Our Response to the LVRPA Chief Executive re the Lower Lee Valley

Dear Board Members,

Following our email to the Board on 14th March 2022, we received a reply on 25th March 2022 from the Authority’s Chief Executive, Shaun Dawson, on behalf of the Authority, here:

https://www.saveleamarshes.org.uk/wp-content/uploads/2022/06/2022.03.25-Julian-Cheyne-email-response-2-1-1.docx

We have delayed our response to the Chief Executive’s comments until after the election to give time for the new Board to be established.

Siting the Ice Centre at Leyton Marsh

First, regarding the Ice Centre, as the Chief Executive says we disagree with the decision to build the Centre at Leyton Marsh.

We disagree because Eton Manor would have been a much better location. It has greatly superior rail and bus connections and would have favoured your plans to turn the Centre into a national facility. Stratford regional station, which is connected to Eton Manor by a bus route, the 308, is now the busiest railway station in the UK. Stratford links to all the mainline stations in London via the London Underground and is also served by a bus and coach station which has its own network of routes all of which would have made it easier for the LVIC to achieve its targets on reducing car usage. It is also next to the A12 Motorway making it a much more suitable site for vehicular access where necessary.

If the LVRPA had built the Centre at Eton Manor it would have been able to keep the old Centre in use while the new Centre was being constructed and thus have been able to keep its promise to its users to continue to provide skating during the construction process. It would also have earned money which would have helped the Centre hold on to the seating it has had to reduce to save costs, a loss which will limit its capacity to host major events and reduce its future earning capacity. It was always ambitious to expect to keep the Centre active as demolition and construction occurred on the same site.

All these points were made by Save Lea Marshes in discussions and in objections but the LVRPA ignored our reasonable arguments.

Eton Manor

Second, extraordinarily, the LVRPA decided not to put the Ice Centre at Eton Manor because it wants to build a hotel there.

In his reply the CEO says building a hotel is consistent with the LVRPA’s remit. However, he doesn’t say how it is consistent with this remit.

Eton Manor is Metropolitan Open Land. It was provided by philanthropists for the use of local people. Among the facilities also provided by these philanthropists were the Manor Gardens Allotments, which were located on another site owned by the LVRPA at the Eastway in what is now the Olympic Park, before they were evicted to make way for the Olympics. However, the Manor Gardens Allotments Society was granted planning permission to return to the Olympic Park at Eton Manor after the Games were over, to this piece of land originally provided by these same philanthropists for the use of local people.

Instead of honouring this agreed planning permission at Eton Manor the LVRPA then acted in concert with Waltham Forest Council to overturn that permission on the grounds that this was a private use of this land, thus effectively forcing the eviction of the allotments society from its land in the Olympic Park twice over.

Allotments are suitable for MOL, they are an environmentally compatible use of the land, the allotments had been the LVRPA’s tenants before the Olympics and their presence at Eton Manor would also have been compatible with the historic purpose of the land as it was provided by philanthropists for local people.

Instead of such a compatible use the LVRPA plans to build a hotel on this Metropolitan Open Land, a private hotel which has no use for local people, is not compatible with the original purpose of the land, is not environmentally appropriate and has no discernible connection to the LVRPA’s remit to protect and enhance the Lea Valley Park. We fail to see how, after deciding allotments were unsuitable for this land, the LVRPA can claim that building a private hotel is more appropriate.

Given these facts we would be grateful if the LVRPA could explain how building a hotel at Eton Manor fits with its remit.

Environmental Benefits of Building on Eton Manor, not Leyton Marsh

Third, regarding the claimed community and leisure benefits of the Centre, all these could have been provided at Eton Manor. The proximity of other sports facilities would have provided synergies for the LVIC, such as sharing staff, providing minibus transport connections for its users of the kind HereEast provides, or joint ticketing arrangements, all of which would have eased the LVRPA’s financial difficulties in building a much more ambitious Ice Centre.

We will have to wait for the claimed environmental improvements at Leyton Marsh as you have cut down a large number of trees and destroyed existing habitats, including areas where an increasingly vulnerable hedgehog population was known to live. The double-sized facility has taken up more land and extended out onto the Marsh. Any replacement planting will take time to mature. We dispute the claims of biodiversity net gain, as in this analysis: https://www.saveleamarshes.org.uk/2021/05/31/biodiversity-net-gain-at-the-ice-centre/

If the Centre had moved to Eton Manor, the open space at Leyton Marsh, which is much more widely used by local people for recreation than Eton Manor, would have been been extended for their benefit and the land would not have had to be cleared and trees and habitat destroyed. Save Lea Marshes had long asked for money provided by the Olympic Delivery Authority in compensation to the community for the loss of access during the Olympics to be spent on planting trees to shield the Ice Centre from the Marsh. The LVRPA had failed to make those improvements.

At the Waltham Forest Planning Committee hearing the Chair of the Committee, when justifying the decision to grant permission for the Centre, described the Marsh as a “pretty scrubby desperate bit of Metropolitan Open Land”, hardly a ringing endorsement of several decades of management by the LVRPA and the opposite of biodiversity gain.

By comparison with Leyton Marsh, the site at Eton Manor would have required little alteration or environmental destruction for construction to occur. Substantial environmental improvements could have been included in the project.

This would have been a genuine win-win situation for all concerned, for skaters, for local people at Leyton Marsh and for the LVRPA. Skaters would have been able to continue skating and would not have been inconvenienced as local transport connections to Eton Manor are as good as if not better than for the site on the narrow and congested Lea Bridge Road. The LVRPA would have had a much better connected Centre with better facilities and local people would have enjoyed an enhanced local space at Leyton Marsh.

Regrettably, all our sensible and considered suggestions were dismissed as hostile, with a campaign to persuade skaters to oppose them, rather than evaluated in terms of their genuine benefits for all parties.

Inadequate Consultation

Fourth, on the issue of consultation, the Chief Executive has not responded to our general point that there is no ongoing consultation with the community at large on the Authority’s activities and plans for this part of the Lea Valley Park.

As stated, there used to be a forum, then renamed a workshop, at which agendas were presented and minutes kept and at which plans could be presented and responses heard. All this has been stopped.

Regarding the meetings which have been held, the CEO says the terms of these discussions are agreed. This is not so. The LVRPA sets the terms of the discussions which are strictly limited, which is why, at the most recent meetings on the Ice Centre, Save Lea Marshes withdrew from the ‘consultation’ as we considered it did not allow for a broad enough discussion of the impacts of the Ice Centre on the Marsh and the Oxbow and was essentially pointless.

When a follow up meeting was held to discuss the impacts on the Oxbow the LVRPA tried to break the connection between the two sites and set it up as a meeting simply to provide information on what it planned to do and not to discuss the relationship between the two sites. This was most certainly not what we had agreed to and was not the reason for calling the meeting.

The LVRPA then cancelled a further onsite meeting without any consultation.

Concerns about the Oxbow

Fifth, regarding the Oxbow, the fact that plans for the island had earlier been drawn up did not take into account the new impacts that could be anticipated from the Ice Centre project. Plans need to be reconsidered when the context changes.

It was plain from our discussions at the LVIC meetings that the LVRPA had not considered how the plans for the Centre and, in particular, its cafe would impact on the Oxbow.

This became apparent when we raised the issue of the bridges, as they appeared on the Ice Centre documents, and their implications for the Oxbow. The immediate response at the meeting was that the two bridges should not have been in the plans and their inclusion was an error. This statement was then reversed and we were told the bridges were in the plans. This confusion demonstrated the lack of thought that had gone into the preparation of these plans.

After the online meeting to discuss the Oxbow the second bridge was abruptly, and sensibly, removed. Nevertheless, it was insisted the land bridge be retained as if it was some kind of permanent feature. However, in reality it had been created by people throwing old tyres and other rubbish into the channel over the culvert. This was an opportunity to recreate the island. We were told the best way to manage a site like this was to allow people access. However, if the island had been recreated management of access would not be an issue as people could not have got onto the island.

We continue to believe this was a missed opportunity for the LVRPA and CART to create a unique environment and we remain concerned at the likely impacts of the cafe on the Oxbow, on nesting sites on the island and on the Marsh.

We consider that our attempts to raise this matter have been helpful to the LVRPA for its future management of the cafe and Centre as we do not think these impacts were being properly assessed.

We have to disagree with the Chief Executive’s assertions regarding the impact of the work on the swans at the Oxbow. We were informed the nest was destroyed by someone working on the site. This was consistent with the fact that the nest was in the channel where the work was being done. Either way the swans were disturbed and they had to build a new nest in a new, less secure location. This work should not have happened during the nesting season and was contrary to the law on protecting nesting birds.

Mismanagement of Three Mills Green

Sixth, regarding the catastrophe at Three Mills, we disagree that this can be blamed on the weather.

Planning for an event of this kind must and should have taken possible adverse weather conditions into account. Rainfall in Britain is not unusual.

More importantly, the Chief Executive fails to note that one of your own members of staff had warned of the damage an event of this kind would do to Three Mills Green. This was mentioned in the LVRPA’s own landscape document. This member of staff explicitly referred to “the grass being sparse and exposed to heavy trampling and wet conditions” and was concerned that the ground “takes longer to recover after the annual music event”.

This makes it clear the “annual music event” was their concern, along with the underlying condition of the grass, not unexpected rain, as “wet conditions” were to be expected. This land was lost to the local community for a year.

The fact is the LVRPA still plans to expand these events on vulnerable sites like Three Mills Green and the Waterworks showing no understanding of how similar results can be expected in future.

Save Lea Marshes has raised the same concerns about the Waterworks Meadow. The public provided £5,000 to cover the cost of surveys, which we have provided to the LVRPA, demonstrating the community’s concern for this land. We consider the surveys strongly support the idea that this land deserves better ecological management, which would keep it available for public recreation rather than short-term exploitation as a venue site and prevent it becoming another “pretty scrubby desperate bit of Metropolitan Open Land”.

Exploitation of Green Open Spaces

Seventh, the imbroglio at Three Mills Green reveals how the LVRPA treats this part of the Lea Valley Park as an area for making money.

It also highlights the lack of public involvement in deciding on the use of the LVRPA’s land in the area.

There is no public involvement in your plans with University College London to build sports facilities at Eton Manor. It is beyond ironical that this land was specifically provided by philanthropists for the benefit of local people’s sports and yet you are proposing to use it to advance the interests of an elite academic institution to “recruit and retain students”, most of whom will have no connection with the area and many of whom will be international students.

Another of the LVRPA’s money-making ventures in recent years was its plan to build a housing estate on Metropolitan Open Land at the Waterworks. It has deliberately run down the Waterworks Centre which local groups like the Waltham Forest Civic Society have registered as an Asset of Community Value, once again showing local people’s concern for these facilities and open spaces.

A decade of so ago the LVRPA speculated on the idea of building another hotel on Metropolitan Open Land in front of the Ice Centre at Leyton Marsh. Now you are planning the same at Eton Manor.

Inconsistently, while it objects to ‘private’ allotments, the LVRPA has built private horse-riding facilities in the form of Livery Stables at the Riding Centre. Livery horses are paddocked at the very extensive paddocks on public land at the back of the Riding Centre and their owners benefit from being able to use the public land of the Marshes to exercise their horses.

None of these actions are compatible with your remit to protect these green open spaces for the benefit of the public.

Failure to Protect the Lower Lee Valley from harmful development

Finally, even when it sees others acting to harm the Marshes the LVRPA takes no action.

The Authority recognised the harm Waltham Forest Council’s development at Lea Bridge Station would do to the Marshes, as its own report to the Board stated. However, instead of then making an objection to these plans it stayed silent and took no action.

Soon the LVRPA will be faced with the prospect of a massive development at New Spitalfields. Indeed, Waltham Forest is building and plans to build towers all along the east side of the Marshes. Has the LVRPA made any representations against any of these plans or against the present draft Local Plan? The Planning Inspectorate has raised serious objections to these proposals but the council ploughs on regardless. Will the LVRPA act to protect our Green Lung or is it going to leave everything to local people?

Will it say anything about the prospect of a small town being built on the New Spitalfields site right next to the Marshes and the River Lea? We attach an indicative plan of what is proposed for New Spitalfields, 2,750 units, a likely population in excess of 6,000, with towers up to 30 storeys high and a cycle/pedestrian route north up the east side of the River Lea to the Waterworks Meadow. Save Lea Marshes is already campaigning against this abominable project.

