Peter Alfrey

Flat 9, Block 4 Primrose Close

Hackbridge

Surrey

SM6 7HJ

6th December 2018

Dear Iain Williams,

RE: Environment and biodiversity observations, objections and recommendations on

Major Planning Application

To: Iain Williams/ Development Manager

Application: DM2018/00160

Address: Rear of 13-59 London Road

1. Policy Context
a) National Policy Context
The National Planning Policy Framework 2018 (NPPF) favours sustainable development
including ‘helping to improve biodiversity (para. 8 c. pg 5) , ‘minimising impacts on and
providing net gains for biodiversity,’ (para. 170d. pg 49), ‘opportunities to incorporate
biodiversity improvement in and around developments should be encouraged (para
175d, pg 51, para 118, pg 28) and limit the impact on light pollution…..on nature
conservation (para 180c pg 52). Furthermore circular 06/2005 Biological and Geological
Conservation states that ‘Developers should be required to undertake surveys where
there is a reasonable likelihood of the (protected) species being present and affected
(para 99).

b) Regional Policy Context:

i) The London Plan 2016 contains relevant instructions which include sustainable
development and design ..promoting biodiversity (Policy 5.3) integrating green
infrastructure from the beginning of the design process (tree planting, green
roofs, walls and soft landscaping) and major developments should be designed
to deliver cooling aid, sustainable urban drainage, mitigation for climate change,
enhancement of biodiversity and growing food( Policy 5.10 and Policy 5.11).
 ii) LDFs: Policy 7.19, Biodiversity and Access to Nature supports taking
opportunities for positive gains for nature

iii) The proposed development is situated within The Wandle Valley Regional park
which has a planning designation in the current London Plan, through the
strategic spatial planning section and in reference to growth corridors. It is also
given Supplementary Planning Guidance (SPG) as part of the All London Green
Grid Framework, and features as ALGG Framework, Area 8.

iv) Furthermore the Mayor’s Biodiversity Strategy (GLA 2005) encourages new
development and landscaping which promotes biodiversity (pg 46)

c) Local Policy Context

i) Sutton Local Plan 2016-2031 Policy 26 (which deals with biodiversity)
particularly relevant ‘the council will protect and enhance Sites of Importance
for Nature Conservation (SINC), Green Corridors and Biodiversity. It will ensure
the restoration of Beddington Farmlands is completed to the agreed quality and
implement its Biodiversity Action Plan and agri-environment schemes’.

Also ‘the council will grant permission for developments that create, conserve or
enhance biodiversity and improve access to nature’ and ‘the council will not
grant permission within or adjacent to a SINC where there would be damaging
impact on nature conservation value or integrity of the site’

Furthermore Policy 40 of the Local Plan states that the development area should
‘respect the open character of the adjacent Wandle Valley Regional Park’.

ii) Building a Sustainable Sutton- The Local Plan Technical Guidance Note includes
TGN 2 on Biodiversity accounting and TGN 3 on Green Space Factor relating to
mitigation and enhancement of habitats.

iii) The Hackbridge and Beddington Corner Neighbourhood Development Plan

2017-2027 contains policies promoting local biodiversity (see below section 2)

2) Planning Application Assessment with regards to Environment Policies within the

Hackbridge and Beddington Corner Neighbourhood Development Plan EP1- EP9

a) EP1- Access to the Wandle Valley Regional Park (WVRP).

As stated in EP 1 all development proposals shall be required to contribute to the
provision of easy access to green spaces including the retention, development and
provision of public access to Beddington Farmlands and the wider WVRP. EP1 objectives
including developing Hackbridge as a major gateway to the WVRP and the development
of visitor facilities for the WVRP.
 Objections to planning application
i) There are no details on how the development will create access to the Wandle
Valley Regional Park

ii) The scale of the development is contra to Policy 40 of the Local Plan that states
that the development area should ‘respect the open character of the adjacent
Wandle Valley Regional Park’. The negative visual impact could have deleterious
impacts on the visitor experience of those visiting/ wishing to gain access to the
WVRP arriving at Hackbridge Train Station.

Recommendations

i) To create access for residents (and for visitors arriving at the railway station) to
the regional park via Mile Road Bridge by developing a landscaping plan to
integrate Mile Road Bridge habitat with the development including biodiversity
enhancement and footpaths to directly link the SINC with the development and
achieve a net positive biodiversity gain and an improved visitor experience for
people visiting the WVRP from Hackbridge Train Station.

b) EP2- Local Green Space Designation

Not relevant although the development of a new designated local green space would be in
line with the policy context (see above)

c) EP3- Trees
EP3 states that development should protect trees in good health that add quality and
character to the area and the equivalent number of new trees should be planted to replace
any taken down. Large canopy trees will be looked upon more favourably. All new planting
needs adequate and appropriate provision for ongoing maintenance.

Objections to planning application

i) There are no tree protection plans or details of how the habitat on Mile Road Bridge will
be safeguarded to ensure there is no net loss of trees (as per claim in Synetegra PEAR)
and there are no detailed tree planting plans

Recommendations

i) To increase the number of trees on site to achieve net biodiversity gains and to favour
large canopy trees and also to take adequate measures to ensure Mile Road Bridge
habitat is protected i.e by developing and implementing a tree protection plan
 d) EP4- Management of Current Public Green Space
EP4 states that public green spaces should be protected and enhanced with the primary
objective to increase biodiversity.

