Objection to the Lea Bridge Gas Works development

The latest iteration of the Lea Bridge Gas Works development is out for consultation. We previously wrote about the development here: https://www.saveleamarshes.org.uk/2020/06/24/save-lea-marshes-objection-to-gasworks-proposal/

Here is our latest objection, which you can use to craft your own:

Removal/Variation of Condition(s) – 252331 – Lea Bridge Gas Works, 78 Perth Road, Leyton, London, E10 7PB – Objection on behalf of Save Lea Marshes

1. In this, their latest and third application, Berkeley Homes claim they are seeking to comply with recent advice from the government as in the attached sections of their new planning statement.

For example:

3.22 Moreover, it is relevant that the 30 July 2024 Ministerial Statement on Building in the Right Places provides strong support for the development of Brownfield Land such as the Site. It states that: ‘… The first port of call for development should be brownfield land, and we are proposing some changes today to support more brownfield development: being explicit in policy that the default answer to brownfield development should be yes; … reversing the change made last December that allowed local character to be used in some instances as a reason to reduce densities; and in addition, strengthening expectations that plans should promote an uplift in density in urban areas’

However, Berkeley/St William have already received permission, twice, to build on this brownfield site so this alleged determination to respond to government policy is nonsense.

Berkeley also claim they are complying with the demands of the Prime Minister and others to ‘accelerate housing delivery’.

1.9 As we explain in Section 3, both the Rt Hon Sir Keir Starmer KCB KC MP (the ‘Prime Minister’); and the Rt Hon Angela Rayner, former Deputy Prime Minister, and Secretary of State for Quod | Lea Bridge Gasworks: S73 Application | Planning Statement | September 2025 3 Housing, Communities and Local Government (the ‘Secretary of State’) have issued many ministerial statements recently encouraging the delivery of new homes ‘now’ to stimulate and accelerate economic growth to address the national housing crisis and the one in London

1.10 This application responds to those directions.

1.11 Given the recognised need to accelerate housing delivery, the immediate urgency of the housing crisis, and the programme for construction on Site, it is critical that the S73 Application is determined within the statutory period of 16-weeks.

However, this is their third attempt at getting this project off the ground.

So despite their protestations that they are simply complying with government requirements, the reality is St William have actually failed to deliver this project despite gaining two previous approvals.

Site Delivery 9.5 Approval of this S73 application would ensure that the Development can be delivered and built out, meeting the Government’s clear direction to accelerate housing delivery, whilst providing St William with viability certainty and the Council with additional housing.

Given they have failed to deliver on two previous occasions, rather than accelerating delivery, it is plainly not critical to determine this application without careful consideration, if need be beyond the statutory period.

2. In fact, a review of Berkely/St William’s multiple applications shows that the key feature of their multiple failures to deliver is a steady decline in the benefits being offered to the community along with greater negative impacts on the neighbouring community in terms of overcrowding, increased stress on services, likely worsening air pollution, harm to local green spaces and the increased sense of being overwhelmed by ever higher buildings.

First proposal 2020

7.4 The Planning Application seeks detailed planning permission for the development as set out in the description of development. A comprehensive phased development comprising demolition of existing buildings and structures, and erection of buildings to provide a mixed use scheme including 573residential units (Use Class C3) in 10 buildings ranging from 2 to 18 storeys

First permission April 2021

This was then not delivered as reported in this July 2022 article in the Waltham Forest Echo (https://walthamforestecho.co.uk/2022/07/26/lea-bridge-gasworks-development-stalls-due-to-construction-industry-issues/)

in (2022) May, Berkeley told residents it had pulled out all of its machinery and stood down its team due to “multiple global and national issues” affecting the construction industry.

An email from the developer’s technical manager, seen by the Local Democracy Reporting Service (LDRS), said ongoing issues around “supply chains, labour availability and material prices” have worsened due to the war in Ukraine.

They added: “At present both our internal team and external team of consultants have been stood down and reallocated to other projects.”

However, resident Simon Rix, 57, said those living near the site are worried the real reason is that the two 26-storey towers being built at nearby Lea Bridge Station have set a new precedent for taller buildings.

He added: “We’re relieved that they’re not doing it at the moment but we’re also worried they may have plans for the future for taller buildings and cheaper materials.”

A spokesperson for Berkeley told the LDRS the company never makes public comments about the timetable of developments.

They said the project is still going ahead as planned and dismissed any speculation as mistaken.

Community before Construction member Ben Copsey, who lives nearby and campaigned for better management of the contaminated soil, said: “My understanding of it after reading about remediation they’re proposing… is it’s too expensive for them.

So in my view what they are doing is taking a step back from that to say to the council ‘if you want this application to be built, you need to lower the offer of social housing or green space’.”

Second Proposal August 2023

This Waltham Forest Echo article below of 18 July, 2024, reported that in August 2023 St William made new proposals of towers up to 21 storeys along with dozens of new homes.

https://walthamforestecho.co.uk/2024/07/18/plans-for-643-new-homes-at-lea-bridge-gasworks-site-green-lit-by-council

Plans for 643 new homes on the site of a former gas works have been provisionally greenlit, though concerns about piping lodged by the Environment Agency will need addressing.

Waltham Forest Council’s planning committee approved the scheme, which includes a new nursery and cycling routes, at a meeting on Tuesday (16th July).

Developers St William Homes – a joint venture between Berkeley and National Grid – was granted permission last year to build 573 homes on the land south of Clementina Road.

However, in August 2023 St Williams Homes unveiled plans for dozens more homes in towers up to 21 storeys tall, citing increasing costs due to “high inflation”.

It turned out that the solution to “high inflation” was inflation in terms of population and the height of towers.

Second permission

The same article above, published in July 2024, revealed that on 16th July 2024 Waltham Forest had been given a further permission, provisionally, for this inflation in numbers and heights.

Third and latest proposal

Amendments include: 770 homes (an increase of 127 homes), Minor mix changes to approved plans; Amendments to the building footprint of Blocks C, D, E, F, G, J; Removal of Block H; Increase in buildings heights up to 26 storeys

In this latest application Berkeley/St William have taken the opportunity to cram in yet more units and thus increase the population on the site and increase the height of the towers, while actually reducing the percentage of ‘affordable’ units.

3. Height of towers

The result of all this failure to deliver is an increase in the height of towers from an original 18 storeys to 26 storeys and thus a greater sense for neighbours of being overwhelmed and overlooked.

In addition, this project further adds to the string of towers along the east side of the Marshes which will impact on the wider neighbourhood and further impinge on the enjoyment of critical green spaces both in Jubilee Park and on the neighbouring Marshes.

4. Affordable Housing

The further result of this repeated failure to deliver is to reduce the percentage of affordable housing being delivered to the point where no figure of the amount of affordable housing is provided in this latest application.

2020/21 Original Proposal/Permission

Total units 573, Affordable 158

2024 Provisional permission 2025 Proposal

Total units 643, Affordable 166 (AR 104) Total units 770, Affordable Unknown

Percentages of affordable housing in Berkeley/St William planning applications

2021. The total of affordable accommodation in 2021 was 158, without a breakdown of the kind of tenancy. This is out of a total of 573 units, making a percentage of 27.5%

There was no social tenure

2024. The total of affordable accommodation agreed in 2024 was 166, which includes all forms of affordable homes. (Berkeley introduce confusion by referring to affordable housing by habitable room as well as by homes.) This affordable accommodation of 166 is out of a total amount of housing of 643 homes. This made a percentage of 25.8%

The affordable rent tenure as opposed to intermediate tenure was 104 homes, a percentage of just over 16%.

There was no social tenure.

2025. Affordable tenures subject to viability assessment.

No percentage provided

No social tenure

5. So it seems Mr Rix and Mr Copsey, quoted back in the Waltham Forest Echo article above in July 2022, provide the best analysis of the behaviour of St William/Berkeley Homes.

However, resident Simon Rix, 57, said those living near the site are worried the real reason is that the two 26-storey towers being built at nearby Lea Bridge Station have set a new precedent for taller buildings.

Community before Construction member Ben Copsey, who lives nearby and campaigned for better management of the contaminated soil, said: “My understanding of it after reading about remediation they’re proposing… is it’s too expensive for them.

So in my view what they are doing is taking a step back from that to say to the council ‘if you want this application to be built, you need to lower the offer of social housing or green space’.”

Mr Rix’s fear that the height of the buildings would rise to 26 stories was prescient while Mr Copsey’s view that Waltham Forest would be expected to lower its expectations of social housing or green space is borne out in the collapse of any clear statement of affordable housing delivery.

In fact, there is no social housing as such, as affordable housing is not actually social housing.

All this application offers in terms of affordable housing is a future negotiation subject to viability assessment.

All of Berkeley/St William’s protestations that they are complying with government requirements are entirely bogus. They have simply played the system in order to extract as much profit as possible.

