Development at 204 -210c Cambridge Road and part of Kingsmeadow: Application 20/02216

 Yet another issue for Norbiton and overdevelopment in an Area of Deficiency to access to open space: loss of biodiversity, development of land destined for leisure but a very sad destruction of a population of slow worms.

I have written the following letter to the Planning Department.

Dear Kingston Planning Department
I have objected to the above application on the council’s website but I wanted to add a video of the slow worms at this site to show that the mitigation strategy is also flawed due to the numbers of animals as well as the timing as indicated in the document attached.

This is an unusual population in such an urban area. The site was only surveyed during July and I have found a greater number of adult slow worms than the report attests. Slow worms are protected under the Wildlife and Countryside as amended under the CROW ACT 2000 but also they are a Priority Species under the UK Post-2010 in the Biodiversity Framework. The protection of priority species and their habitats is an objective of the National Planning Policy Framework.

This is part of a larger population of slow worms existing at Kingsmeadow, Kingston Cemetery and named on the SINC for Hogsmill SW and along the Hogsmill river. This was ignored when I made these comments in respect of the application for the Hammer Cage and Floodlights and the site was bulldozed before planning permission was granted without any slow worm mitigation. I have therefore been forced to video this interest in order for the council to take notice. The council have a legal duty to conserve biodiversity in all their functions under the NERC Act 2006. (Natural Environment and Rural Communities Act).
 This applications does not respect any of the legislative framework mentioned above or the Small sites document that states that the environment will be improved, which of course is a requirement echoed throughout all planning policies that there should be some Net Gain.
Part of this site is earmarked for Leisure and not building land. I have therefore asked Deborah Flintoff how this accords with the Leisure strategy given that this land is used by dog walkers and children playing football as well as people enjoying nature near their home. I have taken many videos to show the informal leisure use of this land as well as invertebrates such as grassland butterflies and the obvious food requirements for slow worms.

The GLA housing grant has to be spent by January according to the report attached how can the following inadequate mitigation be performed when the slow worms will be underground for the Winter months.
 The ecology report attests:
Reptiles: Given the number of Slow Worm recorded at the site, it is proposed that a habitat
manipulation exercise is undertaken to move individual Slow Worm away from construction
areas, to retained and enhanced areas of the site.
4.2.6 The destructive search will involve cutting the grassland within the development footprint
to a short height (~15cm) so as to encourage reptiles to disperse to suitable areas of
retained / nearby habitat, whilst also allowing for a fingertip search of the area. This exercise
should be carried out under the supervision of a competent ecologist during the active
reptile season where practicable (generally March / April to September / October,
depending on prevailing weather).
The last sentence of 4.2.6 was written without the knowledge that the whole area is to be developed -the Barton Wilmore documents show a school to the south-west of the Apartment Block on the grassland -and the Arrow Plastics construction area will spill onto this site meaning that there will be no ‘nearby suitable habitat’. The cumulative impact must also be addressed.
Best wishes
Alison Fure
Ps Dear Barry
A couple of days later this happened- ground investigations (boreholes and trenches) for a faith school on the very habitat the slow worms were destined for.

In addition a colleague has commented on the design detail as follows:
1) the ecology survey (July 2020) does not appear cover the site under application, missing a substantial portion, which has subsequently been added and taken from land belonging to Leisure Services. As a priority protected species was discovered the ecology survey requires updating to cover the entire area.
2) The same is almost certain to apply to the tree survey, which although provides no diagram showing the position of the site trees (unprofessional), was conducted on 06.05.2020, before the ecology survey.
3) I agree with the Council's Design Panel recommendation that "the applicant is encouraged to place a financial value on trees to ensure their value on site is considered" Why isn't this happening? The recommendation was just ignored completely.
4) I agree with Kingston's design review panel - the soft landscaping and gardens should be in the South and the car parking in the North, not the opposite, as proposed. An additional reason, not mentioned by them, is the lack of direct sunlight on the proposed garden area to the North and NNW; it will be in almost permanent shade from the building itself and colder, especially during Winter. Hardly the environment that reptiles would thrive in (although the area is small for the number of residents, let alone allowing any wildlife, apart from a few insects.) Residents are not likely to enjoy it (people like south-facing gardens for good reason) and the garden and play area are also sited closer to the air pollution of the Cambridge Road. Why not have these amenities to the South, looking towards the current green space? It seems very poor design.
5) This application seems very rushed and versions are unclear to me and I assume to anyone else reading the documents submitted by the applicant, or their more limited public consultation. Even the council officer responding to the design brief consultation says as much in Barton Willmore's Design & Access Statement Part 6: "Development Brief: the below mentioned 4 projects are only the first four of 16+ projects to come forward. As such, it is important that all lessons learnt are being applied in the future 12+ projects. This also highlights the importance of the brief previously being developed and the client requirements set out. In the DRP the brief was presented as a "draft" and it wasn't made clear whether the applicant is still working on that document or has it now been superseded for the 12+ potential sites in the future as well: would be good to get some clarity on this as a lot of work went into the development of that document and we've been previously involved in this document's development too."
Please could the documents be re-submitted with the chronology/dating made clear for the public, and where there have been major changes (such as site boundary expansion) an explanation plus a clear description somewhere of the evolution of the design. The boundary changes are not in B&W's explanation on the evolution despite some of the surveys being done within the previous site's boundary.
6) A large part of the site is not brownfield - as described in the application. I am very concerned that the additional land added part way through the design of this development is not brownfield but land belonging to Kingston Leisure Services, which I understand from nearby residents, is used for recreation. This was only discovered recently by looking through the application and seeing a different site boundary in some documents. Nowhere in this application is this made clear and as such it is a disingenuous and undemocratic planning application. Residents should be allowed to comment knowing the land classification, that there will be a loss of leisure service land for the development and have an explanation as to why, especially if a protected species is to be at risk of elimination.
7) The cumulative impact of development and planned development (school, Arrow Plastics) is unacceptable for this area, already very deprived of open space. There is too little for people and even less for any wildlife. The area adjacent to this site should be enhanced as green space for both; there are few opportunities to provide such and this is a rare opportunity to do so.
8) With this particular development, there are only recommendations as to ecological plans and nothing in response from the developer in the application documents. It is unacceptable at this stage of the planning process to have no declared plans in mitigation. The ecology report suggest the slow worms could be encouraged to move on - but to where? Where are the suitable grassed areas? There is no room on this site. Even if somewhere adjacent and suitable is found, this and the potential developments (school, Arrow Plastics) will occupy much, if not most of the area. Slow worms and any other existing wildlife will be eradicated - they, like humans require more than 'pocket' grassed patches because they have to have a certain amount of land to sustain their population with food.


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