The LVRPA was created to protect our Green Lung for the benefit of local communities, not to build over it and exclude local people.

It may be that those representing areas which are well provided with green open spaces are unconcerned about our communities in this part of North-East London. However, green spaces are important for people’s physical and mental well being, even more so in areas like ours which are deprived, built up and lacking in such spaces.

It is our communities using the Lea Valley Park which are most in need of these green spaces and these are the last places that should be treated as opportunities for exploitation. It is these parts of the Park that most need the protection and active intervention by the Authority set up to govern it.

Yours sincerely,

Julian Cheyne

on behalf of Save Lea Marshes.

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UK Power Networks: Leyton Marsh Works

General information on works on Leyton Marsh beginning this month in the first image below, followed by more in depth information on the project:

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Waterworks Wildlife Surveys

In 2020, we successfully crowdfunded for wildlife surveys of the Waterworks Meadow. We did this in order to reveal the biodiversity of the meadow, with the aim of convincing the Lee Valley Regional Park Authority to ‘rewild’ the area, to maximise its potential for wildlife.

Thank you again to everyone who donated.

At the end of last year, these surveys were completed and, after submitting all the findings to the Lee Valley Regional Park Authority, GiGL and Waltham Forest Council, we would now like to share the key findings and recommendations with you.

Brown-banded Carder bee by Russell Miller

The Waterworks Meadow will be assessed for inclusion on the list of Sites of Importance for Nature Conservation (SINCs) by Waltham Forest Council in the coming year. We are still awaiting the outcomes of the Lee Valley Regional Park’s own surveys and its assessment of the area.

Huge appreciation to our surveyors – Annie Chipchase, Alison Fure, Ian Phillips, Rob Sheldon and Russell Miller.

Here are some very brief highlights – you can download the full survey collation here.

Key findings

  • Six bat species were recorded during the surveys. Common (Pipistrellus pipistrellus), Soprano (Pipistrellus pygmaeus) and Nathusius’ (Pipistrellus nathusi) Pipistrelle Bats, as well as the occasional commuting Noctule Bat (Nyctalus noctula) and one Serotine (Eptesicus serotinus) commuting pass. There was a Daubenton’s Bat (Myotis daubentoni) commuting at the culvert during the first survey and two Daubenton’s foraging at the Waterworks nature reserve lake.
  • Two species of amphibian (Common Toad Bufo bufo and Smooth Newt Lissotriton vulgaris) and one species of reptile (Grass Snake Natrix helvetica) were recorded, including young individuals of Smooth Newt. Common Toad and Grass Snake are UK Biodiversity Action Plan (UK BAP) species.
  • Six species of terrestrial mammal were also recorded including Red Fox Vulpes vulpes, Grey Squirrel Sciurus carolinensis and Rabbit Oryctolagus cuniculus.
  • Small mammals recorded during surveys of the Waterworks Meadow included Common Shrew, Short-tailed Vole, Wood Mouse and Muntjac Deer.
  • The wide range of families and species suggests that the Waterworks Meadows provides an important habitat for a diverse assemblage of invertebrates. Twenty bee species were recorded confirming the diversity and abundance of nectar and pollen resources available on site. Possibly the most important species recorded was the Brown-banded Carder bee Bombus humilis which is a priority species for England.
  • Within the Waterworks Meadows the mosaic of scattered trees, flower-rich grassland and proximity to water provide larval and adult habitat for a wide diversity of species.
  • Overall, a total of 166 plant species were recorded across the site with the Central and Eastern Grassland areas being the most diverse with 109 and 92 species respectively.
  • The area as a whole is relatively diverse from a botanical perspective with a good mixture of herbaceous plants, trees and shrubs.
  • A total of 69 bird species were recorded across the 2 sites (including flyovers), with 53 species in the Meadows and 59 species in the Waterworks Nature Reserve.
  • There were 30 species that are classified as Birds of Conservation Concern according to the latest review of bird populations in the UK, of these 7 are red-list species and 21 are amber-listed.
  • Of the red-listed species, three singing male Greenfinch Carduelis chloris were recorded on the Meadows, and singing males were also recorded for amber-listed Whitethroat Sylvia communis, Wren Troglodytes troglodytes, Song Thrush Turdus philomelos and Dunnock Prunella modularis. Song Thrush was confirmed breeding in both the Meadows and the Reserve.
  • The regular presence of a Kingfisher Alcedo atthis along the River Lea, including during the nesting season, suggests breeding nearby (and this has been witnessed and recorded by local birdwatchers this season).

Key recommendations

  • The Meadows is a relatively small area rich in wildlife and habitats that provides connectivity to other neighbouring areas such as the Waterworks Reserve and Hackney Marshes. Providing such connectivity within fragmented urban landscapes is an essential way of helping mitigate the future effects of climate change.
  • Future management of the Meadows should take into account the cumulative impact of other developments within the Lee Valley Park that have seen a reduction in green space and important wildlife habitat.
  • Sites rich in biodiversity, such as the Meadows, should be prioritised for habitat management and enhancement rather than activities such as large mass-participation events that will damage habitats and associated biodiversity.
  • Introduce low-level cattle grazing to the Meadows to help diversify vegetation structure and provide niches for seed germination etc.  Such management will be beneficial for a wide range of invertebrates that will have positive impacts higher up the food chain for a range of taxa including bats and birds.
  • Work with neighbouring landowners and businesses to mitigate the effects of light pollution on foraging and roosting bat species.
  • Undertake habitat improvements to maximise ecological niches for the widest possible range of species. Features such as log piles, excavation of small ponds and targeted scrub planting will provide enhancements for many of the species currently recorded as well as offer opportunities for colonisation from neighbouring areas and habitats.
  • Additional surveys should be undertaken to further improve knowledge of the biodiversity of the Meadows and inform ongoing management.
  • The Waterworks Centre could be utilised as a focal point for public engagement about the wildlife in the surrounding area. Its integrated use as a visitor centre, managed holistically alongside the Meadow and Reserve, could be most helpfully modelled on the successful Fishers Green Wildlife Discovery Centre.
  • No building on, or adjacent to, the Waterworks area.

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Threats to the marshes – Part II

Threats to the Marshes – building and inappropriate uses on open spaces

This is the second of our articles on the threats to the Marshes and other green open spaces. In our first article we dealt with the threats posed by the growing number of tower blocks lining the eastern side of the Marshes and the scale of developments at sites like New Spitalfields, Lea Bridge Station and Blackhorse Lane, their impact on the openness of these vital open spaces and the greatly increased population pressures they bring. Green open spaces have a crucial role to play in improving the physical and mental health of people, particularly those living in over-crowded and deprived areas like South Waltham Forest.

However, not only are there threats from developments on the edge of the Marshes; there are also ever-present threats from development on the open spaces themselves, including from schemes to build sports facilities and other developments like hotels, entertainment events, poor management of open spaces and the lack of awareness on the part of the public about the damage they can do with thoughtless fun.

Developments on open space

The Ice Centre

The LVRPA is building a greatly expanded double pad ice centre at Leyton Marsh, a wholly unsuitable site which has poor public transport connections and is situated on a narrow congested road. It should have been put at Eton Manor, as argued by Save Lea Marshes, where it would have been close to the extraordinarily well connected Stratford Station, now the busiest rail station in the UK and about to add yet another connection with the advent of Crossrail. However, the LVRPA has its greedy eyes on the open space at Eton Manor as a site for a (probably not) money-spinning hotel, so this is the reason why it has had to put the Ice Centre on Leyton Marsh instead.

Just as with the Olympics, when Waltham Forest gave permission for the damaging temporary Basketball Arena, which was barely used, Waltham Forest has viewed the Marsh with disdain. During the hearing into the Ice Centre application, the Chair of the Planning Committee declared Leyton Marsh to be a “desperate, scrubby, piece of Metropolitan Open Land”. Of course, it is the LVRPA which is responsible for the state of this MOL, so if she has such a low opinion of this piece of land it is the LVRPA she should hold responsible. Instead of insisting on proper care of the Marsh Waltham Forest uses the LVRPA’s mismanagement as a reason to agree to its plans.

The new Ice Centre has expanded onto and towers over the Marsh and has already involved the destruction of trees and habitat, particularly an area known to have provided a home for hedgehogs, a species increasingly under threat in the UK. The image below, taken from a video shot by contractors Buckingham Group https://www.youtube.com/watch?v=Yc9sgH0yms4, shows the area taken by the development.

Ian Phillips described these impacts in a video filmed after planning permission was granted https://www.youtube.com/watch?v=WM5_cyW5pb4. Unfortunately ecologists employed by bodies like the LVRPA are there to progress their employer’s plans and these ecologists were no different. The image below shows land at the rear of the old Ice Centre cleared for the development.

The image below, taken by Kimberley Rowley in mid January, shows how the Ice Centre dominates the Marsh.

The LVRPA made specious claims about Biodiversity Net Gain at the Ice Centre https://www.saveleamarshes.org.uk/2021/05/31/biodiversity-net-gain-at-the-ice-centre/, the latest officially sanctioned trick up the sleeves of developers whereby an area is run down so the developer can later claim an ecological improvement when they come to demolish an existing amenity.

The site lacks good public transport connections so despite claims it will reduce car usage it will actually encourage car use. The Ice Centre includes a 155 space car park. The idea is that the Centre will host national events. In fact, it is likely the Centre will fail in this objective as the LVRPA has already had to reduce the amount of seating to save money, which makes it less attractive for important events. For the same reason, it also had to abandon its plans to keep the Centre open while the new Centre is constructed, thus breaking promises made to skaters, who were encouraged to write in in support of the plans.

Whether or not it succeeds in its national ambitions, the Centre will be trying to attract users from wider afield and given the poor public transport links this will mean more people travelling from distance by car. Consequently there may well be overflow problems onto local streets, particularly at weekends when such events are likely to be held.

The Ice Centre will have long-term impacts on the Marshes and, most particularly, on the Oxbow Island, discussed below.

The Oxbow island

Another vulnerable site is the Oxbow island, next to the Ice Centre. The LVRPA has failed to approach the development of the Centre in a holistic way. The Ice Centre will include a cafe, which will also have an outdoor platform where people can consume food.

Save Lea Marshes participated in meetings at the time of the demolition of the Ice Centre and tried to discuss the future of the Ice Centre in the context of the Oxbow and the Marsh. The LVRPA refused to discuss the Oxbow in those meetings.

After considerable argument the LVRPA agreed to hold a separate meeting on the Oxbow but then spent most of that on presentations of what they were doing, which caused considerable frustration for those waiting to discuss the project. Their proposals included two bridges across to the island. The discussion became heated and a further on-site meeting was proposed. However, before that on-site meeting could happen the LVRPA announced it was going ahead with construction of a new land bridge and culvert, see image below. No further discussion or meetings would occur.

Save Lea Marshes had proposed that the island be restored as an island without any bridges so that it could be a unique environment and wildlife haven on this stretch of the River Lea. We do not think the LVRPA’s plans for access are compatible with the ‘island’ being a nesting site for swans and a site for an otter holt.

The Oxbow is a relatively short distance from the Ice Centre and its cafe. The Ice Centre cafe will not just serve skaters and visitors to the Centre but also members of the public using the Marshes. People driving to the Marsh will be able to park for free if they spend money in the cafe. It is not hard to envisage that people will see the Oxbow as a pleasant location to take food to and enjoy as a hangout with all the implications this has for disturbing and harming that environment and the wildlife.

The Oxbow channel will be receiving the melt water from the Ice Centre rinks. This is supposed to be filtered and cleaned in reed ponds in front of the Ice Centre before entering the river at the Oxbow channel. Plainly it is to be hoped this will work and not cause problems for that channel and the river. The creation of water features at the front entrance of the Ice Centre raises concerns that flooding may occur in the future.

To create a flow of water from the River Lea to ensure this melt water is carried away, the existing land bridge and collapsed culvert had to be dug out. Instead of leaving the restored channel open, thus recreating an island, the LVRPA and the Canal and River Trust simply went ahead with building a new bridge and culvert, thus failing to take the opportunity to create a unique environment and wildlife haven on this stretch of the Lea.

