TL;DR

“too long; didn’t read”. AKA the short version

The plans for a BMX track at Stockdove Way, which was originally meant to be on the Gurnell redevelopment site, is now proposed for ABSOLUTELY the wrong location on a Site of Importance for Nature Conservation (SINC). Various reasons it’s the wrong location. The crudely annotated map below illustrates the main one. It will block the last remaining space in the critical wildlife corridor of the Brent River Valley after the Gurnell redevelopment takes place.

The ecology report is also out of date from 2016, and no professional bat surveys have been undertaken which are a legal requirement.  Lodge your objections for wildlife and biodiversity please. The BMX track needs to find another more appropriate location. We need to maintain the integrity of the few urban green spaces we have left in Ealing. We need you to lodge your comments by June 17th here: https://pam.ealing.gov.uk/online-applications/PLAN/201541FUL

Click on the image to enlarge:

Long Version

While I try not to use EWG as a personal or political platform for campaigning on local development, there are some planning decisions that I will object to and speak out publicly on. In this instance,I truly believe a poor decision is about to be made and I’d like to add my two cents and make our membership aware so they can have their say if they so wish. 

I’d like to talk about the proposed BMX cycle track facility at Stockdove Way in Perivale Park. The consultation is open to comments right now, but closing date is 24th June 2020. So it’s pretty urgent that if you want a say, you make your voice heard here ASAP:

https://pam.ealing.gov.uk/online-applications/applicationDetails.do?activeTab=summary&keyVal=Q8XTU7JMKMH00

If you don’t have time to read a long winded post, here’s my summary. The BMX track’s proposed location will be catastrophic to maintaining wildlife corridor connectivity in our Borough and there are far more suitable sites it could be built on with less impact. The plans to integrate it into the surrounding landscape are good, but not good enough in this critical location. The ecology report desk study and field study for the site were done in 2016, and are now out out of date according to CIEEM guidance. There have been no professional ecologist bat surveys done, which is a legal requirement. We need a rethink on a suitable location.

But first, I just wanted to clear up a question I get asked quite frequently. 

What does EWG stand for and do when it comes to local planning and development?

As the founder and Chair of EWG I’ve been challenged over the years as to why I won’t lend my support to certain causes. There are always a variety of reasons but to outline some of them here:  EWG is not my full time job. I work full time in a challenging role and profession, I have a life outside of work, and I try my best to run EWG as a small conservation organisation on an entirely voluntary, free time basis. I do not get paid (or brown envelopes!*) for what we as a group do. And I only have so much time and energy. The vision of EWG is to bring about positive change through education, engagement, protection and safeguarding of biodiversity and space for nature in the Borough of Ealing. 

Rather than spend my time poring over pages and pages of planning documentation, considering evidence, talking to stakeholders and lodging objections, I would rather spend my time** getting out into nature, educating people in the borough and winning where we can – and there are plenty of fights that we can win and some wonderful examples of things that we’ve been able to achieve as a group over the last 4 years.

With regards to planning documentation, lobbying and stakeholder management, there are plenty of fantastic, passionate and largely objective people and groups in our community who have the time to devote to this, and they do a wonderful job. It doesn’t mean EWG or I personally don’t care about certain causes, it means we are all just doing our best.

If EWG politely refuses to help out in an objection to a neighbour’s loft extension, or declines the ‘offer’ to come and do a bat survey at 10pm, or declines the opportunity to collaborate with another conservation group, please don’t take it personally. Usually, it’s because we just don’t have the time or energy – we are all volunteers with lives outside of EWG. I get very upset when people say that if we’re not with you we’re against you. Conservation requires us all to be in this together and sometimes it is necessary that someone else picks up the mantle, it can’t be the same people all the time.  We are but human and prioritisation is always difficult. 

A final word before we get to the specifics of why I am keen to talk about this BMX track. EWG is not in the pockets or control of Ealing Council. We are free to criticise and oppose their decisions if we so wish. We are an independent, volunteer run organisation that operates on three key principles.

What are EWG’s three key principles?

