Tipner West: Don’t Cross the Line

What are we challenging the council to do at Tipner West? 
 

The RSPB and the Trust recognise that Portsmouth needs sustainable employment development and new homes, just as nature needs homes, but we can’t let protected sites be destroyed by a lack of ambition. Current proposals in the local plan still risk crossing key red lines. 

We have tried to show the Council, that there is a potential solution for Tipner West that meets the Council’s goals for housing and development while safeguarding the sites protected for nature. We have tried to show the Council that it doesn’t need to settle on an option that bulldozes over parts of the protected area for nature, as this would set a dangerous national precedent and wreak havoc for our local wildlife.  

Working with Influence Landscape Architects, we produced images to demonstrate to Portsmouth City Council that it would be possible to build a new community with the principles of nature-positive development at its heart, and crucially within the environmental limits of the protected sites at Tipner West.   

Our key principles set out the clear red lines for nature - ones that cannot be crossed or risk undermining the legal protections for nature:  

• Avoid any direct damage to protected areas for nature. Do not build over any part of Portsmouth Harbour’s Special Protection Area, Site of Special Scientific Interest and Ramsar site, including the intertidal mudflats and coastal meadow for the purpose of extending the 'developable' footprint of the site.    

• Mitigate indirect impacts to the protected areas. Replace supporting habitat, including the Firing Range, for brent geese and wading birds in line with the Solent Wader and Brent Goose Strategy.  

• Create space for wildlife within the Tipner West development. Follow the principles of nature-positive design to create a community that people and wildlife can thrive in.  

The current proposals in the local plan still don't go far enough to protect nature, that is why we need your help. 

Why have the Trust and the RSPB been campaigning around plans for Tipner West?   

At the end of 2021, Portsmouth City Council voted to pause the super-peninsula, after 24,000 petition signatories and a record 9,000 Local Plan objections – this was a massive campaign win for us, but the fight isn’t over yet.  

The Council have firmly ruled out no development as they say they need to regenerate Tipner West and build a ‘marine hub’, in line with the commitments of the City Deal funding they have received from the Government (which included a commitment of substantial marine employment space and supporting housing at Tipner West). But the marine hub is now estimated to lead to between 2.1 and 2.6 hectares loss of protected marine habitats, and the maximum housing numbers the Council are now considering for the site in this final draft of the local plan would still build over 3.6ha of protected coastal meadow on the southern tip of Tipner West: this is an unacceptable red line for nature that we cannot allow to be crossed.  

We are again calling on Portsmouth City Council that, if they are going to build on land at Tipner West, to not cross the line of destroying designated sites for nature (Special Protection Area, Site of Special Scientific Interest and Ramsar site) and adopt the highest environmental principles for this development.  

If the Council cannot meet these fundamental principles, then they should not build here at all.   

Why are you promoting any building at Tipner West? Why aren’t you asking for the site to be left for wildlife?  

All three main parties in Portsmouth, Labour, Conservative and Liberal Democrat, have made it clear that they will not support a ‘do nothing’ option at Tipner West.  

The RSPB and the Trust want to continue to work with the local community and Council to get the best possible outcome for nature given the political circumstances.   

Wepreviously  showed there is a potential alternative vision for Tipner West that meets the Council’s goals for housing and development while safeguarding the protected sites for nature. We have done this to make it harder for the Council to settle on an option that bulldozes over parts of the protected area for nature, which would set a dangerous national precedent and wreak havoc for our local wildlife.   

In an ideal world, the unprotected land at Tipner West would be left and enhanced for nature as well. However, with no legal protection this is extremely hard to defend.  The RSPB and the Trust also recognise that Portsmouth needs employment and new homes, just as nature needs homes, but we can’t let protected sites be destroyed by a lack of ambition and imagination. That is why we decided on the unusual move of showing the Council that it is possible to do better for people and nature and setting out clear principles by which Portsmouth City Council must abide if they wish to develop anything at Tipner West.  

Why are you not recommending protecting the Tipner Firing Range?  

