Middle Mill, Kingston University Application 25/02541 Demolition of existing blocks and erection of a 5 -storey tower.

                       Hogsmill Community Garden indicating the suns position 2pm 5.1.26

25/02541/FUL The proposal is for  demolition of existing student residential blocks at Middle Mill (Block A and Blocks G-L), and erection of a new 5-storey purpose-built teaching building for Kingston University with ground floor cafe and gallery space, associated access, blue-badge parking, landscaping and ancillary development. This is work in progress and subject to change.

The Ecological Assessment prepared by Buro Happold (September 2025) states that biological records were obtained from the Surrey Biological Records Centre, rather than from Greenspace Information for Greater London (GiGL). This has significant implications for data coverage.

Personally, I have supplied GiGL with approximately 17,000 biological records collected since 1994 from surveys undertaken across the Greater London area, whereas only a few hundred records—derived from surveys undertaken in Surrey—have been provided to the Surrey Biological Records Centre. As a result, important datasets held by GiGL may not been accessed.

By using a data search from another county, survey data from sites including Knights Park, the Hogsmill River, and Middle Mill would not necessarily have been captured or fully considered within the assessment. This is with the exception of some of the bat data, which was provided by GiGL but not the roost data, which can only be provided by the London Bat Group.

The bat emergence surveys, were not undertaken according to guidelines, which state that three surveys during the recording season: June, July and August should be undertaken on buildings exhibiting features with high potential for bat interest. The bat surveys were undertaken  7th August 2024, 28th August 2024, and 19th September 2024. These would be of limited value only recording post breeding activity. 

I undertook targeted bat surveys at the site on 29 May 2024, 3 July 2024, and 1 August 2024. These surveys recorded four bat species, with over 300 bat passes recorded by a single observer.

The findings indicate that the site functions not merely as a transient commuting route, but as an important destination for bat species, which actively travel to the area for evening foraging. This conclusion is stronger than the characterisation presented in the assessment, demonstrating that the site plays a significant role in supporting bat activity and local bat populations. Light pollution is set to increase within the proposals and will have an impact on all receptors, see previous posts New lights at Kingston University

The extent and density of urbanized land-use is increasing, with implications for habitat quality, connectivity and city ecology. Little is known about ‘densification’ thresholds for urban ecosystem function and the response of nocturnal mammals is poorly studied . In several studies (Hale et al. 2012)common pipistrelle activity exhibited a non-linear relationship with the area of built land cover and was much reduced beyond the threshold of about 60 per cent, implying a tipping point for even the commonest bat species of which increased light pollution plays a part.

As a chalk stream, the Hogsmill River is a priority habitat listed under Section 41 of the Natural Environment and Rural Communities (NERC) Act 2006. On this basis, the river corridor and its associated habitats should be regarded as being of County importance.

Over many years, significant and sustained efforts have been made to enhance the Hogsmill’s ecological condition, including improvements to channel structure, marginal and in-channel vegetation, and bank profiles, with the aim of reinstating more natural fluvial processes and habitats. These works materially contribute to the river’s chalk stream character and ecological value.

Importantly, these improvements extend to adjacent habitats, including the Hogsmill Community Garden, which forms an integral part of the river corridor see previous post Hogsmill community garden The ecological value of this area is further evidenced by long-term monitoring initiatives, including the presence until recently of an eel trap used to monitor eel passage, and regular Riverfly Monitoring undertaken on site Eel monitoring and River Fly. These activities demonstrate both the functional ecological role of the site and its recognised importance for priority species and river health.

The effect of the dust, cement and other pollutants on the Hogsmill river (and Hogsmill community garden) cannot be mitigated and will undermine years of effort.

 The Sunlight, Daylight, Overshadowing Assessment does not look at the impacts of the ecological receptors and ignores two/three of the adjacent SINC's.

Table 4-2 of the Buro Happold Ecological Assessment wrongly states that the Hogsmill Community Garden is owned by the University and identifies it as a Site of Importance for Nature Conservation (SINC) within 5 m of the University, noting only that “a range of common and widespread birds have been reported at the site.”

This description significantly understates the ecological value of the Hogsmill Community Garden. As a designated SINC,  its value extends well beyond the presence of common or widespread bird species. The summary provided fails to acknowledge the site’s its role within the Hogsmill River corridor, and its function as a locally important refuge and ecological linkage within an otherwise urban environment. It is described by others as providing  'a unique form of engagement with nature, ultimately improving attitudes to wildlife'.

