In your own words – SNAVers defend public green space and urban woodlands

The following comments were submitted to Southwark’s planning application website, in defense of the small woodland located between Lomond Grove and Brisbane Street, in Camberwell. Thank you all for speaking up. Keep up the great work!

Comment submitted date: Thu 30 Sep 2021
Protecting open spaces in a dense urban environment is part of the measures we
can take to combat climate change. Further, it is vital to consider the impact on
the environment for residents of Southwark who need open spaces to combat
local pollution.

Comment submitted date: Fri 20 Aug 2021
Given the previous 18+ months whereby we have realised the necessity of green
space in the urban areas we live, the destruction of mature green space is bitterly
disappointing. If we have learnt nothing in the last year it is the wonders of
having green sanctuaries to be able to clear our minds, not to mention the
countless benefits trees and wild areas have on our ecosystem.
Southwark have made great progress recently in encouraging controlled areas of
land to be re-wilded in order to encourage nature to thrive. With a single stroke
this would reverse all of the gains that have been made the last couple of years.
The plot of land itself is tiny and hemmed in on 3 sides, one of them being a
factory and the open side being a busy road. Building more apartments in such a
small plot of land will put even more of a burden on the local area than already
exists with even more cars and traffic on the roads.
The development also also gives no thoughts to the neighbours who live nearby
and will have to put up with the loud building works during construction and
then the increase in noise of having an additional 20+ flats living in incredibly
close proximity. I believe that the building of these flats will have a hugely
detrimental effect on the quality of life for people like myself who won’t even be
able to open a window due to the increase amount of noise.
The plans also talk about building a play area on the Caspian Street side. I fear
this is a token attempt to position the development in a positive light to residents
in order to glaze over the damage being done. Given the removal of multiple
trees I welcome the planting of further plants and trees on the Caspian side but
don’t believe a further play are is needed. There is a very large play area 40
meters away in the Burgess Park Woodland Play Area. Given the amount of noise
a children’s play area would make right outside countless residential flats I think
this would be a detriment to the local area. It would be far smarter to turn this

into a nature area to offset the damage done by destroying the piece of land the
development will be on.
I believe this is a very poorly thought through plan by people who have no links
with the area and see an opportunity to cram housing into a totally unsuitable

Comment submitted date: Wed 01 Sep 2021
I am appalled that in this time of climate emergency the council propose cutting
down mature trees to build on a space which should be cared for as a public
nature reserve.
The destruction of this green space would also have a detrimental effect on the
mental health of those living next to it.
There must be a better solution for fulfilling the accommodation needs in
I oppose this application.

Comment submitted date: Mon 23 Aug 2021
This is yet another development that is incompatible with Southwark Council’s
declaration of a Climate Emergency.
As such, I oppose it.

Comment submitted date: Mon 19 Jul 2021
I find rather ridiculous that even though the ecological importance of the lot, a
better solution couldn’t be found. I also find preposterous that trees will be cut
after a promise to plant new ones as if the objective was to keep the number of
trees the same instead of increasing it. Losing this small but fundamental piece of
nature would be a shame, especially considering other redevelopment projects
are being carried on in the nearby Elis laundry factory and the Edmundson
Electrical, making green areas such as these even more important to protect. Not
to mention how dangerous this project would be considering the estate would be
located on a critical drainage area, making it more prone to flooding.
Please reconsider this project and protect this area.

Comment submitted date: Mon 19 Jul 2021
My thoughts are against the application for new homes on Lomond Grove,
Elmington estate. It will give residents like myself no privacy, restrictions of
lighting coming into the property and also destroying the current wildlife and
habitats which then becomes a danger to the environment. Also, cutting down
the trees isn’t exactly environmental friendly.
I would prefer a communal garden is put in place instead as it is more
environmental friendly and still allows residence to have their privacy and does
not restrict lighting from coming into the properties.
It is unfair that residence have not really been given the chance to put out their

