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  • CarolineShah

Death of Richmond Park and Wimbledon Common

Desecration of rare biodiversity and wildlife in London's ancient habitats is already happening. It will only get worse

Wimbledon Common's North Atlantic Heathland with Erica Tetralix is under threat from the new London Plan

Natural England has given Sadiq Khan, The Mayor of London and Robert Jenrick, Secretary fo State for Housing, Local Government and Communities, carte blanche to destroy London's remaining biodiversity on Wimbledon Common and in Richmond Park. There was time for Natural England to change their mind before the London Plan was published and to speak up in light of the obvious harm being done to both sites from increased recreational pressure as a result of Covid.


But they stayed silent.


Lawyers have given an opinion that there are not grounds to challenge The London Plan on the basis that Natural England’s conclusions that the Plan's policies will not have a harmful effect on protected habitats and species in and around London.


The reason? Simply because Natural England is the body nominated as the nature conservation body in law in relation to the London Plan and its conclusions therefore hold great weight in decision-making


This is despite the fact that expert evidence exists to undermine Natural England's conclusions and despite the fact that, by their own admission, Natural England reached their conclusions without following any corporate process, with no official record of when or how their decision was made and with no audit trail of steps taken to inform them


As the lawyers stated in reference to the Conservation of Habitats and Species Regulations 2017 which dictate that a habitats regulations assessment of the London Plan must take place:

and further in relation to the conclusions of the Inspectors of the London Plan in relation to Natural England's acceptance of the Habitats Regulations Assessment completed by AECOM, the report's authors, despite the conclusions relating to Richmond Park and Wimbledon Common being trivial, incomplete and unjustified:


Specifically, Aecom ignored all threats to Richmond Park and its protected species, the stag beetle, from recreational pressure, referring to out of date assessments by Natural England to support their statement that the Special Area of Conservation is not and will not be threatened by an onslaught of visitors and the effects of high levels of nitrogen deposition from vehicle emissions and other pollutants on the park's ancient woodlands.


In ths case of Wimbledon Common, AECOM basically pointed the finger at the Conservators of Wimbledon Common for 'lack of traditional management" of the Common's protected heathlands, saying that recreational pressure is not threatening this vulnerable habitat. This is contrary to my findings on a recent visit to the Common when - even on a rainy wet morning - people were trampling on the heathland.



In relation to pollution, AECOM accepted that current nitrogen oxide levels are harmful to Wimbledon Common's heathlands but it then relies on the Mayor's future and untested transport and environmental policies, including the now cancelled CrossRail 2, to conclude that pollution levels WILL fall. There is neither a scientific or evidence based justification for the conclusion.



I am hugely disappointed that there are insufficient legal grounds to challenge the Mayor of London's acceptance that the massive population growth and increase in pollution that will come with large-scale demolition and construction-related activities under the new London Plan will NOT affect Richmond Park and Wimbledon Common simply because Natural England has not spoken up.


The evidence already before our eyes is that both these special places for nature and the stag beetle for whom they provide a home are under threat from the targetted growth policies of the London Plan


Natural England cannot find any record of the vague statement that The Mayor of London's office provided to the Inspectors of the London Plan and on which the Inspectors relied themselves in concluding that AECOM's habitats regulations assessment was adequate. There is no evidence either that "further minor changes" were made or indeed even what these further minor changes were made.

London Plan Examination in Public: Legal and Procedural Matters

It is too late now for Natural England to speak up.


It may be too late for Richmond Park and Wimbledon Common to survive.

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