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We note that the application redline boundary deliberately excludes the river or its bank. We would be surprised if the applicants land ownership does not include up to the middle of the channel as is normal in such situations.

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We are astonished that the Ecological Assessment by a supposedly professional Ecological consultant - Tyler Grange – states

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‘’There are no waterways present on or adjacent to site, and all waterways in the surrounding area are separated by significant physical barriers including roads, rail lines and motorways. ‘’

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So completely ignoring the presence of the exposed river which despite its unmanaged and neglected state is hard to miss.

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The report also fails to point out that a further reach of the river runs west in a culvert under one corner of the extensive car park and grassed area.

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Trust surveyors inspect the St Mary's Gate culvert

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The report concludes:

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'Biodiversity Net Gain (BNG): The Defra 3.0 Metric has calculated that without including off-site habitat creation, the proposed development at this stage as illustrated on the attached landscape strategy plan would amount to a measurable net gain in biodiversity value of c. 0.06 biodiversity units, equating to a 37.18% net gain in biodiversity value.'

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In other words by adding a few plants to a minimal existing planting area the bio-diversity impact of the site is increased by almost 40% !! This in our view is a cynical statistical trick.

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Council Policy on river restoration is very clear:

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a) Local Plan Core Strategy Chapter 12 : 

Policy CS 73 The Strategic Green Network 

Within and close to the urban areas, a Strategic Green Network will be maintained and where possible enhanced , which will follow the rivers and streams of the main valleys: 

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a. Upper Don b. Loxley c. Rivelin d. Porter e. Sheaf f. Rother g. Lower Don/Canal; and include other strategic corridors through: h. Oakes Park to the Limb Valley i. Gleadless Valley j. Ochre Dike Valley k. Shire Brook Valley l. Shirtcliffe Brook Valley m. Blackburn Brook Valley and its tributaries n. Birley Edge.

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12.12 The Network will be secured by preserving open space through development control, enhancing existing open space, creating new open space as part of new development and through developer contributions. The draft Public Rights of Way Improvement Plan proposes to enhance the provision of good quality paths and network links to and along the river corridors. It also proposes to integrate parks, woodlands site facilities, canal/riverside, and open country access into the overall path network. 

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b) The Sheffield Unitary Development Plan retained Policy GE 17 states that:

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‘As part of the development of the Green Network, all rivers and streams will be protected and enhanced for the benefit of wildlife and where appropriate, for public access and recreation. This will be done by:

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1. Not permitting the culverting of any river or stream unless absolutely necessary and encouraging the reopening of culverted watercourses where opportunities arise …

2. Expecting the setting back of any new development to an appropriate distance from the banks of major rivers and streams to allow for landscaping 

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National policy 

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The 2021 Environment Act requires a mandatory 10% net gain in bio-diversity. The applicants acknowledge this requirement and use Natural England’s Biodiversity Metric guidance but have sought to satisfy it in a minimal way by proposing a minor planting of a currently bare piece of earth, rather than make a worthwhile contribution by restoring the river. The guidance specifically mentions watercourses as a prime example of how the requirement should be met.

 

Wider Context

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Deculverting and restoration of a significant section of the Porter Brook will form part of a greater project which is already happening throughout the Lower Porter Corridor from Hunters Bar to the Station. Redevelopment of former industrial sites between Shoreham St and Mary St is already opening up continuous access and providing restoration of the channel for wildlife. Major retailers such as Waitrose and Decathlon have played their part in exposing and improving their sections. 

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The Environment Agency and the Council are also currently focussed on a flood defence strategy for the Sheaf and Porter Valley and have recognised removal of culverted sections of river as one of the early ways to create more flood capacity, as demonstrated by the award winning Matilda St  pocket park (see photo below)