Wornington Trees Phase 3 planning application objection PP/21/07028
1. Tree loss and loss of public amenity green space
Wornington Green, phase 3, is self-evidently part of a larger development. Tree loss and loss of public amenity green space in this phase must be viewed in the wider context of overall loss of trees and public realm green space in the immediate neighbourhood. Reference to historic tree planting plans and maps [see attached] shows an estimated total loss of 272 mature public realm trees in Wornington Green estate and Athlone Gardens.
2. Arboricultural Impact Assessment does not give the full picture
The Arboricultural Impact Assessment prepared by Treework Environmental Practice (TPA) is somewhat misleading. The survey, carried out on 11th May 2021, does not take into account an estimated 50 mature category B trees within the boundaries of land designated as ‘phase 3’ during the period 2010 – 2021; prior to this application, but post commencement of development. We assert that the felling of these trees was a cynical move by the developers without genuine purpose. Hence the phase 3 CAVAT loss to the community is significantly greater than estimated. With reference to historic tree planting records and TPO records, the true CAVAT loss in phase 3 is likely to be in the region of £6,227,144 [see attached CAVAT estimate].
The Arboricultural Impact Assessment prepared by TPA admits that 13 trees in phase 3 were not included in the original topographical survey prepared by Chris Blanford Associates (CBA) and submitted as evidence for the 2010 consented masterplan. It is not clear how many trees not included in the CBA survey have already been felled in phases 1 and 2, but reference to historic tree planting plans and maps suggests a significant disparity.
Concerns have been raised about possible double-counting of retained trees. Our understanding is that London Plane trees T1, T2, and T3 in phase 3 were previously also counted as retained trees in phase 2.
3. Need for trees
Mature street trees:
- Reduce pollution and improve air quality
- Encourage birds and wildlife
- Sequester CO2
- Provide wind breaks
- Reduce flooding
- Cool the air in summer
- Are beneficial for physical and mental wellbeing
- Promote social cohesion and leisure use of public spaces
- Provide an attractive environment for shoppers and diners
- Increase house prices
- Make the world a better place
Given the multitude of benefits with few downsides, trees must be considered as essential urban infrastructure, not as a decorative afterthought.
The London canopy cover mapping ward prioritisation tool1 identifies a high need for trees in Golborne ward. On scales of 1-10, with 1 being highest negative affect, Golborne ward in 2019 scores as follows:
- Index of Multiple Deprivation (IMD) decile: 1
- Air quality, PM 2.5 decile: 1
- Air quality, NO2 decile: 2
- Blue / Green decile: 2
- Tree canopy cover decile: 3 (this is likely to have declined as a consequence of further tree felling on Wornington Green estate since 2019)
- Urban heat island decile: 3
- Site of Importance for nature conservation (SINC) decile: 5
- Surface water flood risk, high / medium run-off category: No
- Water quality (WFD) poor or bad: No
There are very few street trees in the immediate neighbourhood. This low level of street planting may be linked to the historically high number of mature trees that stood on the perimeter of Wornington Green estate and in Athlone Gardens. We may assume that planning permission for the original Wornington Green (the clue is in the name) estate was given partly on the basis of its extensive greening and tree planting.
- Increase the number of trees on London’s streets, particularly in areas of currently low canopy cover.
- Increase the number of trees in London’s parks and green spaces, particularly in areas of currently low canopy cover.
- Support Londoners in playing an active role in the protection, growth and management of the urban forest.
- Recognise the productive potential of London’s urban forest
The London Plan also promotes the planting of trees and woodlands in new
developments and, where loss of trees is unavoidable, requires replacement based on the existing value of the trees removed based on for example, i-Tree Eco or CAVAT. It goes on to note that “development proposals should ensure that, wherever possible, existing trees of value are retained”.
In a ward with such a high need for trees, we cannot afford to fell any more. In fact, we urgently need to significantly increase canopy cover and public green space in Golborne.
a. Air quality
RBKC overall experiences poor air quality, with mortality attributable to long-term exposure to particulate matter (PM2.5) estimated at 48% above the UK average.
Living sandwiched between the major thoroughfares of the Westway, Ladbroke Grove, and mainline railway, Golborne residents are particularly vulnerable to effects of Nitrous Oxide and particulate matter. Fallout from the Grenfell Tower fire is highly likely to have further degraded air quality in the area.
In this context, plans that propose the felling of large mature trees to build new roads cannot be supported.
b. Physical and mental health
Research has found consistent negative association between urban green space exposure and mortality, heart rate, and violence, and positive association with attention, mood, and physical activity.
Asthma rates among children aged four and five fell by a quarter for every additional 343 trees per square kilometre.
People living in urban areas with greater amounts of green space show significantly lower mental distress and significantly higher wellbeing.
People who live within 500 metres of accessible green space are 24 per cent more likely to meet recommended levels of physical activity.