6. Flood risk

This site is on flood plain 2 and 3.

The Sustainability Statement claims:

Lea Bridge faces a minimal risk of flooding from rivers and the sea, with an annual probability of flooding ranging from 0.1% to 1%. Due to the protection of the Thames Barrier and the River Lee Flood Relief Channel.

This statement is incorrect.

As is already known the flood relief channel is out of date. It has nearly overflowed on three occasions. Likewise, a further barrier on the Thames will need to be built further downstream as the present barrier is less and less effective.

Development further north in the Lea Valley has reduced the capacity of land to absorb flood water and has added further flows of waste water into the already overloaded sewage system.

The risk of extreme flash flooding is increasing with the acceleration of climate change.

This construction will be present for at least thirty years, almost certainly longer, during which time the risks of flooding in general and of extreme flash flooding in particular will further increase.

7. Climate change.

This application shows no sensible examination of the impacts of climate change and how flooding and other climate related risks are rising exponentially. Just now, for example, a new report highlights the ‘Increasing risk of mass human heat mortality if historical weather patterns recur’.

https://www.nature.com/articles/s41558-025-02480-1

The UK and London are not immune to these impacts as was seen when temperatures reached the extraordinary level of over 40C in July 2022.

In terms of flooding, it is just under two years since Hackney Wick suffered severe flooding and the Old River Lea nearly burst its banks.

The reality is that temperatures are rising rather than falling, as they should be if effective action was being taken on the climate. The consequences are unknown but if the unprecedented kind of event that happened in 2022 is anything to by we can expect very severe impacts with extremes of weather becoming more frequent, even normal.

This section is simply appallingly complacent.

8. Impacts on open spaces and their enjoyment.

The developers and the council have already shown their disregard for the community and its enjoyment of open spaces by agreeing to substantial increases in population and by allowing ever taller towers in other applications. The Lee Valley Regional Park Authority has previously stated in its own documents that the Marshes will be negatively impacted by higher populations and by taller towers. Higher populations will degrade the park and the presence of tall buildings will reduce the enjoyment of those using the open spaces. The same applies with this application. The most severely affected park will be the neighbouring Jubilee Park. It is simply astonishing that the council can consider placing such tall towers right on the edge of such an important local green space.

This application does not seem to feature any analysis of these impacts or even refer to them. There does not appear to be any visual impact analysis. It is now widely recognised that people need green spaces and the experience of openness for their health and well being. This application is not just careless, it is foolish and fails to consider the health and wellbeing of the community.

9. Lea Bridge is already a crowded and deprived neighbourhood.

This is just one of a number of developments which include tall building planned or already constructed in the area and further south in Leyton. The agreed development at Lea Bridge station will demolish an important green space which includes a small wood. This development will greatly add to these pressures.

As shown above, Berkeley/St William have cynically delayed and expanded this project, added to the harmful impacts with ever higher towers, expecting the existing population and the public sector in an already stretched community to meet the extra pressures, all for profit.

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Leyton ‘Oh?’

Hackney Wick stadium, rebuilt 1994 at cost of £12m, closed 1997, demolished 2003

Waltham Forest Council has signed a Memorandum of Understanding with Leyton Orient Football Club. On its website the football club declares: “Leyton Orient partner with Waltham Forest Council to transform East London”. This grandiose pronouncement is expanded on further: “This landmark initiative represents a once-in-a-generation opportunity to create a world-class destination for English football, global sport, innovation and entertainment.” At the moment the O’s sit in the lower half of the third level of the English Football League. They consider their Brisbane Road stadium is too small for their ambitions.

Of course, sporting success is not the only consideration. Demolishing the stadium will provide an opportunity to make a handy profit out of its redevelopment just as it has for West Ham Football Club and Tottenham Hotspur Football Club! As they put it: “Relocating within the borough of Waltham Forest to a state-of-the-art venue could also pave the way for a vital new housing development on the current stadium site.” Given Waltham Forest’s penchant for tall buildings this will no doubt mean yet another set of towers on the east side of the Marshes.

All this raises the question of where this new ‘state-of-the-art venue’ will be? The council and the club say they will collaborate in “identifying a suitable site and progressing through the necessary legal, planning and construction stages.” The club wishes to move to a site near to Brisbane Road.

Speculation about possible sites includes New Spitalfields, Leyton Mills Retail Park and Eton Manor https://www.nelondoner.co.uk/sport/27102025-rolling-the-dice-fans-react-to-leyton-orients-potential-new-stadium. However, there is no indication that the City of London plans to move the market at New Spitalfields and Waltham Forest already has extensive plans for housing at Leyton Mills.

If existing concreted spaces are not available then there has to be concern that existing green open spaces or playing fields may be under threat. In the case of Eton Manor, unless building there means demolishing the existing LVRPA sports facilities this would involve the loss of Metropolitan Open Land green space. Even the demolition of those existing sports facilities might not provide sufficient land for a ‘state-of-the-art venue’.

As always in these cases, Leyton Orient say they are “committed to urban greening [and so-called] Biodiversity Net Gain. A new campus may include publicly accessible green spaces and pedestrian/cycle links to the wider area.” Plainly it is entirely unacceptable that Leyton Orient should be allowed to take over any existing green spaces or playing fields for their private use, as Spurs were given permission to do at Whitewebbs Park.

*Clarification 20/11/25: Thanks to a reader who has pointed out that the ground is not owned by Leyton Orient FC, so they will not profit from any redevelopment of the site. The ground is owned by Matchroom, which is owned by Barry Hearn, a previous owner of the club, and his son Eddie Hearn.

Posted in Eton Manor, Lea Marshes | Tagged | 9 Comments

Flood risk building on the Thames Water Depot

Google map illustrating the site’s proximity to the Old River Lea and Lee Navigation

The following text is adapted from a speech that Save Lea Marshes was intending to give last year. Waltham Forest Council’s constitution states that any petition receiving over three thousand valid signatures – from local residents and those who work or study in the borough – will result in a full council debate. Yet such a debate was denied last July, despite a successful and verified petition of well over three thousand signatures from local people (in addition to a general petition of over 10,000 signatures) opposing the plan to build a secure facility for children on the site earmarked for East London Waterworks Park.

We recently received news that a review of this plan by London Councils has led to it gaining the support of the Labour Government, who will fund the ‘secure children’s home’ on the Thames Water Depot if a planning application is granted.

On 7 October Waltham Forest’s Cabinet met and agreed to a proposal for the ‘Council’s capital delivery team to join the project as development manager to lead the project’s design and build workstream’. Absent at the meeting was the Leader of Waltham Forest Council, Grace Williams, who previously campaigned to successfully save the site from inappropriate development by the Department of Education. She is now one of the directors of London Councils – the prospective developer.

‘Creating East London Waterworks Park is the ideal use of a floodplain during a climate and ecological emergency, yet London Councils are proposing to build on the Thames Water Depot where the park is planned. Half the site is in Flood Zone 3: the highest risk for flooding events. The remainder is in Flood Zone 2, the next most serious category. 

The site once formed part of Leyton Marshes. Considering its location directly adjacent to both the Lee Navigation and River Lea, its vulnerability to flooding events is obvious. Last year the Lee Navigation burst its banks at Hackney Wick and the Old River Lea also came very close to bursting its banks; the very high level of the river was sadly sufficient to destroy the kingfisher nests. Whilst this year we’ve seen record-breaking drought, the Flood Relief Channel has been very close to exceeding capacity on several occasions during the last few years.

It’s now unequivocal: climate change is not a future proposition, it’s today’s reality. Climate instability is worsening at an alarming rate and with it will come the increasing frequency of extreme weather events such as flash floods, already witnessed in Waltham Forest. Heavy rainfall in the summer of 2021 overwhelmed the drainage network and resulted in more than £16.4m in flood damage in the borough. Waltham Forest Council claims it is acting to prevent future damage and loss.

Yet building on the site of a former waterworks will be incredibly costly, require considerable environmental engineering to attempt to mitigate increasing flood risk, and even then, may well not be effective. Whilst we are not experts on child safety, we can say that placing them at further risk: making them vulnerable to the risk of flooding where they are meant to be safely housed, is wrong.

East London Waterworks Park’s use of the site benefits from the addition of water. In the park water will be an asset, not a risk. The currently buried filter beds on site have the potential to store 26,000m³ of rainwater, creating natural swimming ponds and new wetland habitat, massively increasing flood resilience the most effective way, through natural mitigation. Rainwater could be harvested to create beautiful gardens for growing, learning and observing nature. The creation of wild swimming ponds could provide the open water swimming provision that the council promised local people and has so far failed to deliver.

Before the election Labour announced that ‘local communities would be given the right to buy up derelict eyesores and turn them into parks’ under a Labour government. Thousands of people, many of them local, have generously donated to create such a park. Thousands of local children, living in a deprived part of the borough, could benefit from access to abundant green space and a forest school.

