My Letter to Boris Johnson Over Threat to Destroy Scrubs Wood

Boris Johnson: The Mayor of London, Old Oak Vision Consultation, Greater London Authority, City Hall, The Queens Walk, London SE1 2AA. Thursday 5th September 2013Dear Mr Johnson,OLD OAK VISION CONSULTATIONI object strongly to the proposed destruction of Scrubs Wood, a strip of railway land running along the northern border of Wormwood Scrubs open space.Obviously the Old Oak consultation is not within the L.B. of Sutton however I count myself as an interested party because of my historic links with the area. I used to be the ward councillor for the area from 1994, which includes the vast majority of the Old Oak site covered in the TfL consultation. I was born and raised locally, grew up in the Old Oak estate, and was a member of the local tenants and residents association. I used to go birdwatching at Scrubs Wood as a teenager and, from 1985-87, I was part of a mostly successful campaign to save the land from destruction to make way for Channel Tunnel depots. I am now part of the new ‘Save the Scrubs’ campaign established to oppose the new proposal to destroy Scrubs Wood.Scrubs Wood – Missing from the ConsultationIt is clear from graphics and artists impressions that the entire length of Scrubs Wood is earmarked for complete destruction under these plans. Astonishingly Scrubs Wood and its’ wildlife are not mentioned anywhere in the consultation material despite Scrubs Wood having received significant media coverage over decades, including TV and newspaper reports concerning the ‘Urban Birder’ David Lindo, and before that during the mid 1980’s when there was a high-profile campaign to save this land from destruction; a campaign I was involved with at the time. There have been several ecological studies by respected environmental organisations and consultants specifically focussed on Scrubs Wood, and Scrubs Wood has been acknowledged by the London Wildlife Trust, Groundwork UK, CPRE and Hammersmith & Fulham Council who have referred to it in publicity literature and called it an “area of metropolitan importance” on their website. Therefore the omission of reference to Scrubs Wood and its’ wildlife in the is a significant error which means the consultation is misleading to the public and consequently fatally flawed.Scrubs Wood – WildlifeMr Lindo, star of TV birdwatching programmes, has proven the area is a magnet for migrating birds including Pied Flycatcher; Dartford and Wood Warblers; Honey Buzzard; Richard’s, Rock and Tree Pipits; Osprey; Marsh Harrier; Turtle Dove; Long and Short-Eared Owls; Black Redstart; Great Grey Shrike; Nightingale; and Ortolan Bunting to name but a few. Scrubs Wood is also an important site for Common Lizards and over 20 species of butterfly including several species of Skippers. It is a favorite for breeding Lesser Whitethroats, has often seen breeding Skylarks, and attracts wintering Redpolls and Siskins. Nature studies have also highlighted the presence of voles, rare flora and fauna, bats, weasels, rabbits and a thriving colony of lizards. In Inner London terms, Scrubs Wood must rank in the same category as the Welsh Harp for the significance of it’s’ wildlife.Reference to wildlife in the consultationThe only reference to wildlife in the consultation is presented as an asset, clearly implying that this land will not in any way be affected by the proposed development. The document says: “The unique character of the spaces would be retained, particularly for wildlife and recreational use, and new high quality green spaces would be created for the benefit of existing and future residents.” This statement is seriously misleading and the implication that wildlife would be “retained” is entirely untrue with regards to the land that contains the vast majority of wildlife, Scrubs Wood.“Semi-derelict industrial” landThe document claims the area is “derelict and under-used land” and is also “semi-derelict industrial” land. Aside from confusion as to whether the land is derelict or semi-derelict, both claims are entirely untrue in the case of Scrubs Wood. There is substantial evidence that Scrubs Wood is an extremely valuable wildlife haven and ecological paradise. Therefore the document is misleading and untrue.Proposals contradict House of LordsThe plan to destroy Scrubs Wood is in direct contradiction to the majority sentiments expressed by the House of Lords on the Channel Tunnel Bill Committee in 1987 (clause 36), who recognised the ecological value of Scrubs Wood and ordered the then British Rail to protect the vast majority of the site and invest a significant amount of money on remedial landscaping works. Lord Kilbracken told a Lords committee: “The Committee must be quite well acquainted with Scrubs Wood and will not need reminding of its importance as a habitat not only of insects and plants, including trees, but in particular of birds which are my interest. Some 99 species are recorded as having been found there, many of them breeding species. But many more are migrating birds using the land on their way to and from warmer climates. A little wilderness has grown up alongside the railway track [and] has accidentally created a marvelous habitat for wildlife. Ornithologists and bird watchers in the area have established a kind of squatters’ right to it.”Wildlife management has improved ecological valueIn the 26 years since Lord Kilbracken made his statement careful environmental management of the habitat overseen by Groundwork UK and other volunteers has enhanced the wildlife of Scrubs Wood even further. Therefore the sentiments of Peers should be seen in the context that over time the area has become even more important for wildlife.Impact on Nature Reserve on common landThe Nature Reserve on Wormwood Scrubs common land is popular with school children from Hammersmith and Fulham and surrounding boroughs. However this Nature Reserve, and all its’ wildlife, is entirely reliant on the adjoining much larger Scrubs Wood on railway land. The proposed destruction of Scrubs Wood would therefore decimate the environmental value of the Nature Reserve, stripping it of all wildlife that