If every household in England were provided with good access to quality green space it could save an estimated £2.1 billion in health care costs.
20.3 per cent of residents in Golborne have a long-term limiting illness, compared to 12.3 per cent in Kensington and Chelsea and 14.1 per cent in London.
The Local Plan acknowledges that 8.3% of deaths in RBKC are attributable to poor air quality – one of the worst metrics in London
The above findings make a glaring case for retaining as many mature trees as possible, creating extensive public green space, and planting as many new trees as possible. These plans propose the opposite.
c. Index of multiple deprivation
Golborne Ward, in the Royal Borough of Kensington and Chelsea, is significantly deprived. The Index of Multiple Deprivation (IMD, 2007) shows Golborne to be among the 10% most deprived wards in England14, also scoring in the lowest 10% for children living in income deprived households.
Deprived communities suffer greater burdens from air-pollution-related death and sickness. As highlighted in the 2010 Marmot Review, individuals in deprived areas experience more adverse health effects at the same level of exposure compared to those from less- deprived areas.
Trees support biodiversity across a wide range of functional groups, including epiphytes, herbivores, predators and omnivores. They provide structure and food resources for vertebrates, invertebrates, fungi, lichens and other organisms. The number of insect species associated with trees in Britain generally increases with host tree abundance. Urban trees have considerable potential to sustain and enhance urban biodiversity and to help reduce biodiversity loss.16
Felling mature trees inevitably leads to habitat loss and a reduction in biodiversity. Local residents repeatedly voice distress at the ongoing loss of birds, squirrels, foxes, and insects that has become so noticeable through the course of this development.
4. Tree planting plans are inadequate
The developers propose to plant 54 small trees. It is notable that a detailed CAVAT analysis of these proposed trees is not made clear in the Arboricultural Impact Assessment, which imagines projected CAVATs in 2037, 2048, and 2068 but with no breakdown of how much of this CAVAT is attributable to new trees and how much to retained trees. None of the proposed new trees will adequately replace the existing large varieties: London Planes, Sycamores, Maples, Horse Chestnuts, and the like that are to be felled. Even when fully grown, small trees simply cannot achieve the carbon capture capabilities of large, broad-leaved varieties. The projection to reach a CAVAT of £4,872,978 in 40 years (!) leaves a generational deficit of £1,399,166, and is woefully inadequate. It’s as if the developers are saying to RBKC residents, “lend us six million quid, and in forty years time we will give you back four million”. We think not!
This plan fails to meet the Urban Greening Factor target score. The London recommends a UGF score of 0.4 for developments that are predominately residential. This plan scores 0.25, just 62.5% of the Mayor’s target.
5. New on-street parking
In Golborne ward 68.4 per cent of households do not have access to a car or van and hence do not need or want new parking provision. We support RBKC’s commitment to reducing on-street parking. Wornington Green estate within phase 3 boundaries included no on-street parking, hence we assert that all new and re- provided estate parking must be provided off-street.
6. New through roads
New through roads are neither needed nor wanted in what has been, since the 1970s, effectively a low-traffic neighbourhood. Linking Wornington Rd to Ladbroke Grove at Barlby roundabout will encourage rat-running from Great Western Rd. With the development of the Kensal Canalside site, significant traffic increase is inevitable. Data of road traffic accidents recorded by TfL demonstrate Wornington Green has relatively safe roads with no slight, serious or fatal incidents recorded over the last 6 years. Opening Wornington Road to through traffic will significantly increase the risk of serious injury or death. Ladbroke Grove / Barlby Rd roundabout is already a dangerous intersection. Data shows 19 RTAs over the past 5 years, with 6 fatalities and 1 serious injury. Adding a fourth arm will significantly increase the danger for pedestrians and cyclists. The density of primary or nursery schools in the surrounding area and very small catchment areas indicates that walking, cycling, and active travel should be prioritised. Creating new through roads is contrary to all strategic objectives to create healthy streets that prioritise walking and cycling.
Whist we accept that a legible and well-lit street layout has positive impacts on crime reduction, we have found no research to support the proposal that such streets must be open to through traffic or street parking. It is the street frontage alone that encourages community-building and discourages anti-social behaviour. Further, increased provision of street trees has significant community benefits. Current research reveals a strong correlation between access to nature generally – and tree canopy cover specifically – and increased social capital, improved community cohesion, and lowered crime rates.
“The perceived quality, views, and amount of time spent in nature were linked to more community cohesion, and in turn, the perception of cohesive communities enhanced individual well-being outcomes and contributions back to society through higher workplace productivity and environmentally responsible behaviors. Our findings also indicated that local nature was linked to lower crime both directly and indirectly through its effects on community cohesion.”