1. Community
2. Collaboration
3. Conservation

The middle principle is key here. We collaborate. With other local nature organisations (hey Selborne Society, hey West London Birders and hey many more!), community groups (love you guys at Friends of Horsenden Hill!) and our local Council, specifically our wonderful friends on the Council Parks team. Sadly, our collaboration with the Council Parks has riled a small but vocal minority who believe everything the Council does is BAD. I’d like to make this clear; we would not have achieved half of what we have as a group over the past four years were it not for our collaborative approach with the Council.

Can EWG criticise or oppose Ealing Council decisions?

In a word, yes.

• Do we as a committee and individuals personally disagree with some of the decisions the Council makes? SURE we do!
• Do we realise that not everything is black or white and the Council are making decisions based on the 350,000+ people in our wider community, not all of whom have nature and wildlife as their top priority? Again, yes we do.
• Do we recognise that lots of what the Council does (big up to the Parks team here) is wonderful and motivated to help our community and biodiversity, but yes, many of their processes and decisions are super frustrating? Damn straight!
• Does any of this mean we are gagged by our collaboration with the Council? Absolutely not.
• Are we here as a collective of local enthusiasts and experts to help and advise the Council on biodiversity matters if they need that advice? I’d like to think so.
• Does disagreement on some decisions mean we want to sever ties and have no association with the Council in future? No! 

Because that would be the very definition of cutting off our nose to spite our face. We recognise everything in this world is not perfect and we are outward looking enough to recognise that our agenda is ours, and ours alone. There are other agendas, equally deserving and worthy of balanced consideration.

So what’s the issue with this BMX track?

I’m not going to reinvent the wheel here. Our friends at Brent River and Canal Society (BRCS) who advocate for the conservation of the Brent River Park set out the issue very clearly as follows:

“There’s a BMX track proposed for Stockdove Way…have your say …it is an easy process, just takes a couple of minutes..

https://pam.ealing.gov.uk/online-applications/PLAN/201541FUL

Consultation ends: 24th June 2020

……the meadow is designated as a Site of Importance for Nature Conservation (SINC) in Ealing’s policies – the whole meadow is part of Metropolitan Open Land [MOL] and an asset as part of the Brent River Park……

…..more than many locations in the borough, the location identified is a meadow of environmental value and an important asset as part of the mosaic of wildlife habitats in Ealing and West London.

Ealing Council has created this situation by deciding to remove the BMX facility from the Gurnell Leisure redevelopment proposal, thereby having to create a new home for the BMX facility. The proposed location for the new 0.99ha [c100m x c100m] “Bike Park” destroys half the area of an established meadow environment that is poorly represented and dwindling, and introduces infrastructure and social activities that will dominate and change the area.”

Here’s the current proposal, which as you can see makes a massive footprint on what was promised as and meant to be a space primarily for nature, and which was meant to mitigate for the next big controversial development just a stone’s throw away across the river Brent, the Gurnell Leisure Centre redevelopment. Click to enlarge:

High resolution plan here:

201541FUL-PLAN-3329540

My own personal objection in the comments on the above planning application is as follows:

“Dr Sean McCormack: While I’m all for promoting outdoor activity and providing space for young people, the proposed location for this BMX track is totally inappropriate. It is going to encroach massively on an area that’s just been redesigned for nature and green space for residents which is just as important, arguably more so, as many more people benefit from the space as it is than would from a BMX track specifically. A BMX track is reasonable and suited as part of the built environment, and I had thought it was originally to be included in the Gurnell redevelopment area. Now it has been moved to this proposed location, its footprint is going to swallow up a large area of diverse and important grass and wildflower meadow.

We cannot continue to swallow up our green spaces; once they are concreted over that’s the end of them. In this time of climate emergency, the Council should be looking at ways to minimise encroachment on green spaces where nature is thriving and providing the green lungs for our urban landscape. I’m sure there are plenty of areas of monoculture green lawn planned in the Gurnell development that would be much better suited to a BMX track instead.

There are also problems with the proposal in that light pollution of a valuable wildlife corridor will impact wildlife such as protected bats and invertebrates among other species. Finally, it’s going to be a beacon for antisocial behaviour down there when surrounding facilities are closed, and would be less of a draw if placed in a more built upon location. In summary, I’m all for BMX track facilities, but this Site of Importance for Nature Conservation (SINC) is absolutely not the right location and goes against what was trying to be achieved by the wonderful Greenford to Gurnell Greenway. I think an alternative location should be found.” 

