Application Summary
25/02562/FUL | Demolition of existing gasholders and associated above ground structures and buildings. Phased redevelopment of site to provide 8 to 16 storey 5nos blocks with 586 residential units and ancillary residential facilities (C3 Use Class), together with associated works to the existing accesses and internal vehicular routes, new pedestrian and cycle routes, the provision of new publicly accessible open space, amenity space, hard and soft landscaping, cycle and car parking, works to the brook embankment, re-siting of some gas infrastructure, ground works and plant and associated works. Cross boundary application with LB Merton: Development within Merton comprises works to existing vehicle access onto West Barnes Lane, including hard and soft landscaping and new public realm and associated ground works, to provide pedestrian and cycle route with access for emergency vehicles only, new pedestrian/cycle access routes to Marina Avenue and Sir Joseph Hood Memorial grounds.
The site is subject to a number of RBK and cross-borough designations with Merton:
Metropolitan Open Land (MOL),
Green Chain
Site of Importance for Nature Conservation (SINC): Beverley Brook
Flood risk: parts of the site are within Flood Zone 2/3
Wider context:
Green Corridor on Sir Joseph Hood Memorial Playing Fields land (Merton).
Sir Joseph Hood Local Nature Reserve (LNR) and SINC on the eastern boundary (Merton).
Manor Park SINC, approximately 100 m SW (RBK).
The site forms part of a wider area of MOL spanning Kingston, Merton and Sutton.
Running along the eastern boundary is the Beverley Brook Site of Importance for Nature Conservation (SINC)
see beverley-brook. The SINC extends to the south of the site and the north of Kingshill Avenue with playing fields beyond.
Adjacent to the western boundary of the site is the Southwest Railway Line, both the river and railway are natural wildlife corridors.
Most importantly, the site is designated Metropolitan Open Land.
MOL is strategic open land within the urban area. It receives less
publicity than Green Belt, but has equal legal status; it is a
designation that protects open land within London, as opposed to
around the edge (greenbelt). MOL is specific to London, and can be applied to open
space that contributes to the structure of the city, provides open air
facilities for sport and recreation, contains features of historic or
biodiversity value, and/or forms part of the green infrastructure
network. We are of course treated to an expensive denial exercise, this time by Lichfield's. The arguments for protecting Metropolitan Open Land have become routine (Seething Wells has many iterations) and heavily politicised; due to recent government pronouncements, everyone is now claiming their landholdings are Grey Belt see Green/grey belt playing down any strategic and biological significance. The National Planning Policy Framework Golden Rules amendments December 2024 requires 50% affordable housing.
In thier submission, Lichfield's recognise the Jersey Cudweed but not the bat interest nor the reptiles or the strategic importance of the land as corridors, or as an important part of the matrix.The sum of the parts is greater than the whole and species need all habitats in which to nest, roost, forage, rest, socialize and undertake other important interactions.
A cursory look at the Landscape Plan ensures us that every part of the habitat will be designed for and used by people. It will be planted with species that we like and 'design out areas of concealment by ensuring the planting is low level and there are no places that people can hide behind furniture'. Tall lighting columns will ensure that the Beverley Brook will no longer be suitable for the passage of Daubenton's or any other light shy bat species. Events are promised such as outdoor cinema, outdoor fitness, forest bathing, so will any space remain for wildlife? Oh yes I forgot, the roof, where they will stick the Jersey Cudweed.
Surveys
RPS Consulting Services Ltd were commissioned by Berkeley Homes to undertake a:
Preliminary Ecological Appraisal (PEA) 2023;
Phase 1 Habitat Survey, botanical survey, reptile, breeding bird and bat surveys.
Surveys were undertaken over the entire site (an area totalling 2.97 ha) which comprises
three
redundant gas holders, a gas compound, and three associated
outbuildings. Hardstanding connects the site with areas of grassland
and scrub along the boundaries and between the holders.