opinion about the potential planning and I know most of us are in agreement
about not having new homes built.
It is said the Southwark are planning to re-develop the now closed Camberwell
magistrates court which is a big enough space for more homes to be built
without affecting the environment so, it doesn’t make sense to build an extra 22
homes on the little piece of land behind Brisbane Street.
If this development was to have a communal nature garden developed instead
this would be much better as those without gardens will be able to use a
communal nature garden appropriately. Also, since Covid-19 has been around
many individuals have been suffering with their mental health as well as their
physical health. By building a communal nature garden will help ease the
difficulties individuals have been facing since Covid and even after the affects of
covid subside. It will allow someone who has been struggling with their mental
health to be able to breath and bring themselves together if ever they feel being
at home for a while is too much. Those who have a physical health issue will be
able to use the garden especially with it being more convenient to them as they
will not have to travel too far just to get a bit of fresh air.
Having a communal nature garden would be perfect for educational purposes.
There are many schools in and around the camberwell area that would really
benefit from this. Learning about the environment and having this garden there
for school children to see would be an amazing experience for them especially
during the younger years (3- 11).
Another point is the cutting down of trees. This will destroy many habitats for
the local wildlife which is actually needed more than ever since the majority of
London is trying to become more greener. Not only that trees are what we need
to breath, they help us and we help them. Many trees have been cut down over
the years for new homes to be built and this has not benefited us in any way.
More than 26 million hectares of trees a year were lost on average between 2014
and 2018, a 43 per cent rise compared with the period 2001-2013.
Due to the current climate emergency cutting down trees will not be in support
of this which will make it even longer for us as a country to meet our goal. We
need to be leading by example!
Going on to a more personal level which is the privacy concern I am even more
against this. For example, we have a room occupied downstairs in our home with
the outside view from the window being our garden. If new homes are built this
increases the risks of peeping toms which does not create boundaries between
us and our neighbours. It also would feel like less security for my home and this
is most definitely needed within a physical space. The main point is that privacy
is important! This also relates back to those who suffer with their mental health.
Sometimes, privacy is needed to help aid our mental health if it is suffering.

I really hope with the points expressed above the plans you have for the new
homes on Lomond Grove are carefully considered and that the plan does not go

Comment submitted date: Sun 18 Jul 2021
This development will be hugely damaging to the local area, and to quality of life
for existing residents.
The majority of people in this area live in flats, and those of us in older buildings
are in flats with no outside space or balconies. This past year has shown how
invaluable local green space is, and being able to see tree tops from my window
has been a true joy that has helped me to manage the anxiety and frustration of
spending so much time at home. This development will take away both the views
of trees and the utility of a public green space closest to my home.
These trees are also an important part of Southwark’s ecosystem, with several
birds nests that are returned to year on year, squirrels, and other animals.
I have heard project representatives say that this area of woodland is not well
used and so would not be missed. This is not true; as I describe above, they are
the thing that made me want to move to my flat and live in this area.
Furthermore, the area was walled in several years ago and rarely maintained, so
of course litter etc. accumulated. A better use would be to open it up, combine it
with the green space, and create a well managed park, along the lines of the
nearby Benhill Road Nature Garden. The pocket park is too small, and completely
inadequate compensation for the public green space that will be lost.
The proposal details that some trees will be planted elsewhere as part of the
project, but not as many as will be lost, and elsewhere, so there will be an even
greater loss for those of us on Lomond Grove. This is both unfair, and out of line
with the council’s tree planting and preservation commitments.
The building is also too tall, dwarfing neighbours such as Chester Court. The
neighbouring Bellway development has meant that where I had light open views
from my kitchen, I now look directly into someone else’s flat, to the point where I
can tell you what pattern they have on their bed linen and what make of TV they
own. This proposal is threatening the one open view that we have left.
There are also several other developments planned nearby. The development at
the magistrate’s court in particular will cause massive inconvenience for local
residents, and having multiple such projects, especially while so many of us
continue to work from home, will cause huge disruption. This development will
cause huge loss and disruption for an extremely small gain in terms of new
Finally, traffic networks are already stretched beyond capacity. We don’t have

Boris Bikes. Walworth Road is so congested that buses, themselves stuffed to
capacity, crawl along. If more homes are being created, there must be a
corresponding increase in capacity for these people to get to work and travel.
Camberwell station needs to be reopened as soon as possible.

Comment submitted date: Sun 18 Jul 2021
The council should engage with the local community and existing residents.
Giving access back to this section of land as a well needed green area of beauty
and amenity. Destroying over 20 mature trees would be a crime, not only to the
environment (which the council currently has commitments to) but also to the
added risk of flooding and loss of enjoyment and amenity. Please put a halt to
removing this green space before it is too late! A plan to best manage the area
with access plans etc should be a solution, not this.