Lee Valley Riding Centre paddocks

A decade ago Waltham Forest Council Planning Committee acceded to the LVRPA’s planning application to allow it to create a set of livery stables for use by private owners of horses at the Lee Valley Riding Centre, another money-making venture. A large area of land had already been appropriated by the Riding Centre as paddocks at the back of the Centre, removing that land from use by the general public. The owners of horses using the livery stables have been given access to these paddocks, meaning public land is being used by private owners of horses, rather than for a public service as was previously the case.

It is worth noting that Waltham Forest Council and the LVRPA had prevented the Manor Gardens Allotments from returning to the Olympic Park at Eton Manor on the grounds that this would represent the private use of public land. So, while they disputed the right of the allotments to return to land which might be considered their home Waltham Forest and the LVRPA had no compunction about allowing the private use of public land at the Riding Centre.

Livery riders also get to use the public space of the Marshes to exercise their horses. They are supposed to keep to prescribed routes but the Riding Centre does not take responsibility for monitoring their activity and the routes are poorly marked, meaning they can come into conflict with other users.

Another small paddock was created at that time on the Waterworks meadow for a failed pony-trekking project. This area remains fenced off even though the pony-trekking project failed years ago.

It is virtually impossible for Riding Centre staff to oversee such a large area of paddocks. In recent times they have faced the problem of people feeding horses. It is indeed inappropriate for members of the public to feed the horses in any way, but the result has been that the Riding Centre has had to double up the fencing and the fear is further controls over public access to this area may be instituted.

This is a public space now being used inappropriately to serve a private purpose. The irony is that the location of the Riding Centre next to the Marshes provides an added attraction for people coming to the Marshes to look at the horses. The location of the paddocks is therefore bound to be problematic. In reality what needs to happen is for the Riding Centre to hand back this large area of paddocks and stop the provision of livery services.

Further threats to open spaces

Eton Manor, hotel and UCL/LVRPA masterplan

The LVRPA is persisting with its abominable plans to build a hotel on Metropolitan Open Land at Eton Manor. We also hear it has linked up with University College London (UCL) to develop a masterplan for the area. This ‘master’ planning explicitly includes the hotel project so it seems UCL is backing the LVRPA’s abominable project.

According to responses to Environmental Information Requests, UCL wants to build sports facilities for its students at Eton Manor. From UCL’s perspective its investment in the site will be to help the university “attract and retain students”. Once again the use of public land is being discussed in terms of its benefits for private users.

While the need to take account of the interests of a variety of stakeholders are mentioned, including the ‘commercial partner’ for the hotel project, no mention is made of any public use of the facilities.

So far neither of these august bodies has allowed the public any part in this exercise. UCL is a newcomer to the area and why it thinks it has some right to intervene on this site – originally the “Wilderness”, provided and dedicated by philanthropists to meeting the needs of local people – is anyone’s guess.

A hotel at Eton Manor is an absurdity and an offence. Eton Manor is Metropolitan Open Land and thus unsuitable for development in general. Special circumstances could be argued for it to be used for a sports centre such as the Ice Centre, after all Eton Manor already has sports centres on it. However, by no stretch of the imagination can a hotel be considered a special circumstance. To get around this the LVRPA is trying to persuade the London Legacy Development Corporation (LLDC) to change the designation of the land to ‘white land’, land on which development can occur. The LLDC is prone to making unprincipled decisions so this cannot be ruled out.

As mentioned above, the Manor Gardens allotments were supposed to move to Eton Manor after the Olympics, having been evicted from their site in the Olympic Park. First, the site was reduced to half the original size and a second site at Pudding Mill was designated for half of the Manor Gardens allotments. Then the LVRPA and Waltham Forest Council conspired to overturn the planning permission already granted by the LLDC for the remaining allotments site at Eton Manor. The LLDC went along with this underhand scheme http://www.gamesmonitor.org.uk/archive/node/2136.html.

This alleged guardian of the so-called Olympic Legacy is supposed to be ensuring that this legacy benefits the ‘existing population’ of East London. Yet, once again an elite institution is muscling in on public land, and private interests are taking precedence in development projects.

Eton Manor is in the Borough of Waltham Forest and Waltham Forest Council is preparing a Framework for the area. It is unclear what discussions the Council has had with the LVRPA, although the LVRPA claims its plans have been welcomed by the Council. Waltham Forest has said publicly it opposes development at Eton Manor, so who knows what is going on.

However, at the moment the planning authority is the LLDC. Given that the LLDC turned down a set of allotments at Eton Manor, a green development and open to local people to apply to use, it is hard to see how it can agree to a hotel, not green and very definitely private and with no discernible connection to the mandates governing the LVRPA. But then with public authorities of this kind it is sadly hard to know which way they will turn next. Enter University College London! Why and who next?

Hostel/Housing at The Waterworks Centre and car park

The LVRPA has long had its eye on part of the Waterworks as a site for housing development and still dreams of getting Waltham Forest to agree to change the site’s designation to allow for housing. Fortunately, Waltham Forest has resisted this. An earlier attempt to develop the northern part of the site, including part of the old golf course along with the Waterworks Centre and car park, was fought off by Save Lea Marshes, which raised a fighting fund to take the matter to court should the LVRPA persist in its plans. The LVRPA tried to combat hostility by restricting their plans to the Waterworks Centre and car park but this also failed.

However, the LVRPA is persistent. Instead of doing what it should and developing the Waterworks Centre as a genuine resource for the local community it has continued to run it down. A recent programme of ‘engagement’ by the LVRPA with Save Lea Marshes to discuss the future of the Centre went nowhere.

It seems obvious to us that the Centre and the Waterworks Meadow should be treated as a whole when planning for the future. In fact, we understood Shaun Dawson, CEO of the LVRPA, had agreed at a meeting of the Board that the Centre and the Waterworks Meadow would be treated as a whole when planning their future. Of course, when this was brought to his attention he denied ever making such a declaration.

As things stand the LVRPA now has longer-term plans to develop the Waterworks Centre as some kind of hostel. There has to be a concern that this will prove to be a wedge to move on to plans for a larger residential development. Of course, the LVRPA will deny it has any such designs. But then this is an organisation that wanted to turn Walthamstow Marshes into a quarry, mooted the idea of a hotel in front of the Ice Centre, definitely wants to build a hotel at Eton Manor and most certainly wanted to turn this site into a housing development.

The Waterworks Centre should be developed for use by the community, as argued by Save Lea Marshes and others in the area like the Markhouse Corner and Lea Bridge Road Residents Association, which successfully applied for it to become an Asset of Community Value. The Waltham Forest Civic Trust is now applying for the ACV status to be extended.

Waterworks Meadow

The Waterworks Meadow is seen by the LVRPA as another money-making asset rather than a valuable natural open space. It was originally a well used mini golf course, which meant it remained a green open space. However, at the time of the Olympics the LVRPA scented an opportunity to make money by hiring it out as a camp site. It persisted with this usage for a number of years before turning to another money-making scheme, music festivals.

More recently, it ran into massive public resistance https://www.saveleamarshes.org.uk/2020/05/18/application-for-the-waterworks-festival-refused/ when it tried to host a music festival in 2020 although this plan languished with Covid. Fortunately Waltham Forest Council Licensing Committee turned down that application. However, that the LVRPA wishes to continue with these events was made plain in its Landscape document which did not just refer to future events but to investment in infrastructure to enable it to host larger events there in the future.

The potential for harm from such events has recently been highlighted by the extraordinary damage done at another LVRPA music festival site at Three Mills Green in Newham last summer (see photo taken in mid January below) despite a warning from their own staff that such an event would do damage. The Green was fenced off so it was not available for the community to use from the end of July. It was then left in such poor condition that it was unable to recover and it will plainly continue to be so for months to come. The LVRPA remains silent on the damage it has done.

Although Waltham Forest refused permission for the event at the Waterworks it gave permission for a similar event by Secret Cinema at Low Hall Fields to take over most of that open space for most of the summer of 2021, a decision only overturned by the intervention of Sport England which objected to this use of sports fields. The former leader of WF Council, Councillor Coghill, who has since resigned as Leader and become Vice-Chair of a property company associated with the Lea Bridge Station development, failed to respond to residents’ concerns over that Secret Cinema event.

Following the defeat of the music festival application Save Lea Marshes raised £5,000 to carry out ecological surveys of the Meadow https://www.saveleamarshes.org.uk/2020/07/10/crowdfunder-launched-to-re-wild-the-waterworks-meadow/. These surveys demonstrated that a broad range of species utilise the meadow, including locally and nationally rare species, advancing the case that this land should be protected as a green space and be reserved for the recreation of local people. The Meadow is bordered by the Old River Lea and we consider at least part of it, most particularly the river bank, should be given the status of a Site of Importance for Nature Conservation (SINC), a designation which already applies to the Hackney side of the river.

In the past Hackney has allowed a large music event on Hackney Marshes, an event which also met with opposition from Sport England. Plainly it is necessary to remain vigilant about these threats as local Councils and the LVRPA cannot be relied on to protect their open spaces but see them as opportunities to make money.

The Old River Lea

The Old River Lea, as it runs past Hackney Marsh, is a Site of Importance for Nature Conservation (SINC), along with other areas along the River and the canal both north and south of the Marsh. Both sides of the River Lea, south of Friends Bridge at Hackney Marshes and the Waterworks Meadow, have now come to be treated as picnic and party venues. We have even had to contend with newspapers like the Guardian, which published misleading photographs by a local photographer who claimed to be an environmentalist, suggesting it is an idyllic wild swimming location https://www.saveleamarshes.org.uk/2021/04/09/the-guardians-response-to-our-letter-our-reply/. The Guardian even repeated the offence despite letters from Hackney Council and others warning against this activity.

Considerable damage has been done by people partying or paddling in the river, leaving large quantities of litter and lighting barbecues and playing loud music as in this video https://www.youtube.com/watch?v=E1ec46hO3Uc. This resulted in severe damage to the river bank, the cutting down of a tree after someone was injured using it as a swing, and harm to bird life to the extent of causing Little Owls to abandon their nests.

Hackney Council and the LVRPA have started taking steps to tackle the problem, although their effectiveness was not fully tested as the weather later in the summer was not as hot and the stresses of the pandemic were not so great as earlier in the year. However, banners put up by Hackney Council were torn down and thrown away and it is plain there are still plenty of people who continue to regard this area as a playground rather than an important natural habitat or SINC to be respected.

The river also suffers from severe industrial and sewage pollution which is an added and serious concern, ironically also for those who wish to use it to swim. Save Lea Marshes has taken part in discussions with Hackney Council and the LVRPA, and joined with other local campaigns like London Waterkeeper to get action on this serious harm to the river. We have also been carrying out our own testing of river water for phosphates which are an indicator for sewage pollution. The readings, which we regularly post on our Twitter account, have been extremely disturbing.

While it is urgent that this pollution should be stopped, the continuing failure of Thames Water, the Environment Agency and the UK government to get to grips with this problem means this is unlikely to be sorted out in the near future.

Instead of being able to rely on these public and private bodies, volunteers from other key campaigns like Plastic Free Hackney play a crucial role in cleaning up litter and waste matter from the river itself and the river bank as seen in the video below by Ian Phillips https://www.youtube.com/watch?v=oARMNJrwkJg.

Middlesex Filter Beds

Several years ago the generator powering the pump which fills the Middlesex Filter Beds with water was stolen. Since then the Filter Beds have been allowed to dry out, in contravention of the agreement the LVRPA has with Natural England for the maintenance of the Beds. The ecology of the Beds has been drastically altered and will take a considerable period of time to recover once water is finally pumped back into them. The LVRPA appears to be edging towards action but while it is able to find millions to finance pointless and harmful projects like the Ice Centre and a hotel it seems unable to rustle up the much smaller amount of money needed to carry out a task it has an agreement with a regulator to manage in keeping with its mandate to protect the Park.

