Outline planning permission application goes to Council next Tuesday.
We will be speaking to oppose and particularly drawing attention to the damage that will be done to wildlife.
Here is the letter we received.
We will be speaking to oppose and particularly drawing attention to the damage that will be done to wildlife.
Here is the letter we received.
TOWN AND COUNTRY PLANNING ACTS
Erith Quarry Fraser Road Erith
Full planning permission for the provision of new site accesses and access roads, a 3-Form Entry Primary School (4,300 sqm GEA), 86 residential dwellings (Use Class C3) (up to a maximum of 8,926 sqm GIA) and an ecology/grassland area in Phase 1 with outline planning permission in 3 subsequent phases (with all matters reserved except for access) for up to a maximum 540sqm GEA of ancillary non-residential floorspace (Use Classes A1, A2, A3, B1 and/or D1) and up to a further 514 residential dwellings (Use Class C3) (up to a maximum of 64,505 sqm GIA) together with associated works including informal and formal open space; pedestrian and cyclist infrastructure; car and cycle parking.
Update regarding the planning application for this development.
Further details have now been received and the amended application is available for inspection electronically at the Contact Centre, Civic Offices, 2 Watling Street, Bexleyheath between 9 a.m. and 5 p.m. Monday to Friday. You may wish to consider whether these affect your property.
If you wish to make observations, either in support of or against the amended proposal, you should submit them within 14 days of the above date quoting the application reference number. Observations received after the 14-day period will be considered provided they are received before the application is decided. *(Letter was dated 13th February)*
You are reminded that if you have Internet access you can view the application, and submit any observations on the proposal, using the Planning Application Information Online system on the Council’s website using the following link:- http://www.bexley.gov.uk/index.aspx?articleid=2638 .
You may want to send a copy of your observations to the ERITH Ward Councillors, Councillor J Ferreira, Councillor E Boateng, Councillor A Oppong-Asare, at the Members Room, Civic Offices, 2 Watling Street, Bexleyheath, being the Councillors for the Ward in which the application site is located. Councillors who are on the Planning Committee will not be able to comment on the application. For further Councillor details go to http://democracy.bexley.gov.uk/mgMemberIndex.aspx?bcr=1.
Head of Development Control
The deadline for comments on the planning application to build on 75% of the Erith Quarry Grade 1 Site of Importance for Nature conservation was December 17th.
Bexley Natural Environment Forum sought to muster as many objections as possible, including by leafleting the surrounding streets. London Wildlife Trust has also submitted a strong objection.
Our submissions can be read here:
We both believe that the site remains important for wildlife, should retain Grade 1 status, has not been surveyed adequately and would suffer serious biodiversity and bioabundance losses – contrary to important London and Bexley planning policies – if the application is approved .
We are aware that a number of individuals have also submitted objections. Thanks!
We await the date of the planning committee meeting at which this will be discussed and voted on.
See our previous post for a detailed analysis of why this unnecessary development is so damaging.
Chris Rose, Vice-chair Bexley Natural Environment Forum
Erith Quarry, a Grade 1 Site of Importance for Nature Conservation, is now the subject of a planning application for 600 dwellings, which would see three quarters of its semi-natural habitat destroyed. London Wildlife Trust and Bexley Natural Forum are calling for the application as it stands to be refused and will be submitting detailed arguments, but you can help by putting in a simple objection, using some of the points set out below. Unfortunately the site is also subject to other, pro-development policies, and does not have absolute legal protection. London level policies allow some ‘development’ on SINCs ‘commensurate with their importance’, but this proportion of habitat loss is unacceptable and would set a terrible precedent. With enough objections we may be able to wring concessions, as well as helping dissuade the Council from giving too much ground to ‘developers’ ahead of final planning decisions in the future. At present it clearly doesn’t think enough people care enough about nature.
Please send your comments to: email@example.com quoting the application code: 14/02155/OUTM
The last day for submission has been put back to Wednesday 17th December.
There is a powerpoint with lots of information about the site and pictures of it here https://app.box.com/s/dqhdxdlv06sa0kc7zhqq , though this was written before the formal planning application was available. Although the projected number of dwellings has gone down from 700 to up to 600, the boundary of the area proposed for ‘development’ is the same.
