‘Bexley Lepidopterist’ newsletter, butterfly report Jan-April and recording update.

We are pleased to publish issue No. 2 of the ‘Bexley Lepidopterist’ newsletter and a list of Bexley butterfly records from 1/1/18 to 27/4/18, compiled by Mike Robinson. Also included in this post is an update on recording work for the London Butterfly Atlas, which identifies the Sidcup, Lamorbey/Longlands and Albany Park areas as relatively under-recorded, though that is starting to change. 

Mike thanks contributors, and reminds everyone that there are 3 butterfly walks being held over the next few months (see our calendar page), the purpose of which is to encourage more people to do butterfly recording. One does not need a great deal of expertise to start making a useful contribution. Mike says ‘It is particularly important to be aware that the records are not disappearing into thin air: the majority are being submitted to Greenspace Information for Greater London (GiGL), the Kent and SE London Branch of Butterfly Conservation and the London Butterfly Project for further analysis, so are helping to monitor the distribution and health of butterfly populations in Bexley’.

Furthermore, during the next few months he is intending to start work on drafting an ‘LB of Bexley Butterfly Atlas’, with a view to having a solid foundation of data in place by the end of 2019.

‘Bexley Lepidopterist’ No.2.

Download the PDF file .


Bexley Butterfly Records 1/1/18 to 27/4/18.

Download the PDF file .


Butterflies of London Project update 


Download the PDF file .


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Bexley elections, May 3rd. Who to vote for if you care about nature and want a greener Borough?

Bexley goes to the polls tomorrow, Thursday May 3rd, to elect the Borough’s Councillors for the next four years. For those that haven’t voted by post and are casting their ballot on the day, this piece provides links to the list of candidates for each Ward, the manifestos of the parties and summarises their stated local policies on ‘green’ matters.

For its part, the London Wildlife Trust is urging voters to back candidates that are committed to:

  1. Safeguarding nature and wildlife in the borough by protecting and conserving Sites of Importance for Nature Conservation, Metropolitan Open Land and/or Green Belt, and rivers and waterways;
  2. Supporting the full implementation of the Mayor of London’s London Environment Strategy, to promote the design and delivery of ‘green infrastructure’ to benefit nature across London;
  3. Supporting initiatives that help the borough’s residents engage with and benefit from nature;
  4. Ensuring management of the borough’s parks and greenspaces is to a high environmental quality;
  5. Ensuring new development is designed and built to the highest environmental standards, along the lines of At Home with Nature.

The Bexley election is being held on new Ward boundaries, with the number of Councillors being reduced from 63 to 45 in the process. A full list of candidates for all Wards is here:


with a mixture of 2 and 3 seats up for election depending on the Ward. You don’t need your polling card to vote. You don’t have to use all your votes for candidates of the same party, and you don’t have to use all of your two or three votes. You can also ‘spoil’ your ballot paper if you are so inclined, which at least shows you bothered, but couldn’t support anyone on offer.

Besides the Conservatives and Labour, there are 14 UKIP, 13 LibDem, 5 BNP, 3 Green Party, 1 Liberal Party and 1 Independent candidates across the various Wards.

It has to be said that none of the parties currently represented on Bexley Council (Con, Lab, UKIP) have covered themselves in glory as far as environment/nature, wildlife and sustainability are concerned over the last 4 year term. All support the ‘growth’ strategy which will hugely increase Bexley’s environmental ‘footprint’ and destroy more green space, including parts of designated Sites of Importance for Nature Conservation.  Councillors of all sides have voted for one or more ‘developments’ on such sites over the past few years, giving little or no weight to the Borough’s stated biodiversity protection and enhancement policies. So are things likely to get any better after Thursday’s vote ….?

Here’s a quick summary of relevant 2018 election policy from the various parties:

The Conservative ‘manifesto’ amounts to two sides of an A4 leaflet, so is more of a ‘mini-manifesto’. See here:



In it they claim to be proud of the Borough’s open spaces and promise to deliver an extra 2 hectares of ‘green open space’, which is a tiny amount for one year, never mind the next four – and it’s not clear whether this would prioritise nature and is, indeed ‘new’ green space, reclaimed from human-dominated usage, or simply existing private land that would be made public.  1,000 new street trees are promised across Bexley. A figure of 8,000 new homes is given, all purportedly on ‘brownfield land’. Strangely, the much-trumpeted ‘growth strategy’ is not mentioned, with its target of 31,500 new houses by 2047, perhaps because a large number of residents opposed it. Nor is the fact that said strategy proposes building on greenfield and Sites of Importance for Nature Conservation. Instead the Mayor of London is blamed for plans for ever more concrete, even though he’s just following what Boris Johnson planned in this regard before him. 