Lack of consultation with the community

The Lea Valley Park exists for the benefit of the communities living nearby, and their needs and opinions should be at the heart of how it is managed. The one thing that has been highlighted by these cases is the lack of any ongoing consultation by the LVRPA with the community about the management of the Marshes. At one time there were regular forums with proper agendas, discussion and minutes. These were replaced by less formal ‘workshops’ and then by walkabouts with Rangers with no structure or follow up. When ‘consultation’ or engagement does occur, as with the Ice Centre and the Oxbow, it is highly managed and takes the form of presentations of what the LVRPA intends to do rather than discussion of what might be done. Save Lea Marshes complained some time ago to Green Flag about the lack of consultation. Green Flag wrote to the LVRPA to ask if they consulted the public and were told, yes they did. End of Green Flag’s ‘enquiry’.

The LVRPA faces little or no scrutiny by Local Authorities who treat it as a ‘partner’ organisation. Instead of fulfilling its role to protect and improve our vital Green Lung the LVRPA treats this part of the Park as a money-making asset with little or no regard to the needs or opinions of the communities that use it. We have written an open letter to Shaun Dawson, CEO of the LVRPA to highlight this failure https://www.saveleamarshes.org.uk/2022/02/16/an-open-letter-to-the-lvrpa/.

So far no response has been received to this letter.

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An open letter to the LVRPA

Dear Shaun Dawson

We received the latest letter from the LVRPA informing us that work on the Oxbow island would proceed without further discussion bringing an end to our recent attempts to engage with the LVRPA and CART.

We would like to point out that there is now no ongoing engagement or consultation with the community of any kind. Some years ago there were regular forums, which at least allowed for some exchange of views. This was then cut back to ‘workshops’ which emphasised presentations by staff rather than consultation but at least included agendas and minutes. These were then replaced by informal walkabouts of a few individuals with rangers with no agendas or minutes and no structured discussion or means of following up issues .

The recent engagement on the Ice Centre was presented as a kind of favour to the community. However, the terms of engagement and the agendas were strictly limited by the LVRPA. SLM members attempted to hold more holistic discussions regarding the relationship between the Ice Centre and the surrounding Marshes, notably the Oxbow island. We were particularly concerned at the implications of including a cafe as part of the Centre and the possible impacts of this on the Oxbow island. This was firmly resisted by LVRPA staff. After vigorous discussion a concession was made to allow a separate discussion on the Oxbow.

However, when this happened it was set up as a series of presentations, not as a discussion about what could be done with the island. It was even claimed the meeting was never intended to be a discussion of the relationship between the Ice Centre and the island when in fact that was the precisely the reason it was called. Time was limited meaning a key presenter had to leave. This resulted in a degree of passion on the part of those participating in their attempts to be heard, which has in turn led to unfair criticism by the LVRPA of those attending.

A follow up meeting onsite was promised but then, following our further attempts to ensure this included discussion on the possibility of creating an island habitat at the Oxbow, this was called off by the LVRPA. The opportunity to create an island wildlife haven was provided by the need to dig out the channel to restore river flow to the Oxbow ‘lake’ to help carry away the melt water from the Ice Centre.

Save Lea Marshes attempted to engage in good faith to examine the possibilities and risks for the Oxbow island. We still consider this was a unique opportunity to separate the island from the Marsh and create a vital wildlife haven and are sad that this opportunity has been lost. We do not think the possible impacts of the Ice Centre cafe have been properly considered. We fear the island will become a hangout spot for those using the cafe.

This process has revealed the underlying lack of effective consultation with the community. Essentially there is now no consultation with the community and when some kind of discussion is launched it is carefully controlled and limited to agendas set by the LVRPA. The model for these meetings is one of presenting what will be done rather than consultation on what could or should be done.

Members of SLM have been raising similar concerns with you and your colleagues over the years. Will things ever change?

Yours sincerely

Save Lea Marshes

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Threats to the Marshes/Response to Waltham Forest’s local plan consultation

There are many emerging threats to the Marshes (and Wathamstow Wetlands) from planned large-scale developments at Lea Bridge, New Spitalfields and elsewhere in Waltham Forest.

Save Lea Marshes have now been campaigning for a decade to keep our vital green spaces wild, open and free for all. Come to our online event to find out how you can make your voice heard in the Local Plan consultation and join the discussion about what we can do to protect the Marshes from inappropriate development and ensure they are preserved to the benefit of local people and wildlife.

Here is a link to the presentation that we gave on 19th January 2022:

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Threats to the Marshes – Encroachment of blocks around the Marshes

There are a number of ongoing threats to the Marshes and the wider Lea Valley environment, including the River Lea itself. Sadly, many of these threats come from the very public bodies which are entrusted with the protection of the Marshes: notably the Lea Valley Regional Park Authority (LVRPA), the body charged with protecting the Green Lung; Waltham Forest Council as the principal planning authority; and, in the case of the river, Thames Water, the Canal and River Trust and the Environment Agency.

The LVRPA in particular sees this southern section of the Lea Valley Park as an area from which to raise revenue. It has expanded the Ice Centre and the Riding Centre, created moorings on the River Lea, held music events, hosted camping sites and other ventures, planned to build houses and is planning to build hotels on its land; all to raise funds. Not only that but the LVRPA cannot be relied on to defend the Marshes from inappropriate developments on its fringe which will harm the open space.

Waltham Forest has, for the most part, backed the LVRPA’s projects, with the notable and admirable exception of the music festival at the Waterworks. In addition, it has pursued a policy of building tower blocks along the eastern side of the Marshes.
In the first of three blogs we discuss the threats from tower blocks.

New Spitalfields

The largest and most significant threat to the Marshes is the proposal to develop the New Spitalfields site. As far as we know Waltham Forest is continuing with its plans to build a small town on the site of the present New Spitalfields Market. Its latest thinking appears on this website https://wfreg19south.commonplace.is/en-GB/proposals/sa02/step1.

As can be seen from the two stars, Waltham Forest still plans to build tower blocks on the site. It also still plans to build a new bridge across a very sensitive part of the Old River Lea, posing a real threat to the river bank and the Site of Importance for Nature Conservation on the Hackney side of the river. In addition, it plans to build a cycle track north of the site through an untouched piece of land despite earlier showing an interest in saving this for wildlife. Waltham Forest has paid almost no attention to anything said to it. Consultation seems to be a complete waste of time. In every respect this remains an extremely harmful development.

New Spitalfields is right next to East Marsh and across the River Lea from Hackney main Marsh. Waltham Forest has indicated in its original site allocation it intends to build blocks of 18-30 storeys and 10-13 storeys on the site, so given the close proximity of the Marshes it is inevitable they will tower over the adjacent open spaces. No amount of tree planting will make any difference.

This will have a major and, we would argue, a very negative impact on the sense of openness of the Marshes and the enjoyment people gain from the experience of being away from the built environment they have to live with most of their lives. The predicted view from Hackney Marshes below was produced as part of an earlier skyline study of the visual impacts of the New Spitalfields development https://www.walthamforest.gov.uk/sites/default/files/2021-11/Draft%20skylines%20study%20south%20Waltham%20Forest%20sites%20part%201.pdf.

While Waltham Forest acknowledges there are sensitivities around height in its latest site allocation https://wfreg19south.commonplace.is/en-GB/proposals/sa02/step1 – ‘05.5.4 Sensitivities: The following elements of the surrounding context would be sensitive to increased height: – the River Lea and adjacent green / amenity space, which may be vulnerable to overshadowing’ – it continues to press ahead with these tower blocks. However, regardless of this, it is claimed in the plans for Lea Bridge Station, as is discussed below, that tall buildings will actually enhance the visual aspect of the Marshes and provide beneficial views for those on the open spaces.

It is interesting to note that as usual Waltham Forest focused on creating ‘new high quality landmarks’ which would define Ruckholt Road as a ‘gateway’, gateways and landmarks being constantly repeated themes in Waltham Forest planning applications, which it thinks justifies building blocks near open spaces. Height at the eastern edge of the site will ‘complement development at Leyton Mills’. When this site was first presented for consultation Waltham Forest produced the following statement in the skyline document referred to above about the opportunities the site offered:

05.5.3 Further opportunities include: – defining Ruckholt Road as a gateway to the borough with new high quality landmarks, – improving accessibility to the area’s green amenity offer, – capitalising on views to Hackney Marshes and the Queen Elizabeth Park, – clustering height at the eastern edge of the site to complement development at Leyton Mills retail park – potential for investment in sustainable transport infrastructure

The creation of a major population centre will also greatly increase the pressure on the neighbouring open spaces. This is not considered in the plans as presented so far. Given the size of the town to be built and its immediate proximity to the Marshes it is inevitable East Marsh and the Old River Lea will become playgrounds for this new population. These are public spaces for the benefit of the wider community but being so close to New Spitalfields will mean the Marshes will be at risk of being overwhelmed by its new neighbour.

Waltham Forest’s attitude towards these neighbouring open spaces is exploitative. The project will provide benefits by ‘improving accessibility to the area’s green amenity “offer”, – “capitalising” on views to Hackney Marshes and the Queen Elizabeth Park’. However, it isn’t Waltham Forest but Hackney that will bear all the costs of this development and none of the benefits. Hackney Council seems not to have understood the scale of the problem as Waltham Forest is pushing ahead with its developer fest regardless of any concerns or objections.

This is an inappropriate site for housing development under any circumstances, as it is part of the Lea Valley floodplain and will be seriously affected by climate change in terms of both river flooding and rising sea levels. We have already raised our concerns in another pointless consultation with Waltham Forest, as set out in this blog https://www.saveleamarshes.org.uk/2021/07/27/do-we-really-need-a-new-village-on-a-flood-plain/. Plus ça change…

Temple Mills Bus Depot

The Temple Mills Bus Depot site is an adjunct to the New Spitalfields site, on the other side of Ruckholt Road. It is also part of the flood plain and as vulnerable to flooding as the New Spitalfields site.

Once again, from what is known so far, Waltham Forest is planning to build tower blocks on this site. This site did not feature in the South Waltham Forest allocations document so there is no skyline survey. It also doesn’t feature in the latest Common Place web page.

However, as far as we know the blocks are likely to be built on top of the bus depot, which will make it a very cramped site. It is expected to host a new station, which appears on the New Spitalfields Common Place page mentioned above. This will also serve New Spitalfields, so there will be considerable flows of people moving to or from this site across or under Ruckholt Road.

Tower blocks built on this site will further extend the line of blocks running down the east side of the Marshes and add to the impact of the New Spitalfields site on East Marsh. The Bus Depot site is next to the open space at Eton Manor, which is a fairly small space. Any blocks built there will severely affect that space which will also be overshadowed early in the day.

The extra new population at this second site, a village to be added next to the town at New Spitalfields, will further add to the massive pressures on the Marshes.

Lea Bridge Station

To the north of these two sites is the development planned at Lea Bridge Station. Of the projects which have reached the planning stage this is the closest to the Marshes and will have the tallest tower blocks. The highest block on this site is planned to be 26 storeys.

Instead of challenging this development as it should, even though it recognises it will have negative impacts on the Marshes, the LVRPA has chosen not to object but to accept a feeble Section 106 payment, as shown in an LVRPA document below – this is Lea Valley danegeld!

The height of the two towers on Sites 1 and 3 are of concern in terms of their intrusion upon the open landscape character of the Regional Park and the current visitor perception of openness and removal from the surrounding urban area. The proposal has undergone a lengthy design review process to arrive at its current configuration. Amendments to the scheme have been discussed with London Borough of Waltham Forest and it is the case that significant reductions to the height of the development are unlikely, as the number of stories has been determined by the level of affordable units required, together with the considerable costs of dealing with the site constraints and commercial viability. In addition, intensive development adjacent to train stations is accepted policy nationwide.

The development, given its size and location, will generate a regular and sustained increase in footfall to the Park. The potential impacts of this are not considered within the supporting planning documents, although the benefit of the proximity of these green spaces is recognised in terms of recreational facilities available to residents. Whilst the Authority welcomes visitors to its open spaces it needs to be able to manage access to, around and through sites to maintain, protect and enhance the open spaces and key biodiversity features for which they are valued. 5106 contributions are being sought to help reduce the impact on the Regional Park and a package of proposed mitigation measures is under discussion with officers at the London Borough of Waltham Forest; these will be presented at committee. They would be secured via Planning Obligations/S106 contributions as part of any permission, if the Council were minded to grant consent.

