Maiden Lane development by the River Cray – chance to comment

A planning application has been submitted for housing right next to the River Cray, a Site of Metropolitan Importance for Nature Conservation and a key wildlife corridor supporting protected species. The deadline for comments and objections is Monday 10th June 2019. Whilst the site has previously been used for industrial purposes and the developer has listened to some of the comments about biodiversity made to its own public consulatation, several grounds for concern remain, and readers are encouraged to submit their views on these matters. A sample submission is provided below. Despite the fact the developer tries to play the effects down, most people will agree that putting up a four-storey apartment block – and a number of other dwellings – very close to the river, is going to have a lasting and very negative impact on the countryside feel of the Cray and its environs downstream of Maiden Lane bridge. The ecology survey included only one day of fieldwork, in the middle of January 2018, and is consequently poor to lacking in important detail. The carbon emissions and car use considerations of any new development are also increasingly important.

(Above: developer’s own artist’s impression of its proposed four storey building right next to the River Cray bank).

The planning application, reference 19/00941/FULM, is for the demolition of existing buildings, rebuilding of the existing Barn to provide 35 residential units (Use Class C3) as Affordable Homes (Shared Ownership and Affordable Rent) comprising 22 x 2 bed flats, 1 x 2 bed house, 7 x 3 bed houses and 5 x 4 bed houses and provision of car parking, cycle parking, landscaping and associated infrastructure.

Comments can be sent to DevelopmentControl@bexley.gov.uk Include the application reference number in the subject line. Or you can register to comment online. Detailed documentation about the plans can be found here:

https://pa.bexley.gov.uk/online-applications/applicationDetails.do?activeTab=documents&keyVal=PPZSYZBEFMR00

Bexley Natural Environment Forum is submitting comments on this application, but the more people do so the better. While the BNEF document is awaited, this personal submission provides a ‘crib’ for the sorts of things that those who follow ‘Bexley Wildlife’ might want to look at:

COMMENTS ON PLANNING APPLICATION 19/00941/FULM

BELLWAY LONDON PARTNERSHIPS. PROPOSED MAIDEN LANE, CRAYFORD, DEVELOPMENT.

Chris Rose BSc (Hons), MSc.

15 Thirlmere Rd, Barnehurst, DA7 6PU. chrisrose@gn.apc.org

My personal interests/expertise are that I volunteer with Thames21 along the River, managing habitat and clearing litter/fly-tipping and I am volunteer Site Manager of Thames Road Wetland at the other end of By-way 105. I have done considerable amounts of wildlife recording in these and other parts of Bexley.

My views and concerns about this proposal are as follows:

CLIMATE/ENERGY/SUSTAINABILITY

• There is a climate crisis. A number of local authorities have started passing motions to this effect. The UK has a problem with the massive stock of existing, very energy inefficient housing. We should not be adding a further anchor-drag to the business of cutting emissions harder and faster by building any more net emitters. All developments in the Borough should henceforth be zero carbon. The developer presents a far less ambitious target.

• I am pleased to see a commitment to solar panels which appeared to be lacking in the developer’s own public consultation exercise.

• Given that the site is adjacent to a Site of Metropolitan Importance for Nature Conservation and an important and designated wildlife corridor, the lack of green/brown/living roofing is disappointing and out of kilter with the Council’s ‘direction of travel’ on ‘green infrastructure’ as detailed in its emerging ‘Preferred policies’ document. There is no statement to suggest that all available roof space will be covered in solar panels, indeed it appears to be the case that apartment block panels would have to be raised up on frames to achieve optimum angles to the sun.

CAR DEPENDENCY

• Even Bexley Council (in its recent ‘growth strategy’ and Preferred policies documents) now recognises that cars are a serious land-use issue. At most there should be just a few car-parking spaces for visitors and none for residents unless for properties specifically designed for disabled users. This site is a modest walk to a railway station and close to several main bus routes. Given that the developer proposes 46 non-disabled car parking spaces it could probably fit in a few more houses if they scrapped those. I very much doubt that there aren’t enough potential purchasers of a car-free home in Bexley, London or the UK to fill up the proposed amount of accommodation. The dynamic around the assumption that we will carry on being dependent on personally-owned cars needs to be changed. Even the car industry can see the writing on the wall on this.  

BIODIVERSITY

• The Ecological Report refers to an ‘initial’ walkover on 31/1/2018 but as far as can be ascertained this was the only date any fieldwork was done, which is exceptionally poor  and unacceptable. It is no surprise that most of the bird species that use the area were not identified, that reptiles and amphibians were not found or adequately surveyed for, that no Bat detector work was done to assess the importance of the river corridor for Bat foraging and that no invertebrate surveying was done.

• The reality is that this By-way 105 part of the Cray is a known Bat foraging corridor. I have had them flying around my head along the by-way before. I am extremely concerned about the proximity of the proposed housing to the river and its orientation in respect of light spillage. The Ecological Management Plan implies no light spillage beyond the development site boundary, which I find impossible to believe, and whilst the Energy and Sustainability document talks about sound insulation, it doesn’t say anything about stopping light escape.  There is also the key issue of the spectrum of lighting used. This at least has ben recognised. There has been research done on this with amber lighting shown to be more bat-friendly. Negative impacts on Moths have also been found. Macro-moths are in serios decline, particularly in south-east England.  On summer evenings you are also going to get noise pollution of a usually tranquil area from open windows.