Finally, according to the Tories, we need ‘more community, not more politics’. But since politics is fundamentally about sorting out the values that underpin policy, without resorting to killing one another, then given the gross under-valuing of nature and wildlife in this Borough over the last few years, we do need more wide-ranging political debate! The sad fact is that those wedded to ‘growth’ and concrete have long sought to try and sideline this issue by attempting to ‘depoliticise’ it, pretending there is no conflict between their plans and the environment and thereby hoping to remove it as a matter that might sway people’s votes.  There is no mention in the manifesto of ‘sustainability’ in terms of Bexley’s resource footprint at all. 

The rather more substantial Labour manifesto is here:


Bexley Labour claims credit for the ‘growth strategy’ and has stated that it supports it. It apparently fails to see the irony in also claiming that ‘A new Labour council will stop, cancel and reverse the Tories programme to build on parks and open spaces, within days of the election.’ Whether sell-off decisions already taken can legally be reversed is another matter. Like the Conservatives, nowhere is there any indication of when enough will be enough as far as ‘development’ is concerned. Separately, the leader of the Labour Group has said that ‘in principle’ it opposes the ‘growth strategy’ plan to build a by-pass across Crayford Marshes. 

We are told that ‘By using brownfield land and former industrial spaces, we can build the homes and create the jobs we need without destroying Bexley’s much loved green and open spaces.’ Apart from joining the Conservatives in failing to understand the high wildlife importance of some ‘brownfield’/former industrially used land, including here in Bexley (e.g. the Cory/Borax fields) one has to wonder whether there’s really enough of it in the Borough to take 31.5K new homes without a lot of tower blocks. 

Specific policies are:

• Support parks, green and open spaces by stopping, cancelling and reversing the programme to build on the borough’s park and open spaces immediately on the election of a Labour council. • Review cuts already made to the maintenance of green spaces in recent years to find new ways of protecting them now and in the future. • Back measures by the Mayor of London to protect the greenbelt. • Commit the London Borough of Bexley to reducing the impact of climate change, locally, nationally and globally by assessing and reducing the council’s CO2 emissions. • Incentivise carbon neutral development and business in Bexley and microgeneration and renewable energy schemes. • Introduce car clubs, including through the planning process, to reduce car usage by offering an alternative to private car ownership.

so there is some recognition of wider global sustainability issues, though nothing that suggests an understanding of the fact that the ‘growth strategy’ as a whole flies in the face of them, and that there is a pressing need to get beyond tinkering and adopt far greater resource usage reduction measures to protect nature and let it recover.

There’s also a bit of a sense of ‘nature’ and ‘non-nature/tidiness’ mentality here and there, rather than positive statements about managing sites in such a way as to attract and accommodate more wildlife. 

Neither of the main parties has mentioned wildlife as such, or put forward a ‘vision’ or plan for driving forward the Council’s stated policy of protecting and enhancing biodiversity, particularly protected and (Biodiversity Action Plan) priority species. This is in the context of the BAP itself having now expired (in 2015) and 80% of wholly or partly Council-owned SINCs having no management plan, with those that do being several years old. They obviously don’t think that many people take it that seriously, which represents something of a failure on the part of those of us that do. 

The Bexley UKIP website does not provide any detail on its policies for the Borough other than fairly generalised statements with the word ‘Bexley’ inserted here and there:


We are told UKIP Councillors protect open spaces and fight wind farms. 

The Bexley Liberal Democrats, BNP and Bexley Green Party Facebook/webpages don’t carry local manifestos or list specific policies for Bexley to translate their national policy into local action.

In these circumstances, for those of us who think that nature and wildlife should be at the heart of political decision-making, it may be a case of voting for the least worst combination of candidates on offer in your Ward. It looks like whoever is elected on May 3rd, a lot of work is going to continue to have to be done and pressure applied to try and improve the Council’s decision-making as far as our local environment is concerned. 

Compiled by Chris Rose.


