Old allotments, Woodfield Gardens New Malden 23/01158/Ful (anonymous contributor)

 Its important to document the rapidly occurring loss of open land to development in the borough, particularly where that loss seems contrary to policy. This is a contribution from an objector to the development proposals, whose comments we wouldn't otherwise see, as comments are no longer publicly accessible. 

The comments may help with objections to similar applications, where land has been cleared prior to survey; as you read, it becomes clear how alienated we are when it comes to discussing nature. The contributor to the blog is happy for the following to be copied:

I object strongly to this application for the following reasons -

A) Ecology and BNG (and possibly UGF) assessments are all in error due to the site being cleared for the development.

It is impossible to say what was here beforehand as the site was cleared in advance - some time between August 2022 and February 2023 - almost certainly for the development. It looks as if the Preliminary Ecology Assessment and the BNG and UGF baselines were made after the clearance and so are likely meaningless exercises.

On this basis alone the application should be refused as such applications may represent a serious threat to biodiversity in the borough.

i)The Preliminary Ecology Assessment (Feb 2023) admits the land has been cleared: "The Site is located on land between Woodfield Gardens to the south-west, and Queen’s Road to the north-east, see aerial mapping in Appendix 1. It consists of unmanaged land that was previously much scrubbed-over and has since been cleared, so leaving expanses of bare ground covered by wood chips."

Indeed the cut stumps of trees reduced to woodchip just before the survey are marked in the PEA drawing of the site. The PEA says that "there were no trees on site" Also that there were no signs of badger, bats, reptiles, amphibians and breeding birds, which is no surprise on a razed site. Hedgehogs were known at this site.

ii) Design & Access Statement (Feb 2023) confirms clearance on p.7:-

"Woodfield Gardens is accessed via a slip road from the A3 and is made up of detached and semi detached interwar housing. The site is positioned on the North-East corner and accessed between two existing houses at numbers 11 and 13. The site also benefits from a right-of-way from the adjacent Queens Road. The plot is surrounded by residential gardens from the adjacent roads and public playing fields to the North. The land is currently vacant and has recently been cleared to show that it is flat and relatively level. "

iii) Google Street view (looking between houses 11 and 13 Woodfield Gardens) seems to indicate some preliminary clearing between August 2020 - August 2022.

iv) Site views in the Design & Access Statement (p.9, images 06-09) shows major clearance happened after August 2022, leaving mostly bare ground and woodchip.

B) Other inaccuracies and errors, for example the Preliminary Ecology Assessment also says there are no water bodies within 500m but the Beverley Brook is about 200m to the East!

C) The Arboricultural Report is unclear about what happened to on-site trees!

The arboricultural report is dated February 2023 and requires clarification as to what happened to the on-site trees. The report first notes that a survey was done in June 2022 (before the final clearance but likely after the preliminary clearance) and that there were trees on site, mostly young.

"4.2 Assessment" states that one should "Refer to the accompanying TPP, drawing, reference 22-1422-TPP, for the relationship between the proposed development and the trees on and adjacent to the site", but this appears to be missing. Remarkably, the report then concludes that there are no on-site trees affected by the development. It looks as if all the on-site trees were chopped down shortly after the tree survey! The later Preliminary Ecological Survey certainly shows cut stumps of on-site trees marked in their drawing.

D) 23_01158_FUL-Urban_Greening_Factor_and_Biodiversity_Gain_Statement-5405498.pdf are a complete muddle with one saying that the site is mostly vegetated, and the other saying it is mostly bare ground.

The Urban Greening Factor provides no verifiable baseline information and is not helpful. Given the likely site clearance before obtaining such baseline data, it would be difficult not to gain an uplift. However we get further confusion about the original state of this site. In contrast to other reports, the site is mostly vegetated, not mostly bare. ( "This 768m2 Site is currently mostly vegetated, with less than 7% cover of hardstanding. The proposed residential development requires a new access road and car parking and therefore, in accompany with the modest new built area footprint, this necessarily significantly reduces the extent of vegetated surfaces within the Site. As a result, only a modest UGF value is achievable.").

Biodiversity net gain -BNG - problems with the calculation

- The application notes "the bare ground across much of this Site" and inputs it as 'cereal crop' without a properly referenced explanation.

- The bare ground is incorrect baseline information, because it looks as though the site was cleared to achieve it.

Sites which are damaged prior to development should be given a BNG historical baseline level - if a developer clears a site before any ecological assessment has taken place then under BNG rules they have to assume the habitat was of highest quality & mitigate appropriately.


- Doubtful claims? Even with an artificially poor baseline they conclude "a 75.86% loss of biodiversity based on the existing habitat types". However they claim a compensatory gain of 100% based on the new hedgerow planting – see Appendix 4. This would equate to a 24% gain in biodiversity, which is in excess of the required 10% gain in biodiversity required for validation."

Firstly, I don't think that linear features/hedges are additive for the DEFRA biodiversity net gain metric calculations, they are kept separate.

Secondly, how do we know that there weren't mature hedges prior to the clearance of the site? Images in the Design & Access Statement show what looks like a hedge along the boundary with the Cromwell Open Space (see p.9, images 06-09). The OS 6 inch map 1888-1913 shows that this is an old field boundary (and Parliamentary County boundary) so a mature hedge and tree line is likely. It would be very wrong to replace a mature hedge with a new one.

E) Transport statement - a missed opportunity to improve access to green space for residents in the local area. The site is contiguous with Cromwell Open Space and provides a way from Woodfield Gardens and Queens Rd to this public space. Why was better access to the Cromwell Open Space not considered as part of this application? At the moment access looks very limited for residents with a narrow route from the North. Was there a path/track through the site from Woodfield Gardens to the Park and Queens' Rd in the East? Old aerial images show paths across the site and the Design and Access Statement indicates a right of way from Queens's Rd in the East as well as the entrance from Woodfield Gardens. This would make sense for accessing allotments and the routes to the Open Space should not be closed off to the public.