A huge number of new high-rises are planned for the Lea Bridge area, including on the former Lea Bridge Gasworks and close to Lea Bridge station. With all these new developments there will be a significant increase in population, yet the existing pocket park at Orient Way is earmarked for destruction. There is evident need for a brand-new park with expertly co-designed blue and green spaces. As well as being what the community desires, it’s what the council needs to fulfil its own Local Plan commitments.

We understand the times we are living in and what is required of us, so we desperately need to work with Nature, not against it, before it’s too late. Waltham Forest Council has declared a Climate Emergency, yet it looks certain to rubber-stamp a development on protected land that could easily go somewhere more appropriate.’

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Our objection to new threats to our green open space

The London Mayor is consulting on plans to build over the Green Belt, though we know this is unnecessary and will not solve the housing crisis. Metropolitan Land is also under threat without justification. CPRE London are requesting objections are sent before 22 June.

Here is the objection we sent to the Mayor of London, Sadiq Khan.

  1. You state, ‘My preference will always be for us to secure as many new homes as we can on brownfield sites – both large and small – and ensuring that delivery is accelerated wherever possible.’

Many brownfield sites are Metropolitan Open Land (MOL) and rich in habitat. Simply wanting to build on these sites fails to take into account the variety of such sites. Brownfield sites may also be located in areas which are already green and to build on them will be disruptive to the wider parkland.

  1. You say ‘I want to ensure that any release of the green belt to help address the housing crisis makes the best use of land and meets strict requirements. This includes maximising the level of affordable housing; ensuring high-quality housing design and good transport connectivity; and increasing biodiversity and access to good-quality green spaces as part of any developments. The truth is that some land designated ‘green belt’ in London is low quality, poorly maintained and rarely enjoyed by Londoners.’

Of course you will say you want to ensure there are strict requirements. This is meaningless. There already are strict requirements. This is why this land is designated as Green Belt or MOL. You then go on to rubbish these requirements by saying some of the existing Green Belt is low quality, poorly maintained and rarely enjoyed. Of course, the response to that is to maintain it better and ensure it is enjoyed. These arguments about poor maintenance, etc. are already used to allow special requirements to prevail over Green Belt restrictions. Green Belt and MOL are already poorly protected. This is simply an invitation for those holding MOL or Green Belt to stop maintaining it. Green Belt exists for a purpose. Getting rid of it only increases the stress on people who need more open space, not less.

You then go on to say you wish to maximise the level of affordable housing. Most ‘affordable housing’ is not really affordable. We need more social housing. However, that requires public investment. The present developer-led model of house building does not even provide adequate ‘affordable’ housing let alone social housing. Housing is built to make a profit. None of the existing proposals alter this so however much you wish to increase ‘affordable’ housing this will make little dent in the housing needs of Londoners. However, your intention to build some of this housing on Green Belt or MOL will harm the health of Londoners. A lose-lose result.

Referring to high quality design is another meaningless qualification. There is no way you can ensure this as you are not in control of building. All building should be to a high quality. The reality, again, under the present system, is that housing is not built to a high quality. Indeed, planning authorities do not ensure quality in the housing they approve. Until recently they failed, for example, to ensure proper fire safety. It is unclear that this is going to change.

You then go on to state that this housing should be near to good quality green space. Of course it should! However, you plan to reduce the amount of green space rather than ensuring the existing green space is properly maintained and improved. Instead you plan to build on it.

You also state that new housing should have good transport connections. If the transport connections do not already exist then it is hard to see how this requirement can be met. More bus routes will help but some bus routes are now being closed. However, the key transport connections are rail. In so far as these take time to develop this essentially means development should occur near to existing transport connections. This is desirable. However, many of the places you refer to, such as poorly, little used Green Belt, will be precisely the kind of locations which are not well connected.

For all these reasons these statements simply don’t add up. If you are going to build near good transport connections then you are going to continue to build in areas which are, for the most part, already well developed. If you are going to build on green spaces, however poor you may consider these are, you are reducing the stock of green spaces making it impossible to provide the necessary green spaces for these new populations. Your plans rely on a failed building model which doesn’t deliver at the best of times. Developers will simply take advantage of your ‘policies’ to degrade existing Green Belt or MOL to find cheap land to make a higher profit.

The present government wishes to blame the planning system for the failure to build sufficient homes. This is nonsense. For example, in London there are boroughs like Waltham Forest which actually exceed the housing development requirements of the London Plan. Even though they do this building does not always proceed for reasons entirely unconnected to the planning system so even though they exceed the requirements in terms of plans and permissions even this does not result in sufficient development. In giving these permissions Waltham Forest ignores the requirement to protect green space and even argues, ridiculously, that building tower blocks next to green spaces enhances the green spaces!

This set of ‘policies’ will not result in the house building you expect. It will harm green spaces and the health of Londoners, particularly poor Londoners. It will not provide ‘affordable’ housing but it will be an opportunity for house builders to increase their profits.

It would make more sense to concentrate on acting on the number of empty homes than on building lots more houses, which, in any case, are unlikely to be built and will certainly not be affordable.

  1. You say you want to ‘improve biodiversity’. However, instead of looking at improving existing poorly maintained green spaces you intend to build on these spaces. Your aspiration is simplistic. London has a problem with its existing green spaces. As with most other benefits they are concentrated in the more prosperous parts of London see https://www.goparks.london/articles/london-desperately-needs-more-greenspace/ So for many Londoners they actually lack green space. Perhaps you could reduce the amount of green space in these prosperous areas? Plainly that is not going to happen! So the reality is building is going to happen in poorer areas where land is cheaper and also in areas which are lacking green spaces. In addition, your description of poor quality Green Belt or MOL is likely to apply to land in these poor areas, just the kind of area where land is cheaper and where developers will look to make purchases. Hence the likelihood that this poorly maintained land will continue to be poorly maintained and then handed over to housing development. So the cycle of building in areas with inadequate green spaces will continue and accelerate.

Your desire to build more homes may be worthwhile. However, the circumstances to achieve this do not exist. The circle cannot be squared. Your prescription will make things worse without achieving the intended goal.

  1. It is interesting to note that one of the few areas where Habitat Regulations apply in London, the map on page 12, is in a section of the Lea Valley. Yet Waltham Forest Council considers the Lea Valley is a prime site for building tower blocks right up against the marshes. Other boroughs like Enfield and Haringey are also building close to or in the Lea Valley.
  2. It is also interesting to note how much of the indicated areas for building are in already built up areas in central parts of London, see map on page 15, and in areas along the Thames which will be very vulnerable to flooding.

    The risks of flooding do not seem to feature in your assessment of future building capacity. Far from being safe for building on river valleys are not safe. The great increase in development in the Lea Valley has increased the risks of flooding in this sector of London. The same applies to the stretch of the Thames running through the whole of East London. Both of these river valleys feature in your map of corridors of development. Building on these flood plains is reckless.

    1. As above, your map of opportunity areas on page 22, where you consider the most suitable housing sites can be found, focuses on two areas, the Lea Valley and the Thames Valley in East London, both high-risk flood plains.
    1. A further problem arises with your desire to encourage industrial growth. Once again, much of this is located in poorer areas and, as you note, industrial land has declined by 18% since 2001, which you say is unsustainable, yet you think it is possible to take more industrial land for housing. You consider that there may be ‘grey’ land which is not suitable for housing which can be handed over to industry. However, this simply means redefining green land as grey and losing green spaces. Even allowing for some rejigging of designations this is hardly likely to make up for the lack of housing and the lack of industry but will certainly result in a loss of green (redesignated grey) spaces, most likely in poorer areas, already deficient in green space.
    1. You suggest all these circles can be squared in your statement:
      The green belt’s original purpose was to prevent urban sprawl [starts on page 26]. This is still reflected in national policy today. However, our approach now must be allied with a clear focus on supporting nature and the environment and improving access to good-quality green spaces for Londoners. Large-scale urban extensions could enable us to deliver a programme to enhance, expand or establish regionally protected parks (Metropolitan Open Land) and other open spaces accessible for Londoners (as part of an overall infrastructure package with available funding), boost biodiversity outcomes and improve nature in other ways.

    How?

    When discussing the various options for the future your ‘plan’ is, unsurprisingly, short on specifics. The problems of homes being sold to foreign investors, the high rents being charged in the private sector, the lack of new social homes, etc, are all known. You note that, in reality, there is very little available Green Belt or MOL available within the Greater London Authority area. You focus on a few golf courses!

