It’s been a busy week. A group of the friends - DavidJ, DaivdL, Nina, Miriam, Ian, Stephanie, Dan, Susie (anyone I’ve forgotten?) - met with TFL. David J has been working on our group response to the HS2 consultation. We should all now produce individual responses to the HS2 consultation. We’re having an ad hoc meeting on Tuesday to allocate responsibilities a bit more clearly. And there’s a meeting with the deputy mayor in charge of transport in 10 days to prepare.
First the meeting with TFL. This was attended by people from the GLA and LBHF as well as the friends. TFL have another option apart from the viaduct - Option X - which we think is better. It does not encroach on the Scrubs and makes more use of Willesden Junction to solve the train line problem that the viaduct loop is also trying to solve. It is not TFL’s preferred option, but it seems that there is some support for it at LBHF, GLA and the department for transport. Our task is now to build support for Option X over the viaduct loop.
Second, the consultation on HS2. This is not the main battle we face, which is with TFL around their viaduct and, in the future, with the planned Mayoral Development Corporation with buildings. But it nevertheless could potentially have a major impact on the Scrubs and we need to respond.
DavidJ is drafting our group response and has taken on board the comments raised at the last campaign meeting. Our basic position is that we don’t think that the proposal for a wetland to run all along the southern edge of the Scrubs is a good idea. It takes away an area already rich in biodiversity; it crowds out leisure users and puts even more pressure on open space for our common enjoyment. It seems to be a generally ill-thought-through proposal tacked on to the HS2 bill at the last moment. I’ve pasted David’s text with the details of our objections to the bottom of this email.
As well as a group response, it would be good to get as many individual responses as possible. The form for responses can be downloaded here:
filling out the form involves the following steps:
- fill out your name and address on page 2
- tick “Kilburn to Olad Oak Common” on the multiple choice at Question 3, page 5
- fill out the box on question 3 with your reasons for objecting. It’s good to write in your own objections, but just as an example, here is what I wrote:
I am writing to express my objection to the proposal for new wetland planting of an area to the north and west of Linford Christie Stadium as “habitat compensation”.
My reasons are as follows:
- this is not real compensation, in that it would destroy a planted area already rich in biodiversity
- this area is under constant and intense use by the already constrained users of the scrubs. Current users of this space include rugby players, dog walkers, walkers, kiters and families. There is already insufficient room on the Scrubs to accommodate all those who want to enjoy the space. This proposal will further crowd the environment
- this sort of habitat is difficult and expensive to maintain properly, and the likelihood is that within a short time it would be left derelict and without a maintenance budget
- this would cut off an integral part of the Scrubs – the stadium – from the rest of the scrubs and would threaten the integrity of the space and its use for enjoyment of sports people and families
That’s all for this week. The Scrubs is pretty boggy and slippery at the moment, but still being enjoyed by huge numbers!
David J’s detailed group response to the HS2 consultation:
1.The objects of the Friends according to its constitution include the protection and conservation of the Scrubs in accordance with the Wormwood Scrubs Act 1879 (“the 1879 Act”). Under the 1879 Act the Scrubs is held in trust by the London Borough of Hammersmith and Fulham, subject to its military use, for use by the public for exercised and recreation. The last military use was until the beginning of 2012 by the King’s Troop,Royal Horse Artillery.
2.The Scrubs is a registered common. It is protected by (i) the 1879 Act (ii) the Ministry of Housing and Local Government Provisional Order Confirmation (Greater London Parks and Open Spaces) Act 1967 and (iii) the Commons Act 2006. These Acts between them require government ministerial consent to the construction of any building or erection on the Scrubs, the enclosure of any part of it or work which impedes access over it. Under the 1879 Act any construction additionally requires the consent of LBHF as trustee.
3. The Scrubs is designated Metropolitan Open Land and part of it is a Local Nature Reserve.
4. There are two proposals in CFA 4 that directly affect the Scrubs (i) the use of the north western corner as access to Old Oak Common for the purpose of works to Old Oak Common Lane (principally road widening and lowering) (ii) new wetland planting of an area to the north and west of Linford Christie Stadium as “habitat compensation”.