• In this regard it would be better to set buildings back against the northern margin of the site, rather than close to the river.

• It is stated that a Water Vole survey was done and that there were no signs of any. In the absence of evidence to the contrary, it has to be assumed that this too was only done on 31/1/2018, when the river would have been high due to winter rain and this fact, plus direct rain effects, are more likely to have washed away Water Vole field signs. There are Water Voles along By-way 105. I have seen them since the 2003 record date mentioned. I saw one at Thames Road Wetland on 28/2/19. They have been found along the Cray as far as Ruxley Gravel pits at least with a feeding station photographed at the latter location earlier this year. I would be very surprised and alarmed if they had suddenly vanished from along 105.

• Bexley usually imposes a 5m buffer for Water Vole. The diagram in the Ecol Man Plan indicates different planting plans for different width ‘buffer zones’, but it is not clear to what extent this width might be compromised by existing or proposed buildings. It should be Bexley’s ‘standard’ 5m wherever there are no existing buildings, and ideally more than that. It is not entirely clear whether the developer’s ‘buffer zone’ includes its unspecified ‘ground cover’ shrubs, which may not provide suitable Water Vole habitat. The whole width of any ‘buffer zone’ should provide suitable habitat for Water Voles and other native species currently occupying this stretch of the river.

• The suggested provision to residents of information about wildlife sensitivity and appropriate responses to that is welcome, as are references to wildlife-permeable fencing, but the latter makes it even more important  that steps are taken to prevent domestic cats that new residents may bring in catching and killing the protected species of Water Voles and Grass Snakes along the riverbank. There is no reference to how this is going to be achieved

• I welcome the fact that proposed cutting back overhanging trees along the river, even though they are not adjacent to the site, has been left out of the formal planning application. The stated reason for this was to allow local residents on Barnes Cray Road to go down the river in their boats. The reality is that no one goes boating down there as in winter you have to lie down in the boat to get under Maiden Lane Road bridge, and in summer the water level is often below that of the top of the array of rocks under the bridge. Thames21 already does some selective pruning so we that can get our boat down the river for removing litter, and this does indeed necessitate lying flat on/amongst the pile of accumulated rubbish in the boat on the way back up to our yard. There is far too much of the wrong sort of ‘tidying’ of the local environment and I do not support the idea of corporate interests sending in the chainsaws.

• I am disappointed to see continued reference ‘strengthening’ the riverbank vegetation with additional ‘planting’. In my view – as pointed out in the response I wrote to the developer’s own consultation, there is no need for this, and a proper appreciation of local ecology seems to be lacking. There is already a lot of Sedge, of Lesser Reedmace (the less common of the two Typhas on the Cray) and a nice swathe of Marsh Marigold adjacent to the proposed development site.

River-side vegetation will soon fill any bare areas, providing material of local provenance without the developer having to do it (though the fact they are now talking about using plants of local provenance at all indicates some progress in their thinking ….). As I said before, if the applicant wants to do something useful regarding vegetation on the lower Cray it should forget about ‘planting’, and instead help bash the Himalayan Balsam that has now got a foothold here, and the Giant Hogweed on the other side of the river opposite its land – and/or encourage residents to join Thames21 in doing so.  

• As Biodiversity Officer of the Bexley Federation of Allotment and Leisure Gardeners I have surveyed almost all the allotment sites in the Borough for reptiles and amphibians. Grass Snakes and ‘Common’ Toads, both Biodiversity Action Plan species (which kinds of species the existing Core Strategy specifically says it wants to conserve), and considered to be in decline, are present on the adjacent Crayford Way allotment site. It is likely from what plot-holders have said that Grass Snakes breed here. No feature of the development, including for any emergency-only vehicle access at the eastern end of the site, should compromise the ability of Snakes to commute between the river and the allotments, but instead should improve connectivity.

• Installation of Bat boxes on buildings would be appropriate, but could be compromised by the wrong sort of lighting regime. In respect of the proposal for bird next boxes, House Martin nest cups should be installed, and Swift nest boxes and if practical (Swifts need a clear 5m drop and Swift call ‘lures’ should be used to bring them in). Both species forage around the river and there is a modest House Martin nesting colony not too far away at Sherwood Crescent by Perry Street Farm. I was told third hand some time ago that there had once been HM nesting on Maiden Lane, but I have seen no formal records of this nor have I seen any doing so over the last decade.

VISUAL IMPACT

• The countryside feel of this part of the river will be destroyed by this development, if it is approved. The key consideration is the effect on the view from the London Loop/By-way 105 and I do not agree with the ’objective’ assessment of the Landscape and Visual effects document that the impact will subside from moderate to adverse in year one to moderate to neutral in year 15. The 4 storey apartment block is too large/tall and close to the riverbank to be acceptable and will hugely and permanently alter the character of the area to something more akin to walking along a central London canal edged by tall new-build or warehouse conversions. Visual character will be important not just to locals but to the many people who use By-way 105 as part of various long-distance footpath walking routes.

ENDS.

Chris Rose.