Old Oak TfL Consultation Letter

7/29/2019 Old Oak TfL Consultation Letter

http://slidepdf.com/reader/full/old-oak-tfl-consultation-letter 1/5

Councillor Lester HollowayLondon Borough of SuttonLiberal Democrat Councillor for Sutton North Ward

Your Ref Tel: 07527 216 829My Ref: Date: 5th Sept 2013e-mail: [email protected]

Boris Johnson:The Mayor of LondonOld Oak Vision ConsultationGreater London AuthorityCity HallThe Queens WalkLondon SE1 2AA

Dear Mr Johnson,

OLD OAK VISION CONSULTATION

I object strongly to the proposed destruction of Scrubs Wood, a strip of railway land running along the northern border of Wormwood Scrubs openspace.

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 thearea. I used to be the ward councillor for the area from 1994, whichincludes the vast majority of the Old Oak site covered in the TfLconsultation. 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 togo birdwatching at Scrubs Wood as a teenager and, from 1985-87, I waspart of a mostly successful campaign to save the land from destruction tomake way for Channel Tunnel depots. I am now part of the new ‘Save theScrubs’ campaign established to oppose the new proposal to destroyScrubs Wood.

Scrubs Wood – Missing from the Consultation

It 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 inthe consultation material despite Scrubs Wood having received significantmedia coverage over decades, including TV and newspaper reportsconcerning the ‘Urban Birder ’ David Lindo, and before that during the mid1980’s when there was a high-profile campaign to save this land fromdestruction; a campaign I was involved with at the time. There have beenseveral ecological studies by respected environmental organisations and

Please reply to:Councillor Lester

Holloway

London Borough of

Suttonc/o Civic OfficesSt. Nicholas WaySuttonSM1 2EA

www.sutton.gov.uk

Blog – cl l r lesterhol loway.wo

rdpress.com

Twitter – @brolezhol loway



consultants specifically focussed on Scrubs Wood, and Scrubs Wood hasbeen acknowledged by the London Wildlife Trust, Groundwork UK, CPREand Hammersmith & Fulham Council who have referred to it in publicityliterature and called it an “area of metropolitan importance” on their website.Therefore the omission of reference to Scrubs Wood and its ’ wildlife in theis a significant error which means the consultation is misleading to thepublic and consequently fatally flawed.

Scrubs Wood – Wildlife

Mr Lindo, star of TV birdwatching programmes, has proven the area is amagnet for migrating birds including Pied Flycatcher; Dartford and WoodWarblers; Honey Buzzard; Richard’s, Rock and Tree Pipits; Osprey; MarshHarrier; Turtle Dove; Long and Short-Eared Owls; Black Redstart; GreatGrey Shrike; Nightingale; and Ortolan Bunting to name but a few. ScrubsWood is also an important site for Common Lizards and over 20 species of butterfly including several species of Skippers. It is a favourite for breedingLesser Whitethroats, has often seen breeding Skylarks, and attracts

wintering Redpolls and Siskins. Nature studies have also highlighted thepresence of voles, rare flora and fauna, bats, weasels, rabbits and athriving colony of lizards. In Inner London terms, Scrubs Wood must rank inthe same category as the Welsh Harp for the significance of it’s’ wildlife.

Reference to wildlife in the consultation

The 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 theproposed development. The document says: “The unique character of thespaces would be retained, particularly for wildlife and recreational use, and

new high quality green spaces would be created for the benefit of existingand future residents.” This statement is seriously misleading and theimplication that wildlife would be “retained” is entirely untrue with regards tothe land that contains the vast majority of wildlife, Scrubs Wood.

“Semi-derelict industrial” land

The document claims the area is “derelict and under -used land” and is also“semi-derelict industrial” land. Aside from confusion as to whether the landis derelict or semi-derelict, both claims are entirely untrue in the case of Scrubs Wood. There is substantial evidence that Scrubs Wood is anextremely valuable wildlife haven and ecological paradise. Therefore thedocument is misleading and untrue.

Proposals contradict House of Lords

The plan to destroy Scrubs Wood is in direct contradiction to the majoritysentiments expressed by the House of Lords on the Channel Tunnel BillCommittee in 1987 (clause 36), who recognised the ecological value of Scrubs Wood and ordered the then British Rail to protect the vast majorityof 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 notneed 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 99species are recorded as having been found there, many of them breedingspecies. But many more are migrating birds using the land on their way toand from warmer climates. A little wilderness has grown up alongside therailway track [and] has accidentally created a marvellous habitat for wildlife.

Ornithologists and bird watchers in the area have established a kind of squatters’ right to it.”