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Thames Road Wetland – general views and plant photos, 26/4/18

On a generally sunny afternoon there was birdsong aplenty at Thames Road Wetland, with the sound of Reed Warblers, a male Reed Bunting, 2 Cetti’s Warblers, 2 Song Thrushes, a Greenfinch and several Goldfinches prominent. Two juvenile Common Lizards were spotted. Two Green-veined White and a Small Tortoiseshell were the only butterfly species seen. A number of plant species were in flower, including the tiny, annual, Early Forget-me-not (Myosotis ramosissima), Cornsalad (Valerianella sp), Star-of-Bethlehem, Red Deadnettle, White Deadnettle, Ground Ivy, Round-leaved Crane’s-bill, Celery-leaved Crowfoot, Creeping Buttercup, Lesser Celandine, Daisy, Common Vetch, Soft Comfrey, Gorse and Wayfaring Tree.

Thames Road Wetland looking south east from the northern margin.

Looking west-south-west towards the River Cray embankment from the Thames Road bank.

North ditch looking south-west, with Marsh Sow-thistle flower stem from last year left of centre.

Well-vegetated north ditch, looking south-west. A key area for the site’s Water Voles.

River Wansunt crossing Thames Road Wetland. Looking south.

The local traveller’s ponies perform a useful ‘conservation grazing’ function at the east end of the site, and will go paddling for extra food in winter. Having created a few channels by hand-pulling Reedmace, to encourage them in, they’ve opened up a much larger area, which diversifies the habitat.

There are two patches of White or Soft Comfrey (Symphytum orientale) at Thames Road Wetland. It is an excellent early nectar source for Bees, which is why I have it in my garden. I thought I may have accidentally transferred seeds there myself, but subsequently found a few plants further north up Thames Road. A native of S. Russia, N.W. Turkey and the Caucasus, it was in British gardens by 1752 and in recent years seems to have started spreading in the wild in London.

Ground Ivy. The flowers of this species can be a lot paler, but those here are of a good intense colour and again a good early nectar source.

The tiny and annual Early Forget-me-not (Myosotis ramosissima) flourishes on patches of fairly dry, bare soil at Thames Road Wetland.

An unidentified species of Cornsalad flowers together with Early Forget-me-not.

Seven Star-of-Bethlehem plants were in flower. Although an uncommon native these, along with the couple of types of Grape Hyacinth present will, as ‘garden escapes’, have somehow got into the material used to widen the Thames Road embankment some years ago.

The flora of the Thames Road bank shows chalk influences, so the Wayfaring Trees, planted at the time Thames Road Wetland was constructed, are quite at home here.


Chris Rose. Thames Road Wetland Site Manager for Thames21.

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Bexley RSPB Martens Grove 19th April bird walk report.

Stock Doves, Nuthatch and a Painted Lady butterfly were the highlights of Bexley RSPB’s visit to Martens Grove on April 19th, though the hot sunny weather seemed to result in less birds showing themselves than had been expected.

Download the PDF file .

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Bursted Woods – some general views and ground flora photos, spring 2018

Bursted Woods is small area of woodland dominated by old, outgrown Sweet Chestnut coppice, with Oak, and adjoining mown grassland with a more eclectic mix of scattered trees, including several Poplars. It is situated on Erith Road near Barnehurst railway station. The woodland under-storey has Elder, Holly, Cherry, a few Hawthorn, Yew and Bramble. Amongst the ground flora are some indicator species for ancient woodland. Despite heavy usage it is fairly litter-free. Issues include the prevalence of hybrid native x Spanish Bluebells, which are gradually being removed, and an apparent increase in recently trodden pathways where there were none before, which is going to reduce the amount of flowers if not checked.

All photos by Chris Rose.

Some general views:

Sundown over the west end of the wood, 16/3/2018.  

Bursted Woods open space in the snow, looking west, 17/3/2018.

Inside Bursted Woods, 17/3/2018. 

A tracery of Silver Birch in a more open area. 17/3/18.

The setting sun catches the tops of the trees on the north east corner of the wood. 28/3/18.

Bursted Woods. Remnant of long-dead coppice stool front left. Live stool with regrowth centre-right. 5/4/18.

Copse and north margin of Bursted Woods, looking south-east. 16/4/18.

Some spring plants:

Some well-meaning person (or more) has planted a number of different Daffodil cultivars, mainly on the eastern edge of the wood. With none of the native species present, at least they can’t cause hybridisation problems. 

Daffodil cultivars, Bursted Woods. 2/4/18.

Daffodil cultivar, Bursted Woods. 2/4/18.

