charity Plantlife.

We believe the proposed development poses a significant threat to our county’s precious Lugg Meadow floodplain meadow, a locally, nationally and internationally important site. As well as the iconic snake’s-head fritillary and other species associated with floodplain meadows, Lugg Meadow supports one of the best remaining populations of narrow-leaved water-dropwort, an increasingly uncommon plant of water-meadows and wetlands. 

We object to this development proposal for the following reasons:   

• Negative impact upon a nationally important designated site and exceptionally rare and culturally important "Lammas" meadow (one of only 14 in the UK) – the development site lies adjacent to the meadows
• National Planning Policy states that adverse effects on a Site of Special Scientific Interest should not normally be permitted 
• The development contravenes Herefordshire Council’s Core Strategy policy and the developing Local Nature Recovery Strategy 
• The development would be in part of an important ecological “buffer zone” to the meadows
• Increased population in such close proximity to the site will add further recreational pressure impact on habitats and species, especially through dog-walking, to the meadows
• The impact of domestic cats on ground nesting birds will be significant
• Pollution concerns from the run-off of the proposed development
• An increase in the number of footpaths and ‘open space access land’ adjacent to the meadows will increase the footfall on the meadows and cause even more disturbance. 
• The loss of breeding habitat for skylarks  
• A lack of detail regarding proposed habitat enhancements, and need for more detailed botanical surveys 
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In addition, we are concerned about the Council’s failure to require an Environmental Impact Assessment to be undertaken for this development. We believe the Council has failed to give proper regard to the criteria that should be considered and there are a number of things of concern within the LPA's EIA screening matrix:

• No mention of  plant species in the screening matrix (question 9.2 on protected, important, sensitive species in or around site that could be affected). We would argue that the indirect impacts from the site (e.g. nitrogen deposition) could impact species around and on the Lugg SSSI e.g. Nationally scarce Narrow-leaved Water-dropwort (Oenanathe silaifolia). The species is also listed as “near threatened” in the vascular plant Red List for Great Britain. Mousetail (Myosurus minimus), a nationally declining species listed as ‘vulnerable’ in the vascular plant Red List for Great Britain and rare in Herefordshire.  

• Disagree with the assessment (question 9.1 on impact to protected areas) that embedding mitigation measures into the design would mean significant effects in EIA terms aren't likely. No mention development is in SSSI Impact Risk zones

  Disagree with the assessment (question 6.1 & in latest Ecl Impact Assessment) that 'no significant adverse ecological effects are likely' from nitrogen deposition, despite modelling showing the nitrogen deposition load in the SSSI was exceeded in all scenarios

• The Ecl IA says that the SSSI has exceeded nitrogen deposition critical loads since 2003, & relies on an NE SSSI condition assessment from 2011 saying the SSSI was in favourable condition - so this assessment isn't based on an up-to-date condition assessment
• Our previous recommendation - to conduct a National Vegetation Classification survey (not just a UK Habitat Classification survey - was not taken on board by the latest Ecl IA
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Take Action

We strongly encourage anyone who is concerned about this development to respond directly to the planning application (P240422/F) which you can do through the Herefordshire Council website: Planning Search – Herefordshire Council.

Guidance

Our general guidance note on responding to planning applications can be found here

Our objection to the original application, and our further responses can all be viewed on the Herefordshire Council planning portal.

Our further objection on the revised application, submitted 26/09/25 can be read here.