Ok, so let’s have some more context…

I want to offer some alternative plans, sites or solutions to what I consider to be a really bad decision to locate this BMX track. This track will also bring with it floodlights, hard standing, concrete and shipping containers taking up at least a third of the width of the current green belt here. The Gurnell redevelopment and its 6 new towers will also present a major obstacle to wildlife to navigate our urban environment.

I don’t doubt for a moment that many BMXers will use the rest of the surrounding meadow and wetlands to cycle around too, disturbing sensitive wildlife species. 

The fundamental objection I have to the BMX track being placed right here is that it creates too much of a bottleneck and blocks an already natural narrowing in this green corridor. And down the line it’s to be further narrowed with the Gurnell Towers going in. I’m not anti-BMX track. It’s just a really poorly thought out place to put it if we value biodiversity and wildlife in the landscape. 

The simple diagram illustrating my main objection is worth repeating here (click to expand):

I’m going to bullet point my critical arguments as I’ve already gone on too long:

• This was planned to be part of the Gurnell Development across the river and makes sense there
• One of the mitigating factors for the Gurnell development in the first place for me was that we likely had net biodiversity gain in the vicinity with Greenford to Gurnell Greenway (G2GG) works
• To now cannibalise on G2GG by relocating the BMX track back onto a SINC and what was meant to be new and pristine space for nature is a backpedal (pardon the pun)
• The more we allow this to happen the less value that green spaces, SINCs or MOLs hold
• I’m all for the BMX track. I just feel strongly that’s not the right location for it. And it colours my judgement now on weighing up the pros and cons of the Gurnell redevelopment too

As great as a state of the art BMX track will be for some in our community, its location will have serious impacts for our wildlife, Borough wide biodiversity and climate! There are other locations more suitable with less impact, and BMX track users can still be kept happy:

• Just as we don’t need to cram sports facilities into human-centred areas, we also don’t NEED to plonk them into spaces for nature either
• The footprint of the Gurnell redevelopment encroaching on green space needs to be minimised, so building up is the only logical and practical solution to that end. Development and housing is a fact of life and where we live! If we continue to encroach outward on precious green space for nature, bit by bit, fragment by fragment we further our negative impact on nature, in already pressured urban environments
• No matter the sensitivity of the plans to the environment and local wildlife, lighting designed to be bat friendly (to all bat species, or some?!), native planting to shield and integrate the facility from and into the landscape, just the presence of more human activity and man made structures/effects will disturb wildlife, reduce biodiversity and ultimately place an unnecessary barrier into an already narrow and extremely important wildlife corridor
• One which is already going to be heavily impacted by 5-6 high rise tower blocks very soon

What is the actual impact on wildlife if this goes ahead at this location?

To illustrate the problem in blocking this important wildlife corridor here’s just one single practical example of the potential impact on a particularly vulnerable wildlife species of this poorly thought out plan.

Ealing has recorded Brown Long Eared bats using its railway assets as roosting or hibernation sites. This is a locally scarce species in London which relies on total darkness to navigate its environment between roosting, feeding and hibernation sites. ‘Bat friendly’ floodlights or not, it won’t like floodlights interrupting the important green corridor that is the Brent Valley. Should we just say “well the Common Pipistrelle bats don’t seem to be bothered by the light so we’ve done our bit” and shrug our shoulders? 

Should we take the risk of potentially losing the Brown Long Eared bat in Ealing (and affect the ecological niche it contributes to) because perhaps we’ve made life very difficult for it? Because we unknowingly (or knowingly) placed a very difficult barrier in its way between the species’ only maternity roost in the Borough and good feeding grounds or somewhere to hibernate (e.g. railway viaducts). These are impacts we won’t know we’ve caused until we cause them, or perhaps we’ll never find out if we blindly eat into more green space with tokenistic ‘mitigation’ to ease our conscience. As the Bat Conservation Trust says: “Some bat species have been shown to be impacted by significantly lower lighting levels than others, certain colour temperature environments also play a factor in the level of impact. However, all bats require dark roosting areas, corridors through the landscape and habitats to feed.”