Comment submitted date: Sat 17 Jul 2021
It would be a real shame to destroy the existing small woodland area with
mature trees, especially at a time when Southwark is supposed to be addressing
the climate emergency and air pollution. Trees are so important to counter
pollution and being near green spaces is really good for residents mental health.
The woodland should be reopened instead. Of course new social housing is
needed but this should be achieved by mandating inclusion on new
developments, not by destroying woodland.

Comment submitted date: Sat 17 Jul 2021
Outrageous to propose building over an ecological site. Access was originally in
the tenancy agreement of the council building that backs onto it. Removed for
some probably lazy reason some point previous. However this doesnt change
that the ground has become a wildlife sanctuary, and should be saved. The land
should be managed and open to the tenants as was originally stated. How mean
to take it away and then act like its unused space. This is also another example of
southwark council infilling council housing to meet their quota. After selling off
land for years for luxury housing they will now squeeze more buildings into
already overcrowded council estates. After the pandemic surely the need for
open and green space is priority. This development should also be taken into
account with all the other developments in the area around burgess park, which
threaten to damage the local areas of woodland that will surround and inhabit
them. I pity the poor residents who will have to see their woodland cut down, the
years of building work within their own backgardens and the loss of privacy that
will follow through the years. I also pity incredibly the wildlife that call it home
already, how is this legal?

Comment submitted date: Sat 17 Jul 2021
I don’t think it’s fair to sacrifice green areas / precious woodland in order to
build flats.
The green areas should be protected, and access to them should be allowed and
encouraged for the residents of the surrounding estates, especially ones that
don’t have access to gardens.

The benefits of access to the green areas for residents are long lasting and vital,
both in terms of physical health but also mental health.
Destroying the woodland would also pose environmental risks, increased flood
risk, loss of habitat for wildlife etc.

Comment submitted date: Sat 17 Jul 2021
I object to cutting down of trees in this mini woodland on Lomond Grove which
provides significant amenity value for local residents. It has significant green
amenity value for the area.
In developing the site proposals there seemed to be no attempt to retain the
woodland as an option, the woodland could provide play and amenity space for
the development and the wider estate.
The proposals were initially developed some years ago and do not adequately
respond to the Councils Climate Emergency strategy and action plan which seeks
to support: “A Thriving Natural Environment for the maintenance and security of
the borough’s natural environment e.g. increasing tree canopy coverage… and
any loss of existing trees cover is a last resort… Enable building and development
that works alongside and enhances our natural environment”. The Climate
Emergency action plan has the specific target to deliver: Tree coverage is
maintained and increased. With planned actions to map key green spaces, SINCs
and soil carbon stocks which store CO2 in the borough.
The need to increase tree cover and the council’s tree planting plans will not be
achieved if existing trees are being cut down.
The planning policies on biodiversity and protection of trees need to be given the
strongest consideration in assessing this application which needs to be given
sufficient attention in the decision making process.
The NPPF, the London Plan policies on trees make them a material consideration
which needs to be fully addressed and the basis for rejecting this application. The
new Southwark Plan policy Trees P60 includes: Development must retain and
enhance the borough’s trees and canopy cover.
It is not necessary to cut these trees down (or as many) if a different approach
had been taken to the site assessment and options for design and strengths of the
site. From the Design and Access statement there is no indication that this was
an option despite the feedback from residents that they wanted green space and
trees retained.
It is not clear why this land has been fenced off and this amenity space lost to
residents. It must have been part of the green space on the estate for use of
residents originally. The planning statement and design and access statement do
not provide sufficient information about the previous site history and how it has
been locked and fenced off. If this was amenity, garden space then residents in
flats have lost out over the last 20 years.
The replacement tree planting based on canopy cover and CAVAT value
completely ignore the pressing need to retain existing trees.
The Urban Greening Factor calculation achieving the minimum is welcome but

does not consider the green natural capital lost from the site. Should this not be
part of the calculation?
I support the proposals to enhance the street trees by extending the pavement,
the improved planting and the expansion and improvement of the existing play