Tower blocks built on this site will further extend the line of blocks running down the east side of the Marshes. The image below, taken from the planning application, gives an idea of how the two blocks, one tastefully concealed behind a tree, will dwarf the existing Motion blocks.

The scale of the two towers is shown in this graphic taken from the planning application.

The further images show how they will appear from the Marshes and Leyton Marsh. The first is taken from the Draft Skyline document https://www.walthamforest.gov.uk/sites/default/files/2021-11/Draft%20skylines%20study%20south%20Waltham%20Forest%20sites%20part%201.pdf. This is an old graphic. The blocks have since increased in height so their visual impact is understated. No graphic was presented of the impact on the Marshes in this Skyline document so the best view that was available was this view from Lea Bridge Road.

The second graphic, also taken from the Lea Bridge Station planning application, shows the two Lea Bridge Station blocks, as seen from Leyton Marsh, along with the cumulative effect achieved with the Motion blocks and the Gas Works development, which is also tastefully partly concealed by a bush.

Waltham Forest is brazen about its desire to build tall buildings. As elsewhere, the draft skyline document emphasised the creation of “landmark buildings that complement the taller heights already introduced nearby”. In other words, existing tall buildings need more tall buildings around them! The document goes on to say “The following elements of the surrounding context would be sensitive to increased height: – residential houses to the east of the site”, no mention of the Marshes to the west.

In the planning application the applicant was keen to provide ‘context’ in that there are other tall buildings in the ‘townscape’. So why not some more?

10.170 The Proposed Development would be perceptible in the backdrop of the view and would introduce several new blocks of tall and large development into the townscape. Blocks would be recognised within the context of existing tall and large development along Lea Bridge Road, although the scale (height) of the proposals would become the tallest feature on the skyline

Not only does the applicant not feel embarrassed about these developments close to the Marshes, it now brazenly makes the ridiculous claim that these developments will be beneficial and will actually improve the visual amenity the Marshes. Are we supposed to take this seriously?

10.175 The Proposed Development would form an attractive skyline feature and will improve the visual amenity of the view with high quality architecture. It would give rise to a Moderate Beneficial likely effect. This likely effect is significant.

During the consultation Waltham Forest’s agents declared the Marshes were only ‘apparently natural’ as they were man-made! The reality is all landscapes in the UK are man-made, even the Highlands of Scotland. And being man-made doesn’t mean they shouldn’t be protected from development in their current form.

Applications of this kind, as at the Gas Works, have already been accepted by Waltham Forest and are plainly pitched to fit in with the Council’s approach. According to the Lea Bridge Station planning statement the site is not even indicated for tall buildings and won’t comply with policy on delivering social housing yet they feel able to put plans of this kind forward for approval.

This aggressive approach suggests they know perfectly well that the whole point of open space is the sense of openness experienced by those using the space and that putting tall buildings on the edge of open spaces defeats the whole purpose of having open spaces, which is to allow people a feeling of freedom from the restrictions of the city and give them a place where they can enjoy nature. The benefits of green spaces for mental and physical health are now well established. Pouring enormous amounts of concrete is both harmful to that enjoyment and harmful to the environment.

Should these developments happen, the Marshes will be ringed on their eastern side by a line of blocks with: the Motion development already built; the Gas Works sites in Lea Bridge and the Score Centre in Oliver Road already granted permission (https://www.london.gov.uk/what-we-do/planning/planning-applications-and-decisions/planning-application-search/score-centre); Lea Bridge Station awaiting discussion at planning committee; the Bywater site at the south end of Orient Way, Leyton, along with New Spitalfields and the Bus Depot, all at an early stage of planning; and completed developments further south in the Olympic Park and further north towards Tottenham. The developments already built at the Motion site and those further north and south are shown below.

The Motion blocks as seen from the back of the Riding Stables
Developments to the north of the Marshes
Developments to the south in the Olympic Park

This latest round of developments at Lea Bridge Station and New Spitalfields and the Temple Mills bus depot will be the most damaging of all and need to be strenuously opposed.

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LVRPA: Commit to Protecting the Environment!

Our speeches to the Scrutiny Committee, Regeneration & Planning Committee and Executive Committee of the Lee Valley Regional Park Authority on Thursday 18th November.

We are sharing our concerns about the continued commitment to investing a large amount of capital into leisure venues, whilst the protection and enhancement of our green spaces seems to come a very poor second, despite the climate and ecological emergency.

We would also like to see much more robust opposition to the high towers being proposed around the marshes which are not compliant with policy on height or visual impact and will have a negative impact on biodiversity.

Executive Committee meeting

Save Lea Marshes welcomes the discussion that will take place at today’s Scrutiny Committee meeting about establishing an environmental policy. It is critical, if we are to escape the very worst of climate change and biodiversity collapse, that we put the needs of the environment first when making decisions. This applies to individuals, and all the more so to organisations that manage green spaces on behalf of the public.

With this in mind, we would urge you to consider the choices you are making at this meeting. If we have read the papers correctly, you are proposing to pay for routine maintenance to the venues from capital expenditure, but are planning to wait for Section 106 money to fix the problem of no water in Middlesex Filter Beds. We have been promised a sluice for several years now and you are in breach of your Higher Level Stewardship Agreement with Natural England, and losing out on that revenue, by not dealing with the problem.

Today is a great opportunity to demonstrate that your nascent environmental policy is not greenwashing, by committing to pay for the sluice from capital expenditure and sending a strong signal to the public that you think the open spaces in the park are as important to you as the venues.

Regeneration and Planning Committee meeting

It was interesting to see that you have many of the same concerns as Save Lea Marshes about the development at the Lea Bridge Station sites, and we note that you believe these concerns can be allayed with Section 106 money. Please can you explain what you have asked for, in terms of Section 106 money, and what you intend to spend that money on?

Scrutiny Committee meeting

Save Lea Marshes welcomes the introduction of an environmental policy. It is critical, if we are to escape the very worst of climate change and biodiversity collapse, that we put the needs of the environment first when making decisions. This applies to individuals, and all the more so to organisations that manage green spaces on behalf of the public.

We noted with interest that you do not want to develop a weak policy or a policy that can be accused of greenwashing. That is commendable. However, as it currently stands, the policy is both weak and an exercise in greenwashing. It needs to be much, much bolder.

The Authority must not ‘aspire’ to be an exemplar of environmental innovation and best practice; it must ‘be’ an exemplar of environmental innovation and best practice. It cannot do this by considering ‘how far we can go to support environmental actions without damaging our core objectives’; it must change those core objectives to put the environment first. It cannot do this by accepting that the Authority cannot impose its standard on third-parties; it must make working to the Authority’s high environmental standards a condition of contracts.

The grounds maintenance contract is a very good example of a contract that could be made much, much, much more environmentally friendly. At the moment, it is heavy on tidiness and light on nature. Leaves are not ‘debris’; they do not need to be tidied away and they do not need to be tidied away with noisy, fossil-fuel driven leaf blowers. Leaves should be left to rot in situ, to nourish the earth. This is absolutely essential for improved biodiversity.

Talking of biodiversity, the policy seems to be limited to sites with designations. It should apply to all green spaces within the park.

There should also be a blanket ban on pesticides, insecticides and fertilisers, all of which disrupt the natural processes that should be allowed to flourish and be given the time to self-correct.

Where is the discussion of rewilding and a commitment to protect the green spaces within the park from development?

And where is the commitment to ensuring farming businesses within the park reduce leachate?

There is lots to be commended about the drive to establish an environmental policy that is regularly scrutinised, but please don’t waste this wonderful opportunity by signing off a policy without teeth.

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Object to the Lea Bridge Station Sites Development to stop more towers surrounding the marshes

The Motion Towers as viewed from Walthamstow Marshes

Please help us avoid the awful spectacle of yet more high-rise towers crowding the marshes and ruining the open landscape forever.

Ideally please object to the planning application for the Lea Bridge Station Development, which is out for public consultation, by the end of 27th September. Relevant objections should be considered after this time.

Proposed tall towers situated next to the current Motion Towers

You can use any of our objection to support your submission. Here are some bullet points you may wish to include:

  • The Lea Bridge Framework is still under consideration and no planning application for this area should be brought forward until it is complete, otherwise it is rendered useless. Similarly, the application cannot rely on the Emerging Site Allocation because it is part of the Draft Local Plan and is yet to be fully scrutinised.
  • The Planning Statement states that the development will provide publicly accessibly green space yet it will destroy existing green space at Orient Way Pocket Park, home to 125 semi-mature and early-mature trees. If Waltham Forest Council is serious about its commitment to the climate emergency, then it should be safeguarding mature trees because of the important role they play in mitigating the effects of climate change. New trees are not a substitute for mature trees and new green space is not a substitute for existing green space.
  • The fact that there is no social housing planned is unacceptable.
  • The proposed development will have a detrimental impact on air quality during construction and, when complete, by increasing the number of people living in the area with cars and removing the mitigating effect of the trees in the Orient Way Pocket Park.
  • The Planning Statement says that the site is not affected by tidal flooding. However, the site is situated on the flood plain of the Lee Valley, which will be increasingly subject to flooding. The Planning Statement acknowledges that parts of the site are indeed at risk of fluvial flooding. Our floodplain should not be developed; it should remain undeveloped and permeable.
  • Building 23-story and 26-story tower blocks in this location constitutes significant over-development, especially as the location is not identified as a location for tall building development in the adopted Development Plan.
  • Astonishingly, the Planning Statement claims that these tower blocks will have a ‘moderately beneficial impact’ on the Lee Valley Regional Park and other open spaces. This is clearly contrary to any reasonable understanding of openness.
  • Waltham Forest Council has declared a Climate Emergency and this over-development on a flood plain runs contrary to combating climate change locally.

Save Lea Marshes Full Objection

To: Planning Department, Waltham Forest Town Hall, Fellowship Square, 701 Forest Road, Walthamstow, London E17 4JF

dmconsultations@walthamforest.gov.uk

Dear Waltham Forest Planning Committee,

Re: Planning Application 212685 – Lea Bridge Station Sites

We object to the Proposed Development for the following reasons:

1. Lea Bridge Framework

1.1 The Planning Statement refers to the Lea Bridge Regeneration Masterplan which states that the development:

2.27 Delivers a mix of uses which align with the GLA and LBWF objectives for the Lea Bridge Regeneration Masterplan;

1.2 However, it makes no mention of the Lea Bridge Framework which is still under consideration. How is it possible to proceed with a major development in an area as yet without a Framework? How can any Framework, which is still being considered, have any point when plans for such a key section of the neighbourhood are already decided? Plainly any Framework is rendered pointless by this application. This is the most important site in the area already decided.

1.3 The Planning Statement later refers to the Emerging Site Allocation

7.13 LBWF’s vision for the Site is sought to be enshrined within planning policy through the emerging site allocation proposed within the draft LBWF Local Plan Part 2 (ref. SA07).

1.4 However, this reveals that not only is there no Framework for the area but the Local Plan on which this planning application is based is a Draft Plan. So in fact there is a lack of concrete agreed planning guidance available.

2. Pocket Park green space and biodiversity net gain in the development

2.1 The Planning Statement refers erroneously to the Orient Way Pocket Park, a green space with 125 mature trees, being ‘developed’.

7.9 It is important to note that the three sites have been identified for development by LBWF through a longstanding regeneration programme of the Lea Bridge area. This is sought be formalised through the emerging site allocation in the draft Local Plan Part 2. Therefore, to deliver the aspirations of the site allocation and wider policy designations such as the opportunity area and housing zone, development of the pocket park at site 2 is required.

2.2 The Pocket Park is not being developed, it is being demolished.

2.3 The Planning Statement goes on to say the development will provide a publicly accessible green space:

2.27 Provides publicly accessible green space for the wider community to utilise

2.4 However, there is already a publicly accessible green space for the community which the project will demolish.

2.5 The Planning Statement recognises there will be a loss of open space but seeks to reduce the significance of this space by referring to it as ‘undesignated’ and ‘informal’ and by referring to the trees in dismissive terms. Whether or not it is designated or informal makes precisely no difference in terms of its ecological value.

3.13 Site 2 measures approximately 0.62 hectares and is currently used as an informal open space with footpaths with an area of adopted public highway and road on the northern edge. It features some semi-mature and early mature trees. It is important to note that Site 2 includes one TPO tree, a Sycamore, number T72.

