Draft response to Camden’s Biodiversity Strategy

CEC have been preparing our response to the Council’s proposed Biodiversity Strategy, on which Camden is currently consulting. Link to Camden’s consultation.

We think that Camden should be much more ambitious and are calling for a much more rigorous approach, with clear and measurable targets. Please see our thoughts below, which respond to the sections in Camden’s consultation. Please let us know if you have anything to add, or go straight to Camden’s consultation:

CEC Response (draft) to Camden’s Biodiversity Strategy

The Vision: “The London Borough of Camden is a place where nature thrives, a place where wildlife can make a home in our green spaces, gardens, streets and on buildings, and moves freely along corridors and steppingstones of habitats through the Borough and beyond. Camden is a borough where nature is part of the everyday lives of residents, visitors and workers, where development increases biodiversity, and where everybody is cooperating to nurture healthy ecosystems and increase the quality of life for all.”

The vision is inspiring. But the vision is unlikely to be fulfilled while there is no Action Plan; the aims and objectives remain vague and there are no firm completion dates.

The Strategy: Five aims are discernible in the ‘Strategy’ section: 

  1. Produce an Ecological Plan for Camden
  2. Raise officers’ awareness of the need to consider biodiversity
  3. Roll-over two actions not achieved under Camden’s Biodiversity Action Plan 2013-18)[1]:
    • Find ways to provide more natural spaces
    • Reduce inequality of access
  4. Establish a Nature Recovery Network
  5. Make a new Action Plan


First: What actually is Camden’s current biodiversity situation? It is not evident that any new biodiversity audit has been completed since the one carried out in 2012 which Camden’s last Biodiversity Action Plan (2013-2018) relied upon. It is urgent that this audit be updated, particularly now that Covid-19 lockdown has caused increased footfall in our open spaces. The recent Nesting Birds survey (2020) led by Dr Jeff Waage for the Heath and Hampstead Society is not encouraging. That survey found a loss of 20 bird species in the areas of the Heath surveyed since previous records began.

Second: Where is the analysis of the factors causing Camden’s accelerating loss of biodiversity?

Third: Where are these factors frankly unpacked to see which Camden can influence and how? 

We cannot now avert changes in our climate which have already brought long summer droughts, intense heat and torrential rainfall. But the Council can influence, alter or control many damaging local activities: 

  • lack of connectivity for wildlife
  • shrinking areas of un-built land
  • building over greenspace and disturbing topsoil in the course of development; 
  • excessive pollarding and tree felling;
  • paving/ asphalting/ astroturfing in gardens/ tennis courts/ playing fields; 
  • over-tidy garden maintenance;
  • use of pesticides, both public and private; 
  • neglect and loss of wet spaces of all kinds;
  • footfall and dogs on sensitive parts of public greenspace;
  • noise (such as fireworks);
  • outdoor light pollution.

The Objectives


Proposed objective: Protect, maintain and enhance Camden’s designated sites, buffer them and make the network more resilient through strengthened connectivity, and increase the proportion of Sites of Importance for Nature Conservation managed for biodiversity.

Designated sites tend to be fragments of greenspace isolated by urban barriers. Birds, insects and other creatures need to move around to survive, so the aim should be overcome this isolation by linking habitats in various ways. ‘Stepping stones’, i.e. relatively small patches of suitable habitat, can help wildlife to move around. An insect pathway (B-line[2]) should be created across Camden. Green wildlife corridors with continuous tree shrub canopy also support the spread of seeds and pollen which enhances biodiversity and strengthens ecosystem resilience. Blue corridors of continuous water also have a vital ecological role in link wildlife sites together.

The objectives should be to increase the area of designated sites, by including wasteland where diverse species can flourish, and second, to strengthen the current weak protection afforded to existing green areas, i.e. to change designations from Site of Importance for Nature Conservation (SINC) to Local Green Space (LGS), wherever possible. The list of SINC sites should be reviewed to decide which should be given this added protection. Such sites could be augmented by the creation of pocket parks (as proposed for Oxford Street) and areas of Sustainable Drainage Systems (SuDS) planting / bioretention areas to lessen surface water runoff and trap silts and pollutants.  Other SuDS measures should include biodiverse living roofs, permeable paving and living walls.  

Further targets should be set for planted traffic calming and landscaping streets by using trees and shrubs to alleviate the urban heat island effect and to provide habitat for wildlife.

Work is needed with schools, communities and developers to educate the wider public about nature and help people to recognise nature in urban environments. 


Proposed objective: Maintain and improve priority habitats and increase the area of species-rich grassland, woodland and reedbed.

It is essential to create new areas of habitat and not simply to maintain existing ones, especially on Council estates. Creating new habitat should be an integral part of the planning process for new developments. 

Landscape architects should research the courses of Camden’s several buried rivers[3] for opportunities to create new areas of natural water. Targets should be set for new retention basins, wildlife ponds, swales, rills, daylighted rivers and wetlands. 