[We apologise for the short notice. This is due to severe overload resulting from several other wildlife-hostile proposals, and the huge amount of material needing to be read concerning this application.]
GENERAL POINTS AND PRECEDENT-SETTING
– Recent survey evidence, though inadequate in several key respects, confirms that the site is still very important for wildlife and worthy of continuing SINC Grade 1 status. On the basis of ranking and size it is one of the 12 best wildlife sites in the Borough, and by far the best scrub site in the north of Bexley. We believe that the number of species present and their abundances will fall with this scale of ‘development’, and that species of conservation concern, including reptiles, would almost certainly be negatively affected and that some will be lost. Consequently there would be a breach of a number of important London and Bexley level policies regarding the conservation of biodiversity. The application should be refused on these grounds.
– Destroying nearly 75% of a Grade 1 SINC, sets a bad precedent and throws into question the Council’s commitment to protecting such sites, especially in the light of its proposals to sell off a quarter of open spaces (or parts of them) and its sudden 5-fold increase in projected housing builds to 2030. This degree of ‘development’ is not commensurate with the importance of the site for biodiversity. If the same extent of loss was allowed across all Grade 1, Grade 2 and Local classes of SINC in Bexley then that would be equivalent in land area to 8.3 Danson Parks or 18 East Wickham Open Spaces.
– The ‘developers’ are making much of the increase in bramble cover over recent years, which they say reduces the site’s biodiversity value, and according to them makes much of it expendable. This is a management issue and does not require a covering of concrete to sort out. If Bexley had any biological Sites of Special Scientific Interest (SSSIs) in this condition, the requirement would be to restore them, not build over a large chunk of them. If the Council accepts a ‘developer’s’ argument that a large part of a designated site should now be destroyed because of ‘unfavourable’ vegetation changes, then that will be a licence to owners of other private SINCs, who might want to sell them for ‘development’, to allow or encourage changes unfavourable to key species on them precisely in order to increase their prospects of getting planning permission.
– The developer’s own report admits that the potential of a site should be taken into account, but only the building and not the future wildlife potential is properly discussed in the voluminous planning application documents. We know that bigger sites are better for wildlife, and the new focus on ‘landscape level’ conservation and ‘habitat connectivity’ is the logical consequence of that. Leaving a margin of hemmed-in woodland and a small area of grassland in one corner contributes to the general trend of habitat fragmentation and erosion of site sizes.
– There is no analysis of the potential impact on biodiversity and thus conservation status of the neighbouring SINCs at Hollyhill or Erith Cemetery/Streamway, where numbers of species of insects and birds, and their abundances, may well be negatively affected.
– The ‘State of Nature’ (2013), ‘Living Planet’ (2014) and DEFRA ‘Biodiversity Indicators’ (December 2014) reports all show serious problems with declines in both species numbers and abundances (including of hitherto commoner species) in the UK. We submit that the appropriate and rational conclusion to draw from this is that semi-natural habitats should be protected and enhanced, not built over.
– Survey work for the ‘developer’ in 2014, though not conducted according to Natural England best practice in terms of the spread of months over the year, nevertheless found 47 invertebrate species of formal conservation concern, representing 12.5% of the total species inventory. The best sites for invertebrates in the wider London area are said to record 10% or greater, depending upon habitat type. We therefore we conclude that this is one of the best sites, and that the objective should be to make it better by appropriate management rather than just protecting the diminished area currently suitable for many of these species.
All UK reptile species have a degree of legal protection, but unfortunately not from having their living space destroyed. On the grounds of ‘Japanese Knotweed control’, the ‘developers’ have conveniently had Slow Worms, Common Lizards and Grass Snakes, all of which are thought to be in decline nationally, and for which Bexley is a London ‘hot-spot’, moved to a small 1ha reptile-fenced ‘holding area’, within the 3.25ha area that they are claiming can support the site’s total reptile population indefinitely. It is clear from the recent aerial photography and mapping in the ‘development’ application that there is still much more suitable reptile habitat than this 3.25ha that they are ‘generously’ proposing to leave in the north west corner of the site, despite the increase in bramble. LWT and BNEF believe that reptile populations at Erith Quarry will be seriously affected by being forced into too small an area, and could be lost entirely. Numbers of animals found/caught were downplayed by the ‘developer’, but in our view are high by London and Bexley standards, and there are very few places in the Borough where all three of these species can be found, and they are large sites.