5. As to (i) this is referred to in paras 2.4.50, 5.4.20, 9.4.7, 9.4.20 and 9.5.2 and is said (5.4.20) to involve “access to a small area of land at the northern edge of Wormwood Scrubs Park (less than 5%).” The area concerned is shown in Plans Volume 1 Euston-Ickenham sheet 1-16 and Map Books Volume 2 CT-005-009a. It is clear from these references that vegetation, trees and shrubs will be removed from the western end of the Scrubs and from the embankment “close to North Pole Depot”. 9.5.2 includes “…Measures that have been incorporated into the design of the Proposed Scheme include: woodland planting to replace trees and shrubs removed from Wormwood Scrubs (around the new access road to the North Pole depot)”.
The Friends are reliant on the work being confined to the area as described and the vegetation, trees and shrubs being replaced. Subject to
(i) preparation of a schedule of vegetation, trees and shrubs to be removed
(ii) an assurance that such vegetation etc will be replaced with similar vegetation etc
(iii) replacement of vegetation etc to be completed within 12 months of completion of work/end of use of work space
the Friends have no comment to make on this proposal.
6. As to (ii) this is referred to in paras 2.4.44, 5.4.20, 7.4.19 and shown in Plans Volume 1 as before sheet 1-52 and Map Books Volume 2 CT-05-009a, CT-06-009a, CT-05-008- L1, CT-06-008-L1. Para 2.4.44 asserts that “an area of Wormwood Scrubs immediately to the north and west of Linford Christie Stadium has been identified for habitat compensation and currently comprises amenity grassland and areas utilised by sports groups.” 5.4.20 says that a “small area near the southern periphery of Wormwood Scrubs will be used for ecological mitigation. This will not affect land used for recreational sports pitches.” 7.4.19 adds after discussion of the loss of certain habitat elsewhere “Given that opportunities to mitigate at the site of the impact are limited, a compensatory area of new wetland planting will be provided in the southern part of Wormwood Scrubs…This will include the creation of seasonal pools and scrapes with swales planted with…species such as rushes and sedges and areas of wildflower grassland and native shrubs. The new habitats will be sited appropriately to allow continued use of the recreational sports pitches within the defined area linking to existing areas of woodland and grassland habitats”.
7. The area stretches virtually the whole width of the Scrubs from east to west, stopping short at the woodland on the western boundary. Its northern edge runs deep into the Scrubs and its total area is more than eight hectares, in excess of a tenth of the total of the Scrubs. The Friends would challenge the statement in 5.4.20 that it is no more than a “small area” (see above). The Report is silent as to how or why the area has been “identified for habitat compensation” nor is there any mention of the proposal in the Draft Environmental Statement, hence there has been no previous consultation about it. There are references from para 7.4.4 onwards to loss of habitat from Acton Railsides, Northolt Corridor and Silverlink Metro and Dudding Hill Loop none of which is identified as wetland and, apart from the general statement at 7.4.19 (see above), the nature of the loss intended to be compensated is unspecified.
8. In any event the proposal is not creating fresh space to compensate for loss of habitat elsewhere (principally adjacent to railway lines): it is taking an existing open space out of use to accommodate ecological enhancement. The effect is to rob Peter to pay Paul.
9. At first sight the creation of a wetland habitat on a site (the Scrubs) part of which is already LNR might seem attractive but, on closer examination, the Friends consider that any possible advantage is illusory and outweighed by the disadvantages such as
(i) no survey seems to have been carried out as to the suitability of the area for conversion to wetland
(ii) no reason is given why the Scrubs has been chosen for such habitat compensation
(iii) a significant amenity presently used for general recreation and sport will be taken out of such use. There is at present considerable pressure on the use of the area for sport, two football pitches having been recently added to the western end. The increase in sports use of the Scrubs drives other recreational users into what is becoming a diminishing space. The Scrubs can ill afford to lose the area to ecological enhancement
(iv) the area is valued for its existing biodiversity which would be destroyed
(v) the area would be out of use during its conversion
(vi) substantial inconvenience would be caused to users of the Scrubs while the area was being converted
(vii) there is no plan for the use of the area once converted, e.g. whether it would be fenced or require separate access
(viii) there is no plan for its maintenance or how it would be funded once completed
(ix) it would impede access to and egress from the rest of the Scrubs from and to the public car park south and east of the area and Hammersmith and Queen Charlotte’s Hospitals.