    This is not a circle that can be squared and instead of trying to invent a fantasy plan to overcome the failures of national government London should simply state that the demands being made on the city are unreasonable and unachievable. London should state clearly that it has important issues to address, notably the need to improve the quality of life of its existing population, to protect and enhance its existing green spaces and to protect the city against the risk of severe flooding. London needs to state clearly that the housing shortage, which is really a lack of genuinely affordable housing, cannot be solved by continuing with present failed developer-led policies. Government needs to think of other routes to provide homes as, for example, by taking control of empty homes.

    We suggest that, rather than trying to achieve the unachievable, you concentrate on what can be achieved. Nature, contrary to what the present government seems to think, really is important. Protecting nature is integral to combatting climate change and its impacts, such as city heat, flash flooding, pollution. Green spaces are vital for our health and well-being. They are also important as part of a strategy to combat air pollution and flooding. Building more, taking green spaces to do this and doing this to poor communities in vulnerable areas like river valleys is foolish, harmful and, given the existing housing ‘delivery’ system, unachievable. Protecting and enhancing green spaces can be achieved. Meeting absurd housing targets cannot. A different strategy for meeting housing need has to be devised to ensure housing
    is affordable. If national government cannot devise sensible plans then London has to find ways, and lobby for them, to make use of existing resources. Making use of empty homes is an obvious starting point. Reducing dependence on the private developer model is critical. It is time to stop plucking fantasy plans out of the air.

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    Open Letter: Whitewebbs decision of concern to all London

    Today we received a letter on behalf of the Secretary of State confirming that she will not be calling in Spurs’ planning application to develop Whitewebbs Park in Enfield. Whilst this is disappointing news, the Mayor of London can still call in the application. Below is our open letter to the Mayor requesting that he does so.

    We believe that this application is of significance to the whole of London, and the Mayor’s decision will impact the future of all the capital’s parks and green spaces for years to come. So we encourage other green groups to raise their voices in support of Whitewebbs.

    If your organisation would like to add their name to this letter, please leave a comment below or get in touch with us directly: leamarshes@gmail.com

    Dear Mayor of London,

    We are urgently writing to you regarding the decision by Enfield Council to grant planning permission to Tottenham Hotspur Football Club for the construction of commercial and industrial scale facilities on Whitewebbs Park in the Metropolitan Green Belt. This decision is deeply concerning for all Londoners who enjoy their local green spaces, including those with Metropolitan Open Land, Green Belt and Public Trust designations that should be protected by law for the benefit of the public. Green public spaces enhance the health and well-being of us all. Vast swathes of public land should not be reallocated for exclusive use by elite professional clubs or players.

    Tottenham Hotspur Football Club already owns seventeen private pitches and facilities at its existing football academy in Enfield which could easily be shared with its women’s team (for example, Arsenal owns a total of ten shared pitches). These facilities were constructed on Green Belt land north of Myddelton House in the Lee Valley Park.

    The Very Special Circumstances case that Enfield Council’s Planning Officer presented recommending the granting of planning permission to Enfield Council’s planning committee was misleading, inadequate and unsound. The Greater London Authority agrees that Very Special Circumstances are also necessary to outweigh the harm to the Green Belt and its purposes from developments otherwise considered inappropriate. Whilst the benefits of the application were exaggerated, there was a complete failure to assess the significant adverse and permanent impact upon the openness of this cherished Green Belt site. The massive re-landscaping, earthworks and construction required by the applicants would permanently and adversely alter the park’s historic character.

    This is not just a few grass pitches; it is a large-scale industrial construction with significant built form. As well as omitting key visual and landscape impacts, there were also very significant omissions in the planning application relating to ecological impacts, including on protected species.

    If it is accepted that such a flawed justification can be used to enable private development of such a large area of currently publicly accessible open space, then it appears that no green and open space in London is safe from privatisation, inappropriate development and irreversible loss. The land in question was purchased by Enfield Council in 1931 for the benefit of the people of Enfield, is held in Public Trust, and should have been protected by a 999 lease ensuring the accessible golf course area would revert to full public use in the event of closure. If the new lease arrangement with THFC was to be signed, the football club would control all access to the park and it would ‘extinguish’ existing legal public rights of access. There are alternative and more suitable sites nearby, for example the extensive, now abandoned, brownfield Sunset Studios site. Private businesses should not take over public land; they ought to acquire private land if they want to extend.

    Half of Whitewebbs Park’s naturally rewilded biodiverse grassland and over two hundred trees, including veteran trees (as verified by The Woodland Trust ATI), stand to be lost (and a further 40 transplanted) eliminating habitats for priority species.

    London’s Green Belt Review has been ‘accelerated’ in Enfield, risking a rushed process that fails to adequately assess the value of the Green Belt, not just to the borough, but as a vital green lung for London during a climate and ecological emergency. Piecemeal, partial and rushed assessments are inadequate in such circumstances; risking the loss of some of the capital’s most nature-rich sites, contrary to your stated objectives in the London Plan.

    The Planning Inspector has expressed doubt that Enfield Council has effectively assessed the site allocations in its Local Plan, including Whitewebbs. In its supporting documentation, criterion 2 of Policy CL4 supports ‘development for sport and recreation’ without mentioning the need to preserve openness or the purposes of the Green Belt. It is premature to grant planning approval to applications within the Green Belt prior to the Inspector examining whether the site allocations are sound and should be located within the Green Belt at all.

    In your prior election manifestos, you promised that London’s Metropolitan Open Land and Green Belt were safe, and would only be developed in genuinely ‘exceptional circumstances’. This was a popular message. Before his election as environment secretary Steve Reed stated, “Nature is under threat. Our children and grandchildren deserve to be astounded by the magnificence of our landscapes […] and enjoy our iconic wildlife, just as we can.”

    As Londoners based across the city, coming from all walks of life, who value our local green spaces, not just for recreation but for their vital contribution to nature recovery, we agree. There are serious legal and environmental shortcomings in Enfield Council’s handling of this application and associated conservation policies. Should the planning permission for Whitewebbs Park be upheld by the Greater London Authority, a completely detrimental precedent will be set for all parks and green spaces across the capital. The Public Interest Law Centre has even concluded that there will be ‘no real protection in law for public parks’.

    Therefore we, the undersigned, request that this application should be refused under article 7 of the Mayor of London Order (2008). 

    Kind regards,

    Guardians of Whitewebbs

    Save Lea Marshes

    Enfield Community Action

    Enfield Roadwatch

    Wild Clapham

    ReNature London

    Edmonton Cycle Club

    Friends of Finsbury Park

    Sustainable Hackney

    Community Planning Alliance Committee

    Wyld Edges

    Friends of Clapham Common

    Friends of the Welsh Harp

    Barnet Community Harvesters

    Trees for Bermondsey

    The PeaceTime Zone

    Protect Brockwell Park

    London College of Garden Design

    Save Wimbledon Park

    Posted in Uncategorized | 17 Comments

    Beating the Bounds along the Old River Lea!

    Join us for this year’s Beating the Bounds on Sunday 25 May at 2pm. Meet on the towpath outside The Princess of Wales pub E5 9RB

    Beating the Bounds is a traditional walk that marks significant boundaries, such as the boundaries of a parish, a manor, commons or another important public open space. The event usually takes place during Rogationtide, in springtime, when prayers for a good harvest are offered. Willow sticks decorated with flowers and ribbons are carried and used to hit important boundary markers.

    Locally, this tradition was resurrected by the late Katy Andrews of the New Lammas Lands Defence Committee, and we have hosted a biennial version of this event since Katy’s untimely death a few years ago.

    A previous Beating the Bounds event on Leyton Marsh

    This year our Beating the Bounds walk will be one of the many exciting events that are taking place as part of the Love Lea Festival.

    We’ll set off from the Lee Navigation towpath next to The Princess of Wales pub (E5 9RB) at 2pm and aim to finish outside Hackney Marshes User Centre by 4pm on Sunday 25 May.

    We’ll walk along a short section of the Lee Navigation, crossing over to Middlesex Filter Beds, and then join the path that runs alongside the Old River Lea on Hackney Marshes, exploring the history of this precious common land and significant boundaries. We will be joined by local resident Sarah Bancroft who will tell us stories about local history along the way.

    This is a map of the route we will take. There will be short, intermediate and long options for the walk – you can walk as much or as little of the route as you like:

    • Short route:0.8 miles, The Princess of Wales to Friends Bridge
    • Intermediate route: 1.8 miles, The Princess of Wales to Hackney Marshes User Centre (via route marked blue, then red)
    • Long route: 2.4 miles, The Princess of Wales to Hackney Marshes User Centre (via route marked all in blue)

    The walk is completely FREE, with donations welcome in advance or on the day.

    There’s no need to book for the walk, just turn up!

    If you’d like to join us for traditional willow dressing at the pub prior to the walk, just let us know by contacting leamarshes@gmail.com and we’ll share the details with you by email.

    All welcome, including families. We will have a special activity for children to do along the way.

    We look forward to seeing you there!

