Ickenham Marshes development proposals: October update

Following on from the well-attended and lively public meeting organised by the Association on 15 Sept, we are now making available the Association’s London Plan consultation response, set out below. The response reflects feedback from association members. Our Member of Parliament, our GLA Assembly member, ward councillors and our local authority have all stated that they oppose development on the Marshes.

Please feel free to use our response to inform your own response. You may simply copy and paste all or parts if you wish.

The deadline for responses is Thursday 15 October. 

You can take part via an online form: https://consult.london.gov.uk/londonplan or simply email your response to:  londonplan@london.gov.uk

Ickenham Residents’ Association:  London Plan Consultation Response

Key points

The proposed designation of  land “east of Ickenham” in the draft London plan should be deleted.  The area, known locally as the Ickenham Marshes, is unsuitable for development because of the extensive and significant wildlife habitats in the area and the substantial recreational and community value of the land. Development would also reduce the area’s natural water-storage capacity, and over-stetch the local drainage system, making the existing river and surface water flooding issues in local residential areas much worse.

The site is also heavily constrained by the A40, the Metropolitan railway and narrow residential streets, making construction access difficult and disruptive. The proposal raises wider concerns about the Draft London Plan’s 1,200-metre station walking-distance threshold, which exceeds the 800-metre national policy, and about applying high-density development in a low-rise suburban location. Given these constraints, uncertain demand for high-density flats and the availability of more suitable locations such as Uxbridge and Hayes, the Marshes should remain protected from development.

Noting the GLA’s stated intention to submit the consultation draft London Plan for examination, with a summary of representations, we consider the consultation process to be ineffective and inappropriate. In effect, the GLA are not consulting us on whether the Marshes should be developed, they are notifying us. The GLA is a democratic body and it has an obligation to  engage with local people on important matters. We have not been consulted; neither have our local authority. We feel hugely let down by the GLA on this matter, and are concerned that this course of action is a deliberate attempt to swerve difficult questions and avoid scrutiny.

Flooding

Environment Agency flood mapping show large parts of the area are at high risk of river flooding, and even larger parts at risk of surface water flooding. Each winter the entire site is typically heavily waterlogged, demonstrating its considerable value as a giant sponge; absorbing water and helping to reduce local flood risk. Even though there are parts of the Marshes that are on higher ground, where new homes would be at a lower risk of flooding, it’s important to note that homes either side of the Marshes suffer from flooding on a regular basis and development on the land would considerably worsen these issues. There are two watercourses on the marshes and the local surface drainage system relies on them to prevent surface water flooding during heavy rain. Unfortunately, because the area is so flat, these systems regularly back up during intense rainfall, mixing with sewer waters and flooding homes. Development would put additional strain on these systems and would reduce the ‘sponge’ capacity of the area, leading to a significant increase in the risk of local river and surface water flooding.

Nature

The area, made up of around 40 fields, with woodland, meadow, scrub, and ponds, also has tremendous nature value. National planning policy promotes development near train stations, but not at the expense of the most nature-rich areas.  The Marshes have long been noted as a Site of Important Nature Conservation, and more recently as an area of particular importance for biodiversity in the GLA’s own Local Nature Recovery Strategy. Field boundaries have remained mostly unchanged for centuries, as evidenced by the 1780 enclosure map. 1940s aerial photographs show that the Marshes were predominantly hay meadow, but since then, around a third of the area has been largely unmanaged, allowing nature-rich scrub to dominate.  Scores of veteran oaks and ash trees provide habitats for bats and owls, with historic paths like Hill Farm Road acting as bat super-highways most evenings. Badgers, foxes and deer populations are all well-established on the Marshes, as are the miles of native hedgerows and wildflower-rich hay meadows. The wildflower meadow blooms draw visitors from around the area, and recently people have travelled from across the country to see the Brown Hairstreak butterflies that are present. Habitats like the Marshes are rare locally, and in serious decline nationally.

Amenity Value

The area also has enormous amenity value for local people. The Residents’ Association has worked closely with the Council over the years to improve public access, and with the Wildlife Trust and the Ickenham Festival to encourage local people to help manage the nature reserve and maintain the extensive footpath network.

Access

The area is surrounded by the A40, the Metropolitan railway and narrow residential streets. Access for construction traffic would be a complex procedure. It is not clear how this could be managed. New railway bridges might be needed and there is understandable local concern about these issues, given the level of disruption that cold be caused. The area has been blighted for a decade by HS2 HGV traffic.

Broader London Plan Issues

The draft London Plan also conflicts with national policies on critical matters in relation to development near train stations. Firstly, on reasonable walking distances, the national policy expectation is 800m, while the GLA have proposed 1,200m. This is critical for the Marshes because most of the area falls within 800-1,200m of a station. It is unclear why the GLA have taken this approach, perhaps they believe that people in London are willing to walk longer distances to get to the station than in other areas. No evidence on this matter seems to be available. 

Fundamental issues also exist regarding housing density expectations. The Hillingdon Local Plan has clearly identified Uxbridge and Hayes are the only areas in the borough suitable for the sort of tall buildings needed to deliver the GLA’s density expectations. Locating new tall buildings in Uxbridge and Hayes makes sense because of the suburban low-rise nature of the rest of the borough. If applied in areas The building densities expected in the London plan would result in inappropriate development, out of character with the area. Furthermore, there are profound questions over the demand for flats on outer London. It is widely reported that new build flats are not selling in the south of the Borough, and that housebuilders are reluctant to build at high densities because demand is low and costs are high.