Slow worms at Kingsmeadow, Cambridge road, Kingston

This is a woeful tale of a council & its record on biodiversity conservation; namely the war of attrition on a population of slow worms at Kingsmeadow and a council who:

  • Gave themselves  planning permission in an application for a hammer cage 19/00873/FUL with 13 mature trees felled;
  • Issued misinformation at an environment committee about the number of trees felled (a quiet correction issued sometime later);
  •  Half-heartedly replaced 22 of the trees, where only 5 survived;
  • Made the site's lessee, Weir Archer, take the fall from an Environment Agency enforcement order 2019, so that landfill waste bulldozed down the Hogsmill river bank was removed at a cost of £8,000;
  • Promoted an announcement for a school- by Sir Edward MP and Lady Davy- at Kingsmeadow in October 2020 (pictured at Kingsmeadow  here) while issuing a planning condition for habitat improvement for slow worms at the same site May 2021.


This resulted in several Freedom of Information requests and led to:
  • Defensive action by the council who sought to play down the slow worm interest in the meadow and paid consultants to issue a counter-commentary on a video made to highlight the true number of slow worms;
  • This commentary was put on the planning file after the close of consultation so no one could comment;
  • Ignored Stage 1 & Stage 2 complaints  from February to July 2021, only concluded when representation was made directly to the CEO of Kingston Council;
  • A council that gave their own development company planning permission for a block of flats, 1/8 of which impacted leisure services land;
  • A council that propose to lease the remainder of the leisure services land, in an Area of Deficiency of access to nature and open space, to the church for 125 years to build a school for a peppercorn rent;
  • Mitigation that 'fell away': although we were told that translocation was too risky and planning applications were heard 'case by case'; and
  • The disturbance of  habitat in a Cemetery designated as a SINC to expedite a plan for a school yet to be submitted.
    • This was an unusual population of slow worms in an urban area much filmed and described in publications. The site was only surveyed during July 2020 by the consultants which Government Guidelines state is a month to avoid.
    • 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. The fact was ignored  in respect of the application for the Hammer Cage and Floodlights and the site was bulldozed (see photo) before planning permission was granted without any slow worm mitigation.  
    Here is one of ten videos, the only one publicly released The council have a legal duty to conserve biodiversity in all their functions under the NERC Act 2006. (Natural Environment and Rural Communities Act) of which they have been reminded.
    This application 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.      unfortunately  all we have been told to expect has indeed 'fallen away' with the announcement here  
Cllr Emily Davey, Portfolio Holder for Housing, said:
  • We are committed to both protecting the local environment and delivering much needed council homes across the borough to help meet the housing crisis. 

    The proposed habitat improvements at the cemetery will create a space where our slow-worm population’s habitat will be protected in the long-term, while also enabling us to deliver energy efficient low cost rented housing for local residents.

    Here are some articles on the grassland interest at Kingston Cemetery SINC:
     Claire Mellish writes: 
  •  All of us raising concerns for the slow worms in Kingsmeadow were told that we should not conflate harm from multiple developments: it had to be taken on a case by case approach with planning applications. By suggesting translocation, the Council are now disregarding the mitigations suggested by their Ecology Report - for a planning application already given permission (the 'Small Sites' CRE decant site to the rear of 204-210C Cambridge Road). They are instead prejudging the outcome of another planning application, which has not yet even been submitted by the Diocese of Southwark for their new school (Kingsmeadow adjacent to 204-210C Cambridge Road).

    Why are the council pre-determining the requirements of future planning applications? Under pressure from the Diocese? Embarrassed that their choice of school site is going to kill protected species? A realisation that their plans to develop multiple sites in Kingsmeadow and the Hogsmill flood plain are actually very harmful and they want rid of all the pesky reptiles?

    To couch this as somehow doing protected species a favour is disingenuous - they know translocation is a last resort and is usually not successful. To choose such an inappropriate site, which would take many months, if not years to make more suitable, is concerning. I doubt they've even done an ecology survey or a survey of slow worm populations in the cemetery.

    Translocation is contrary to Natural England Government advice for this site in Kingsmeadow as:
    1) translocation is a last resort as it is usually not successful, but the requirement for doing this has not been demonstrated at all (either by the planning application's Ecological Report (see 5. here), or the Decision Notice's conditional Ecological Management Plan (see 6. here).
    2) the suggested site is unsuitable habitat and there is not enough time to make the habitat suitable
    3) the changes to the proposed habitat have not been assessed for harm to the environment at Kingston Cemetery SINC (sustainability, habitat, ecology, protected species etc)
    4) the site is outside the home range of the slow worms so against Natural England advice:

    "Look at suitable habitat within the home range of (the distance the animal normally travels from) the development site. Surveys should aim to establish the population size and distribution of reptiles on and near the development site." (Natural England guidance under 'Survey & Methods')

    The proposed translocation is also contrary to:-
    5) planning mitigation for the Small Sites development at 204-210C Cambridge Road: the Ecology Report did not advocate translocation. Mitigation was to allow the population to stay on site and allow permeability to the Kingsmeadow field to the South
    (see A. below).

    The nearest suitable habitat, which is already part of this population's range IS the proposed Kingsmeadow school site. The greatest chance of this population's success is to be allowed to remain in Kingsmeadow. That was the point of planning the site to be permeable to adjacent Kingsmeadow habitat.
    ⁠6) the Ecology Management Plan - does not advocate translocation at all (4.4.2 is the only mention of translocation and it says "Alternative mitigation methods that are available, such as undertaking a reptile translocation exercise is not considered appropriate; as the works required would likely cause greater disruption/risk of killing or injury of reptiles due to [the site's] small size")
    7) recent research showing slow worm populations don't translocate successfully:

    Nash D. J. et al., (2020) Effectiveness of translocation in mitigating reptile-development conflict in the UK. Conservation Evidence,17, 7-11.

    "Although translocation may prevent the immediate death of slow worms that would otherwise be destroyed with their habitat by development: "The study found no confirmatory evidence that mitigation-driven translocations are compensating for the losses of populations to development"


This has led to concerned individuals issuing further Freedom of Information requests to ascertain what  survey methods were used to survey the cemetery and ensure that no harm would come to receptors in the cemetery. S. Sivanesan has asked for information of:

Evidence that the survey method used to assess the population of any reptiles on proposed receptor sites followed the Froglife guidelines, as they are the only comparable method that people have to estimate populations. As such please provide the evidence of:

  1.  the number of survey visits and survey dates and weather conditions for all surveys  across the whole of the active reptile season
  2.  the surveys using the correct minimum size of refugia (1m by 0.5m to get 0.5m2 not 0.5m by 0.5m which is often incorrectly quoted by some ecologists;
  3. the survey reports which state categorically the evidence that slow worms need to be moved under the granted planning permission for the housing development at Kings Meadow to maintain their conservation status;
  4. all of the sites surveyed as possible receptor sites in the Kingston area, to evidence any form of good ecology practice; rather then what appears to be some flawed decision by someone in the council that the cemetery site was the only viable site and that’s where they will be moved to. 


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