7.10 The Proposed Development will bring significant planning benefits to Lea Bridge and the wider borough which outweigh the loss of this undesignated open space. Furthermore, the proposals include more usable public realm and landscaping improvements including a net gain of trees across the Site which results in a substantial biodiversity net gain.

2.6 Plainly, if left to grow the existing semi-mature and early mature trees will become mature trees a lot more quickly than any newly planted trees.

2.7 The applicant claims there will be substantial biodiversity net gain.

7.271 The Proposed Development seeks to retain three existing plane trees along Orient Way (numbers T26-T28). There are currently 125 existing trees with 122 to be removed. It is then proposed to replant 144 new trees. Therefore, there is a significant net gain of new trees as part of the proposed landscaping scheme.

2.8 The first thing to note about this alleged biodiversity net gain is it will depend on the trees actually surviving planting. The reality is many newly planted trees die a short time after being planted.

2.9 More than that, planting an extra few trees does not overcome the damage done by removing a large number of trees as the gain from retaining and allowing existing mature trees to continue to grow will last for years whereas the alleged gain from new planting will take years to be realised and may never occur; damage to small newly planted trees is a frequently reported occurrence.

2.10 Moreover, the nature of the green space will change. It will lack the same mass and density. The new trees will be separated and scattered which will also make them more vulnerable to damage.

2.11 If Waltham Forest is looking for significant biodiversity gain from this development the easiest way to achieve this would be to improve the planting and habitat in the existing Orient Way Pocket Park. It is precisely by failing to properly maintain or improve the existing green space that Waltham Forest is able to try to claim Biodiversity gain in the first place as this makes it possible to claim a replacement can better what is already there.

2.12 However, it is totally at odds with sense that a developer can claim biodiversity gain by demolishing an existing green space and replacing it with new trees which will take years, decades even, to grow when existing trees will continue to mature and the woodland of which they are part can be improved more easily and effectively by leaving that green space in place. The existing space’s capacity to provide biodiversity gain for the development as a whole is completely ignored.

2.13 It is worth noting that policy on Biodiversity includes making ‘improvements to existing natural environments’:

7.277 Emerging Local Plan Part 1 Policy 81 (Biodiversity and Geodiversity) states that: • All development should maximise opportunities to create new or make improvements to existing natural environments, nature conservation areas, habitats or biodiversity features and link into the wider green infrastructure network;

2.14 Maximising these opportunities will best be achieved by retaining and improving the existing Pocket Park green space and this is consistent with policy.

2.15 It is also the case that the benefits in terms of climate change, an emergency supposedly declared by Waltham Forest Council, of a denser area of woodland will greatly outweigh even a few extra scattered trees, assuming they survive, which will take years to grow, whereas an existing green space can be improved and further trees can be planted.

2.16 The demolition of this Pocket Park makes no sense in any of these respects.

3. Affordable Housing

3.1 The Planning Statement contains the following:

7.90 Policy H6 of the London Plan states that in order to satisfy the threshold approach to affordable housing on a habitable room basis 30% should comprise genuinely affordable homes, 30% intermediate homes and 40% to be agreed with the Borough.

7.91 At a local level, LBWF Development Management Policy DM3 (Affordable Housing Provision) stipulates a tenure split of 60% social/affordable rented units and 40% intermediate housing units.

7.93 The scheme does not meet the requirements of the adopted or emerging Local Plan as a tenure split of 50% shared ownership and 50% London affordable rent is proposed.

3.2 The development does not provide any genuinely affordable housing and will not assist those in housing need in Waltham Forest.

3.3 When trying to encourage people to agree to its constantly repeated ‘vibrant’ neighbourhood Waltham Forest tried to set the need for ‘affordable housing’ against people’s concerns over height, see screenshot below. Plainly if people ‘voted’ for lower towers, even if they had good reasons to be concerned, such as they considered they would have a negative effect on the neighbouring Marshes, they were put in the position of being against ‘affordable’ housing.

Section from the ‘consultation’

3.4 However, the reality is the development does not produce genuinely affordable housing so the consultation was misleading.

4. Air Quality

4.1 The development will have negative effects on the Marshes. One of these will be in terms of increased traffic and thus congestion and pollution on Lea Bridge Road.

7.249 of the Planning Statement references air quality but fails to record that the development at Lea Bridge Station is likely to draw more traffic on to Lea Bridge Road where it passes Leyton Marsh and the Ice Centre, further increasing congestion and air pollution on that section of Lea Bridge Road.

4.2 There is no discussion of how this development will combine with the development of a double size Lee Valley Ice Centre at Leyton Marsh. The development of a double size ice centre complex, which intends to bring skaters and visitors from across the nation and not just the region, will further add to the flow of traffic through the area, even if the Lea Valley Regional Park Authority says it wishes to reduce car usage. The reality is the poor public transport connections in the area and the fact that Ice Centre users do not use train services, as evidenced in the LVRPA’s own travel plan documents, will mean more people will travel by car to the Lea Bridge area from further afield.

5. Flood risk and Climate Change

5.1 The Planning Statement states: 7.293 A Flood Risk Assessment (FRA) prepared by Waterman accompanies this Application. The site is not affected by tidal flooding, but parts of the site are at risk of fluvial flooding.

5.2 This statement is incorrect. The River Lea Valley is in danger of tidal flooding depending on the management of the Thames given the likelihood of sea rise. Climate Central has produced a map showing that a part of this site would be in danger of tidal flooding in ten years time. This does not take into account a longer time scale, see here

5.3. Regarding fluvial flooding, Waltham Forest Council produced a report in 2011 https://geosmartinfo.co.uk/wp-content/uploads/2020/03/BEB15-Waltham-Forest-Level-2-SFRA.pdf which stated:

3.1.5 The River Lee Flood Relief channel was constructed in the 1970s and was built to accommodate an event of similar scale to the flood of 1947, which, at the time, was estimated to be a 1 in 70 event. As such, this structure no longer provides an adequate level of protection to the surrounding area. Furthermore, the North London Level 1 SFRA (Mouchel 2008) identifies that the level of protection is known to have been reduced further by extensive development in the upper catchment. 

5.4 Note the statement that extensive development has reduced the level of protection. That extensive development continues and will be further exacerbated by these developments.

5.5 The Planning Statement adds: 7.294 Due to a range of constraints pumped outfalls would be required on all three sites. Runoff will be discharged to the Thames Water public sewer network. Attenuation will be provided in the form of below ground tanks and permeable paving.

5.6 So, in recognition that the sites are vulnerable extra measures are required on a site which will become more vulnerable as time passes.

5.7 The Climate Emergency, which doesn’t seem to be specifically mentioned in these documents, despite being declared by Waltham Forest Council, is beginning to kick in.

5.8 This is a floodplain, another term seemingly avoided in this section of the document. Flood plains will be of vital importance in alleviating the longer term effects of climate change.

5.9 7.302 of The Planning Statement – the APZ (on archaeology) defines an area associated with the River Lea valley and its tributaries and is an area characterised by alluvial deposits which have been shown to preserve important archaeological remains dating from the Prehistoric period and later.

5.10 How curious that floodplain turns up in the section on archaeology, where reference is made to alluvial deposits.

Alluvium, material deposited by rivers. It is usually most extensively developed in the lower part of the course of a river, forming floodplains and deltas, but may be deposited at any point where the river overflows its banks or where the velocity of a river is checked—for example, where it runs into a lakehttps://www.britannica.com/science/alluvium

5.11 Climate change is considered in the Environmental Statement Part 1. This document makes the extraordinary statement that future climate conditions will have no bearing on this development:

2.66 The likely projected future conditions for each of temperature, precipitation, wind speed and cloud cover have been considered. It is considered that the magnitude of impact and resultant nature and scale of the effects of the Proposed Development during the operational phase will not be changed under the future climate conditions.

2.67 Overall, the likely effects of the Proposed Development are unlikely to change as a result of climate change

5.12 Considering the likelihood of severe weather conditions occurring as the Climate Emergency gathers pace and the location of this development in the Lea Valley floodplain, which also faces the possibility of tidal flooding arising from rising seas, these assertions seem extraordinarily dismissive of possible risks.

6. Gateways and tall buildings and the Lea Valley

6.1 Curiously, the Planning Statement admits the location is not identified as a location for tall building development. 

7.144 In summary, the Proposed Development is not identified as a location for tall building development within the adopted Development Plan.

6.2 Of course, this is then explained away. However, it remains the case that the existing guidance is that the site is not identified as a location for tall buildings. The further guidance in the remains in draft form.

6.3 The Introduction to the Design and Access Statement repeats the refrain so often found in Waltham Forest’s planning applications:

Marking the Gateway to Waltham Forest with elegant new buildings which signpost the new Lea Bridge station

6.4 Over and over terms like ‘Gateway’ and ‘landmark’ buildings appear in these documents as if tall buildings have some inherent value as territorial markers.

6.5 Waltham Forest uses a tree as its logo yet nowhere does one find any kind of reference to, recognition or appreciation of its green spaces, most particularly the Marshes, as a marker of the Borough’s boundaries, as a welcoming place to a Borough bearing the name of Forest.

6.6 Indeed later on Waltham Forest declares:

the Lee Valley occupies a strategic position in the London-Stansted Cambridge-Peterborough growth corridor and provides a range of development opportunities for higher density development including growth at Lea Bridge and Lea Bridge Roundabout”.

One might be forgiven for forgetting there is a green lung somewhere in this ‘corridor’.

6.7 Likewise the statement of Site Opportunities endlessly repeats this refrain

3.49 The Proposed Development Site does however have a number of opportunities through redevelopment to establish the area as a new ‘place’ and destination:

Gateway to Waltham Forest and the Lee Valley Regional Park. A visible and high-quality designed scheme can serve as an identifiable gateway to these areas and act as an attractor for further footfall and investment;

• Station identity on Site 1 – A tall building within Site 1, adjacent to the adjacent Lea Bridge Station entrance, can act as an identity for the new local centre, accentuating the station and its new public realm setting within the wider area;

• Views into the Lee Valley Regional Park – Taller buildings with residential uses located at this Proposed Development Site can take advantage of long vistas into Lee Valley Regional Park to the west.

6.8 Not only an identifiable gateway to Waltham Forest but also to the open spaces of the Lee Valley Park and of course, to the benefit of developers, vistas over those open spaces.

6.9 Once again Waltham Forest repeats its obsession with landmark buildings marking a gateway. Waltham Forest uses a logo of a tree to trademark itself yet at no point does the Borough take pride in its green spaces and take advantage of them as landmark features welcoming visitors to the Borough.

6.10 Everywhere the emphasis is on height. Yet this site is not identified as a location for tall buildings.

7. Description of the Marshes

7.1 The Planning Statement, while it makes mention of NPPF guidance, makes no mention of NPPF 133, which states:

The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence”(our emphases).

7.2 The term Green Belt applies to the Marshes, as Metropolitan Open Land has the same legal status as Green Belt.

7.3 Indeed, from what I have read this guidance is never mentioned in this application.

7.4 Leyton Marsh, which is not named and was recently described by the Chair of the Planning Committee as a ‘pretty scrubby, desperate piece of Metropolitan Open Land, it’s not like it’s a beautiful green meadow’, Walthamstow Marshes, the Waterworks Nature Reserve, the Waterworks Meadow, also not mentioned, will all be affected by the two towers being built on Site One. Hackney Marshes will also be affected. The Committee chair is welcome to her opinion of Leyton Marsh, although it is not one shared by those who enjoy the Marshes.

7.5 However, it reveals much about how Waltham Forest Council views the Marshes.

7.6 During the ‘consultation’ the same approach was adopted in describing the Marshes as an “apparently natural landscape” and “largely man-made”, see screenshot below.

7.7 This statement only reveals the ignorance of those seeking to diminish the importance of the Marshes as both a natural environment and a vitally important place of recreation.

7.8 Every landscape in Britain, including the Highlands of Scotland, is ‘largely’ man-made. The Highlands were covered in forest until people cut them down. Much of the present wilderness is the result of the eviction of cultivators in favour of sheep farming, new forestry or grouse shooting.