Daffodil cultivars, Bursted Woods. 2/4/18.

Daffodil cultivar, Bursted Woods. 16/4/18.

The ferny leaves of Pignut
(Conopodium majus) emerging through last year’s leaf-litter. A member of the carrot family, it has a bulbous edible root. 2/4/18.

There are two patches of Climbing Corydalis (Ceratocapnos claviculata) in the wood. Here seedlings are coming up amongst Bluebell foliage and leaf litter. The only other known location for it in the Borough is Lesnes Abbey woods.

Lords and Ladies/Cuckoo Pint (Arum maculatum). A fairly well-spotted plant. Many are plain green.

Wood Sorrel (Oxalis acetosella) seems to be present in only one small area of a few square metres at Bursted Woods. 16/4/18.

Wood Anemone (Anemone nemoralis) is plentiful in Bursted Woods. The flowers close up for the night and are pretty much shut by late afternoon. 16/4/18.

Lesser Celandine (Ficaria verna) is a member of the buttercup family that survives summer/autumn dormancy by means of small underground tubers.  16/4/18.

Hedge Woundwort (Stachys sylvatica) seems to be scattered and none too prolific in Bexley. Here are two of three shoots coming up in Bursted Woods. There is also a small patch at nearby Barnehurst railway station. The flowers are Beetroot-purple and the leaves unpleasantly scented if crushed. 16/4/18.

The emerging leaves of Poplars in the grassland area give off a strong but pleasant Balsam scent, detectable over a distance. 16/4/18.

Daisies (Bellis perennis), with the northern margin of Bursted Woods on the horizon. 16/4/18.

Chris Rose

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Bexley Natural Environment Forum responds to Parks and open Spaces consult

Whilst Bexley Council’s consultation on the value and use of our  parks and open spaces was primarily aimed at individual residents, Bexley Natural Environment Forum has taken the opportunity to submit a group response (below), addressing the issues of management and the lack of up to date site plans, the scope for enhancing wildlife value, and therefore the need for linkage with a revamped Biodiversity Action Plan, which is now 3 years past the expiry date . It has re-iterated its opposition to open space sell-offs and building on designated Sites of Importance for Nature Conservation, and is concerned that the format of the consultation questionnaire did not provide scope for commenting on these wider – and more controversial – ‘policy’ aspects of the issue. Local wildlife experts in the Borough remain willing to assist the Council on such matters – if it is prepared to listen. 

Download the PDF file .


Thames Road Wetland – a fantastic example of Bexley Council restoring and enhancing biodiversity, sadly offset by a string of planning permissions to destroy high-value nature sites elsewhere in the Borough made over the last 3 years. (Photo: Chris Rose)

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Bexley RSPB walk report – Foots Cray Meadows – Upper College Farm – Five Arches, Tuesday 20th March 2018

Kingfisher, Skylark and an unusual concentration of Jays were highlights of this post-snow walk to the west of Bexley village. Full report from Ralph and Brenda Todd:

Download the PDF file .



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Community Infrastructure Levy spending consult – deadline 5p.m. Fri March 2nd

Bexley Council is consulting on what the priorities should be for spending money obtained from developers who are given planning permissions. The deadline is  5p.m. Fri March 2nd. E-mail views to SP&GTeam@bexley.gov.uk  You may wish to draw on the following suggestions put forward by Bexley Natural Environment Forum. These are somewhat generic, so more proposals about specific local areas, particularly in the north of the Borough – which is being earmarked for most of the extra concrete – would be valuable. Left to its own devices the Council is likely to go for more ‘hard’ infrastructure, so we should argue in favour of enhanced green/blue infrastructure instead. Apologies for not flagging this up until close to the deadline.

Bexley Council’s call for comments is set out at the foot of this post, after the BNEF submission.  This also covers an on-line survey option for responses.

Future state of Bexley … The Council wants ever more building in the Borough, including taller structures and denser arrangements, supported by more ‘infrastructure’ paid for by developer contributions. We need to argue for an emphasis on green/blue ‘infrastructure for wildlife, human well-being and sustainability. 


Bexley Natural Environment Forum, the umbrella group for Friends of parks and open spaces and wildlife conservationists in the Borough.

Chris Rose, Vice-chair.


CiL spending – ‘infrastructure’ priorities response.

