MASTERPLAN RESPONSE - please take action to support us!
Dear Friends,
The Masterplan has been long in the making, and the final version is sadly not what we’d hoped, despite our considerable contribution to all the discussions.
The first letter is our explanation of this, and our request to you to take action quickly to support this view.
The second letter is what we are writing to the OPDC; the third letter is what we are writing to the Wormwood Scrubs Charitable Trust. These two are also in the attachments.
Firstly, here is our formal response to the planning application made by Wormwood Scrubs Charitable Trust (WSCT) to Old Oak and Park Royal Development Corporation (OPDC), who are the planning authority for the Scrubs excluding Linford Christie Stadium, for those works requiring planning approval in connection with the Masterplan. You will see that we are objecting to:
The location of the pond and the resulting need for a borehole
The provision of excessive hard standing adjacent to the pond
The provision of excessive paths, and the risks of cycles etc., on all the proposed paths
The design and location of swales blocking the pedestrian route from LCS to the playing fields.
The total lack of consultation on this plan, which is different from those previously consulted on, though ignoring the many comments made by FOWWS and individual Friends.
Please write to OPDC in support of any of these points, or any others you wish to make.
All the documents say responses should be sent by April 19th, but if you cannot achieve this, it doesn’t really matter, so please do send your views anyway, as they have to be considered if they arrive before the application comes to the planning committee, which will not be until well into May at the earliest.
It’s most effective if you use your own words, even if you copy some of ours, rather than us providing a standard letter. You can also just write and say you support the whole of what we have written. PLEASE WRITE!
Your comments should go to
planningpolicy@opdc.london.gov.uk
You can send copies to any Councillors or MPs or others you wish to inform.
To see and study the full application, you can go to
https://planning.agileapplications.co.uk/opdc/application-details/10329
You may have to register first, but then click on Documents to see the plans and details – the Design and Access Statements, parts 1 to 4 give a summary of all the proposals, including plans and other drawings.
Secondly, we have written to Cllr Alex Sanderson, WSCT Manager Osama El-Amin, and WSCT Development Manager Vicky Abel with our comments on the rest of the Masterplan which does NOT need formal planning consent, but is planned for implementation.
You will see that we* think there are too many hedges, cutting the meadow area into unsatisfactory small sections and taking risks with safety issues, particularly for women walking alone; too many ‘biodiversity features’ scattered like confetti; and some signs seem to have become extremely large. We make some other points too, as you can see.
Here also, we’d very much like you to add your voices; one email to them all would work well, (click here to email all 3) to these email addresses: you can also write to other Councillors you may know.
I am very grateful to Trustees Smita Dave and Sarah Abrahart and to Henry Peterson and Tilly Collins for their work and help in preparing these two letters, which have now been approved by all your Trustees.
Best wishes
Stephen Waley-Cohen
*the majority of Trustees agree with this, with one suggesting much shorter lengths of more carefully located new hedging to avoid blocking walkers, one suggesting new hedging should only be round the edge of the meadow area, one supporting all the new hedging.
FOWWS RESPONSE TO OPDC
Planning Application 24/0036/FULOPDC
This is the formal response from the Friends of Wormwood Scrubs (FOWWS) to the Planning Application from Wormwood Scrubs Charitable Trust (WSCT) by consultants LUC as being for Alternative Ecological Mitigation, but will be referred to as the Masterplan.
We regret that we are writing with objections and opposition to a disappointingly large proportion of its proposals.
FOWWS is a charity representing about 500 regular users and supporters of the area owned and managed by WSCT. Our purpose is the protection and promotion of the Scrubs, and our role is recognised by WSCT both by regular discussions and consultations, and by the co-option of 2 nominees of FOWWS to the WSCT sub-committee of the London Borough of Hammersmith & Fulham (LBHF) tasked by LBHF, as sole Trustee of WSCT, to manage the Scrubs.
The primary purpose of the Masterplan, funded by HS2, is supposed to be the ecological enhancement of the Scrubs, which FOWWS fully supports; unfortunately, the proposed works in the area covered by the planning application footprint will in reality cause the opposite effect.