Comment submitted date: Thurs 15 Jul 2021
My objection is for several reasons firstly this area of land is the last green space
in this road and is a habitat for many wild animals and plants. It is also widely
used by the community effectively as a garden, the majority of the dwellings in
the road are flats with no gardens of their own, this was a much used life line
during the recent lockdowns. I think there is a great opportunity here to create a
great open space for the surrounding community.
Secondly the height of the proposed flats does not fit in with the other
surrounding buildings, however your planners try and dress it up. The
Elmington Green development went a storey over what was first planned ,
seemingly with no penalty.
Which leads me to the near continuous development in this area over the last 8
years. Piper court and the huge development the other side of Broome way, all of
which has created a deeply unpleasant environment to live in. Piper courts
outside walls had to be stripped down and rebuilt because they had been built so
badly and the Elmington green development used Broome way as a overflow to
their building site. Storing materials in a unstable and dangerous manner(I have
photos), when questioned about this they would become aggressive and
threatening. Southwark council just wasted their hands of this saying it wasn’t
their site. This is not an acceptable way to expect people to live.
Lastly why have you just laid new paving the length of Lomond Grove if your
planning all this building work, what a waste of our money.
Whilst I understand the need for new homes this road has been very developed
also with the prospect of the redevelopment of the magistrates courts at the other
end of the grove more than ever this remaining green space should be preserved
for the good of the surrounding community.

Comment submitted date: Tues 13 Jul 2021
Dear Planning Officials,
As a Southwark resident I object to this proposed development.
The following are quotes from A London Councils Member briefing

Valuing London’s Parks and Green Spaces Overview February 2018:
‘The urban heat island effect means cities and urban areas are significantly
warmer than surrounding rural areas. Green areas within cities can help reduce
this effect, countering high summer temperatures, which helps combat
associated ill health. There are also benefits from carbon storage, with 3.1
million tonnes of
carbon held in London’s trees, giving an estimated benefit of £8 million per year.’

‘Twenty nine per cent of London’s public green spaces are parks. However, parks
are not spread uniformly across the capital; with outer boroughs typically having
a higher percentage of parks compared to inner London boroughs. The benefits
and expenditure therefore varies across London. The natural capital accounts
found that, in areas where there are plentiful green spaces, individual parks are
less valued compared to those in areas with limited public green spaces’.
Thank you very much for taking the time to consider these objections. I am afraid
however that all our voices will be heard but ultimately ignored.
Comment submitted date: Wed 07 Jul 2021
As a part II, architectural assistant it really saddens me to see the priorities of
new builds in areas during our time. Despite the overwhelming amount of
information available which attests to benefits of wildlife flourishment in our
cities, new buildings tend to push this agenda to one side. It would be a shame to
see a pocket of this neighbourhood’s ecology being lost to another set of
developments which aren’t actually needed. The loss of this green space has
larger irreversible loss to the diversity of our communities that isn’t being
account for or synced correctly in these new plans.
Comment submitted date: Tue 06 Jul 2021
A few simple objections:
1 – What will become of the trees?
2 – the site is too small
3 – the last council led development on lomond Grove was a nightmare
4 – if approved, the land outside Pope House should not be used as a site office –
was a large nuisance last time.

Comment submitted date: Mon 05 Jul 2021
Thank you for giving people the chance to voice their opinions regarding this
proposed project, and have some influence as to whether it goes forward or not. I
oppose this project because it is very much in the wrong location, for several
First of all, in this time of climate and biodiversity crisis, it is simply unacceptable
to cut down 20-30 mature trees, and destroy a rare urban woodland ecosystem.
It goes against the council’s own Biodiversity Action Plan, which commits to
enhancing biodiversity.
Furthermore, this site is strategically located between Camberwell’s main
biodiversity resources, Brunswick Park, Benhill Road Nature Garden,
Camberwell Green and Burgess Park, and is a key part of the new Camberwell
Green Corridor, and as such provides an important stepping stone between the
parks, increasing the resilience of wildlife populations. If Southwark is serious
about protecting its biodiversity and allowing people to experience nature, it
cannot be locking up and destroying the precious few scraps of mature
woodland where our birds and foxes have managed to find homes and resources.