Over the past three years Bexley Council has approved building on substantial parts of several Sites of Importance for Nature Conservation and adjacent areas that on objective biodiversity grounds should have been within their boundaries. Bexley’s ‘growth strategy’ sets out plans to build on more SINCs, as well as other open spaces. Meanwhile the general environmental situation worsens, and there is a UK and global biodiversity crisis. At the same time we are recognising the physical and mental health benefits of open spaces and nature.

It is the contention of BNEF that the priority for spending CiL monies should therefore be on protecting and enhancing open spaces for wildlife, for ‘ecosystem service’ provision and health and well-being. Also on measures that will reduce resource use and improve self-reliance and resilience in an increasingly resource-constrained world. These should be implemented in such a way that the less well off are prioritised.

It should be noted that in seeking to improve sites for wildlife, BNEF is not agreeing that Bexley Council’s de facto policy of claiming to protect and enhance biodiversity whilst seeking to cram it into ever less space is either credible or acceptable.



– Money should be spent on implementing more of the Biodiversity Action Plan, which appears to be stalled and is now 2 years out of date. This should follow a review involving local wildlife experts and relevant Friends groups. This would include, for example, the heathland re-creation objective. [Relevant to many parts of the Borough].

– Work with local wildlife experts to identify and map ‘key habitat features’ in the Borough that fall outside of SINCs, but should be protected e.g. key House Sparrow roost hedges. [Relevant to many parts of the Borough].

– The proposal in the Parks and Open Spaces strategy to improve **at least** 15 of them for biodiversity should continue to be implemented, pushing well beyond 15. Some of this is as simple and cheap as cutting less grass and less often …. [Relevant to many parts of the Borough].

– Fund the existing plans for further River Shuttle enhancements/restoration.

– Contribute to the removal of the Vitbe Mill sluice on the River Cray and its replacement with a double rock weir (as proposed by the EA) in order to enable Eel (in serious conservation trouble) and Brown Trout to repopulate the river whilst retaining water levels below Maiden Lane and reducing flood risk. Fish ladders on the weir at Crayford Rough etc. are of little use unless this is done.

– The restoration of tree-planting funding is welcome, but this should be extended to hedges, especially in important areas for House Sparrows e.g. around the rest of the Erith School fields. 

Consider establishing an orchard at Danson Park in the area to the left beyond the Crook Log entrance (opposite the tennis courts and leading to the bowling green) in order to recognise the fruit-growing heritage of the Borough up to the 1930s, and make better use of an under-utilised part of the park.

– Setting up mini-nurseries for native trees and shrubs in under-utilised parts of school fields, using locally-collected seed. This would provide a valuable educational resource as well.

– Produce materials encouraging people not to pave over gardens (increases localised heating, increases water run-off, reduces wildlife and damages the aesthetic qualities of the Borough) and, for example, to improve permeability for Hedgehogs and other ground-living wildlife. See:


This becomes even more important as Bexley Council promotes ‘densification’ and loss of ever more green space, including gardens. Those left should not be car parks.

Money should also be spent on taking enforcement action against those who, having paved over their garden, think that gives them the right to treat the grass verge outside as part of their private driveway, rather than the public asset it is.

[Relevant to many parts of the Borough, but particularly parts that are already more densely ‘developed’ and more grey and sterile].

– Community capacity-building – add wildlife conservation thinking and habitat management training to the horticultural training scheme that was recently instituted, since open spaces managed by Friends groups should be a key part of any biodiversity enhancement work (not just ‘tidying’ things up), and relevant know-how and skills could well be lacking. 

– Run wildlife identification courses and develop the capacity to establish accurate distribution and Borough-wide **population size** data for BAP species so that planning decisions can properly assess whether proposals are consistent with Bexley’s ‘protecting and enhancing biodiversity’ and ‘protected and priority species’ policies. At present it is repeatedly being taken as read that there is no significant impact without any data being produced for a proper Borough level overview or an assessment of cumulative effects.

– Offer subsidised Swift and House Martin nest-boxes/cups to residents in/immediately around the known nesting aggregations, in order to enhance the relevant housing estates, increase engagement with nature and support declining species. [Relevant to several parts of the Borough, including the Chandler’s Drive/West Street area where open space is being sold off for ‘development’, also close to the Erith town centre scheme].


– Fund a demonstration zero-carbon/Passivhaus, car-free house or three in the Borough to push on beyond existing building standards. The existing ‘Core Strategy’ was supposed to identify a site or more for such developments, but nothing appears to have been done about this. Make part of it open to the public so they can see how to make their homes more energy efficient. [Target one of the north of the Borough development areas for this].