– The translocation that has taken place is contrary to Natural England best practice guidelines, and the paid ecologists have verbally admitted that this is the case. Approval of the ‘development’ as proposed would be the third total or significant partial destruction of a reptile site in the Borough due to Council-supported ‘development’ in the last 5 years. The last reptile translocation in the Borough was also an expedient affair that broke NE guidelines and has probably failed according to the available data.
– The London Biodiversity Partnership, consisting of Local Authorities and other organisations, has a policy aim ‘To protect and conserve the native reptile populations of Greater London.’ DEFRA says conserving species includes not just presence, but ranges and population sizes. The LBP says ‘Development and unsympathetic land management has reduced the amount of habitat available for reptiles.’
– LWT believes that several bird species are almost certainly going to be lost from the site as breeding birds because of the lack of suitably retained undisturbed habitat, and that this will include Whitethroat and Red-listed Linnet. Other species will also have a much reduced capacity to breed due to available space and disturbance. Vulnerable species like the Song thrush, Chiffchaff and Dunnock have the potential to become extinct on the site. A Turtle Dove was recorded on the site this year. This species is in serious danger of UK extinction, and relies on scrubby edges to woodland – which will be lost to buildings here – and good supplies of weed seeds.
– LWT is sharply critical of the quality of the Bat survey work. All Bats are strongly protected under UK law. It is proposed to have a road close up to the edge of the retained woodland, with buildings adjacent to that, contrary to the Council’s Biodiversity Action Plan policy of allowing woodland to ‘bleed out’ into scrub, and despite the emphasis in the planning application on the importance of such ‘edge’ habitat for Bats and other animal species. However well designed the lighting regime, there is likely to be leakage from buildings plus other disturbance in areas where bats might otherwise forage.
There is a 134 page document dealing with the effects of the development on views, complete with a number of photographs. Incredibly, this fails to include photos of the best and most open view across the valley (of the now buried Streamway stream) from Hollyhill, which provides one of the most rural-looking panoramas in the Borough. Instead it uses a sight-line in which the Quarry site is largely obscured by substantial trees.
The Nature and Welfare Act is being proposed with the invitation to all parties to include it in their manifestos.
“A thriving natural environment is part of the solution to our most pressing social, economic and environmental problems.”
As someone who already ‘votes for nature’, I welcome this attempt to get politicians to recognise the importance of the natural environment for our health and well being even if they appear to have no concern for wildlife.
The report can be viewed online at: http://www.wildlifetrusts.org/sites/default/files/nature_and_wellbeing_act_final.pdf
Or downloaded from our website at: https://app.box.com/s/j9pfgkszdeadixjhb23i
Erith Quarry is one of the largest Grade 1 Sites of Importance for Nature Conservation in Bexley, at twice the size of Bexley Woods. If Bexley Council gives the current ‘development’ plans the go-ahead, it will become one of the smallest.
SINCS do not have any national legal protection, but Councils are obliged to take biodiversity ‘into account’ when making planning decisions. Bexley Natural Environment Forum has therefore sent a list of questions (set out below) to the Council’s Planning Department to try and determine the extent to which this has been the case so far, and what action the Council plans to take to ‘make up for’ the loss of this extensive wildlife habitat if it grants planning permission. We have also asked about increases to sustainability criteria to ‘offset’ the effects of Bexley’s projected five-fold increase in its housing allocation to 2030, should building be allowed.
The questions were sent on October 26th. As of November 2nd there has been no response or acknowledgement.
At present there are no Sites of Special Scientific Interest designated in Bexley for their biological interest. That makes Grade 1 SINCs the second most important type of site for wildlife in the Borough. According to the London Wildlife trust in the 2013 SINC review:
QUESTIONS TO BEXLEY COUNCIL PLANNING DEPARTMENT WITH REGARD TO ERITH QUARRY, WILDLIFE AND SUSTAINABILITY
From Bexley Natural Environment Forum. 26/10/2014.
Dear (Council Officer)
A number of specific questions we have about where things are now on this issue are set out below.
> Dear Chris, As far back as 1996, in the UDP, this site was >designated for development, and also as a SINC. No grandfather >rights exist. This case does not set a precedent. All sites are dealt >with on their individual merits.