    Posted in Hackney Marshes, River Lea | Tagged , | Comments Off on Beating the Bounds along the Old River Lea!

    Rewild the golf course!

    This read will take you a few minutes, but we think it’s worth your time; it will cover:

    • The inadvertent impact of public health measures and the ‘Hackney Beach’ craze on the Waterworks
    • Our vision of a better future for wildlife and people at the Waterworks Meadow
    • The positive impact of habitat enhancement on neighbouring Hackney Marshes
    • Inspiring examples of other reclaimed and rewilded golf courses
    • Risks to the marshes, in particular the Waterworks, from development proposals
    • What you can do to help safeguard this precious place for Nature and community
    Photo of the Waterworks Meadow by Dee O’Connell

    Everyone remembers (and many try to forget) the height of the Covid pandemic and the era of lockdowns.

    One of the unintended consequences of public health measures was the sheer pressure put upon our local green spaces, particularly the former golf course at the Waterworks, which became a party destination for people lacking options for leisure and enjoyment at the time. The banks of the Old River Lea became a strong magnet for crowds during the blazing hot summer months, a phenomenon only exacerbated by glamourised coverage of ‘Hackney Beach’ in The Guardian.

    Sadly significant damage was done to the environment, and vulnerable wildlife species, such as the resident Little Owls, were driven away. To add insult to injury, the site was proposed for the ‘Waterworks Festival’ in 2021. Thanks to a united local campaign, we prevented the applicants from receiving a licence to blast music next to a nature reserve with known Red List species. The festival went elsewhere.

    After all the disruption and damage that had occurred since the golf course was closed in 2012, we were intent on ensuring a better future for the meadow. A future where the fragile riparian habitat was protected from damage and disturbance, inappropriate commercialisation was prevented, and wildlife was brought back. We wanted a flourishing natural environment and the potential for this site, with proper protection, to be a haven for Nature was obvious.

    Stonechat on the Waterworks Meadow by Jo Wheeler

    We launched a successful crowdfunding initiative to fund ecological surveys of the meadow and the adjacent Waterworks Nature Reserve. Local experts, some of whom were subsequently involved in the impressive habitat works on Hackney Marshes, carried out these surveys and found a wealth of wildlife at both these interconnected sites in 2021. There was strong evidence for the site to receive Special Importance for Nature Conservation (SINC) status, especially the presence of rare species such as the Brown-Banded Carder Bee.

    On the Hackney side of the River Lea, which already has Metropolitan SINC status, Hackney Council took the initiative and consulted with local groups such as ours to try and limit the most destructive behaviour such as the use of disposable barbeques and sound systems next to the Old River Lea. Whilst unsuccessful in the short-term, once the crowds had diminished (there were many unofficial reports of illness from swimming in the very polluted waters), something was set in motion which really did achieve results.

    ReNature London and Wildlife Gardeners of Haggerston recently screened a film premiere showcasing the amazing work they have carried out over the last few years to rewild North Marsh and carry out river restoration, including the replanting of the denuded banks of the Old River Lea, work funded by Hackney Council and the Mayor of London. A group of dedicated experts and volunteers have brought back a number of imperiled wild species, on the edge of local extinction, such as Short-tailed Voles, Weasels and Wood Mice, that rely on undisturbed habitat.

    Short-tailed Vole brought back by habitat enhancement on North Marsh grassland, photo: ReNature London

    Despite some initial positive noises, and the wealth of evidence we gathered for giving the Waterworks Meadow statutory protection and initiating similar habitat enhancements on the Waltham Forest side of the river, there has sadly been no affirmative action by either Waltham Forest Council or the Lee Valley Regional Park Authority.

    So, we thought it time to remind the authorities of the amazing potential that exists for fully rewilding this naturally regenerated golf course, land which forms an important link in a lower Lea Valley wildlife corridor which stretches all the way from Walthamstow Wetlands to the QEII Olympic Park. The evidence of the existing ecological value of this particular site, once part of Leyton Marshes, has been carefully recorded and detailed. The results of specialised habitat works at adjacent Hackney Marshes couldn’t be more inspiring or instructive. What’s more, there are an increasing number of councils and landowners across the country who are rewilding disused golf courses to improve local ecology and combat the climate crisis, whilst at the same time maintaining public access and enjoyment.

    With two percent of land and thirty-three percent of all open space in Great Britain taken up by golf courses, it seems only fair to reclaim these sites for Nature and local people when the opportunity arises.

    We’ll begin with the most inspiring example from our city: Warren Farm in Ealing, another naturally rewilded urban meadow in London, home to an array of rare species, including Hedgehogs, Slow Worms and Skylarks. There was an incredible community campaign against the council’s plan to bulldoze half the site for football pitches. After eight years of determined campaigning and huge public support, the demand to halt the destructive development and grant nature reserve status to the wildlife haven was won just under a year ago.

    Another example of a former golf course in London being rewilded after closure is Beckenham Place Park in Lewisham, which received a £3m grant for regreening and enhancing the river corridor. Mete Coban, former member of Hackney Council’s Cabinet and now London Deputy Mayor for Environment and Energy, said of the scheme: “This outstanding project showcases how improvements to green space can help Londoners to access and enjoy nature, improve biodiversity and mitigate the impacts of climate change. Sadiq has pledged to turbo-charge restoring nature to London’s rivers and waterways and this transformation of the River Ravensbourne is a great example of what can be achieved. We are proud to support this project through the Mayor’s Green and Resilient Spaces Programme, as we create a greener London for all.”

    In Exeter, a former golf course is being transformed into a public green space, wildflower meadow and community orchard. A former municipal golf course in Sunderland will become a new country park and wildlife area. Waterhall Golf Course in Brighton is set to be restored to rare chalk grassland by the local council with the assistance of Heritage Lottery funding. On a far grander scale, there are plans for a large urban rewilding scheme on the site of a 320 acre city park, including a former golf course area, at Allestree in Derby. In Leeds, Cheshire, Erewash and the Vale of Glamorgan abandoned private golf courses will be transformed into varied biodiverse landscapes once more. The potential for bringing back Nature, alleviating flood risk and combating climate change through the restoration of disused golf courses has been recognised by local authorities and environmental charities across the country. These sites range from relatively modest former 10 and 12 hole courses in urban settings to extensive former countryside ranges.

    Waterworks Meadow: a former golf course that has naturally regenerated

    At this location, the thriving natural regeneration of the Waterworks Meadow can be fully enhanced with specialised grassland management. But only if the land owner (the Lee Valley Regional Park Authority) and Waltham Forest Council recognise the ecological importance of the site. It is vital that it is included in the council’s SINC review and conversely not included in the Authority’s corporate development plans.

    Areas ringed in yellow are currently low-rise industrial sites but are allocated for high-rise housing in LP2

    The Waterworks Meadow will be impacted by its close proximity to the new high-rise housing developments proposed at Lammas Road and Orient Way, as well as the Lea Bridge Station Sites and Lea Bridge Gasholders developments which have already received planning permission from Waltham Forest Council. The cumulative impact will be one of unacceptable urban cramming and further population pressure on the marshes, not to mention the additional flood risk associated with building adjacent to the outdated Flood Relief Channel. The inclusion of Lammas Road and Rigg Approach developments in the council’s Local Plan (LP2) means that sites within the Lee Valley Park have been proposed for housing for the first time. When the LVRPA fails to make its private reservations count as formal objections in the planning process this is hardly a surprise. Whilst the Waterworks Meadow lacks statutory designation, it remains vulnerable to inappropriate development by both the LVRPA and the council.

    Orient Way and Lammas Road flood maps
    Development areas identified at Lammas Road and Orient Way, adjacent to the Waterworks

    The threat posed by local authorities failing to properly assess the ecological value of sites like this could not be more evident than in the case of Whitewebbs Park in Enfield. The former golf course at Whitewebbs closed in 2021. The land has been held in public trust since the 1930s, and the 999 year lease states that if the golf course were to close, it would revert to public use. Since its closure, everyone has continued to enjoy this beautiful park. There has been minimal maintenance, and the end of herbicide use, which has meant, just like at the Waterworks, the old golf course has been naturally rewilding ever since. Sandwiched between Enfield Council’s landmark beaver enclosure on one side and ancient woodland on the other, this mosaic habitat of grassland, scrub, ponds, and sandpits boasts over a hundred trees, including majestic redwoods and a myriad of wildlife species.

    Despite this, Enfield Council has agreed to lease the land to Tottenham Hotspur Football Club (THFC) who wish to expand their commercial elite football training centre into the rewilded grassland section, and build a new road through a portion of the ancient woodland near Whitewebbs Lake, and take away a huge swathe of public space. The existing football academy boasts no fewer than seventeen pitches on land formerly within the Green Belt, to the north of Myddelton House. We understand from local campaigners that land within the Lee Valley Regional Park was sold off in order to facilitate this development over seventeen years ago.