– Retrofit buildings with brown roofs to help offset loss of ground-level wildlife habitat and improve insulation.

– If legal (or set up an arms-length body), lease residential roofs, install solar and split the FiT payments with the residents.

– Pump-prime facilities for local re-use of recyclate. Help set up a wood recycling yard, for example. A recycling rate of just over 50% is not good enough. We should be creating local jobs as part of a plan to dramatically improve this.

– Remove excessive hard-surfacing and re-vegetate.

– Deploy (more) camera traps in known fly-tipping grot spots.




London Borough of Bexley

News Release

For Immediate Release

05 February 2018 / PR 10668

Help decide the infrastructure priorities in your area

From today (5 February), the Council is inviting local people to share their views on how to spend the Local Community Infrastructure Fund.

The fund is the local element of the Community Infrastructure Levy (CIL), a charge developers pay to build in the borough. The Council must allocate 15% of the money raised towards improving infrastructure, such as schools and transport, which is needed to support new homes and businesses.

In comparison to other London boroughs, Bexley’s CIL charges are relatively low because development is generally more profitable in other parts of London.

Charging came into effect in April 2015 and since then £1.6 million has been collected, currently leaving £240,000 to spend on infrastructure improvements that are needed in areas being developed.

The fund is split between areas in the borough depending on the level of development. It will only be spent in an area once an appropriate level of funding has been collected.

It is used to provide, improve, replace, operate or maintain infrastructure, or on anything else affected by development demands. It can also be used to contribute towards schemes or strategic projects, normally funded by the wider CIL fund, that clearly benefit neighbourhoods affected by development. 

Cllr Linda Bailey, Cabinet Member for Regeneration and Growth, said: “We’ve already set out a list of suggested priorities, which include improving educational, sports, leisure and health facilities, enhancing open spaces, pavements and pathways, and improving public transport facilities and connections. But we really want to hear from our residents so that we can factor in what matters to them most, so please make sure you have your say.

The survey, which is also available online (www.bexley.gov.uk/communityinfrastructure), will be open until 5pm on Friday 2 March.

Alternatively residents can email SP&GTeam@bexley.gov.uk or write to the Strategic Planning and Growth Team, London Borough of Bexley, Civic Offices, 2 Watling Street, Bexleyheath DA6 7AT.   

A copy of the consultation can be viewed during normal office hours at the Civic Offices or at Bexley libraries.  

Responses will be used to inform how the Council prioritises the spending of its local CIL. Details of CIL collection and spend is reported in the CIL Annual Monitoring Report, which is on the Council website.


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Deadline for ‘London Plan’ responses is 2nd March. Here are suggestions for comments.

The Mayor’s London Plan sets out the framework within which Boroughs are supposed to operate. It is a driver for Bexley’s massive proposed increase in house-building, ‘densification’ and further loss of green space, including designated wildlife sites – though in classic ‘have your cake and eat it’ style it claims otherwise. It is fixated with ever greater consumption of resources, yet claims sustainability and places too much faith in technical fixes to environmental issues rather than the cheaper option of behaviour change. On the pure open spaces side of things, the London Friends of Green Spaces Network believes that the Plan does not give enough protection to our parks and green spaces and calls on people to take action by submitting the following short or longer set of comments:


Dear Supporter,

The Mayor is consulting on his draft London Plan and we are concerned that stronger protections are needed for London’s green spaces.

* Please take a few minutes to respond to the Mayor’s consultation. We’ve made it easy – just email londonplan@london.gov.uk (mailto:londonplan@london.gov.uk)  by 2 March(include name and postcode). A suggested response is set out below.

The London Plan will be the biggest single influence on the future development of our city for many years. Please help us make it as green as possible!



Suggested short response

Dear Consultation Team,

I am writing to respond to the draft London Plan consultation. I am pleased that the draft recognises the importance of green spaces but policies need to be stronger to give them adequate protection, in particular:

* Protecting the Green Belt requires stronger enforcement.

* It should not be possible to ‘swap’ designated Metropolitan Open Land.

* Private and public gardens should be protected alongside other local green and open spaces.

* Policies and funding are needed to improve the quality of green space by reducing noise, light and air pollution, increasing biodiversity, and by giving stronger protection to mature trees and hedgerows.

* Informal and formal outdoor sports facilities, including for ball sports, should be protected and enhanced.