currently enjoys the Scrubs Wood habitat.Wormwood Scrubs common landThe consultation graphics / artists impressions clearly show a railway line (Overground) and station built on Wormwood Scrubs common land. This contravenes the Wormwood Scrubs Act 1879 which forbids “permanent erections” of anything other than army rifle butts and “their related appurtenances.” In addition, the plans seem to show the common land being divided up by rows of trees across the common. This will be detrimental to community safety, will restrict the use of the land for small aircraft enthusiasts, and will take the land permanently out of use as football / rugby fields which used to extend to the west but appear to be restricted only to the east of the common land in the plans.Grand Union Canal Conservation Area / “Green Links”The consultation plans show substantial development covering the Grand Union Canal Conservation Area, which is a haven for wildlife including waterfowl and dragonflies. Artists impressions depict six-storey housing blocks built right up to the waterfront with no allowances for wildlife whatsoever. I note that the area covered by the Grand Union Canal Conservation Area is omitted from the “Green Links” map. I can only assume that is because there are no plans to protect wildlife in the conservation zone. I am very concerned about this.No strategic plans for Old Oak siteI am concerned that this proposed development has come forward without any planning framework to provide an overarching strategic vision for the land. I note that City Hall are currently busy writing an Opportunity Area Planning Framework while the public consultation is underway; this is unacceptable. L.B. of Hammersmith and Fulham are also working on a strategic plan after proposals have been put out to consultation. Therefore the area is not currently subject to a strategic vision that should guide development plans, and to consult at this stage is putting the cart before the horse.Rushed timescaleThe public consultation proposes a ridiculously short timescale from consultation to construction. TfL plan to have completed nine steps in the planning process by “early 2014” which suggests that a number of steps may have been completed before a strategic vision is in place.Over-developmentCramming 19,000 homes into 155 hectares constitutes a gross over-development, and restricts opportunities for social infrastructure such as schools and shops. Further, including of a 40,000-seater stadium for Queens Park Rangers will either dramatically scale down the promises of 19,000 homes or lead to an even higher density development and thus even greater over-development. The comparison in the consultation document with Canary Wharf in terms of height and scale is entirely inappropriate as west London does not require a Canary Wharf-style development, especially as what is being proposed is primarily housing not businesses.High rise blocksI can see no justification in the consultation for high rise development approaching ‘skyscraper’ heights on the site other than it would provide a “landmark.” The erection of “landmarks” in this area is completely unnecessary and their inclusion would need substantiating beyond this flimsy justification.Regeneration and local facilitiesThe nearest shopping center is the run-down Willesden High Street and recent history of major developments in LBH&F – in particular Westfield – demonstrate that promises of trickle-down stimulation of private investment and regeneration in surrounding areas does not necessarily materialise. Thus suggestions in the Old Oak consultation that the proposed development will automatically lead to regeneration of areas like Old Oak estate are at best fanciful and certainly unsubstantiated.Job creation – figures do not add upTfL’s figures in their consultation document do not appear to add up and estimates of 90,000 jobs being “created” do not tally with the small area ear-marked for businesses, which can only amount to a very limited number of small retail outlets. The first 10,000 homes, proposed to be built within an eleven year period, are estimated to ‘create’ 10,000 jobs while the next 9,000 homes will apparently lead to 80,000 jobs. I can only assume these figures do not involve jobs being created at all but factor in guesstimates about additional economic activity for the capital as a whole rather than the Old Oak development specifically, as well as counting existing construction workers and suppliers of materials that would be involved for a short period building the project rather than long-term economic benefit.Population density, lack of social housing and social engineeringThe proposed development would make College Park and Old Oak ward arguably the most populous ward in Britain. The complete absence of any reference to social housing in the consultation would suggest that the development would socially-engineer this ward – which has historically been a ‘solid’ Labour ward – into a Conservative-supporting ward in one go, and thus constitute a far more extensive reorientating of the political map than Westminster Council were accused of. There is only one brief reference to affordable housing, however there is no mention of what proportion and in any case there has been extensive debate about how ‘affordable’ housing is no longer affordable for all but top bracket earners.Public reactionAlmost 1,900 mostly local citizens have signed a Change.org petition which was launched in response to the consultation. There are also hundreds of comments by petitioners with a high proportion citing wildlife and particularly rare birds – including a colony of breeding Meadow Pipits – as key reasons for rejecting the proposal.ConclusionThere may be development opportunities on parts of the industrial land, however I object strongly to Phase 4 proposing the destruction of Scrubs Wood. I wish to see Scrubs Wood preserved in its’ entirety and wildlife protected alongside the canal and no building on Wormwood Scrubs common land. I also believe that the rest of the concentrated, high-density and high-rise development be dramatically scaled back on all three fronts.