Wildlife management has improved ecological value

In the 26 years since Lord Kilbracken made his statement carefulenvironmental management of the habitat overseen by Groundwork UK andother 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 land

The Nature Reserve on Wormwood Scrubs common land is popular withschool children from Hammersmith and Fulham and surrounding boroughs.However this Nature Reserve, and all its’ wildlife, is entirely reliant on theadjoining much larger Scrubs Wood on railway land. The proposeddestruction of Scrubs Wood would therefore decimate the environmentalvalue of the Nature Reserve, stripping it of all wildlife that currently enjoysthe Scrubs Wood habitat.

Wormwood Scrubs common land

The consultation graphics / artists impressions clearly show a railway line(Overground) and station built on Wormwood Scrubs common land. Thiscontravenes the Wormwood Scrubs Act 1879 which forbids “permanenterections” of anything other than army rifle butts and “their relatedappurtenances.” In addition, the plans seem to show the common landbeing divided up by rows of trees across the common. This will bedetrimental to community safety, will restrict the use of the land for smallaircraft enthusiasts, and will take the land permanently out of use asfootball / rugby fields which used to extend to the west but appear to berestricted 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 GrandUnion Canal Conservation Area, which is a haven for wildlife includingwaterfowl and dragonflies. Artists impressions depict six-storey housingblocks built right up to the waterfront with no allowances for wildlifewhatsoever. I note that the area covered by the Grand Union CanalConservation Area is omitted from the “Green Links” map. I can onlyassume 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 site

I am concerned that this proposed development has come forward withoutany planning framework to provide an overarching strategic vision for theland. I note that City Hall are currently busy writing an Opportunity AreaPlanning Framework while the public consultation is underway; this is

unacceptable. L.B. of Hammersmith and Fulham are also working on astrategic plan after proposals have been put out to consultation. Thereforethe area is not currently subject to a strategic vision that should guidedevelopment plans, and to consult at this stage is putting the cart beforethe horse.

Rushed timescale

The public consultation proposes a ridiculously short timescale fromconsultation to construction. TfL plan to have completed nine steps in theplanning process by “early 2014” which suggests that a number of steps

may have been completed before a strategic vision is in place.

Over-development

Cramming 19,000 homes into 155 hectares constitutes a gross over-development, and restricts opportunities for social infrastructure such asschools 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 thuseven greater over-development. The comparison in the consultationdocument with Canary Wharf in terms of height and scale is entirely

inappropriate as west London does not require a Canary Wharf-styledevelopment, especially as what is being proposed is primarily housing notbusinesses.

High rise blocks

I can see no justification in the consultation for high rise developmentapproaching ‘skyscraper ’ heights on the site other than it would provide a“landmark.” The erection of “landmarks” in this area is completelyunnecessary and their inclusion would need substantiating beyond thisflimsy justification.

Regeneration and local facilities

The nearest shopping centre is the run-down Willesden High Street andrecent history of major developments in LBH&F – in particular Westfield – demonstrate that promises of trickle-down stimulation of private investmentand regeneration in surrounding areas does not necessarily materialise.Thus suggestions in the Old Oak consultation that the proposeddevelopment will automatically lead to regeneration of areas like Old Oakestate are at best fanciful and certainly unsubstantiated.



Job creation – figures do not add up

TfL’s figures in their consultation document do not appear to add up andestimates of 90,000 jobs being “created” do not tally with the small areaear-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 aneleven 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 thesefigures do not involve jobs being created at all but factor in guesstimatesabout additional economic activity for the capital as a whole rather than theOld Oak development specifically, as well as counting existing constructionworkers and suppliers of materials that would be involved for a short periodbuilding the project rather than long-term economic benefit.

Population density, lack of social housing and social engineering

The proposed development would make College Park and Old Oak wardarguably the most populous ward in Britain. The complete absence of any

reference to social housing in the consultation would suggest that thedevelopment would socially-engineer this ward – which has historicallybeen a ‘solid’ Labour ward – into a Conservative-supporting ward in one go,and thus constitute a far more extensive reorientating of the political mapthan Westminster Council were accused of. There is only one brief reference to affordable housing, however there is no mention of whatproportion and in any case there has been extensive debate about how‘affordable’ housing is no longer affordable for all but top bracket earners.

Public reaction

Almost 1,900 mostly local citizens have signed a Change.org petition whichwas launched in response to the consultation. There are also hundreds of comments by petitioners with a high proportion citing wildlife andparticularly rare birds – including a colony of breeding Meadow Pipits – askey reasons for rejecting the proposal.

Conclusion

There may be development opportunities on parts of the industrial land,however I object strongly to Phase 4 proposing the destruction of ScrubsWood. I wish to see Scrubs Wood preserved in its’ entirety and wildlifeprotected alongside the canal and no building on Wormwood Scrubscommon land. I also believe that the rest of the concentrated, high-densityand high-rise development be dramatically scaled back on all three fronts.

Yours sincerely

Councillor Lester Holloway

Old Oak TfL Consultation Letter

Documents

Transcript of Old Oak TfL Consultation Letter