The guiding principles of the Masterplan and this application are to retain the wilderness and openness aspects of the Scrubs, and to introduce greater biodiversity, but in reality the proposals contain significant interventions that are the opposite of this principle, with the introduction of features that will require major and permanent management and maintenance.
FOWWS strongly support the guiding principles, and acknowledge their involvement in consultations over an extended period, but regret certain aspects of the application. We also disagree with some aspects of the Masterplan which are not part of the application, and are writing separately to WSCT to express and explain our reasons for those disagreements.
OPDC have long recognised the special nature of the Scrubs by their formal adoption of the description ‘more wild than tamed’ for the Scrubs, but the proposals in the planning application are all designed to reduce the wildness and enhance the tameness.
The application disregards points made previously by FOWWS and others, in particular the location of the proposed pond, the locations of some of the swales, and the very large increase in hard paths.
In addition, and contrary to the impression given in the submission, there has been a total lack of consultation on this plan, which is different from those previously consulted on.
We are concerned at the significant increase in maintenance costs that the proposed works, especially the pond, will require, and question whether there will be sufficient finance available in both the short and long term.
The Pond
The proposed pond location is at one of the higher points of the Scrubs – not one of the lower, which is misleadingly implied in the application - which is also in one of the most biodiverse habitat zones of the Scrubs. The proposed location is inappropriate.
We note from the contractors’ documentation in the application that the pond, and perhaps the swales, will require dredging every three years, which will be a major intrusion and highly negative to any biodiversity achieved. This is a further reason for moving its location, if it is retained at all, to one of our suggested positions in either the south west or south east corners of the planning application area north of the prison.
There appears to be no recognition or understanding of the existing biodiverse richness of this part of the Scrubs, with its manifold grasses, lizards, butterflies and other wildlife. Lizards, like all native reptiles, are protected species, and that we understand that their principal breeding ground may be in the area of the gaelic football pitches, where major path and pond work is applied for. If consent is granted for the plans, as proposed, it may be necessary to organise their total relocation, which might take a whole breeding season, before any work should be allowed to start, further delaying the Masterplan implementation
As outlined in the application, this will require a borehole, of unstated depth, and no mention of the necessary power and equipment to operate it. It is stated, with no supporting information, that the ecological impact will be negligible, but to us it appears invasive and intrusive. In the hotter drier climate we are warned to expect, and on a site which is naturally dry (the Scrubs always develops significant cracks in dry summers), there are no convincing or supporting arguments to justify the statement that the impact will be minimal. Unnecessary works in a location that currently manifests a huge level of biodiversity are bound to have a negative impact.
We fully recognise the desirability of wetland features, and support those within Martin Bell’s wood to the south east of the planning application area. (We also support those in the north-west corner of the Scrubs, outside the application area)
We believe that the proposed pond, should it be retained at all, should be located in the planning application area in either the south west or south east corners as these have naturally higher water provision, will cause less disturbance during construction and subsequent three-yearly dredging.
We note that all the illustrations misleadingly fail to show the need for the pond to have a surrounding fence, which is included in the proposed site plan. We expect that a fence will be essential to protect the pond from dogs, and to protect children from the risks associated with this pond.
There is substantial evidence (please see Appendix A) that allowing dogs to use ponds in urban areas destroys banking (and then requires concrete entrance points) reduces the biodiversity, damages water edge plants, and deters birds, and poisons the water as a result of pesticide residues.
We note the proposed depth of the pond at about 60-85cm which is quite shallow for a pond to achieve worthwhile biodiversity, although it will require excavation to about 1.5 to 2m to form the base. We do question the validity of the pond but if it is to be retained, strongly suggest one of the other less intrusive locations already identified above.
Hard Standing adjacent to the Pond
We do not think it appropriate to have a substantial area of hard standing adjacent to the pond, as this will be an invitation to antisocial behaviour within earshot of the hospital and the prison. (The propensity to antisocial behaviour was evidenced by the provision of two picnic tables at the terminus of the hard paths onto the Scrubs at the northern end of Braybrook Street, which had to be removed within weeks of their erection, due to their immediate use for mini-raves and drinking events).