Areas of amenity grass, should, wherever possible, incorporate new areas of acid grassland, native hedging, trees, wildflowers and habitat pilesMicro habitats, such as tree pits, planters and pocket parks should also be nurtured.

Camden should support the work of charities such as No InsectinctionBuglifePlant Life and the Wildlife Gardening Forum and seek their advice and help.  Create a B-line across Camden.

Ensure council parks, grounds and estate maintenance contracts prioritise protection of habitats. 

The Council persists in spraying glyphosate on pavements, tree pits and other parts of the council estate. Glyphosate is a highly toxic chemical dangerous to the workers who handle it and to residents, especially children and pregnant women[4].


Proposed objective: Monitor and increase populations of key priority species through conservation action.

An up-dated Biodiversity Audit should be prioritised to give planners a realistic benchmark of the actual state of wildlife in the borough (see Questions the Biodiversity Strategy does not address, above).

It is likely that many of the species’ recordings relate to land that is managed by City of London or the Canal and Riverside Trust.  The list should be revised to identify species found on land managed by Camden and in private gardens.  Targets can then be set to increase habitat provision to support these and other species, including through the establishment of B lines (in association with Bug Life) and wildlife corridors across Camden.

To isolate ‘key priority species’ for monitoring seems rather narrow. Biodiversity depends on relationships between many species: vertebrates, invertebrates, plants and funghi. There should be more research and education with a holistic view of habitats and diversity, to ensure that ‘key priority species’ and interdependent organisms of all kinds are protected and supported.


Proposed objective: Increase tree canopy cover and promote tree species diversity. Make planting decisions that are informed by their potential to support wildlife and resist the loss of ancient and veteran trees.

The council’s actions do not currently match this excellent objective, which we support. The council needs to improve its stewardship of existing trees. Mature trees and trees valuable to wildlife should be protected in any developments across the borough – which is often not the case, as in the redevelopment of the Morrison’s site in Chalk Farm and the proposals for Kentish Town West and Murphy’s Yard.

Pollarding street trees over-frequently reduces canopy cover and is environmentally harmful. This policy should be changed to maximise the value of leaves to insects and wildlife and the contribution of the canopy to shading and cooling our streets. Pollarding should never be done while deciduous trees are in leaf. Overly harsh and too frequent pollarding weakens trees, causing them to fail before their time: this practice must cease.

Annually record the extent of the borough’s tree canopy cover in order to accurately monitor canopy loss and additions, both in private gardens and on land managed by Camden.

Camden should place far greater emphasis on the retention of existing trees and allowing them to grow to maturity. This could be facilitated by: 

  1. Making and publishing inventories of:
    • ancient and veteran trees
    • trees with a high potential to support wildlife 
  2. Greatly increasing the number of Tree Preservation Orders (TPOs) served, including to conserve an area’s character
  3. Not permitting developers to fell trees which have a high value to wildlife
  4. We note:
    • felling of up to 500 trees by HS2 (Freedom of Information (FoI) response awaited), 
    • felling of trees between Hampstead Heath and Gospel Oak by Network Rail (FoI response awaited)
    • pollarding of an average of 1,747 trees per year by Camden (from FoI response).


Proposed objective: Manage Camden’s parks and green spaces to maximise opportunities for space for nature alongside space for people and continue to provide an increase in inclusive and welcoming areas for people to enjoy wildlife and for wildlife to thrive.

Camden is responsible for a relatively small proportion of the parks and green spaces in the borough. The council should set targets to create more parks and green spaces for the nature-deprived areas in the south and east of the borough and should permit no more trees or greenspace to be destroyed by developers, as at Brill Place in Somers Town, at St James’s Gardens and at Euston Square.

In parks and green spaces, incorporate native hedging, trees, areas of wildflowers, habitat piles, swales, rills, retention basins, wildlife ponds and wetlands, as well as wildlife or habitat piles.  Create fenced-off dog-free areas to protect wildlife.

Ban absolutely all use of artificial fertilisers and pesticides.


Proposed objective: Ensure Camden’s green and natural spaces are inclusive and welcoming and increase opportunities for Camden’s residents to experience and learn about the natural environment through volunteering, engagement, access and communication.

The objective should be to create new areas of nature, rather than to rely on existing over-used areas.  For example, the 3.2 sq. km of Hampstead Heath received up to 15 million visitors (and their dogs) during 2020.  This is more than the number of visitors to the Peak District covering 1,438 sq. km.  Not surprisingly, this has caused a 30% reduction in the number of bird species on the Heath and the complete eradication of ground nesting birds.

Further increasing Camden residents’ visits to existing green and natural spaces is not a sustainable objective.  Instead of encouraging further damage to the natural world, Camden must invest in biodiversity and create new areas of natural habitat in areas of deficiency, including through Site Allocations, Murphy’s Yard and the O2 Centre.

