[In the interests of transparency, I like to say that until yesterday I was an employee of Croydon Council as a commissioner of children’s health services and my work had no links to the planning department]

Last Friday, my other half and I cycled to the Hutchinson Bank reserve, managed on behalf of Croydon Council by the London Wildlife Trust, as part of my 30 days wild challenge. It’s a lovely mixed chalk grassland and woodland site, well-known for supporting a large number of butterfly species including rare Brown Hairstreaks and Small Blues, Glanville Fritillaries and Grizzled and Dingy Skippers which are all Section 41 “species of principal importance” under the 2006 Natural Environment and Rural Communities Act.

While we were there, we read information about an ongoing planning issue and I looked it up when we got home.

The facts as I understand them are as follows.

On the 24th of March 2020, a planning application was submitted to Croydon Council to build a four story building of eleven flats on a scrubland area 70 metres from the Hutchinson’s Bank nature reserve. As of today, 165 public comments on the proposal had been received, of which 163 objected, 1 was neutral to and 1 supported the proposal.

The status of the application is shown as awaiting decision. The next meeting of the Planning Committee is on the 18th of June but the agenda won’t be published until 11th of June so it’s not clear whether this application will be considered then or whether there will be a longer delay. I am about to send a Freedom of Information request asking this and what actions the Council anticipates taking place between now and the proposal being considered.

Croydon Council is the main shareholder of the the development company, Brick by Brick, and have read but not validated that the Council’s planning committee has never turned down a Brick by Brick application.

In support of the planning application, Brick by Brick commissioned FOA Ecology to carry out a Biodiversity Survey Report. FOA Ecology’s report says that the site was visited twice by an “suitably experienced ecologist”, once on the 1st of November 2019 and then on the 3rd of December 2019. Given the time of year, it’s perhaps unsurprising that the survey makes no reference to butterflies but nor does it refer to the easily accessible records of butterfly transects carried out in 2019.

The FOA Ecology report makes a number of recommendations, which I believe most importantly include carrying out before tree-felling or works: bat, badger, dormouse, reptile and Roman snail surveys. There are no recommendations to other invertebrates, with the exception of building a loggery for stag beetles.

London Wildlife Trust were not officially consulted despite managing the nearby reserve.

In London Wildlife Trust’s position statement , its view is “There is unlikely to be any direct impact from the building onto Hutchinson’s Bank nature reserve” but…

  • “There is loss of (common) habitat on site that may support brown hairstreak butterfly (which can be found at Hutchinson’s Bank), a Species of Principal Importance which was not surveyed for as part of the ecology report accompanying the application;
  • Consequently there is no indication of how loss of this on-site habitat would be mitigated or compensated for to ensure no net loss of breeding habitat for this butterfly;
  • The landscaping enhancement for the proposal does not take enough account of the local ecological character or provide details on the site’s future management”.

LWT offers in this position statement to work with the development company to redesign the proposal to minimise impacts and create new butterfly habitats.

Back in March/April, a large number of concerns were raised including from high profile conservation supporters like Patrick Barkham and Iolo Williams. So it’s surprising that only 163 objections were received. I’m going to tweet about this to encourage more responses to the proposal.

I have very little experience or knowledge of development and planning, but my worry is that with lockdown arrangements for the Council’s Planning Committee, the attention has moved on and this proposal could be approved leaving responsibility for going about this in a way that is sensitive to biodiversity in the hands of the developer. I’m going to keep an eye on Committee agendas to see when it’s going forward.