Objections to planning application

i) There are no detailed plans of how the development will interface with Mile Road
bridge. Mile Road is the main public access to Beddington farmlands. The entrance
to Mile Road bridge is formed by a pocket park that was recently constructed as the
entrance for the farmlands and public access to the Wandle Valley Regional Park. It
is vital that this development interfaces with this entrance sensitively.

Recommendations

i) As per recommendations to EP1.

e) EP5- Management of New Public Green Space

EP5 states that all new developments should include multifunctional landscaping utilising a
mixture of native and non-native species and plants, to create and enhance wildlife
opportunities as well as providing aesthetic and landscape appeal including creating and
managing flower rich grasslands in green spaces in addition to the use of formal and
informal grass areas. EP5 also states that urban green spaces should be managed for habitat
for birds and other wildlife including butterflies and invertebrates and to use green roofs
and roof gardens. EP5 states that SUDS, Bio-swales and rain gardens should be used, mixed
hedges should favour fencing and green walls should be used to extend green corridors.
Guidelines for developers on how to increase biodiversity in urban development is provided
in the appendix (1 and 2) of the Hackbridge and Beddington Corner Neighbourhood
Development Plan (NDG) including reference to RSPB Conservation Advice- Managing urban
Green Spaces for Wildlife which in addition to the above also includes the installation of bat
and bird boxes. The Bat Conservation Trust, British Trust for Ornithology, Butterfly
Conservation, Buglife and Plantlife all provide recommendations for developers on how to
increase biodiversity in urban developments (appendix 1 and 2 NDG plan)

Objections to planning application

There are no detailed plans for the landscaping of the green spaces.

Recommendations
To develop detailed landscaping plans in line with EP5 and to consult the Hackbridge and
Beddington Corner Neighbourhood Development Group and refer to guidelines for
developers from the conservation NGOs (appendix 1 and 2 NDG plan). Pre and post
evaluation of biodiversity should be undertaken to determine no net loss or net gains for
biodiversity in line with the council’s TGN and in accordance with BS42020:2013. Detailed
ongoing maintenance plans need to be drawn up with are adequately financed and
undertaken by competent nature conservation contractors.
 f) EP6- Green Infrastructure
EP6 states that all development shall be required to extend the biodiversity and amenity
value of the surrounding open spaces particularly to the provision of the three main green
links between the River Wandle (and wider WVRP) and Beddington Farmlands.

Objections to planning application

i) The planning application sits on one of the main green corridors as per Map 8 of the
Hackbridge and Beddington Corner Neighbourhood Development Plan. There are
no detailed plans of how the development will strengthen that corridor.

Recommendations

i) Strengthen the green corridor by applying recommendations as stated in EP1 and EP5

g) EP7- Urban Greening

EP7 states that development proposals should use soft landscaping in an innovative way to
combat climate change and to develop a multi-functional landscape (food growing,
increasing biodiversity and flood mitigation). This policy also supports EP3 and EP5 by
recommending the installation of green roofs, green walls, hedges instead of fencing and
provide large canopy trees.

Objections to planning application

1) There are no detailed plans of how the development will contribute to urban greening

Recommendations
See recommendations for EP5, EP1 and EP6 The forthcoming details should include
consideration of biosolar roof around the PV panels, extensive biodiverse roofs and
brown roofs.

h) EP8- Water Efficiency and EP9- Water Efficient Landscape Design

EP8 and EP9 encourage water efficiency including the use of SUDS.

Objections and Recommendations to Planning Application

There are no details on water efficient designs and the use of SUDS. Details are
recommended.

3) Planning application assessment (OTHER)

a) Preliminary Ecological Appraisal Report (Syntegra Consulting 2018)

Observations
The site is immediately adjacent to Beddington Farmlands SINC and little
consideration has been given to the proximity of the development contra to
Sutton Local Plan 2016-2031 Policy 26 ‘the council will protect and enhance Sites
 of Importance for Nature Conservation (SINC), Green Corridors and Biodiversity.
It will ensure the restoration of Beddington Farmlands is completed to the
agreed quality and implement its Biodiversity Action Plan and agri-environment
schemes’.

View over the Southern Lake at Beddington Farmlands looking southwest. The
proposed development is west of view, immediately behind the large poplars
to the right over the railway. Lighting and massing effects on the SINC plus the
negative visual impact on the Wandle Valley Regional Park must be considered
and adequately mitigated.

No record search has been undertaken. No Biodiversity accounting has taken

place (see above TGN 2) and no lighting plan is provided (that details low lux
level lighting to decrease impact to the SINC).

The removal of Japanese Knotweed has been noted and is welcome.

A full Construction Environmental Management Plan is recommended.

A detailed lighting scheme is recommended.

b) Design and Access Statement (Create 2018)

c) Observations
No information is given on proposed green infrastructure. Mention is made of fruit trees
which is welcome but no details are given.
Concluding note
Air quality in the area is already poor. This development should not contribute further to
increasing poor air quality. Also the tower blocks will only be 62 meters from the height
of the Beddington Lane incinerator chimneys- will air pollution modelling take this into
account for the residents?

Yours Sincerely

Peter Alfrey BSc (Hons) MSc

Naturalist and Director of Little Oak Group