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.
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.
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.
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.