This location is also within a Critical Drainage Area, as identified within the
Southwark Strategic Flood Risk Assessment. A mature tree can absorb a huge
amount of water through its roots every day– the retention of trees is a vital part
of flood risk management. To protect its residents, Southwark should be
increasing localised surface treatment and storage of flood waters such as that
already provided for free by this woodland — not destroying them. We can
expect increased flooding due to the climate emergency.
The National Planning Policy Framework states: “Planning policies and decisions
should contribute to and enhance the natural and local environment.” The 2021
London Plan Policy G7 Trees and Woodlands states: “The Mayor wants to
increase tree canopy cover in London by 10 per cent by 2050.” In 2019
Southwark Council committed to planting 10,000 new trees by 2022 and being
carbon neutral by 2030. This project violates all three of these policy aims.
Obviously, tree cover obviously cannot increase unless existing trees are
retained — and beyond that, a decades-old, mature or semi-mature tree is worth
exponentially more in terms of carbon stored, biodiversity supported, shade
provided, and flood water absorbed, than a newly planted one.
So while I support any project that provides good social housing, I strongly
oppose the siting of this one, for all the reasons mentioned above. Southwark
must be aware that there are several nearby sites which would be much more
appropriate to re-develop as social housing, and which would not necessitate
destruction of residents’ green space and animals’ lifelines. These include (1) the
Elis industrial laundry facility next door, which has long been a danger and a
hazard to local residents, driving heavy duty lorries on the pavement and
dumping toxic waste in the unclaimed land on Brisbane Street, just adjacent to
where residents have planted a small wildlife garden as part of the green
corridor. (2) the small brick warehouse on Jago Walk, which presents a blank
brick wall to the community and seems to contribute nothing? and (3) the
currently vacant magistrate’s court next to the library.
I am a nearby resident and walk past this woodland at least once per week. I can
hear the birds singing and always wish it could be opened up so people could
walk beneath the trees. Please, Southwark, don’t destroy one of the few urban
woodlands in this area, which has taken decades to develop – open it up, cherish
it, and maintain it safely as a resource for nature.
Comment submitted date: Sat 03 Jul 2021
My son attends special needs Orchard Hill College on Lomond Grove. He and his
disabled peers often access the local community, often in wheelchairs. There
needs to be more open, accessible green space and less pollution in this area for
the health and wellbeing of the students and staff at the college and for local

Comment submitted date: Fri 02 Jul 2021

Dear Sir/Madam,
I have been living on Elmington Estate for over 10 years. I am highly concerned
for the proposed plan to build new council homes behind Brisbane Street. This
location of woodland is home to local biodiversity including wildlife such as 20
mature trees – some of which are occupied by squirrels and birds, plants and
foxes (protected wildlife). You have mentioned that is is ‘unused’ which is false.
It is in fact used by our local wildlife as mentioned above. Female foxes have
periods where they use these local woodlands as dens when they are due to give
birth to Cubs. Destroying the home of local wildlife would give you the
reputation of cruelty towards animals. I do hope you wouldn’t cause unnecessary
suffering to animals. We should be attempting to protect our local wildlife not
destroy their homes. Additionally, Southwark Council has a climate emergency
declaration which was made in March 2019. One of the key points in this
declaration is “protecting Southwark’s biodiversity.” Your plan to build in this
used woodland contradicts your declaration.
Thank you for your time and consideration.
Elmington Estate Resident and Elmington Community Gardens Volunteer

Comment submitted date: Thu 01 Jul 2021
I am really worried about this plan to build new council homes behind Brisbane
Street on Lomond Grove. This location is the home to our local wildlife such as
trees, plants and foxes. It is not ‘unused’. We should be attempting to protect our
local wildlife not ruin it. On top of that, Southwark Council has a climate
emergency declaration which was made in March 2019. One of the key points in
this declaration is “protecting Southwark’s biodiversity.” Your plan to build in
this used woodland goes against this. I also want to mention that we already
have high traffic of cars and other large vehicles on Brisbane Street as well as
Lomond Grove. A few residents and myself have recorded incidents of parking
breaches and health and safety risks on both of these streets as careless drivers
manoeuvre around the areas. Adding more properties would probably increase
the number of traffic and vehicles adding more to existing issues.
We live here and so we have a lived experience of what it is like around here. I
don’t think this plan would benefit us at all. I appreciate more council homes are
needed but not here! I live in a block of flats on the first floor and taking walks
around the estate in our small local green areas really helped with my mental
health when I needed a space to breath during the pandemic. It would be
gratefully appreciated if we could have access to all of the local green spaces.
Best wishes,
Elmington Estate Resident
Comment submitted date: Thu 01 Jul 2021