I am still of the opinion that unless the Council can explain persuasively why ‘development designation’ should apply to this Grade 1 SINC and not others, then there will be people who will seek to cite any planning permission as a precedent relating to applications to build on all or parts of Grade 1 and below sites elsewhere. That may not work, of course and I will be pleased if no one does try this on. It would be more accurate to say that sites are dealt with against various criteria, which increasingly favour concrete over nature, with the Government hardly concealing its opinion that protection of the environment is ‘green tape’ getting in the way of ‘development’. Otherwise I might be more optimist that it was a fair 50/50 fight, but I can’t see any sane bookie giving me odds to that effect, especially when they look at the sudden inflation in the Council’s housing target.
According to the Open Space strategy (2008) the Council ought actually to be acting to:
• retain, protect and enhance sites that support wildlife, biodiversity and their habitats
Of interest to us now is the negotiating position of the Council, which has clearly spent some time discussing proposals with the ‘developer’. As you know, the projected number of houses has been reduced from 700 to ‘up to 600’, but according to the ‘developers’ at the 2nd exhibition, the boundary of the developed area is not being reduced accordingly. That compromises the potential biodiversity/bio-abundance claw-back. We believe it should be pulled in, and that the area of contiguous ‘wildlife’ space should be as large as possible if any development permission is granted,on the basis that an enlarged so-called ‘ecology area’ within the ‘developed’ footprint is not likely to support the reptile and bird species currently found on the site as a whole, not least because of intensity of disturbance and lack of appropriate vegetation structure. The explanation given at the 2nd exhibition, that the change in numbers was due to removing houses close to/under trees did not seem particularly credible, since as I recall the UDP required the retention of the woodland anyway. At your suggestion we will write to Mr. Bell asking him to pursue this matter with the ‘developers’ – otherwise there is a danger of it looking like 700 was simply an over-bid so that the number could be reduced later to mollify objectors, without actually reducing the ‘taken’ area.
Our questions are:
i) Has the Council’s aim been to have the site left in a good enough condition to retain Grade 1 status for what we might call the ‘un-developed’ ‘doughnut’ or ‘horseshoe’ that would remain around the housing area?
ii) If so, what evidence base has been used to determine that the plans as they now stand – which we understand will have met, in principle, various Council approval criteria – will leave the site in that condition. In particular, what species and species abundances have the Council asked the developers to take all possible steps to ensure will remain on what is left of the site as was? Why is grassland apparently being favoured by the ‘developers’ over scrub in this particular instance? It may be noted that the area slated for retention has (or had before bulldozing), some remnant heathland vegetation, and nothing has been done about the BAP policy onre-creating (new) heathland in the Borough.
iii) Reference LDF Policy CS18 Biodiversity and geology b) protecting, conserving and enhancing Bexley’s Sites of Special Scientific Interest (SSSI) and Sites of Importance for Nature Conservation(SINC); in what way is building on 3/4 of the site protecting, conserving and enhancing it?
iv) Reference CS18 c) resisting development that will have a significant impact on the population or conservation status of protected species and priority species as identified in the UK, London and Bexley Biodiversity Action Plans; One of the relevant species, according to the ‘developers’, is Slow Worm. Mark Taylor previously said that there would be no need for a translocation. What peer-reviewed evidence can you point to to ‘prove’ that reducing the available habitat by the amount proposed will enable the existing size of population to be maintained? What does Bexley consider to be an ‘insignificant impact’?
v) The Council may default to a pan-Borough outlook, claiming that major reductions on any one site do not matter. In which case we would refer again to the fact that Bexley is signed up to the London Biodiversity Partnership. One of the aims of the Reptile SAP is • To protect and conserve the native reptile populations of Greater London. Given that Bexley is one of the very best Boroughs for reptiles, it is particularly important that this is done here. Instead this fact seems to be seen as a licence for complacency, with the Council having approved the clearance of two sites of ‘Common’ Lizards and Slow Worms in the last 5 years, one of which did not follow official best-practice translocation guidance and appears to have been a failure because the animals were put in obviously unsuitable habitat. We note that DEFRA’s Biodiversity Guidance for local authorities is very clear that ‘Conserving biodiversity includes restoring and enhancing species populations and habitats, as well as protecting them.’
vi) What evidence has the Council got that building on 3/4 of the site will restore and enhance the populations of the following species recorded there, both of which have declined significantly, or does it consider that this is nothing to do with habitat loss, or that it has no legal, moral or other responsibility in this matter?
