Several concerned residents have been in touch with EWG to ask if we could advise on a proposed new floodlit tennis facility in Lammas Enclosure, a sanctuary for people and nature between Walpole and Lammas Park. We won’t go into too much detail here as it’s all in my comment below, and want to reiterate that we can’t always wade in on local planning proposals. But this is another classic example of poor planning that will have a seriously detrimental impact on an important wildlife corridor and pocket of green space in our urban landscape.

Here’s where to search for the proposals on the council website:

https://pam.ealing.gov.uk/online-applications/

The application reference is 212116FUL.

And here is the objecting comment from me:

“The main issue that makes this proposal inappropriate is that it’s yet another encroachment and fragmentation of important green space for biodiversity in our already pressured urban landscape. We are in a biodiversity crisis, and pockets of green space like this are crucial so that both flora and fauna can survive. They are also crucial as wildlife corridors allowing threatened wildlife species to move from one habitat to the next as well as being important habitat in themselves. The more we chop up these spaces, or light them at night, the more pressure our biodiversity faces and ultimately it is lost over time through this perpetual chipping away and degradation of the quality of the habitats within.

My objection to this from an ecological point of view (apart from increased flood risk due to yet more hard standing) is the impact of lighting and activity on biodiversity in the area. Bats in particular are very prone to lighting disturbance, and the Lammas enclosure is without any doubt an important transit route for bats through the urban landscape. Even with so-called ‘bat-friendly’ lighting, certain light sensitive species will struggle to commute from feeding and roost sites across an area that is floodlit. We at Ealing Wildlife Group have records of several bat species using Lammas and Walpole Park spanning the last 4 years. We have also detected bats around the perimeter of this site. Lammas enclosure is undoubtedly a flight route for them between these habitats. I notice on the ecology report it says there is a tree on site with moderate roost potential for bats. It also says rather bizarrely that there is low suitability as foraging habitat on site and adjacent. I have to categorically contest this as we have reports of and ourselves detected foraging bats around the enclosure and adjacent gardens.

The report also admits that “Without mitigation there is the potential for adverse impacts through lighting”. The amount of floodlighting in what is currently a dark refuge for wildlife at night is extremely damaging, even if apparently ‘bat-friendly’.

There are also confirmed hedgehogs and at least two species of owl (Tawny and Little) confirmed in this immediate area which rely on the cover of darkness and in the case of hedgehogs are declining rapidly due to encroachment of urban development and loss of habitat.

It’s important to note that the ecological impact report was carried out two years ago in April 2019 and is not in line with CIEEM guidelines on effective duration. It needs to have been carried out within 12-24 months depending on species, site and potential impact so is effectively now invalid. In terms of bat activity, April is also just the start of the season when bats become active and may not fully reflect the suitability or use of the site by bats, hence the incorrect assertion in the report that it’s of low suitability for foraging. Ideally the site should have been visited to assess specifically for bats on two occasions when bats are most likely to be active. Which is not in the middle of the day in April.

Herein lies the problem with ecological assessments that don’t factor in the connectivity and wildlife corridor potential of the site between other sites. And fail to even survey for active foraging bats in the first place.

We are not so concerned about the footprint of the hard standing referred to as “the site” so much as the impact of the lighting and increased activity in the whole space surrounding “the site”. It’s shortsighted to say there are no bats or breeding birds “on the site” when the proposed works’ wider impact is way more far reaching.

As outlined in the report itself: “Given the mobility of animals and the potential for colonisation of the site over time, updating survey work may be required, particularly if development does not commence within 12 months of the date of the most recent relevant survey.” So the proposal cannot legally be granted permission without further ecological surveying being done in an appropriate manner.

On enhancements, a few token bird boxes and some tree planting will do nothing in the short or medium term to mitigate for the increased activity and lighting in this space at night time which will have seriously detrimental impact on already beleaguered wildlife species such as bats, hedgehogs and owls. With all due respect, we have plenty of Blue Tits!

Finally, I do find it worrying that Will to Win appear to be recruiting supporting commentary for this proposal from so many people who don’t live anywhere near the borough of Ealing let alone Lammas Enclosure. I hope like others that the opinions and concerns of local residents and groups such as ourselves are taken into account and given greater weighting.

Yours sincerely,

Dr Sean McCormack BSc (Hons), MVB, MRCVS
Founder & Chair, Ealing Wildlife Group
www.ealingwildlifegroup.com”

If you too feel that it’s important to preserve this space for wildlife and nature, and perhaps a more appropriate place for the proposal should be found then please make your voice heard.