Dear Sir/Madam,
As a resident of Elmington Estate and community member; I am worried and
against the proposal and plan to build council homes on Lomond Grove. The area
where you plan to build on is one of the biggest biodiversity homes including
wildlife such as trees, squirrels, birds and foxes. You have mentioned that it is
‘unused’ which is not true. It is actually used by our local wildlife as mentioned
before. This is where our resident female foxes give birth to their cubs each year.
I know this because I have a lived experience of the estate and I do nature
watching. It would be disheartening if Southwark Council were responsible for
destroying the homes of our local wildlife and causing unnecessary suffering. We
should protect our local wildlife not destroy it. Southwark Council made
a climate emergency declaration in March 2019. One of the key points is
“protecting Southwark’s biodiversity.” Your plan to build in this used woodland
contradicts your declaration. During this worldwide pandemic which is causing
difficulties with breathing if an individual contracts COVID-19; getting rid of 20
mature trees that help provide oxygen is controversial and unacceptable. At this
address, I am support Elmington Community Gardens – a voluntary group,
supported by Southwark Council, set up to save local green areas by litter
picking, creating wildlife gardens, creating food growing and encouraging
community spaces. ECG have been working very hard to save and improve our
local green spaces.

Comment submitted date: Thu 01 Jul 2021
Southwark Nature Action Volunteers oppose this application, which is located in
an area that Southwark Council acknowledges to be “strategically important
from an ecological point of view, forming part of a green corridor stretching from
Burgess Park to Camberwell Green” (Elmington SuDS Retrofit and
Environmental Improvement Scheme – Project brief, p4). The proposed
development would destroy at least 20 mature or semi-mature trees, forming an
urban woodland, which is an important link in the above-mentioned green
corridor. As such it is not policy compliant with the council’s own Biodiversity
Action Plan, which commits to enhancing biodiversity and states: “In Southwark
the mosaic of parks, open spaces, gardens and green infrastructure linked by
wildlife corridors provides the opportunity for wildlife to flourish and for all to
experience nature.” Bird and bat boxes and bug hotels included in the
landscaping of the proposed new development will not deliver the required net
gains in biodiversity.
The National Planning Policy Framework takes a robust approach to protecting
and enhancing the natural environment, and states: “Planning policies and
decisions should contribute to and enhance the natural and local environment.”
The 2021 London Plan Policy G7 Trees and Woodlands goes further still, saying:
“The Mayor wants to increase tree canopy cover in London by 10 per cent by
2050.” Canopy cannot increase unless as much existing canopy as possible is
retained. The proposed development is non-compliant when judged against both
these policy documents.
In 2019 Southwark Council declared a climate emergency and it has committed
to planting 10,000 new trees by 2022 and being carbon neutral by 2030; to meet

its targets it will need also to retain mature trees. The “replacement” trees
proposed in the on-site landscaping or planted elsewhere in mitigation will not
compensate in terms of carbon sequestration for the trees lost, nor will they
have the same cooling effect during heatwaves as mature trees.
In addition, we note that the New Southwark Plan has identified two further sites
on Lomond Grove for redevelopment, currently occupied by the Elis laundry
factory (39 new homes) and Edmundson Electrical (50 new homes). The now-
closed Camberwell magistrates’ court is also going to be redeveloped
(potentially creating around 160 new homes). The current application does not
take into account the need to protect green space locally to meet the needs of a
rising population in an area of intensive new development. The issue of flood
risk is also an important consideration here: the council is proposing to build
within a Critical Drainage Area, as identified within the Southwark Strategic
Flood Risk Assessment. A mature tree can absorb up to 450 litres of water
through its roots in a day, and the retention of trees should be a vital part of
flood risk management.
Finally, we believe the plans submitted under this application are out of date,
having been drawn up before the pandemic and not subsequently adapted to
reflect societal changes since then. With many more people now working from
home and spending more time in their local area, trees and green spaces have
become of even greater importance to residents’ physical and mental wellbeing.
The council should withdraw this application and engage with the community to
meet the demands of both housing provision and environmental protection.