Any hard standing should be very minor, and any benches or picnic tables restricted to a minimum. This will still risk antisocial behaviour, to the detriment of all other users. Any hard standing will become a focus for requests for lighting in that area, something to which all voices have been opposed, for many reasons including its negative impact on biodiversity and wildlife.
We question whether the Hospital, the Police or the Prison authorities have been consulted.
Paths
The proposed placement of the pond is driving the placement of paths, and we wish to state our view that there are more proposed than are necessary, and these, identified below, should be eliminated.
The Northern most path is useful to connect the Linford Christie Stadium (LCS) and parking area to the Braybrook Street playground area in terms of benefits for child-buggies and wheelchairs. BUT, it will also attract bicycles, e-cycles and e-scooter traffic, including delivery riders and illicit drug activity.
Cycling is not now permitted on the Scrubs, per bye-laws, and this path will make that impossible to enforce. The Law Enforcement Team are currently unable to control the professional dog walkers who disregard the dog management requirements in the PSPO, and this path will invite totally unenforceable disregard of the rules against bicycles etc.
The eastern-most path is already a grass path along meadow grasses and there is a parallel existing hard (tarmac) route, relatively close, slightly further east. The southern path also runs parallel, and relatively close to, an existing hard (tarmac) path, and neither of these are necessary.
Appendix B sets out studies showing why broad paths such as those proposed create population fragmentation for ground-dwelling insects and other small animals, of which lizards are of particular concern on the Scrubs. Many walking/crawling insects avoid crossing the exposed path surfaces as the microclimate is not suitable. Putting broad paths across what is currently a broadly contiguous and biodiverse meadow-ish area threatens to fragment populations and potentially reduce genetic diversity of some species.
Swales
FOWWS welcome the principle of swales for biodiversity and water management.
They do bring with them an added problem of litter, and the trial swales already show this, with bicycles and other detritus dumped in them. The proposal to plant attractive wild flowers, while on the face of it desirable, also detracts from their healthy aspect of encouraging children to run up and down slopes, an opportunity that is in very short supply in the Scrubs and in other LBHF open spaces.
Those outside the entrance to LCS– previously agreed to require the provision of sensible pedestrian access from the stadium to the playing field area – now comprise an excessive number of poorly-placed swales.
There is a need to ensure a proper pedestrian access between LCS, which is used for the storage of sports equipment, water and changing room facilities, and the sports field area.
This area is heavily used by hundreds of players and supporters for football, baseball, lacrosse, gaelic football, and running events and tournaments throughout the year. As currently proposed, access to the sports field will be severely restricted not only by the swales but also by the proposed further tree planting in that area, and will significantly hinder the movement of people.
We question whether the principal sports users have been consulted, including gaelic football club, Kensington Dragons, London Sports and others.
Summary
FOWWS are disappointed to have to write so negatively about this application, and in formal objection to many of its proposals – the location of the pond, the need for a borehole, the excessive number of paths, the provision of a large hard standing area, and the location of some swales, as we so strongly favour biodiversity and the improvements that this might bring to the Scrubs to the benefit of current and future users.
Finally, we regret that there is no postal address, as opposed to digital, which might enable any of those older users and potential users to comment who may not be digitally comfortable.
Your sincerely,
Sir Stephen Waley-Cohen
Chairman, Friends of Wormwood Scrubs
Prepared by the Trustees of FOWWS with added support from FOWWS planning adviser Henry Peterson, and FOWWS honorary ecologist, Dr T. Collins.
Appendix A
Pond parasiticide contamination – dog swimming
from a manuscript in preparation:
Dog swimming and ectoparasiticide water contamination in urban conservation areas:
a case study on Hampstead Heath, London.
Lauren Yodera, Melanie Eglib, Alexandra K. Richardsonb, Adrian Brooker, Rosemaryd Perkins, C.M. Tilly Collinsc, Leon P. Barronb and Jeff Waaged
We found levels of imidacloprid (common dog parasiticide treatment and highly toxic insecticide) in the Hampstead heath dog swimming ponds that were over 100 times the average annual environmental quality standard
Also see
Duncalf-Youngson, H. et al., Pet treatments could be harming freshwater life, Freshwater Biological Association, (2024).