    Redwoods at Whitewebbs Park on a frosty day in January

    Enfield Council’s SINC review was conducted without carrying out a specific study of Whitewebbs Park despite the area being surrounded by SINCs, just like the Waterworks Meadow.

    We will not allow the Waterworks to remain devalued and at risk of corporate development ventures. Waltham Forest Council must include the meadow area in its SINC review, and we call upon the LVRPA to protect and enhance the vital meadow habitat. The Waterworks Centre, built as a base from which to enjoy the nature reserve, has been shut since 2020. It is an Asset of Community Value (ACV) and needs to be re-opened for use by the community.

    Agree with us?

    Please write a personalised email to the Chief Executive of the Lee Valley Regional Park Authority, making the case for safeguarding and fully rewilding the Waterworks Meadow through habitat enhancements and specialised grassland management. Address your email to: sdawson@leevalleypark.org.uk and CC Waltham Forest’s representative in the LVRPA: cllr.terry.wheeler@walthamforest.gov.uk

    If you wish to include a complaint about the closure and deliberate dereliction of the Waterworks Centre ACV, please CC: crm@leevalleypark.org.uk

    We also encourage you to write a short email to Cllr Clyde Loakes, Cabinet Member for the Environment cllr.clyde.loakes@walthamforest.gov.uk, and the Leader of Waltham Forest Council, Cllr Grace Williams, cllr.Grace.Williams@walthamforest.gov.uk to request that the Waterworks Meadow (also known as WaterWorks Fields) is included in the borough’s SINC Review using all the evidence available to make such an assessment, including the ecological surveys carried out by the LVRPA and Save Lea Marshes, as well as GiGL records.

    Posted in Hackney Marshes, Leyton Marshes, River Lea, Waterworks | Tagged , , , | 3 Comments

    We Marched Together for Our River Lea!

    Save Lea Marshes joined six local groups to march together at the national March for Clean Water in central London on 3 November.

    Organisations who have been locally advocating for the River Lea joined forces for the first time to call for urgent government action to clean up the polluted river.

    Save Lea Marshes gathers with EcoACTIVE, Leaside, East London Waterworks Park, Sustainable Hackney and local members of the National Bargee Traveller Association (NBTA) before the March for Clean Water

    They united with thousands of people, representing hundreds of organisations across the country, in the largest ever demonstration for water in the UK’s history. Participants all wore blue to form a symbolic ‘river’ which wound its way from Embankment to Parliament Square. Marchers demanded emergency measures to clean up the UK’s rivers and seas.

    Caroline Day from Save Lea Marshes said, “We have been campaigning alongside other organisations to clean up our heavily polluted local river – which runs through the marshes – since 2013. However, we have seen the pollution get steadily worse over the years, witnessing first hand some devastating pollution incidents which have caused mass fish deaths and lasting environmental damage to our precious river. Since 2021, we’ve regularly tested water samples from the Old River Lea which runs through Hackney Marshes. We’ve seen chemical markers of pollution from run-off and sewage at consistently very high levels. Put simply, immediate action is needed to end this pollution, and it was heartening to see so many people out united in calling for the necessary action from the authorities on Sunday 3 November.”

    Leaside and River Lea boaters outside Parliament

    Beth Summers from Leaside, a community hub for water-sports, adventure and nature, said “Leaside supports 3500+ people each year paddle, bike and boat on the River Lea through our youth club, schools programme, community groups, adult paddlers and local residents. Our community is passionate about the River Lea, it is a precious resource that brings joy, adventure, calm and transformative life experiences. Yet each year we see water quality getting worse, plastic pollution increasing and biodiversity struggling. Whilst we do all we can to monitor water quality and the majority of people have a fantastic time, some are getting ill from contact with the water. It’s not good enough. Young people and our communities should be able to explore and enjoy our waterways without the fear of falling ill. Leaside is passionate about facilitating community led action and collaboration so together we can create a healthy, vibrant and thriving River Lea.”

    Colin Legge, a boater on the River Lea said, “It was great to witness a genuinely co-operative spirit with Leaside Trust, Lea boaters and the National Bargee Traveller Association (NBTA) – that’s boaters, canoeists, kayakers, the local community, both younger and older – all collaborating to ensure healthy waterways for future generations.”

    360 capture of the River Lea contingent joining London Waterkeeper by National Park City ranger Michael

    Theo Thomas, founder of London Waterkeeper, an independent charity campaigning for clean rivers in London explains why the current system of regulation and enforcement is failing to curb pollution and why the march was so important, “We have all the laws we need in place, the result of campaigns stretching back decades but regulators have not been using them to their full strength. Light-touch enforcement just lets polluters get away with damaging nature. This show of solidarity for clean water means the pressure on Government, water companies and agricultural polluters will only increase.”

    Jess Dolan, director of environmental charity ecoACTIVE, said: “The River Lea is one of the most polluted in the UK. It is contaminated with sewage, wastewater, chemicals, plastic and oil. Levels of faecal e-coli bacteria can exceed international standards more than 40 times. We can only imagine the harm this is causing to wildlife. We know that Walthamstow Marshes, a Site of Special Scientific Interest, has been in unfavourable and declining condition for years. We cannot let this disregard for the health of the Lea any longer. Action to clean the river and restore nature is needed now.”

    Peter Mudge, one of the directors of East London Waterworks Park, who joined the march said, “Water is the most important element in our plans for East London Waterworks Park. We believe that we can provide clean water for wild swimming solely using natural processes. But the River Lea flows along the boundary of our site, and it has been suffering from severe pollution for many years. We envision a better future where people and wildlife will be able to enjoy the benefit of clean water throughout the lower Lea Valley and were delighted to join other local groups calling for an end to pollution of our precious waterways on 3 November.”

    With even more dire news about the plight of our rivers emerging since the march, including the perilous state of Thames Water, we pledge to continue and step up our campaign for clean water for all.

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    Looming tower blocks over the marshes and nine thousand+ new residents: OBJECT to Waltham Forest’s shocking new Local Plan

    We are gravely concerned by the latest Local Plan recently announced by Waltham Forest Council. If enacted, there will be a number of new large-scale developments, mostly tall high-rise buildings, in areas adjacent to the marshes. An additional nine-thousand residents could be housed in the most overcrowded and deprived part of the borough, with its already overstretched services and overburdened green spaces, including the Site of Special Scientific Interest on Walthamstow Marshes.

    We encourage everyone to object to these wholly unsuitable plans which we will summarise here (with images) so you don’t need to trawl through hundreds of pages of documentation.

    Draft Local Plan overview
    Lea Bridge strategic area in LP2

    There are significant changes from the Draft Local Plan. When the Draft Local Plan, LP1, was first presented it did not show the western end of Lea Bridge Road as part of the Lea Bridge Strategic Area (map on left).

    A change appears to have been made in the closing stages of the LP1 modifications process after the main consultation had ended. The line marking the Lea Bridge Strategic Area has been carefully drawn to cut across the Thames Water Depot site, designating the eastern part of the site where the proposed secure facility for children would be built as part of the Strategic Area and excluding the footprint of the heritage buildings (map above right).

    This appears to have happened after the proposal to build a secure facility for children on this part of the site was first publicly known. The change was not included in the draft LP1 consultation and associated inspection. It only cropped up in the ‘modifications’ stage when minor changes were being negotiated with the planning inspectors after they had regrettably dropped their earlier objections to LP1.

    The current LP2 consultation does not include any allocations for this site. However, Waltham Forest Council’s support for a secure facility for children, which would be built on this eastern part of the site, was recently expressed at a full council meeting by council leader Grace Williams. Williams is one of the directors of the London Councils consortium that desires to create London’s first ‘secure children’s home’ at this location. Including this section of the depot site in the Strategic Area seems to be designed to enable the planners to treat it as a development site, an important deviation from the original Local Plan.

    The eastern part of the site is where the filter beds from the former Lea Bridge Waterworks are buried. The area outside of the development line is where the heritage buildings are located. So dividing the site in this way would be a back door means of ruling out the possibility of creating East London Waterworks Park at the Thames Water Depot site.

    It is interesting to note that the planning application for the secure children’s home was held back just at the time this LP2 consultation got under way. The planners may view the planning application as more likely to succeed once this LP2 process is over and the status of the Lea Bridge Strategic Area is confirmed.

    Anyone who supports East London Waterworks Park should object to Local Plan 2. If the other developments proposed for the surrounding area are built, the population of the area will be massively increased, as will the pressure on local green and blue spaces. This area has the worst health outcomes in the entire borough. Even without these developments, the park will be essential to support the health and well-being of the local population.

