How to comment on planning applications, or SNAV’s Planning Doc Cheat Sheet
adapted from Elizabeth Borowiecka’s piece originally written for the Camberwell Society (Winter 2021)
Are you ready to take your planning comments to the next level? Want to be a more effective voice for nature? Read on…
From the point of view of the council, the most basic requirements for a successful building application are:
Good quality design, and
Respect for existing buildings and their occupants.
That said, these are not qualities that can be judged very objectively, in most projects that have already made it to the planning stage. And how does nature and sustainability fit in to these criteria? Your comment will be more effective and highly regarded if you are able to reference the language, terminology, and stated intents of specific Southwark planning documents– which is easier said than done!
The sheer number of pages of policy and intention to get a handle on is overwhelming, for the average person. SNAV’s ongoing project is to make effective commenting easier, by extracting some of the most important principles from each document.
Remember — even if you can’t get through the documents (or even this cheat sheet), it’s still better to speak up for nature in your own words, than not to write anything at all.
Some points you may wish to bring across:
Trees lost to development cannot be replaced. A small, newly planted tree, which may not survive, will not provide the same value as a mature tree in terms of carbon storage, flood risk abatement, reduced heat island effect, and natural habitat. We need these benefits now – we cannot wait decades for replacement trees to grow.
The National Planning Policy Framework states: “Planning policies and decisions should contribute to and enhance the natural and local environment.”
In 2019, Southwark Council committed to planting 10,000 new trees by 2022 and being carbon neutral by 2030.
We support the building of much-needed new council homes, but it has also been proven that living close to trees and green spaces is very important for people’s physical and mental health.
Maintaining existing trees is vital for carbon sequestration in response to the climate emergency.
Southwark council should be protecting and enhancing green space to meet the needs of Southwark’s rising population–not destroying it.
We reject the idea that people must choose between social housing and protecting trees and green spaces.
Also, remember to write and save your comment in a separate text editor, before pasting it into the planning website, which may time out without warning.
Following are highlights from some of the most relevant official documents for commenting on how developments in Southwark will impact nature and green space:
The London Plan, a massive document which came into effect in March 2021, is supported by several detailed planning guidance initiatives. Quote the London Plan in your comments, and say that Southwark policies and decisions should be “in conformity”. 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.”
One of the policies recently adopted by the London Plan, that may be most helpful for SNAVers speaking up for nature, is Biodiversity Net Gain (BNG), whose intent is to make London greener and wilder. Under BNG all developments are now required to be a 10% net gain for biodiversity. This biodiversity should be provided on-site, not off-site, where at all possible. Some ways for developments to meet BNG targets – ask for these to be maximised:
Maintaining existing natural areas and trees
Adding at-grade meadows, ponds, and woodlands
Incorporating swift bricks, bird houses and bat boxes
Local Planning Authorities are also encouraged to consider the following questions when implementing BNG:
What biodiversity is rare or declining locally? In Southwark, woodlands and wetlands are rare, although they once were the dominant landscape types. Birds that live in Southwark, whose populations are fast-declining nationally, include house sparrows, tree sparrows, song thrush, starlings, swifts, and most water birds — these species need extra protection right now.
What are the most important biodiversity assets, and how are they ecologically connected? In Southwark, the biggest biodiversity assets include our parks and gardens, but also railway verges, and any form of connectivity, such as hedges and street trees.
Where are the most and least beneficial areas for delivering BNG, and is there enough evidence for these conclusions?
Another part of the London Plan will be the Urban Greening Factor (UGF), which is already being done on applications in Southwark. It applies to large developments. This aims to bring an appreciation of green issues to proposed developments in London boroughs, including:
green routes that promote active travel;
sustainable drainage to combat flooding;
biodiversity, including green roofs;
publicly accessible open space;
and tree planting.
And don’t forget:
The Southwark Climate Action Plan (SCAP) was published in July of 2021 and states the borough’s intentions to address climate change.This is not part of Southwark planning policy. So unfortunately the SCAP does not contain any enforceable planning or design requirements (actual policy), but it will help councillors to be reminded of the stated intentions.
The Southwark Nature Action Plan (SNAP) was published in 2020, and states the borough’s intentions to improve and support biodiversity, and contains a lot of good ideas which you can suggest and remind decision makers of in your comment. Once again not part of planning policy. So unfortunately the SNAP does not contain any enforceable planning or design requirements (actual policy), but it will help councillors to be reminded of the stated intentions. Also ask about use of SNAP at consultation events and make sure landscape designers/architects are aware of it.
The Southwark Streetscape Design Manual – DS 502 planters which also has a lot of good ideas, eg “Southwark has a strong preference for the provision of planting beds as opposed to planters.”
In addition, for some projects, it may also be helpful to reference:
Transport for London has devised the PTALs or Public Transport Accessibility Levels, to assess the suitability of an area for new residential development in terms of the availability of public transport. Each location is scored a rating from 0-6b where 0 represents the least accessible locations and 6b is a town centre location with excellent transport links.
The New Southwark Plan, is currently in the final stages of scrutiny before adoption, which will likely be some time in 2022. This includes policies on trees, biodiversity, green space, which sit under Policy 6 Cleaner, Greener, Safer. The plan is being used as the basis for decision making now. “Development must retain and enhance the borough’s trees and canopy cover.”
In 2011 Southwark Council produced “Residential Design Standards” , a document which contains detailed practical guidance for planning applicants and those who wish to comment on planning applications.