Kestrel (amber listed) 1970-2012 minus 48%, 1995-2012 minus 35%
Linnet (red listed, UK and London BAP species) 1970-2012 minus 57%, 1995-2012 minus 25%
vii) What account has the Council taken of its own BAP policies in seeking to influence the boundary of the ‘developed’ area, and of the importance of scrub to the breeding birds? In particular, the closeness of the margin of the housing estate to the woodland, as suggested by the ‘developer’s’ maps, would appear to leave little or no room for ‘bleed out’, as called for in BAP policy, and regeneration of the woodland as trees age and die. The ‘bleed’ into excellent scrub habitat which existed before was, of course, bulldozed by the previous owners, delivering a prime example of the sort of ‘baseline shift’ now cited as leading to reduced expectations of what conservation should in fact be aiming for.
viii) At the 2nd exhibition the ‘developer’s’ staff pointed to the fact that they would plant a lot of trees amongst the houses, but seemed not to understand that that is not the same thing as natural structure. Are you pushing for indigenous species that are naturally found in this part of the Borough?
ix) It is our view that Erith Quarry very probably acts as a significant reservoir of wildlife moving to and from neighbouring SINCs at Erith Cemetery and Hollyhill. What data has been gathered on that point, and what account has the Council taken of the impact of the likely loss of species and bio-abundance at Erith Quarry on these neighbouring sites and their SINC grading in discussing the Erith Quarry proposals?
x) No doubt it will be claimed that there will be no ‘significant’ damage to biodiversity resulting from approval of this ‘development’ proposal. What follow-up monitoring of the remaining ‘wild’ areas will the Council be commissioning to establish whether this turns out to be fact or fiction and, as in i) above, what measures will be used to determine that? We understand that residents will be paying a ‘service fee’, part of which will fund ‘management’ of the unbuilt upon parts of the site, but it is obviously important that any such monitoring is independent of the ‘developers’.
xi) Please tell us what site or sites the Council is going to ‘re-wild’ in an attempt to ‘mitigate’ what would be a significant loss of wildlife land at Erith Quarry, in particular, in the mapped ‘biodiversity deficient’ area of Erith itself, and in respect of quality scrub habitat? Note again that biodiversity includes populations and abundances. We suggest that the required area is approximately 15ha, preferable contiguous rather than across scattered sites.
We note, in support of such action, that the Open Spaces strategy talks about: 1.17 • promoting and protecting biodiversity and habitat creation; Section 5: there is significant potential to enhance the quality and quantity of biodiversity in parks. Some parks are high in biodiversity, for example Lesnes Abbey, designated as a site of high metropolitan importance, while others offer little in the way of habitat and biodiversity. Improving the array of biodiversity in parks is a key target of the biodiversity action plan. The provision of habitats in parks is also an important way of offsetting deficiencies in access to wildlife. SECTION 7 – DELIVERING, MONITORING AND REVIEW: Promote environmental management and conservation to increase biodiversity at the Borough’s open spaces … And … encourage an abundance of flora and fauna in parks and promote the inclusion of natural areas within parks.
xii) Given the sudden inflation in the Council’s proposed housing ‘allocation’ to 22,000 by 2030, what requests are being made of the Erith Quarry ‘developers’ and others to ratchet up the sustainability standards of new buildings in order to ‘offset’ this increase, and at least make sure the Borough’s ecological footprint in terms of non-land resource use does not grow any further? At their 2nd ‘exhibition’, the ‘developers’ were still exceptionally vague about sustainability standards, which does not inspire confidence.
In this context we would remind the Council that the Government has made the following commitments to the international community on behalf of the UK: http://www.cbd.int/sp/targets/ , in particular this promise: ‘By 2020, at the latest, Governments, business and stakeholders at all levels have taken steps to achieve or have implemented plans for sustainable production and consumption and have kept the impacts of use of natural resources well within safe ecological limits.’
Yours sincerely, Chris Rose. Vice-chair, Bexley Natural Environment Forum.