8. Impacts on the Marshes

8.1 Extraordinarily, in the Planning Statement, it is claimed that these towers will have a moderately beneficial impact on the Lea Valley Park and other open spaces

7.132 The significant likely effects will be to the visual receptors in the following views: 

• View 11 – Lee Valley Park, Moderate Beneficial;

• View 14 – Ive Farm Sports Ground, Moderate Beneficial; 

• View 18 – Walthamstow Marshes, Moderate Beneficial.

8.2 Towers will increase the sense of being enclosed which runs directly counter to the idea of open space, making nonsense of these claims.

8.3 The discussion about sites refers to the value of landmark buildings in terms of impacts on neighbouring open spaces. It has to be pointed out no NPPF guidance is cited for this claim. The guidance is entirely the opposite, that such buildings will negatively impact on neighbouring open space.

9. Visual amenity

9.1 The Environmental Statement Vol 2 Part 1 considers the impact of the development on local open spaces. It notes that some developments are visible, so the argument seems to run that as some are already visible why not some more? In fact it fails to mention that there are considerably more towers available both in Lea Bridge with the Gas Works Development and further north, as in the photo below, as already made known to Waltham Forest in the previous Save Lea Marshes Gas Works objection.

I also attach the objection from Save Lea Marshes to the recent Gas Works development which includes photographs from a number of different locations showing how those earlier developments have already had an impact on the visual amenity of the area.

9.2 Now two more, even taller buildings will be added to the list.

9.3 The applicant describes how existing existing blocks are visible and form “part of the surrounding in which this area is experienced”.

6.22 The location and open nature of Walthamstow Marshes, Lee Valley Park and Hackney Marshes affords a number of views towards the Site, the wider Lea Bridge area and Stratford. In views towards the Site, the existing Motion Development (Beck Square) is visible and forms part of the surrounding in which this area is experienced. In longer views, tall and large buildings marking the location of Stratford are visible and are characterised feature in views further south.

9.4 So as existing blocks are part of the surrounding in which this area is experienced some more blocks are ok? The wedge has already been driven in. Now it can be pushed in a bit further.

9.5 View 11 below is from the edge of Leyton Marsh and Walthamstow Marsh in the Lea Valley Park.

9.6 The applicant is keen to provide ‘context’ in that there are other tall buildings in the ‘townscape’. So why not some more?

10.170 The Proposed Development would be perceptible in the backdrop of the view and would introduce several new blocks of tall and large development into the townscape. Blocks would be recognised within the context of existing tall and large development along Lea Bridge Road, although the scale (height) of the proposals would become the tallest feature on the skyline

9.7 The development would be “perceptible in the backdrop of the view” and “introduce several new blocks”. So there are already blocks there. A few more will be “perceptible” and “introduced”. The context is of “existing” tall and large developments.

9.8 There is already tall development. Once the wedge is in the door can be pushed open further;

9.9 The point is made explicit in the 10.172 ‘this will not change the character of the backdrop of the view’.

10.172 The Proposed Development will form a new feature for the visual receptors, although this will not change the character of the backdrop of the view, which already includes tall development. The proposals will be seen over some distance which will contribute to reduce visual impact of the Proposed Development.

9.10 An attempt is made to moderate the impact. Distance will reduce the visual impact.

9.11 However, a further statement shifts back to the idea that tall landmark buildings will, in fact, ‘improve the visual impact’.

10.175 The Proposed Development would form an attractive skyline feature and will improve the visual amenity of the view with high quality architecture. It would give rise to a Moderate Beneficial likely effect. This likely effect is significant.

9.12 Then the cumulative view, see screenshot above, reveals another block, partly conveniently hidden by a bush, so now a line of blocks with the latest seriously altering the skyline. But no matter…

10.177 Where visible the cumulative development does not introduce a change to the visual receptors, nor does it change the magnitude of impact arising from the proposals. As a result, the likely effect would remain at Moderate Beneficial. These effects would be direct, long-term, permanent and is not significant.

9.13 So despite the arrival of new blocks there is apparently no change to the visual receptors on the Marshes nor any change to the magnitude of impact.

9.14 It has to be remembered that at one time there were no blocks here at all. The visual receptors are most definitely impacted and are steadily more impacted as new blocks are added.

9.15 All this is then repeated when referring to View 13 of the towers from Hackney Marshes, see screenshot below.

9.16 The blocks are now “an interesting feature” and have become “complementary”.

10.202 When viewed from this location, the form and massing of the blocks is simple and attractive, which creates an interesting feature on the skyline. The scale of the development varies across the Proposed Development Site with blocks varying in height between, 5, 11, 23 and 26 storeys. The height of the volumes is complementary to the adjacent Motion development, echoing the stepping effect of the existing building on the skyline. The slender volumes of Towers 1 and 2 rise to 23 and 26 storeys and mark the location of the development, Lea Bridge Road and the associated station.

9.17 Once again “perception”.

10.203 Over this distance, the observer will be able to readily perceive the architectural quality of the proposals. The façade of the blocks is primary formed of brickwork, whilst the crown of each building uses a mix of brick and concrete. The use of brick throughout the blocks ensures the development reads as one, although changes in their colour, band and detailing creates variation, further distinguishing the volumes from one another and reducing the overall perception of mass.

9.18 This is entirely fanciful. I very much doubt anyone will be able to make out the architectural quality, the brickwork, and changes in colour, banding and detailing of the towers from Hackney Marshes. They will simply be able to see a block of some kind rising above the tree line.

9.19 The argument then shifts to the idea that the blocks will only be “perceived” as part of an “existing backdrop” the impacts of which distance will reduce. 

10.204 The significant separating distance between the marshes and the Site would further reduce the magnitude of the visual impact and the Proposed Development would be perceived as part of the existing backdrop. The magnitude of impact to receptors would be Low.

9.20 Then in the next breath the argument shifts back to the blocks being an “attractive” skyline feature and will “improve” the visual amenity.

10.205 The Proposed Development would form an attractive skyline feature and will improve the visual amenity of the view with high quality architecture. In our professional judgment, for the reasons above, the Proposed Development would give rise to a Minor Beneficial effect. These effects would be direct, long-term, permanent and not significant.

9.21 Interestingly the language used seeks to mirror the references in the NPPF guidance, which it has failed to quote. Words like ‘visual amenity’ and ‘permanent’, although not “openness” find their way into the text.

9.22 The applicant then turns to consider the problem of this being yet another block surrounding the open space of the Marshes. The solution is to return to the idea of landmark buildings. The buildings mark out Lea Bridge and Leyton when being viewed from Hackney Marshes. It is assumed this is a good and necessary thing.

10.206 In the cumulative context, the black wirelines demonstrate further tall and large development in the backdrop of the view, and marks the location or development at Lea Bridge and Leyton.

9.23 And of course, “in the cumulative context” being among “further tall and large development” makes these blocks of less significance as they are now just a couple among several.

9.24 The applicant then moves into technical speak…

10.207 From this location, the visible cumulative scheme at Lea Bridge Gas Works (application ref. 201329) would contribute to the increased height datum in the backdrop of view and reduce the prominence of the Proposed Development within the view.

9.25 The “visible cumulative scheme” at the Gas Works adds to the ‘increased height datum in the backdrop of view’. In other words because there are (will be) blocks at the Gas Works the new blocks at Lea Bridge Station are just part of a development process which is leading to ever higher buildings towering over the Marshes and because these other blocks have already increased this ‘height datum’ everything is ok as they won’t be as prominent as they would have been if the Gas Works blocks weren’t (they aren’t yet) there.

9.26 Except of course it is now possible to see yet more cumulative and clearly defined sets of blocks rising over the treeline, where originally there were none, plainly greatly adding to the sense of intrusion and reducing the visual amenity and sense of openness of the Marsh.

9.27 No doubt the next towers will achieve a further ‘increased height datum in the backdrop of view’ which will in turn ‘reduce the prominence’ of the next set of blocks to be added to the jumble of blocks around the Marshes.

9.28 It is interesting to note that the applicant is prepared to provide images of the view of the new development when they are contained within the “existing townscape” as below, although even then  the image is obscured by a tree which could easily have been avoided, but not to transpose those images to show how they will appear on the Marshes.

9.29 To provide some idea of how these blocks will intrude on the Marshes I attach some images from an earlier objection by Save Lea Marshes to show how the Motion development appears from some viewpoints on the Marshes. These new towers will have a much greater impact than appears in the rather flimsy representations presented.

9.30 Existing view above of the Motion blocks from Leyton Marsh. The Station development will tower over the Motion development.

9.31 Existing view of the Motion blocks from Walthamstow Marsh

9.32 Existing view of the Motion blocks from the Waterworks Meadow, showing where the Gas Works blocks will be behind the FedEx warehouse. The Station blocks will tower over the Motion blocks

9.32 Above, the existing view of the Motion blocks from the Waterworks Nature Reserve.

9.33 Existing view of the Motion blocks from behind the Waterworks cafe

9.34 If these statements are taken to their absurd logical conclusion then the Lea Valley Park will be improved by more and more towers until it is surrounded by them, assuming of course these towers are of ‘high quality architecture’. How this fits with the NPPF guidance as quoted above is anyone’s guess:

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Do We Really Need A New Town on A Flood Plain?

Waltham Forest’s plans to build a small town within spitting distance of the Marshes is alarming

Waltham Forest is looking at a major development right on the edge of Hackney Marshes at the site of the New Spitalfields Market, next to East Marsh.

Google Satellite image of New Spitalfields site

It plans a mixed development of housing and commerce for the site. However, its most important feature is the inclusion at least 3,000 homes. We are particularly concerned at the implications of such a large housing development on such an important site next to the River Lea and Hackney Marshes.

On the other side of Ruckholt Road it plans to build yet more housing at the Temple Mills Bus Depot. Both sites will include towers.

These two sites are part of the Leyton Mills Development Framework, which also includes the Leyton Mills retail park and Eton Manor. Leyton Mills is a bit off the beaten track for Save Lea Marshes but Eton Manor is another key site for us.

Planning permission has been granted to move the New Spitalfields Market to a site on the Thames in Barking. It is planned for the Barking site to open in 2025/6 and development of the present Spitalfields site to start at some point after that. You can read the initial plans and timeline here:

https://www.walthamforest.gov.uk/sites/default/files/CoL.Newsletter.NEWSPITALFIELDS-WEB.pdf

The land belongs to the City of London Corporation, which stands to make a considerable profit out of the sale or development of the land. The Corporation owns and manages land all over London, including well known parks like Epping Forest and Hampstead Heath, and bears a responsibility to ensure the development is appropriate.

Save Lea Marshes was invited to participate in online meetings with the Council and its consulting architects, Gort Scott, and also provided online written responses in the consultation on this Framework.

We welcome attempts by local boroughs to involve the community in the early stages of planning and we would encourage local people to participate. However, this has to be more than a tick-box exercise. To make it really work the community has to actually help decide what will happen in its neighbourhood and not just be allowed a peek at what is already planned.

The basic conditions for these developments have already been set by the council so this is not the community deciding what should be done with this land but rather just being allowed to see a preview of what is planned with a limited opportunity to modify the plans as they are developed.

The process has involved presentations about what is already on the table followed by some discussions about those proposals. Some of this was of use. However, a very short time after the initial discussions the plans moved on very quickly and very substantially with little consideration of alternatives.

If this process is to really involve the community it has to involve local people from the start in deciding how the land should be used and take into account the background to the area and all the alternatives.

Lammas Land and flood plain

The first thing to say is the Spitalfields site was originally Lammas land before it was taken over by the railway. It was then used to house the Market when it was moved from Spitalfields on the edge of the City of London.

In Save Lea Marshes’ opinion the best result would be to return it to marsh land. This is not just starry-eyed environmentalism.

This land is flood plain. According to predictions this part of East London is at risk of flooding after 2030 as sea levels rise: https://www.thisislocallondon.co.uk/news/19051800.maps-shows-parts-london-underwater-10-years/

We have seen very graphically in the last few days the level of flooding that is already happening in East London, with extensive flooding occurring in Hackney and Waltham Forest.