“We found that there is a strong inverse relationship between tree canopy and our index of robbery, burglary, theft and shooting. The more conservative spatially adjusted model indicated that a 10% increase in tree canopy was associated with a roughly 12% decrease in crime. When we broke down tree cover by public and private ownership for the spatial model, we found that the inverse relationship continued in both contexts, but the magnitude was 40% greater for public than for private lands.”
Hence, we oppose new through roads and propose instead the provision of pedestrianised, access-only spaces that will allow for the retention and planting of many more trees and will also allow space for green walls, hedging, shrubbery, wildflowers, and other desirable greening measures.
7. Potential to retain more mature trees
These plans represent a failure of imagination and a missed opportunity to retain mature trees and plant many more trees. Provision of pedestrian-priority, access- only streets without on-street parking would allow for the retention of trees T4, T5, T11, T12, S13, S25, T33, T34, T36, and T37. The creation of pedestrian-priority, access-only streets without on-street parking would also allow for a denser planting of trees along Wornington and Portobello Roads and at the apex of these two roads near Ladbroke Grove / Barlby roundabout. Minor adjustments to some building lines would allow for retention of trees T6, T7, T8, and T35. Trees T14 and T15 were not included on the 2010 CBA survey, hence there is not even outline permission to fell these two large Sycamores.
Lack of consultation
Golborne residents and local businesses have not been meaningfully consulted about tree loss, loss of public green space, and reprovision of trees and public green space. Consultations have been treated as presentations in which the
developers “spin” their narrative to residents. There has been no true co-design or community participation on important issues such as choice of architects, building heights, social / private housing mix, street layout and uses of streets and other public spaces, tree felling and tree planting / species selection. Local community group Wornington Trees has garnered 3,100 signatures to two petitions respectively demanding a halt to tree felling and the provision of more trees in the Wornington Green neighbourhood. Despite repeated requests and the urging of RBKC’s Overview and Scrutiny Committee, the developers have not engaged in any discussions or co-design process with this group. We go further and say that the developers have actively avoided such opportunities. Had developers chosen to engage meaningfully with the local community they might not now be experiencing so much resistance to this plan.
In the absence of meaningful dialogue with the developers, Wornington Trees Community Group canvassed residents on their opinions about tree loss in the neighbourhood. Here is what they said:
“Trees are my medicine.” - Kate, local resident
"I've lived in this area most of my life and it saddens me to see so many trees cut down." – Angela, local resident
“Not hearing birds tweet will be a shame... they’re the little mystery things of nature that capture your senses” – local resident
“In this climate of world pollution, it’s sacrilege to even think about removing well established and beautiful trees. All we need is the air that we breathe and to love them.” – Christine, Wornington Green resident
"Before the redevelopment, we used to have a most beautiful big park filled with trees of all kinds and birds and birdsong. A park for children, grownups, dogs and birds. We miss that as it was a vital center of our community to socialise in. It is important to have fresh air to breathe in this increasingly urbanised world." – Sophie, local resident
“Our trees represent so much more than a monetary value can ever hope to measure; they are our peace, our beauty, our birdsong, our bees, our protection, our harmony, and our community. We love our trees, and we miss them so much.” – Jess, local resident
“These trees are our trees... they should be there for the children of tomorrow.” – Keith, Wornington Green resident
Since outline planning permission was first granted in 2010, the global context has dramatically changed. We must seriously consider:
- RBKC declared a climate emergency in 2019
- The climate impact of tree loss and green space loss
- The climate impact of new construction
- The climate impact of increased traffic
- The consensus that retrofitting existing buildings creates far less carbon that new builds
We agree with the statement released by the UN Climate Conference, COP26: “We cannot afford to wait to act against the threat of climate change. We must work together to protect our planet and people and ensure a greener, more resilient future for us all.”
The plans submitted are outdated and out-of-step with public opinion and the urgent reality of climate change.
Whilst we fully accept the need for more housing in RBKC, particularly housing for social rent, we are disappointed by the developer Catalyst’s plan for phase 3. Aims of RBKC’s Local Plan: Vision for Golborne in 2028, include provision of good public open space, improved pedestrian and cycling links, enhanced safety and permeability of the area, improved local air quality, and reduced health inequalities. These plans deliver none of the desired enhancements and will in fact increase traffic, increase pollution, decrease canopy cover and public green space, reduce biodiversity, contribute to climate change, and have lasting negative impacts on the physical health, mental wellbeing, and social cohesion of residents.
We believe that homes and trees can, and must, co-exist. Sustainability and wellbeing are the cornerstones of excellent urban architecture and planning. It is not too late to revisit these plans, in genuine co-design with the local community, and produce a 21st century sustainable, green, architecturally significant housing scheme that we can all be proud of.
We urge the council to allow no new through roads, no new on-street parking, and insist on the retention of an additional 16 trees, as detailed above. We further urge the council to insist on the planting of 73 new trees, 50% of which should be large, broad-leaved species, to bring the total number of trees within the boundaries of phase 3 back to the number that existed in 2010, plus 10%.