Trees
Several trees were felled in advance of the surveys, see above with four additional mature tree stumps shown in the site images (3 pg. 10) and others (see slide 44) cited as 'pruning' in the ecology report (3.3.20). There are many contradictions across the information submitted to the planning file. For example the council's pro forma Biodiversity Checklist states that no mature trees (or scrub) will be felled or lopped.The Arboricultural Report (pg 15) 5 Trees and 3 groups of trees will be lost. 2 groups of trees will be partially lost'. There was a recomendation to remove 6 further trees, some exhibiting ash die back and tree overhang will be cut back from the river to facilitate access. I lost count at 20 felled trees, many of these mature, with dead wood components, important for the generation of invertebrates that are of interest to particularly the larger bat species such as the Leisler's bats (a feature of the area).
There is
legislation regarding the calculation of the BNG of the site when
features have been removed. The Landscape Plan states there will be an uplift of 34% BNG while the Ecologists state 40% BNG, while many colleagues in the field state that the benefits are often bogus
biodiversity-net-gain-fail. ecological-leveling-up . Biodiversity Net Gain seems to be confused with Green Infrastructure provision.
Significant plant species found during the surveys include a Schedule 8 protected plant species, Jersey
cudweed, recorded in 'small numbers' to the south of the site. A licence
will be required, as well as an appropriate management plan to retain
these species, which we are told, 'will focus on creating open mosaic
habitat,' on the so-called 'biodiverse' roofs'. This plant exists on
other development sites in the borough where there is open ground including Cambridge Rd estate where it is weedsprayed.
By
putting ecological features on the roofs, which have a large failure rate unless
irrigated, translocation success cannot be ground-truthed or evidenced.Greenroofs form part of the Mayors Green Infrastructure not the Biodiversity Net Gain. It is interesting that these surveys often reject the existence of 'Open Mosaic Habitat', a priority habitat, until they have to recreate it and then any iteration will suffice, whether it fits the criteria or not.
Badgers
Badgers have been recorded within a 1km search area, according to the London Biological Records Centre, yet there is no mention of them in the Ecology Report. Badgers are inconvenient in planning especially as this will be a gated area, so access previously available to ranging animals will be removed. There are currently many animal access points or 'push- unders' along the fencing (see below).
Hedgehogs
There are also
many Hedgehog records within the neighbourhood. These are available from
PTES Hedgehog Street map.
Bat activity surveys revealed that the peripheries of the site, i.e. the adjacent watercourse and railway track supported relatively good levels of bat activity, largely from more common
species such as Common and Soprano pipistrelle. Several mitigation measures have been proposed in order to protect roosting and foraging/commuting bats, which included a 'sensitive lighting strategy' which is not evidenced in the Landscaping documents. Not only will the Beverley brook corridor receive damaging light spillage from the columns situated along the access road, but this application fails to recognise the effect the gargantuan buildings will have. As the amount of vegetation and canopy cover reduces, so the urban gradient increases;
it is thought that when the urban surface reaches more than 60% (of which lighting plays a part) we lose
our commonest bat species for a suite of reasons, but largely due to reduction in their insect prey.
When light levels increase above moonlight, Daubenton's bats are prevented from moving along the river corridor, a bat dependent on such linear features. There is a maternity colony along the lower stretches of the Beverley brook see
new-site-Daubentons-bat-maternity .
When we increase the lighting and remove canopy cover (removes important light shields) then Brown Long-eared bats, who rarely leave the cover of trees, are also lost from development sites.
Leisler's bats are rare, but we keep reading how common pipistrelle bats are, in the text of the survey. The London Bat Atlas shows the distribution of Leisler's bats across London and there is a stronghold in this corner of SW London, which may represent one breeding colony. see this post for BLE and Leisler's bat info
article with Leisler's distribution map . This species was first recorded in the area feeding over the former Worcester Park Sewage Works and now the lake at the Hamptons. They have a different foraging strategy to pipistrelle bats, utilising a larger more open area, feeding at height on larger prey items. This explains why the reduced number of passes over pipistrelle bat passes, which tend to forage backwards and forwards along the river corridor at an accessible mid- canopy height.
