Biodiversity and Ecosystems Inquiry Submission



Evaluating measures to conserve and enhance biodiversity:



      How effective are the new measures to enhance biodiversity within the Environment Bill, particularly biodiversity net gain and Nature Recovery Networks?





21st September 2020



Representing Wimbledon Swift Group




The implementation of the concept of net gain for biodiversity in relation to swift conservation has been only partially effective in the London Borough of Merton, my home borough. All progress has been purely a result of consistent efforts to influence the outcome of local planning applications through the planning system, so that artificial nests for swifts will be considered and incorporated into new builds.  The London borough of Merton does not generally set planning conditions for swift bricks/boxes. New homes for swifts are regarded by swift experts as vital to the recovery of the UK’s dwindling swift population, since renovations and new builds lack the small cavities needed by swifts for nesting.


In my opinion, the slow progress in providing new artificial nest sites for swifts is is likely to be due to the fact that the current national guidance (referenced below) lacks the status and authority of legislation, and is regarded as optional.



National Planning Policy Framework 2019:  ...requiring net gains for biodiversity, through practical measures, ...


Paragraph: 023 Reference ID: 8-023-20190721:

'Planning conditions or obligations can be used........ to achieve biodiversity net gain.............. The work involved may...........involve creating new habitats, enhancing existing habitats,.............Relatively small features can often achieve important benefits for wildlife, such as incorporating swift bricks’ and bat boxes in developments.....'



The Government's Building Better Building Beautiful Commission report 'Living With Beauty'

(30/01/20, Policy Proposition 33, page 110)

Recommends: 'Bricks for bees and birds in new build homes'.





An example of a planning application for an extension to a local  church (below) provides evidence that the LB Merton planning department recommended artificial nest sites be installed in the new construction, but fell short of setting planning conditions for this conservation intervention. This church is within a few metres of a small established natural swift colony.


Application 19/P2060: A local church successfully obtained planning permission for a large extension.



September 2020