How to comment on planning applications, or SNAV’s Planning Doc Cheat Sheet
Are you ready to take your planning comments to the next level? Want to be a more effective voice for nature? Read on…
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.
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
Some general points you may wish to bring across:
- Mature trees lost to development cannot be replaced. A small, newly planted tree, which may not survive, will not provide anything close to 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 mature 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. People need good quality housing which includes easy access to good quality green space.
- 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 survey existing habitat conditions before development, and to be a 10% net gain for biodiversity. This biodiversity must 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
- Green roofs
- 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.
Another part of the London Plan is the Urban Greening Factor (UGF), which is already being done on applications in Southwark. It is non-mandatory but still is considered seriously. Every large development should provide sufficient high-quality, biodiversity-friendly green space to meet an Urban Greening Factor of at least 0.4. 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-friendly green roofs, public realm and streetscapes
- 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.
p45: To be carbon neutral by 2030, Southwark must:
- Improve biodiversity and introduce new green corridors to help wildlife to move
- Make our streets a green place to walk, play and relax
- Further increase tree canopy coverage across the borough with more planting
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.
P17 image 1
The proposed North Camberwell Wildlife Corridor develops quality habitat in conformance with the planned N-S Strategic Habitat Corridor from Burgess Park southward toward Brockwell Park.
P31-32 How we will promote, conserve and enhance habitats and species:
- Create wildlife habitats such as meadows, small areas of woodland, orchards, and hedges within the landscaping around estates, and enhance existing habitats;
- Install bat boxes, nest boxes for birds, bumblebee boxes and hedgehog homes in suitable places on estates
- Plant native trees
- Create loggeries and insect hotels
- Create sustainable drainage systems on suitable land
- Review mowing regimes to benefit spring flowers and wildlife
- Plant Alder buckthorn, Birds-foot trefoil and other food plants for butterfly caterpillars
- Plant nectar-rich flora to provide food for bumblebees and other insects
P33
- Encourage residents to get involved in improving their estates for wildlife with events such as community planting days
- Provide information about local wildlife and events in newsletters and on noticeboards
P37
- Provide news and information on wildlife and events in the sites they manage, Southwark’s parks and on their websites incorporating social media and other mediums
- Broaden information sharing and provide onsite interpretation
P37-38 bats, linear features:
- Plant night scented plants to attract insects
- Avoid installing lighting to the exterior of buildings and gardens
- Install bat tubes or bat bricks/boxes
- Promote bat conservation through habitat enhancement
P46 stag beetles
- Report sightings of the beetle to LWT or the Ecology Officer
- Retain dead wood and tree stumps where applicable
- Build loggeries
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.”
- https://www.southwark.gov.uk/assets/attach/1820/Sustainable_Design_and_Construction_SPD.pdf
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
Other:
The World Health Organization recommends the availability of a minimum of 9 m 2 of green space per individual with an ideal UGS value of 50 m 2 per capita. (5 Oct 2018). The World Health Organization recommends that all people reside within 300m of green space.
All Londoners should live within a 10 minute walk of green space.
https://www.london.gov.uk/programmes-and-strategies/environment-and-climate-
change/parks-green-spaces-and-biodiversity/green-infrastructure-maps-and-
tools/10-minute-walk-map
https://www.theguardian.com/environment/2024/jan/13/children-living-near-green-spaces-tronger-bones-study?CMP=share_btn_wa