Serotine and Nathusius' Pipistrelle bats were recorded at this location using static bat detectors. In the case of the former this is due to beetles associated with animal dung in offsite fields. See the distribution, reflecting their relative abundance, of Common,
Soprano Pipistrelles and Leisler's bats, in our June 2025 bat survey
(GPS photoplot below).
Bat distribution 30th June 2025 M. Wagstaff
Reptile surveys identified a small population of Slow Worm and lizard see
Kingshill reptiles.
Mitigation measures have been proposed in this report to manage impacts on reptiles within the site, including 'enhancement of existing woodland edge habitat'. Little is said regarding the impact on existing populations of the fragmentation of the habitat, predation by pets and the degradation of the food and refugia available for the Slow Worms and Viviparous Lizards.
Breeding bird surveys a total of thirty species were found on site, of which twenty-three were
confirmed to be breeding within the redline survey area. This is an arbitary boundary of course, as birds not only fly, but they obtain food, shelter, dust baths from a range of different habitats, which are not always within the red line. Well known neighbourhood bird species such as Tawny Owl, would have been heard, during the bat surveys if real surveyors (instead of AI) had have been undertaking them. Of the twenty-three species found breeding, nine met at least one criteria relating to conservation importance. Nevertheless, the breeding bird assemblage was found to be of Local importance, which could become an artefact of history if the development is allowed to proceed, due to the increase in urban gradient and the sheer number of introduced feline predators. More can be seen here
https://sparrowfeld.com/Impacts on this adjacent sites in summary
Tree loss is not properly accounted for in the Biodiversity Net Gain, it is not clear how many will be removed perhaps >20. The councils Biodiversity Checklist attests to a big red 'NO' in the box for tree removal or lopping. Dead wood removal, tree canopy reduction and the lopping proposed in the Arbor report will curtail the food availability for bat and bird species.
Key and protected species are ignored. Badgers are recorded within a 1km search area (Greenspace Information for Greater London 2025) and haven't been included in the assessment. There appears to be no permeability within the site as it will be gated. There are also many Hedgehog records within the neighbourhood. These are available from PTES Hedgehog Street map. Large animal push-unders are seen along the fence, but are not accounted for in the surveys.
The Council have a Species Action Plan for bats. This has an action which states that 'raise awareness amongst Council Officers and the public of the
importance of bats to encourage greater levels of council &
community driven conservation and appreciation across the borough'. For this reason, please make my planning comments public.
The Ecology Report does not reflect the complexity of the bat activity recorded on the site. The area is well known for Leisler's bats, which are rare. These are not mentioned in the Metropolitan Open Land report by Lichfield's, who only claim Jersey Cudweed as an ecological feature, so it can be dispensed with by translocation to the roofs (where it cannot be evidenced). Nathusius's Pipistrelle is also rare, Serotine bats are rare in London. Brown Long eared bats 'rarely' leave the canopy of trees and together with Daubenton's bats, which only use the linear river corridor are 'light shy'.
Light pollution will impact all species, as well as adjacent habitats. It will particularly affect invertebrate species, which form the prey items for the bats, birds and reptiles. Light will bounce off the reflective built surfaces changing the suburban to an urban gradient beyond, which many of these species can exist.
The impact on strategic areas such as corridors will be gross and these impacts have not been mitigated. The Landscaping is designed for people appeal and the proposed activities (outdoor cinema, forest bathing) will impact the SINC's & their features. How will Slow Worms or birds navigate the reduced habitat availability and greater predation risks once many cats and dogs are unleashed. This runs counter to the MoL designation, is against councils Biodiversity Policies and the newly implemented Biodiversity Action Plan and should be refused.
more to come on the proposed 40% Biodiversity Net Gain, Flood Zone 3b and contaminants.
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