 This was expounded in the  Kingston SINC Review 2020, Landuse Consultants, described the two areas as follows:

This site comprises of the Hogsmill Community Garden (westernparcel) and an area of non-publicly accessible land owned by the Environment Agency (eastern parcel). The site is located in the west of the borough, it is adjacent north of the Hogsmill River in central Kingston. The Community Garden project aims too addresses the need for more outdoor community spaces, it provides opportunities for the local community to improve their health and gain practical skills in environmental practices.
The Community Garden is open the public three days a week, where anybody is able to enjoy the space. Ecologically the garden is of moderate interest but for people the site is an important place to relax, learn and engage with nature.The site is small and split into two parcels. The western parcel is the community garden where habitats included amenity grassland,hedgerow, pond, planting beds, a polytunnel, hardstanding, shedsand a seating area. The eastern parcel is private land owned by Kingston University and is not part of the community garden facility.

 

Despite Community Garden's small size, it provides an invaluable service to local community. It enables people to visit and enjoy a well- designed garden. For people without their own gardens, this community garden enables them to enjoy a garden in a way that is very different from visiting park or local nature reserve.
 

The Community Garden also have projects that teach local people practical gardening skills, empowering them to improve their own personal greenspace at home, whether that be in an actual garden or simply a balcony. By giving people the skills to improve their own personal spaces, the project indirectly improving greenspaces across the local area. Encouraging people to take stewardship of their own gardens and balconies is a highly important, Although the site is small and supports common and widespread habitats, which are not considered of distinct ecological value on their own, it is considered to be of key importance for people in the local area.

 

London Plan Policy G6 states that Sites of Importance for Nature Conservation (SINCs) should be protected, and that SINCs and Ecological Corridors should contribute to the establishment of coherent ecological networks. This policy intent is to safeguard and enhance the functional ecological role of these sites, ensuring they are managed as integral components of London’s biodiversity network.

Treating a SINC or ecological corridor merely as a visual setting or passive backdrop for development is inconsistent with Policy G6. Such an approach fails to recognise the site’s ecological function, connectivity value, and contribution to priority habitats and species. Development proposals must therefore demonstrate how SINCs and ecological corridors are actively protected, enhanced, and integrated into a wider ecological network for the future, rather than subordinated to commercial or operational uses.

Enhancements

The Environmental Impact Assessment States:

Habitat enhancement and creation:The majority of habitat on-site is due to be retained or enhanced. The existing mixed scrub will be retained (0.34ha), as well as the majority of modified grassland (0.005ha) and the majority of trees (27 trees equating 0.3135ha). A large proportion of the retained modified grassland (0.055ha) will be enhanced from its existing low distinctiveness species-poor grassland of poor condition to a medium distinctiveness biodiverse neutral grassland of moderate condition.The proposed habitats that will mitigate the loss of habitats to facilitate construction include the planting of an additional 21 small urban trees, introduced shrub (0.004ha), rain garden (0.047ha), and other neutral grassland (0.036ha)).
All watercourses will be retained. Due to the additional landscaping occurring along the riparian zone of the river, this will likely enhance the bank top vegetation structure river condition indicator (B1) score from 1 to 2 (further details on the watercourse scoring are found within the BNG report (Buro Happold, 2025) submitted alongside this report for planning).The implementation of the supplementary mitigation measures will lead to the significant effect of habitat loss to be reduced to temporary minor adverse effect.

In summary, the proposed rain gardens, as largely artificial habitat features, represent a limited and unimpressive form of ecological mitigation when set against the scale and sensitivity of the affected environment. While recommendations to improve riparian habitat are welcomed in principle, they are presented only as non-binding recommendations rather than secured or compulsory measures.

As such, the proposals do not provide adequate certainty that meaningful ecological enhancement will be delivered. Given the perceived and likely impacts of the development—particularly noise, dust, airborne pollutants, and shadowing—there is a clear need for secured compensation and mitigation, especially in relation to the Hogsmill Community Garden, which stands to experience the greatest adverse effects.

Any mitigation and compensation measures should therefore be clearly defined, proportionate to the impacts, and secured through enforceable mechanisms to ensure the protection and enhancement of this SINC and its role within the wider ecological corridor.

    

Theo from the London Waterkeeper testing water quality at Middle Mill opposite the Hogsmill Garden