Structured learning opportunities should be provided through the curriculum in primary and secondary schools and in day centres for elderly residents and young families.


Proposed objective: Achieve net gain in biodiversity through planning decisions that are supported by policy and guidance and identify and deliver opportunities to increase biodiversity in urban areas.

Opportunities to increase biodiversity range from removing a section of impermeable hard surface or planting a new wildlife hedge to incorporating hanging baskets, bird bricks or a lighting scheme that minimises disturbance to bats, birds and moths.

The problem is that the council’s planning decisions are currently a long way from this objective for planning decisions, which can be evidenced in the inequality of nature provision across the borough. Protection and enhancement of biodiversity should be included and enforced as a common requirement across all planning applications. 


The Strategy needs identify the main causes of Camden’s ongoing and accelerating loss of biodiversity and decide:

  • Which of its own and others’ damaging activities the Council will set out to prevent
  • Which biodiversity enhancing actions it will undertake itself and which it will incentivise, advocate and encourage residents and developers to take.

The most extensive areas of wildlife habitat missing in the draft strategy are the borough’s private gardens. A rough estimate would suggest they amount to 20% of potential greenspace in Camden. They are a huge resource for wildlife: some contain veteran oak trees, others have ponds, yet others still have areas of acid grassland.  Camden should study Manchester’s nature-based solutions to climate change (see below), including the My Back Yard project, consisting of citizen research into the nature and extent of the city’s private gardens, engaging local people, raising their awareness of the valuable ecoservices performed by their gardens and helping them to improve their gardens’ contribution to well-being in Manchester. 

There is a thriving culture of gardening in Camden. Several private gardens are opened to the public annually as part of London’s Open Gardens scheme. Plant Heritage, the garden plant conservation and research society, holds its bi-annual plant sales just outside Camden in Highgate Village. A major effort should be made to follow Manchester’s well researched model and reach out to all Camden’s gardeners (including anyone who grows a plant on a window ledge) to raise their awareness of the vital role they and their windowsills, balconies and gardens play in sustaining, nurturing and developing the ecological well being of this and neighbouring boroughs. A these people’s help should be enlisted in an unprecedented campaign of local engagement and consultation.

Development is the most glaring threat to the borough’s fragile ecosystems. While many of Camden’s gardeners love wildlife and want to help to nurture and conserve it, large gardens, especially in the north of the borough, have currency as encashable wealth. The results of recent planning applications[5] suggest that, despite massive local protest, developers are still able to build on gardens that are extremely valuable to wildlife and local residents, and even adjacent to the Heath. If Camden Council had any real awareness of the ecological emergency we are in, such developments would never be permitted. 

Camden’s forthcoming Ecological Action Plan should include firm, time-bound commitments:

To engage in nature-based solutions to address climate change, as adopted by Greater Manchester:

  • My Back Yard[6] – reviewing the importance of domestic gardens
  • Living Laboratory part of the Urban Laboratory of Europe (Salford University);

To lay out a new system of multi-use green and blue infrastructure across the borough, learning from: 

  • IGNITION[7]:  Innovative Financing and Delivery of Climate Solutions in Greater Manchester – use of green and blue infrastructure to tackle climate-related challenges;
  • Planning for the Environment and Resource eFficiency in European Cities and Towns (PERFECT) [8], the European project on good practice in multi-use green infrastructure in towns and cities.

Camden’s Biodiversity Strategy outlines the ecological emergency we face. But over many years the borough has failed to change its own harmful practices such as using glyphosate on streets and estates and over-pollarding street trees. And most shamefully, it has a record of supine acquiescence to land-grabbing and tree felling by developers. The response proposed to the ecological crisis in Camden’s Draft Biodiversity Strategy does not yet suggest the borough intends to change its habits or do very much at all.

Camden could take this opportunity to lead the way for other boroughs by setting its own minimum level for biodiversity gain from developments:

  • Give the added protection of Local Greenspace (LGS) designation to many more of Camden’s currently designated SINC sites.  
  • Incorporate a requirement to achieve a net gain in biodiversity and to sustain it over 30 years into Camden’s Local Plan and into Camden Planning Guidance.

[1] https://www.camden.gov.uk/documents/20142/2205931/Camden+Biodiversity+action+plan.pdf/ab6c69bc-3769-3719-5481-a7fbc22555ce

[2] https://www.buglife.org.uk/our-work/b-lines/

[3] The rivers Kilburn, Tyburn and Fleet have all been ‘lost’, and now run into the sewers.

[4] https://www.pan-uk.org/glyphosate/

[5] www.hamhigh.co.uk/news/55-fitzroy-park-community-petition-against-overdevelopment-next-to-heath-3619438

[6] https://www.mmu.ac.uk/media/mmuacuk/content/documents/school-of-science-and-the-environment/urban-environments/MBY-ActionPlan.pdf://

[7] https://www.uia-initiative.eu/en/uia-cities/greater-manchester

[8] https://www.interregeurope.eu/perfect/

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