* A more strict approach is needed to reduce reliance on the private car, including reduced parking provision in new developments and promotion of more sustainable transport modes.

* Excessive housing densities in new development should be resisted to protect the local character of London’s neighbourhoods.


Suggested more detailed response if desired: The following more detailed response provides more detail on how draft policies can be amended and improved to deliver these objectives

I welcome Policy G2 and particularly the proposal in Policy G2B that ‘de-designation’ of Green Belt will not be supported. This policy needs to be reinforced for it to be effective. Proposed change:  A presumption against the alteration of Green Belt boundaries which reduce its extent should be included in policy G2B so that it reads: ‘The extension of the Green Belt will be supported and its de-designation will not. We will enforce a presumption against the loss of Green Belt’.

I welcome recognition that Metropolitan Open Land (MOL) should be protected from inappropriate development but this policy is undermined by Policy G3 C and the provision to allow ‘land swaps’ because MOL is characterised by its ‘permanence’.

Proposed changes:  Policy G3 C should be deleted along with the sentence in paragraph 8.3.2 “The principle of land swaps could be applied to MOL where the resulting MOL meets at least one of the criteria set out in part D of this policy”.

Policy G3B should be amended to read: ‘The extension of MOL designations should be undertaken through the Local Plan process, in consultation with the Mayor and adjoining boroughs.’

I am concerned that Policy G4 contains insufficient recognition of the contribution of private gardens to the extent of green space. A policy is needed to prevent extensive ‘garden grabbing’. Proposed change: Policy G4 A should be revised to include reference to private gardens to read: ‘Local green and open spaces, including public and private gardens, should be protected’.

I welcome support for the creation of new areas of accessible green and open space.

These provisions should be strengthened by requiring measures in Policy G4 to improve the quality of green space.

Proposed change

* Policy G4 C – should read “Assessments should identify areas of public green and open space deficiency, including an assessment of deficiency in quality, taking account of Green Flag criteria, noise and air pollution, and using the categorisation set out in Table 8.1 as a benchmark for all the different types required.”

* Policy G4 E 1) should include at the end ‘including an assessment of, and where appropriate a plan, to improve the quality of the space’.

The policy on noise should make explicit reference to the need to reduce the impacts of noise on green space, and other relevant policies amended accordingly. Proposed change: Additions should be made to Policy D13 Noise as follows:

* Para B: Boroughs [etc] should identify and nominate new Quiet Areas and protect existing Quiet Areas in line with the procedure in Defra’s Noise Action Plan for Agglomerations and ensure local green space is improved in line with Policy G4 (as amended) including by:

* taking action to reduce traffic noise around parks which are severely impacted by traffic noise and pollution, using such measures as temporary/weekend street closures and/or permanent re-routing of traffic; or introducing natural or man-made noise barriers.

The provision and improvement of green space requires funding to help deliver the Mayor’s aspirations for ‘good growth’ and increasing London’s green cover and should be addressed in Policy DF1. Proposed change:  Policy DF1 D (2) should be amended to read as follows: ‘Recognise the importance of affordable workspace and culture and leisure facilities, including public green and open space, in delivering good growth.’

The ‘Urban Greening Factor’ outlined in Policy G5 does not address the human use of green space and overlooks qualitative considerations and a wealth of knowledge about how people use green spaces and how design can enhance their experience.

Proposed change: Policy G5 – a further sub-section should be added as follows: (C) Urban greening required and delivered in new developments will be additional to requirements to provide adequate green and open space as set out in G4. New developments must allow for provision of new green and open space in addition to meeting urban greening requirements.

The approach to biodiversity and access to nature outlined in Policy G6 needs to be strengthened to avoid the loss of valuable habitats and wildlife. Proposed change:

Policy G6 – The second sentence in sub-section A of this policy should be deleted, along with the whole of sub-section C.  The following sentence should be added at the start of  sub-section D ‘All new development should seek to achieve a net gain in biodiversity.’

Mature trees are a vital part of London’s green infrastructure and there should be strict controls over felling them in Policy G7, along with recognition of the importance of established hedgerows. Proposed changes:

The value of hedgerows should be recognised in subsection B 1) of Policy 7 by amending it to ‘protect ‘veteran’ trees, mature hedgerows and ancient woodland,,,’.