    Borough site allocations marked in red

    Some of the new areas allocated for residential development are in close proximity to East London Waterworks Park and in immediate proximity to the Waterworks area in the Lee Valley Park. Included for the first time are significant housing developments at Rigg Approach, Lammas Road and Orient Way.

    These previously industrial areas are now earmarked for tall residential buildings. This is in addition to the tall buildings proposed all along the eastern side of Walthamstow Wetlands, the already-approved Lea Bridge station sites, New Spitalfields and Leyton Mills (as can be seen from this map).

    Buildings of ‘3-20 storeys’ are considered ‘appropropriate’ for Rigg Approach and Lammas industrial area, whilst the council considers Orient Way (which will lose its pocket park to the Lea Bridge development) appropriate for buildings up to ’15 storeys’ high. It plans high-rises of ’18+ storeys’ for Lammas Rd and Rigg Approach!

    390 new homes are proposed for Rigg Approach and 240 homes for Lammas Road. The Local Plan does not include any new provision for health and social services for this influx of new residents to the area. Lea Bridge and Leyton have the highest under-75 mortality rate linked to preventable causes and deprivation in Waltham Forest (see graph).

    Despite the significant impact of such high towers close to the marshes, there are no visual representations of how these buildings will appear on the skyline, including views from the marshes. We can only surmise this is because this would demonstrate how such construction would significantly adversely impact the openness of the marshes. As Metropolitan Open Land the value of ‘openness’ should be a protected characteristic.

    Currently Orient Way is an industrial area which mainly houses one-storey warehouses. It is now proposed as a site for 320 new homes, plus industry. This is in addition to the already-approved Lea Bridge Gasworks development that was bitterly contested by local residents and waived through by a council planning committee blatantly ignoring the environmental contamination issues plaguing similar developments of other former Victorian gaswork sites.

    The Lee Valley Regional Park Authority (LVRPA) currently oppose the new site allocations due to the serious adverse impact upon the Lee Valley Park. In their recent internal papers, they state:

    At this stage there is no indication that the evidence base underpinning the site allocations have taken account of the Regional Park and its openness in respect of the additional tall buildings designation for these areas.

    References to buffer habitat and new green edges and the design and siting of buildings to protect and enhance the openness will not be sufficient to overcome the enclosing and barrier effect of tall buildings in these locations, particularly given the cumulative impacts with consented schemes such as the Lea Bridge Station sites which include residential blocks with heights of 23 and 26 storeys.

    If the LVRPA had put up a more robust defence against Lea Bridge Station Sites planning application, it would likely be in a better position to now defend the park against these further intrusive and inappropriate developments planned for the local area.

    The inclusion of new areas for development is staunchly rejected in the Authority’s Regeneration papers (RP/85/19):

    It is noted that the both the Rigg Approach and the Lammas Road site allocations have been amended to allow for the potential co-location of residential and industrial floorspace.

    The Authority does not consider the Area of Change within the two sites to be suitable locations for tall buildings given their location within the Regional Park and adjacent to important areas of open recreational space most of which are protected for their ecological value.

    However the new designation for these areas of change as ‘locations suitable for tall buildings’ would open up the potential for tall buildings within the Park, on either side of Lea Bridge Rd and along the eastern boundary of the Lee Valley WaterWorks Centre.

    Despite the Site Allocation requirements for public realm and landscape improvements, tall buildings in these locations will both enclose and intrude upon the adjoining open landscape character of the Regional Park and the current visitor perception of openness and removal from the surrounding urban area.

    There will be even larger scale developments at New Spitalfields and Temple Mills as per the Draft Local Plan, and the same concerns about intrusion apply. Temple Mills is considered suitable for towers of between 15 and 25 storeys. New Spitalfields is stated to be suitable for towers of ‘between 18 and 30 storeys’, even higher than those proposed for the Lea Bridge area.

    Nearby open spaces at Eton Manor and Hackney Marshes (particularly East Marsh) will all be severely impacted by the presence of tall towers and by a very large new population utilising these spaces for recreation and leisure. The impact of pets, increasingly posing risks to sensitive and easily disturbed species, is not assessed for these ecologically important areas.

    If this Local Plan is adopted, Lea Marshes will have towers of considerable and intrusive height all along their eastern fringe from Lea Bridge Station to New Spitalfields.

    We have previously discussed at length the unnecessary risks involved with this foolish intention to build on floodplain at New Spitalfields during a climate emergency. Even as this consultation takes place, there is serious flooding deluging streets, playing fields and residential areas across England.

    Flood risk isn’t seriously addressed in the numerous pages of documentation. Waltham Forest Council merely make the following comment regarding the New Spitalfields site:


    V. Mitigate the Flood Zone 2 fluvial flood risk across the site through the use of effective
    design, siting buildings to the lowest flood risk areas and prioritising vulnerable uses
    and/or infrastructure to be sited away from the areas of highest flood risk

    Quite how this ‘mitigation’ is meant to be applied when there are no ‘lowest flood risk areas’ on the New Spitalfields site is anyone’s guess. The site is all located in Flood Zone 2 and some of it in the higher risk Flood Zone 3 (see image above).

    What is the reason a deluge of development should be unleashed upon the most deprived part of the borough and in close proximity to its most ecologically valuable sites? It seems the advantage is simply to drive up Council Tax revenue for a cash-strapped council who have an ideological commitment to growth at all and any cost. With the new Labour goverment very much committed to national residential growth per se, rather than building the right homes in the right places, unfortunately there will be a carte blanche for this type of inappropriate and damaging planning at a local level.

    So what can we do? Firstly we must object. Please send your comments to localplanconsultations@walthamforest.gov.uk 

    You can read our full submission to LP2 as well as our previous (ignored) submission regarding New Spitalfields for further context and detailed analysis of the inappropriate site allocations.

    CPRE London have also objected to Local Plan 2, specifically the unsoundness of the plans for the New Spitalfields site and the Lea Bridge Station sites. The charity also continues to support plans for East London Waterworks Park at the Thames Water Depot and another much-needed community park on currently fenced-off green land east of Banbury reservoir.

    Key points to include in your objection:

    • Oppose the division of the Thames Water Depot as indicated in the Lea Bridge Strategic Area map. There has not been a transparent consultation about the status of this land. Moreover the whole site, which is Metropolitan Open Land, should be retained as open space and not divided in any way. As Waltham Forest Council stated in their planning refusal for the two free schools, the whole of the depot site should be accessible to the public in its entirety. The Local Plan should designate the depot site as East London Waterworks Park – a vital community asset that will improve the health and well being of the local population in the most deprived part of the borough. As a floodplain adjacent to the Lee Navigation and River Lea, the area not suitable for new buildings, including a secure facility for children.
    • Oppose the allocation of Rigg Approach, Orient Way and Lammas Rd for high-rise residential blocks. These areas should be retained for low-rise local industrial buildings to support local business, and due to their close proximity to the Lee Valley Park and their location in an overcrowded part of the borough, should not site tall residential tower blocks.
    • Oppose residential development at New Spitalfields. This area is in Flood Zone 2 and 3. It should be partially or fully restored to functional floodplain to improve flood resilience. It is highly unsuitable for tall buildings, and under no circumstances should tower blocks of up to 30 storeys in height be situated adjacent to ecologically sensitive sites of Hackney Marshes and the Old River Lea.

    Please send in your objection before 9 October 2024 if possible.

    Posted in Hackney Marshes, Lea Marshes, River Lea, Thames Water site, Walthamstow Marsh, Waterworks | Tagged , , , , , , , , , | 7 Comments

    New Spitalfields development threatens disaster

    New Spitalfields development threatens ecological and flooding disaster!

    The New Spitalfields development is back as part of a new consultation on the Leyton Mills neighbourhood. You can download the consultation document using this link https://talk.walthamforest.gov.uk/leyton-mills-spd

    You have until 14th April to comment.

    We would urge you to do so.

    First, there are some improvements on earlier plans. The absurd idea of building a pedestrian/cycle bridge across the Old River Lea from New Spitalfields to the opposite bank of Hackney Marshes, directly onto the Site of Metropolitan Importance for Nature Conservation (SMINC), has been taken out. Access to the Old River Lea from New Spitalfields is to be prevented by a green barrier along the river bank and the pedestrian/cycle path up the east bank of the river has also been abandoned, all points strongly argued for by Save Lea Marshes to protect Nature.

    However, that is about the sum of the good news.

    The scale of the development remains much as it was. The whole Leyton Mills area, which includes the present Leyton Mills Shopping Centre, New Spitalfields Market, the Temple Mills Bus Depot and Eton Manor, will host up to 5,400 homes. No breakdown per area is provided. However, based on existing average households this will mean a total new population of around 13,000. New Spitalfields and the Bus Depot site will most likely account for more than half of that number, meaning a new town of around 7-8,000 people right next to the Marshes. Such an enormous site is simply unsustainable in such an important and vulnerable environment.

