• CarolineShah

Natural England's silence brings legal challenge of London Plan closer

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"...we are sorry that in this instance we are unable to help"

Natural England - silent in the face of nature's destruction?

Natural England has replied after seeing scientific evidence and expert opinion about how the stag beetle and its habitat is adversely affected by factors to which policies in the new London Plan will give rise through mass development and urbanisation across Greater London, and that were not considered in the Habitats Regulations Assessment of the Plan

The Joint Nature Conservation Committee ("(JNCC"), on which Natural England's deputy chairman is a board member, has also already expressed concern at the effects of urbanisation on the long-term prospects for this legally- protected and "near vulnerable" Red List creature

Yet, the reply from Natural England ignores the evidence before them that the London Plan will put the stag beetle at risk

The short reply only refers in a vague and oblique way to Natural England's opinion of the effects of the London Plan on stag beetles and their habitats from recreational disturbance. It does not however explain the organisation's original opinion on this matter, on what that opinion was based or why their opinion has not changed:

"We take our consultation responsibilities very seriously and are always interested to receive updated information and evidence which may influence our advice and decisions.

We have shared your documents with our Senior Invertebrate Specialist but the additional information does not change their expert judgement on stag beetles and recreational disturbance in this instance"

Equally important, Natural England's response avoids giving their senior invertebrate specialist's updated opinion on all the other impact pathways and effects of London Plan development policies raised by experts and researchers. These include:

  1. Fragmentation of the stag beetle's habitat as gardens and other green spaces are developed and mature trees felled for development

  2. Isolation of habitats as areas all around existing habitats are destroyed

  3. Pollution on the ancient woodland ecosystem on which the stag beetle relies

This lack of comment is despite one of Natural England's "senior invertebrate specialists" commenting in an email forwarded to me in July 2020 that "the real issue would be disturbance to, or destruction of, their dead wood habitat through the proposed developments"

Most seriously, in the Joint Nature Conservation Committee ("JNCC") 2019 statement to the EU on the long-term trend for the conservation status of the stag beetle, members already expressed concern at pressure on the beetle from "construction or modification in urban areas" which the Habitats Regulations Assessment of the London Plan and Natural England have overlooked. This is before the London Plan's new growth targets had gone to Examination in Public:

These oversights raise a simple question:

Why is Natural England staying silent about significant factors arising from the new London Plan's policies that could affect the long-term survival of the stag beetle when there is ample scientific evidence and expert opinion to support the harmful impact those policies could have?

The JNCC is a public body that advises the UK Government and devolved administrations on UK-wide and international nature conservation. The deputy Chair of Natural England, Lord Blencathra, sits on the JNCC's Joint Committee which has overall responsibility for the JNCC's work

Scientific and expert evidence appear to show indisputably that a spatial development strategy for London that involves digging up huge areas of gardens and other land, and felling mature trees - all of which provide the habitats on which the protected stag beetle relies for its long term survival in south-east England, its largest remaining stronghold in England - must inevitably be considered to pose a long term threat to the survival of the stag beetle in England as a whole

This has not been considered at all in the London Plan or the Habitats Regulations Assessment of the plan. The effect of pollution on the stag beetle and its habitat have equally been overlooked and the dismissal of the effects of vastly increased recreational pressure have not been justified

I call on Natural England to speak up now before the London Plan is published so that these issues can be considered properly in revised policies in the Plan

Please donate to help take the London Plan to judicial review when it is published

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