The first sentence of Policy G7(C) should be amended so it reads as follows:

“Development proposals should ensure that existing trees of quality, mature trees and hedgerows, and trees of value in terms of delivering eco-system services such as water or air quality management, are retained.

Policy SD1 on Opportunity Areas should require sufficient space for the amenities usually provided by parks, in particular playing fields and courts for open air sport. Proposed change: Policy SD1 B(3) should be amended to read ‘plan for and provide the necessary social and other infrastructure to sustain growth, working with infrastructure providers where necessary, and ensuring open and green space is planned to accommodate informal and formal outdoor sports.

A decline in the quality of use of sports facilities is often used as an excuse for allowing development of public open spaces which needs to be addressed in policy S5.

Proposed change: S5 B(4) This should be amended to read: “ensure that there is no net loss of facilities. If there is evidence that ongoing or future demand for sports means facilities are under-used measures should be taken to ensure demand is promoted through a local sports strategy or to repurpose the space for an outdoor sport for which there is demand.”

The plan seeks to further restrict car parking in new development and to reframe the link to PTAL. Allowing excessive car parking in Policy T4 is inconsistent with the main transport policies which seek to reduce car trips. Proposed changes:

* The following amendments should be made to Policy T4(C) – ‘Where appropriate’ should be deleted and Policy T4(D) should be changed to read “..planning permission [DEL: may :DEL]  will be contingent on the provision of necessary public transport and active travel infrastructure.”

* Table 10.3 – The bottom four rows should be amended so that the maximum parking provision in a development in any area (whatever the PTAL) is 0.3 spaces per unit.

* Paragraph 10.4.4 – the word ‘Ideally’ should be deleted and the sentence reworded as follows: “[DEL: Ideally :DEL]  New development of all sizes, but in particular that which will give rise to significant numbers of new trips,should be located in places well-connected with public transport…”

* Policy T6 H: should be amended to read “Boroughs wishing to adopt borough-wide or other area-based car-free policies will be supported. [Delete the outer London caveat sentences.] Minimum standards are not appropriate for residential or non-residential land uses in any part of London.”

We welcome the overarching policy GG2 concerning making the best use of land. This should be strengthened by reference in policy H1 to making use of excessive or redundant road space.

Proposed change: Policy H1 B2d) should be amended to include reference to excessive or redundant road space and other car-related infrastructure so that it reads ‘the redevelopment of surplus utilities and public sector owned sites, including excessive or redundant road space.’

We broadly welcome policies D1 to D6 in the draft London Plan which seek to improve the design and land use efficiency of new housing. We believe policy D6 concerning the optimisation of housing density needs to be amended to avoid a lack of associated public infrastructure, and excessive housing densities and ‘town cramming’.. Proposed changes:   The phrase ‘in exceptional circumstances’ should be deleted from the last sentence in Policy D6B 3) so that it reads ‘This may mean that development is contingent on the provision of necessary infrastructure and public transport services…’. The density levels specified in Policy D6C should be amended to 80, 170 and 260 units per hectare respectively so that it reads: ‘ 1) 80 units per hectare in areas of PTAL 0-1; or 2) 170 units per hectare in areas of PTAL 2 to 3; or 3) 260 units per hectare in areas of PTAL 4 to 6’.

The draft Plan gives insufficient consideration to the protection and enhancement of London’s diverse local character.  Policies D1 and and HC1 need to be amended to ensure that greater attention is given to the character map of London, and community or neighbourhood plans, in planning and designing new development. Proposed changes:

The first sentence of Policy D1 ‘London’s form and characteristics’ should be amended to make specific reference to neighbourhood and community plans so that it reads ‘Development Plans, area-based strategies, neighbourhood and community plans and development proposals should address the following:’  The phrase ‘reflect and enhance local character and distinctiveness’ should be added to the list after 1) in Policy D1A.

The first sentence of Policy HC1 ‘Heritage conservation and growth’ should be revised so that it reads: ‘Boroughs should, in consultation with Historic England, other relevant statutory organisations and local community and neighbourhood planning groups, develop evidence that demonstrates a clear understanding of London’s historic environment, local character and distinctiveness.’



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BRSPB Sidcup Place walk turns up interesting sightings after starting in sunshine and ending in snow

The latest in Bexley RSPB’s series of introductions to our lesser-watched local sites gave attendees the pleasure of seeing Redwings, Fieldfares, Lesser Redpolls and Lapwings. Walk leaders Ralph and Brenda Todd provide a full report:

Download the PDF file .




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