    The document lists “Hackney Marshes and the Old River Lea protected and enhanced for ecology and biodiversity” as one of its goals. It is hard to understand how a new population of this size right next to Hackney Marshes, plus the thousands at Leyton Mills and other developments nearby at Estate Way and Coronation Square, can allow for the protection and enhancement of the ecology and biodiversity of the Marshes and the Old River Lea.

    The plan for this enormous set of developments clearly emanates from the same mindset that has given us the much smaller development at Lea Bridge Station. The Lee Valley Regional Park Authority (LVRPA) noted that the Lea Bridge Station development would have a negative impact on Lea Marshes: the growth in population would result in increased footfall, and the tall towers would produce a decreased sense of openness. Sadly, despite being charged with the protection of the Marshes, they kept these findings to themselves in an internal report (see the screenshot below) preferring instead to take the Section 106 money on offer.

    The developments at New Spitalfields and the Temple Mills Bus Depot will inevitably entail a far greater increase in footfall than at Lea Bridge Station. Furthermore, the cumulative impact of building at all three sites will create a concrete vista of towers all along the east side of the Marshes (see the graphic below from the consultation document) thus severely reducing the prized sense of openness and freedom from urban intrusion. Exactly how tall the towers will be is not stated but previous documents referred to heights of up to 30 storeys. Much was made of the views over the Marshes in earlier documents, obviously good selling points for flat occupiers and developers. One of the ways that planners attempt to justify such overbearing and inappropriately sized buildings is to refer to them as ‘gateways’ or ‘landmarks’ for our green spaces.

    It will, of course, be possible to create the required Biodiversity Net Gain on both New Spitalfields and the Bus Depot as, at present, they are almost entirely concreted or tarmacked over. The negative ecological impacts will primarily be on Hackney Marshes and the Old River Lea. These burdens will fall principally on Hackney. Waltham Forest Council will be the beneficiary, collecting significant additional council taxation from these high-rise developments.

    It may be possible to protect the Old River Lea at New Spitalfields itself with a green buffer along the river bank, as set out in the plans. However, it will not be possible to stop people accessing the river and the Site of Metropolitan Importance for Nature Conservation (SMINC) at East Marsh or when they cross the river at White House Bridge to South Marsh. In recent years the river has become popular with swimmers and party-goers. Despite the fact that the number of these visitors has been limited there has been an immense amount of damage caused to vegetation and wildlife at  the SMINC on the Hackney side of the river as well as to the opposite Waterworks river bank.

    The denuded Waterworks river bank at the Old River Lea

    However, if the New Spitalfields and Bus Depot developments go ahead the situation will become much worse. The number of people visiting the river will rocket and the impact on the ecosystem will become quite intolerable. The thousands who will move into these new homes will have the Marshes on their doorstep. It was suggested at the planning consultation held at ASDA that marshals may be able to keep the harm from this additional new population in check. This seems optimistic. It would mean round the clock security at immense cost. PSPOs which have previously been taken out by Hackney Council have had no impact on the behaviour of swimmers and party goers.

    Green and blue spaces like Hackney Marshes and the River Lea are supposed to be places for relaxation and the improvement of our physical and mental health. However, they have a limited capacity to provide health benefits when crowded out by tall buildings and when crammed with users and their pets. Placing so many thousands of new residents so close to the Marshes and the river will overwhelm their capacity to meet the needs of the community living in the wider area. Far from enhancing the environment, the new developments will severely compromise the existing and already degraded ecology of Hackney Marshes and the Old River Lea.

    Existing transport connections, air quality and noise pollution are already stretched. The consultation document notes: “The Leyton Mills area features significant highway infrastructure including the A112 High Road Leyton, A106 Eastway / Ruckholt Road and the A12. These routes take high volumes of traffic accessing the local area and the strategic road network, and present challenges in terms of severance, air quality, noise pollution and comfort for walking and cycling.” Pouring so much concrete and putting these open spaces under such pressure from users will further reduce the capacity of the Marshes to combat air pollution and city heat. The site will attract new traffic and there will be considerable demand for delivery and other services worsening air pollution. While the plan is to make these sites car free it is likely expensive flats will have to be provided with garage space to make them attractive.

    Such an enormous new population will need far better public transport, which may be hard to achieve given cuts in bus services. The plans include a new railway station at the Bus Depot, however, this is by no means certain as Stratford Station is already overcrowded and lacks the capacity to absorb yet more passengers. There is already a serious traffic bottleneck over the railway. If a new railway station is constructed, there will be heavy movements of people across Ruckholt Road to get to the station adding to traffic problems. If the station is not provided, the roads into Leyton will be crowded with people walking to Leyton Tube Station, further stressing the capacity of that station.

    The document also recognises this part of Waltham Forest is the most deprived part of the Borough: “The SPD area is surrounded by relatively high levels of deprivation – over 30% of the Lower Layer Super Output Areas (LSOA)2 are in the top 20% most deprived nationally, which is well above the proportion for Waltham Forest or London as a whole. Particular challenges faced by people in the area are access to housing and services, living environment”. The document fails to mention that the south of the Borough is also the most overcrowded part of the Borough and suffers the highest levels of health inequality, which the council claims it is tackling. Yet despite these already desperate conditions of deprivation, overcrowding and poor access to services this is the part of the Borough in which the council is concentrating its development programme. It is next to impossible to improve health inequalities when services will be ever more stretched by such a massive rise in population. Once again this project is simply unsustainable.

    Finally, and most seriously, on top of these very severe shortcomings, the greatest risk these developments pose arises from their location, smack in the middle of a river valley. The consultation document recognises this is flood plain and that there is a risk of flooding (as is seen in the graphic below). The sites are not just next to or near the Old River Lea but also the Dagenham Brook, which crosses New Spitalfields, and the Fillebrook which runs between the two sites.

    It is known the Flood Relief Channel is no longer adequate to cope with a major flood and has nearly overflowed on several occasions. Cumulative development further north means there is too much hard surfacing and run-off from roads, too much sewage from Combined Sewage Overflows, and too little land to absorb floodwaters all the way down this part of the Lea Valley. A recent upsurge in rain caused the Lea Navigation to flood Hackney Wick and Fish Island and brought the Old River Lea to the edge of New Spitalfields and Hackney Marshes.

    The River Lea is already severely polluted. The river is reaching its limits.

    Under normal circumstances it may be that some technical fixes can be implemented. The plans propose the following such fixes: “Setting floor levels above flood level • Including flood-plain storage compensation • Incorporating flood evacuation and civil contingency systems.” However, these are not normal times.

    Nowhere in the document is any mention made of the often declared climate emergency. Waltham Forest has declared one of these emergencies! These are not sites set back from the river, they are right next to rivers, three of them, all at risk of flooding. If the flood relief channel overflows at the Waterworks the river will be in danger of turning into a torrent as it discharges just north of New Spitalfields. The river is on a bend at New Spitalfields, which is also where the Dagenham Brook joins the Old River Lea, making it a particularly vulnerable point.

    The risk is increasing. The climate emergency is not a ‘maybe’. It is now. In July 2022 temperatures in London exceeded 40°C. Meteorologists quoted in The Guardian were astonished by what was happening

     “In my training, which was only about 10 years ago, I was led to believe that 40°C in the UK was nigh on impossible, because there are all sorts of factors that should stop that from happening, not least the fact that we are surrounded by ocean. It should be too moist for temperatures to get that high.”

    What was considered ‘nigh on impossible’ happened. “Even as a climate scientist who studies this stuff, this is scary.” “I wasn’t expecting to see this [40°C] in my career,” said Prof Stephen Belcher, at the Met Office.

    Extreme weather events of this kind are no longer future events. If anything these risks are underestimated. This is not just about heat but about extreme events of all kinds. As Professor Michael Mann, at Pennsylvania State University in the US put it: “This is because of processes that are not well-captured in the models but are playing out in the real world – e.g. the impact of warming on the behaviour of the summer jet stream that gives us many of the extreme heatwaves, floods, droughts, wildfires we’re seeing,” he said. “It suggests that models, if anything, are underestimating the potential for future increases in various types of extreme events.”

    These developments are already problematic, given the harm they will do to Lea Marshes and the Old River Lea, and their location in the most deprived and overcrowded part of Waltham Forest. Additionally, such development prevents a sustainable use of the land which could alleviate flood risk and genuinely improve ecology: returning the area to absorbent floodplain and marsh. Once built, this vulnerable development will be there for half a century at least, just as the climate emergency ramps up and things are likely to get a lot worse. We have to expect not just worse weather but extreme weather, including extreme flash flooding.

    We are constantly warned against building on floodplain, yet here we are again planning to do exactly that in the heart of a vulnerable river valley in the midst of a climate emergency!

    Posted in Hackney Marshes, Lea Marshes, River Lea | Tagged | 1 Comment