The Tipner Firing Range has no legal site protection for wildlife (Special Protection Area, Site of Special Scientific Interest and Ramsar site), although it does play a key role in supporting wintering brent geese and waders. Because of this supporting role, it is classed as a Primary Support Site in the Solent Wader and Brent Goose Strategy (SWBGS). There is a well-established precedent in place for how development in these circumstances is treated, and this is set out within the SWBGS.  If the Council builds over the firing range for housing, they must meet the guidance within the SWBGS Mitigation Guidance, which states:  

‘The Primary Support Areas are land that, when in suitable management, make an important contribution to the function of the Solent waders and brent goose ecological network. However, it is generally considered that, where on-site avoidance or mitigation measures are unable to manage impacts, there may be opportunities for the loss or damage to these areas to be off-set by the provision of new sites to ensure a long-term protection and enhancement of the wider wader and brent goose ecological network.’  

Therefore, if loss or damage to the site is unavoidable, the Council must identify another site to replace the loss of the Tipner Firing Range Primary Support Area, ensuring that there are significant net benefits to the wader and brent goose ecological network.  

Why would building over the Special Protection Area set a precedent?  

The mudflats and coastal meadow are legally protected as a Special Protection Area (SPA), Site of Special Scientific Interest (SSSI and Ramsar site in recognition of their importance for wildlife.    

Protected sites like these cannot be damaged or destroyed unless there are truly exceptional circumstances. In the case of the SPA and Ramsar site (the highest tier of protection in this country), whoever is promoting the damaging scheme (in this case the Council) must be able to demonstrate that there are no feasible alternative solutions that would be less damaging to the protected sites, and that there are “imperative reasons of overriding public interest” (IROPI) for the proposal to go ahead. The Government would have the final say on that, and if they felt a satisfactory case had been made, then the Council would still have to put in place compensatory measures (in this case replacement mudflat and coastal meadow, significantly greater than the area damaged).   

It is clear that these are very strict tests, and as such a successful case has never been made in England to allow this type of development (housing in particular) to be built directly on such a heavily protected site for nature. Therefore, this development could set an extremely dangerous precedent for building over many more protected sites nationally. If an area with the highest level of protection for wildlife can be destroyed and built upon for this type of development, nowhere will be safe for nature anymore.   

What is protected for wildlife at Tipner West and what isn’t?  

Tipner West is a peninsula in the north west of Portsea Island, totaling around 25ha in size. Roughly 10ha at the north of the Tipner West peninsula is currently developed land, used by the cruising, boating and angling club, shipping yard, waste and recycling centre and Harbour School. A further 10ha in the centre of the peninsula is the decommissioned Tipner Firing Range, an important habitat that helps to support the wintering brent geese and waders, but is not part of the legally protected area.  

In the southern corner of Tipner West, below the firing range, approximately 3.5ha of coastal meadow is protected as part of the Portsmouth Harbour Site of Special Scientific Interest (SSSI), Special Protection Area (SPA) and Ramsar Site due to its historic importance as a high tide roost for wintering waders.  

Surrounding the whole peninsula, the mudflats and other marine habitats around Tipner West are also protected as part of Portsmouth Harbour, Site of Special Scientific Interest (SSSI), Special Protection Area (SPA) and Ramsar site. Together the protected Solent sites support 30% of the UK population of dark-bellied brent geese who migrate every winter from Siberia to feed on our mudflats.   

What is a Local Plan and why does it matter for Tipner West?   

Local Plans are where the big decisions on planning for the future of communities and land are made. This includes deciding the future of cities, towns and villages, where new development should be built, as well as setting out policies for protecting and enhancing nature.   

If plans that build over protected nature sites at Tipner West are included in the final adopted Local Plan, it makes it much harder for us to challenge the proposals later on as the principle of development will have been agreed and the Council will be committed to delivering it to reach their overall development needs.  

Portsmouth City Council consulted on a draft Local Plan (Reg 18) in Autumn 2021 which included the Tipner West ‘Super Peninsula’ proposals to which 9,000 objections were submitted.  The Council is now consulting on a pre-submission draft of the Local Plan.  This is a technical consultation that focuses on legal compliance, compliance with the Duty to Cooperate and soundness.  For the plan to be legally compliant it needs to meet all legal and procedural requirements.  

Everyone is welcome to comment on the Local Plan. All comments received in writing will be passed in their entirety to the Local Plan Inspector, who is appointed on behalf of the Government to examine the Plan.  This means it is the last chance to ask for any changes to the Local Plan, therefore the last chance to stand up for nature and protect Portsmouth Harbour and its wildlife from the damaging and precedent-setting proposals at Tipner West. 

Want to get in touch with us about this campaign? Contact campaigns@hiwwt.org.uk