Let’s not forget the scarce and incredible migratory bat species, the Nathusius’ Pipistrelle which comes here to breed all the way from Eastern Europe! It uses river valleys to navigate and migrate, and London is a major influx route for the whole of the UK. We’ve recorded those using the Brent River Valley at night too. I could go on with more species impacts, but I digress.

The fact that there is plenty of space across the river within the developed landscape of Gurnell that could be used, and that seemed to be the original plan, means we don’t have to cause these negative impacts on what is an exciting fledgling nature reserve being created. As I say, it’s a backpedal on the original BMX facility plan.

Almost like saying: “We’ll give you space for nature to get these Gurnell plans through, but then we’ll take it away”.

The more this happens the more negative impact on biodiversity in the whole Borough over time. Sometimes we have to call a stop to this chipping away mentality. And if that means segregating space for people/space for nature with firmly held lines at times I’m all for it.

I just have to hold my stance that this placement of the BMX track is wrong, and represents the slippery slope of unnecessary encroachment bit by bit onto what should be protected green space. Once it’s gone and under concrete it is gone for good! And our wider environment, and our vital connection to nature is worse off for it.

And it’s not just Brown Long Eared or Nathusius’ Pipistrelle bats. It’s Barn Owls, migrating birds, hedgehogs, toads. You name it. Poorly placed and ill thought out development gets in their way, and we lose them for good. 

What’s the solution then? Are there alternative and more appropriate sites?

Yes! Here’s a list of sites that might be more appropriate and less impactful:

• The Gurnell redevelopment site as originally planned?!
• The golf course further along on the other side of the railway line which is already of poor biodiversity value
• Somewhere else in Perivale Park that isn’t a bottleneck in the crucial wildlife corridor of the Brent River Park
• The athletics track site on Stockdove Way
• Ealing Central Sports Ground
• Horsenden Hill Golf Club
• Elthorne Park
• Marnham Field
• Berkeley Field (behind the tennis courts)
• Grove Farm
• Bixley Field
• Clayton Green

In conclusion…

Please, if you value wildlife and biodiversity in Ealing, and feel the Council should not place a BMX track here lodge your constructive comments before the 17th June 2020 here:

https://pam.ealing.gov.uk/online-applications/PLAN/201541FUL

We shouldn’t obstruct what’s left of an already pinched wildlife corridor and green space for a facility that could be easily relocated to a more suited location and be just as wonderful but have far less impact on our Borough’s nature and open spaces.

I ask you to share your concerns in the consultation, and I ask Ealing Council planning department not to backpedal on their original promise and to reconsider a more suitable location. We should be able to have Gurnell, BMX tracks, bats and barn owls. Space for nature is just as important as leisure facilities. 

Thanks, 

Dr Sean McCormack

Founder and Chair, Ealing Wildlife Group 

 

NOTES/DISCLAIMERS:

*In the interests of full disclosure, and before anyone tries to later label this a ‘brown envelope job’ as is so common when criticizing local politics or planning, I’d like to take this opportunity to share (as I did at our AGM) that I’m finally getting paid for some of my local conservation work. By the Council. A modest sum in future for the work I’m doing currently. Which is writing Species Action Plans (SAPs) for Ealing’s Biodiversity Action Plan (BAP). In a capacity independent of EWG. Hurrah!

Some of those local, vocal critics may say that means I’m in the pocket of the Council, or getting paid by them. I say I’m charging them for my time and expertise and helping Ealing’s biodiversity in the process. It’s another collaboration I’m only too happy to be part of to help shape our Borough’s Biodiversity Action Plan.

**Also to prove my point on the best use of my spare time running EWG, I’ve probably spent about 6-8 hours of my time on this issue reading planning documents, talking to various stakeholders, doing my own bat surveys, researching independent reports on biodiversity of the area and writing this blog post that I hope is fair, reasonable and objective in its aims. It’s concerned with the unsuitability of location alone of this proposal; and its detrimental impact on wildlife, urban green space and nature. I have not benefited financially or otherwise from this time.

References & Further Reading

Meadow Biodiversity Survey carried out by expert naturalists and ecologists in 2019: https://www.perivalepark.london/archives/20106

Guidance notes on bats and lighting

https://theilp.org.uk/publication/guidance-note-8-bats-and-artificial-lighting/

https://www.bats.org.uk/news/2018/09/new-guidance-on-bats-and-lighting