Pet treatments could be harming freshwater life — Freshwater Biological Association (fba.org.uk)Egli, M. et al., A One-Health environmental risk assessment of contaminants of emerging concern in London’s waterways throughout the SARS-CoV-2 pandemic, Environment International, 180 (2023). https://doi.org/10.1016/j.envint.2023.108210
Appendix B
This paper is about roads – but mentions paths in several places, and is also applicable to paths: https://link.springer.com/article/10.1007/s10531-014-0831-2
https://www.natcapresearch.com/resources/what-is-the-fragmentation-of-ecosystems
FOWWS RESPONSE TO WSCT
Dear Cllr Sanderson, Osama, and Vicky
We have written formally from FOWWS to OPDC about the Masterplan application, and our response is attached to this.
Separately, we have significant concerns about aspects of the Masterplan that do not form part of that application, and we set those out here:
Although there has been extensive consultation along the way to this final version of the Masterplan, this final version has not previously been consulted on, and this seems very unfortunate for such a major intervention on Metropolitan Open Land and a Common.
In our view, which we believe you all share, the Scrubs is unique among all of London’s parks and green spaces in a dense urban environment, offering the chance to experience comparative wilderness within a small compact area. It needs a little better maintenance for people to enjoy open skies, long views, swathes of varied grassland, briars and brambles (within reason) and other biodiverse features which already exist.
The guiding principles in the Design & Access Statement claim to maintain this openness character and scrubby nature, but in practice they show many significant interventions which will achieve the opposite effect.
Hedge planting along very many paths in the meadow area, forming solid boundaries. If, unlike the recently created hedges, they have multiple pathways through them, this will somewhat negate their biodiversity benefit.
These hedges* achieve the undesirable effect of carving this open wild space into enclaves/enclosures which will change completely the nature of this part of the Scrubs that the proposals claim to protect, and is certainly not in keeping with the objectives of the Wormwood Scrubs Act, our governing document. It also increases the risks to walker safety, especially women walking alone; we need longer sight-lines, not more obstacles.
*the majority of Trustees agree with this, with one suggesting much shorter lengths of more carefully located new hedging to avoid blocking walkers, one suggesting new hedging should only be round the edge of the meadow area, one supporting all the new hedging.
Biodiversity features – log piles, hibernaculae – seem to be scattered like confetti, to the extent where they are highly intrusive compared with the more naturally occurring ones.
Signs – the size of some of these seems to have grown considerably, and we must remember that they are not the main attraction, but there to draw attention to the glories of the Scrubs.
Maintenance – we are very concerned to be assured that at least £1m will be retained in a management/maintenance fund, and that this is a definite plan. All that is planned will be wasted if not properly maintained until it is fully established and can be managed within the regular routine programme of maintenance.
Has the three-yearly cost of dredging, and the additional costs of removing litter from the pond and swales been calculated and allowed for?
Meadows and trees: We would welcome your definition of a meadow, and wish to insist on details of plants planned for these areas, to ensure they are both native UK species and in keeping with the nature of the Scrubs. Similarly for the new trees proposed.
Access: We would not welcome any restriction on the ability to walk through the northern/eastern periphery woodland, which is a unique attraction for many Scrubs users.
In this connection, we are concerned about the possibility of a heavy vehicle route from Scrubs Lane just south of the enclosure let to Power Networks, which would be highly intrusive in one of the more sensitive bat/bird areas of the Scrubs, apart from coming off what is now a very busy road.
There is a perfectly good route for even the largest vehicles (after some necessary widening which will intrude into a not very significant corner of Martin Bell’s Wood) along the existing road entrance by Scrubs Lane car park to LCS.
With best wishes
Sir Stephen Waley-Cohen
Chairman, Friends of Wormwood Scrubs
Prepared by the Trustees of FOWWS with added support from FOWWS planning adviser Henry Peterson, and FOWWS honorary ecologist, Dr T. Collins.