The site is at risk from the River Lea bursting its banks. The Spitalfields site is just south of the point where the River Lea flood relief channel discharges into the Lea. The flood relief channel has reached full capacity on three occasions in the last two decades. A Waltham Forest Council report in 2011 explores this problem: https://geosmartinfo.co.uk/wp-content/uploads/2020/03/BEB15-Waltham-Forest-Level-2-SFRA.pdf :

3.1.5 The River Lee Flood Relief channel was constructed in the 1970s and was built to accommodate an event of similar scale to the flood of 1947, which, at the time, was estimated to be a 1 in 70 event. As such, this structure no longer provides an adequate level of protection to the surrounding area. Furthermore, the North London Level 1 SFRA (Mouchel 2008) identifies that the level of protection is known to have been reduced further by extensive development in the upper catchment.

3.1.6 The Environment Agency’s historic flooding records are presented… As shown on the mapping, there has been no major flooding in this region since 1947. However it is understood that the flood relief channel almost reached capacity in 1987, 1993 and 2000, highlighting that the flood risk posed to Waltham Forest is a realistic threat.

Over the past weekend Stratford has experienced a taste of what may be to come with the astonishing and frightening scenes at Pudding Mill DLR station https://www.mylondon.news/news/east-london-news/london-floods-swamped-dlr-station-21149444

Neither of these sites, the Spitalfields nor the Bus depot sites, is suitable for major housing development, due to this long-term threat and for the reasons set out at length in this blog.

Returning this land to marsh land would provide a reservoir for flood water which will help protect the area; concreting it over will simply add to the flood risk.

In addition, more and more research shows the value of green open space in terms of both physical and mental health. This has real economic benefits. Putting housing in the right places is important. Flood plain and green open spaces are not the right places, especially during an ecological and climate emergency.

Of course this land is now industrial land but that purpose has now come to an end. This is an opportunity to restore it to its pre-industrial Lammas (common) land status, enable it to become an important reservoir in the event of flooding and a benefit to the health and well-being of the population at large, and to contribute to climate resilience.

Of course, we know this is not the sort of thing planners have in mind and it was not on the table, which is a sad commentary on the nature of the planning process, which is likely to get worse before it gets better.

Waltham Forest and open space

As a borough which includes the word ‘Forest’ in its name and uses a tree as its logo, Waltham Forest has shown little appreciation of its own and neighbouring boroughs’ open spaces. It considered it reasonable to allow Low Hall Fields to be used for most of the summer by Secret Cinema despite all the talk of the importance of green open spaces for mental and physical health, particularly during a pandemic and a climate emergency.

Sadly nothing in these plans suggests Waltham Forest is any further forward in its thinking on these issues.

Commercial use

If returning it to its original status as marsh land is off the table, the second alternative Save Lea Marshes proposes is leaving the Spitalfields and Bus Depot sites as they are, as commercial sites. Further below we discuss the negative impacts housing sites will have on Lea Marshes.

Of these we argue that leaving these sites as they are is the least damaging use.

By comparison with the proposed high-rise housing developments, its present low-rise commercial uses have had little negative impact on the Marshes. In addition, there are positives from such use. Waltham Forest needs commercial sites and businesses can relocate from elsewhere to free up other sites for housing. These sites are excellently situated near the A12 Motorway and traffic to the sites is easily taken away from the area, not adding to the congestion on Ruckholt Road, something which housing sites most definitely will do.

Commercial use – plan B

Given that Waltham Forest has already set the terms for developing these sites as a mix of housing and commercial uses, Save Lea Marshes would argue that on the Spitalfields site the housing should be at the south (Ruckholt Road) end of the site and the commercial activity should be at the north end of the site.

The principal reason for this arrangement would be the protection of the river, as is explained below. The present commercial uses have limited impacts on the river by comparison with any future housing development. Of course this will not please developers as the river at the north end of the site is a key attraction.

Building towers

To our mind this consultation went off the rails very quickly. After a fairly uneventful and cordial opening discussion, only a couple of weeks later Waltham Forest unveiled a detailed plan for the Spitalfields and Bus Depot sites, which was presented at a second online workshop. See the screenshot below.

At every opportunity in this process, in online written responses and in online face-to-face discussions, Save Lea Marshes has argued against placing towers on the Spitalfields and Bus Depot sites. Waltham Forest had indicated it intended to place towers on the Spitalfields site from day one. We pointed out towers will have a serious impact on the visual amenity, the sense of openness, of the Marshes, already adversely affected on the Hackney/ Waltham Forest border at Lea Bridge and by considerable high-rise development at Stratford. National planning guidance warns against these impacts on Metropolitan Open Land like Hackney Marshes (which has the same planning status as Green Belt).

In the opening online discussion we were asked to provide examples of possible low-rise housing which made us slightly hopeful that such an alternative might be considered. However, regardless of any attempts to suggest alternatives Waltham Forest and its consultants immediately came back with proposals to put towers on these sites.

Waltham Forest loves building towers. It has agreed to developers placing two towers right next to Jubilee Park, calling them ‘landmark’ buildings as if this was some kind of justification for their existence. It is planning the same at the Lea Bridge Station site with two towers of 26 or more storeys within easy sight of the Marshes. Now it plans to build more towers on the Spitalfields site, right on top of East Marsh, as well as at the Bus Depot site.

Up till now the towers around the Marshes have been built a little distance away and screening by trees has sometimes reduced the impact. However, towers at Spitalfields and the Bus Depot will almost be within spitting distance of the Marshes where they will have an immediate and overwhelming visual impact on the green open space. If towers are built towards the north end of the Spitalfields site they may even cast a shadow over the river across to the Marshes.

Population pressure

Not only will towers severely impact the Marshes but placing such large-scale housing developments so close to the Marshes will greatly increase the pressure on these open spaces. The impact of new populations is also a planning issue for developments near open spaces.

Towers will also mean less connection between those living on the site and the green spaces on the development. The views from the towers will be of the Marshes and for those residents the Marshes will be their garden.

Towers will mean blocks of open space rather than smaller intimate spaces on the development itself. Low-rise housing allows for a greater connection for residents with those green spaces and more opportunity for gardens and diverse planting.

The River Lea

At the heart of the problems with the Spitalfields site is the status of the River Lea. This is not a concreted river bank, as on the Navigation, but a vulnerable earth bank. We have already seen the damage that party-goers can do to such an environment on the Hackney Marsh side of the river.

The present proposals include the possibility of riverside cafes and pubs with a road running all round the site right up to the north and along the river. Waltham Forest seems to have given no thought to the implications of building a massive housing development next to such a vulnerable river environment. The river bank will be a permanent attraction and place to hang out for a very large population, most likely added to by visitors coming to enjoy the river and pub environment. It is hard to see how the river bank will survive this pressure and it may have to be concreted over, permanently disfiguring this part of the River Lea.

Just as the so-called Hackney Beach is now a swimming and picnicking venue, this site on the other side of the riverbank will add to the pressure on the Lea from human activity.

Not only that but it is also intended to build a bridge across the River Lea to allow direct access to Hackney Marshes, to the part of the river which is designated as a Site of Importance for Nature Conservation (SINC). Building such a bridge in itself will be damaging to the river environment, even if it is only for pedestrians. It will always be difficult to restrict cyclists but a bridge for both pedestrians and cyclists will be a heavyweight construction. It will be a further reason for people to come to New Spitalfields: both to enjoy the riverside pubs and to be able to cross directly over to the other side of the river, possibly with drinks in hand.

The plans includes other points of access to Hackney Marshes across East Marsh without any consideration for the impact on that open space. The bridge will make that access less attractive so those routes may be surplus to requirements if the bridge goes ahead. It is hard to see why residents on the site should be granted such privileged access to the neighbouring green spaces. This will certainly be a gift to its developers.

The reality is that with or without properly permitted access, people living on the site will take it into their own hands to gain access to the Marshes. Even if the Spitalfields site is heavily fenced it has to be expected that people will breach the fencing. 

All these access routes will, of course, require permission from Hackney Council.

The irony is, of course, that all the benefits of this arrangement will go to Waltham Forest (increased council tax revenue, contribution to its housing target set by central government) and the developers (profit). The costs of environmental damage will be accrued by Hackney Council.

Too many roads

The design includes an entirely unnecessary road around the site which will only add to the pressures on the river with visitors using it to access these most vulnerable but attractive areas. Run-off from the road will add to the pollution of the river.

Roads should only be needed on such a site to allow access, so they can be cul-de-sacs rather than circuits. These roads will mean higher emissions and air pollution. The fact that the designers have been so unimaginative in the road design bodes badly for what will happen on this site.

The Bus Depot

The Bus Depot site also involves building towers, in this case on top of the bus depot. It is expected the bus depot will undergo alteration when electrification occurs.

This will be a very cramped space. It is hard to see how it can ever be a desirable environment to live in, particularly for young families. In addition, the site is intended to include a new station meaning people from the Spitalfields site will have to cross the busy Ruckholt Road during rush hours, adding to the congestion on the site. It is unclear whether this will involve a tunnel, which many will dislike.

The Bus Depot residents will be using the major retail facilities on the Spitalfields site, as well as its schools. All in all there will be considerable movements of people between these two sites over or under the busy Ruckholt Road.

The towers on the Bus Depot site will add to the visual impact of the towers on the Spitalfields site further damaging the sense of openness of the Marshes, East Marsh and Eton Manor in particular.

City Street

Vague statements are made about improving Ruckholt Road. However, given the extra traffic these sites will generate, the movement of people across Ruckholt Road and the lack of any proposals to solve the bottleneck at the bridge over the railway, it is hard to see how this is going to be achieved.

Eton Manor

There are some pluses from the proposals as they stand, particularly at Eton Manor, which is good news. Waltham Forest says it is not going to allow any development at Eton Manor, which is very welcome. Eton Manor can provide a haven for those living at the Bus Depot but this will require pedestrian-friendly crossing points on Temple Mills Lane. Unfortunately the development at the Bus Depot will reduce the sense of openness of Eton Manor.

The proposals for Eton Manor are otherwise unimaginative. Eton Manor needs to be seen as part of Hackney Marshes, again meaning pedestrian-friendly crossing points on Ruckholt Road. The connection with the Olympic Park is poor and the west end of Eton Manor is a completely uninteresting blank space. If it were planted up and made an attractive play area people might then choose to move to the green space at the east end of Eton Manor. Other routes around the back of and through the Hockey and Tennis Centre are not enticing.

Outdoor events

The present layout of car parks on Eton Manor breaks up the green space which could be used for outdoor events, which in turn might attract more users. Eton Manor is of much less ecological value than the Waterworks Meadow and would be a possible viable alternative for the kind of events the public has vigorously opposed at the Waterworks.

Wildlife haven

Another piece of good news is that Waltham Forest has also accepted that the section along the river just to the north of the Spitalfields site, which is at present inaccessible and serves as a wildlife haven, should be left as it is. The river never had a tow path so there wasn’t a route along the river at this point.

Connectivity northwards is already provided for pedestrians and cyclists up Orient Way and across Hackney Marshes. The present road layout makes the Orient Way cycle path difficult to access and this needs to be improved.

Other environmental improvements

Another welcome improvement to Waltham Forest’s plans following our discussions is that the triangle on the south-west of the site on the Ruckholt Road frontage will be left as a green space.

The plans include considerable amounts of tree planting along the railway although we have argued that trees should be planted or retained all around the site. In addition more imaginative tree planting should occur at the other sites, Eton Manor and the Bus Depot.

Housing need – environmental benefits

Of course, we know Waltham Forest argues the need for housing. In their eyes this has always taken precedence. However, this may not be as straightforward as it seems. It is now thought the population of London will decline: https://theboar.org/2021/02/why-is-londons-population-in-decline/

Given its proximity to the Marshes, Spitalfields is a high-value site so there is no certainty developers will be inclined to include the quantities of ‘affordable’ housing indicated by Waltham Forest and much of that ‘affordable’ housing will not be affordable anyway.

Whilst genuinely affordable housing is a priority, green open space and the preservation of flood plain is also a priority; it is time Waltham Forest paid proper attention to this, especially on such an important site as this so close to the Marshes.

Lea Marshes are one of the most valuable green spaces in London, East London’s “Green Lung”. Housing brings in Council Tax revenue which is a key concern for councils. However, green open spaces are known to provide health benefits and reduce health costs and thus to provide social and economic benefits. They can also play a role in protecting the wider area in the event of flooding, a key economic and environmental issue for the future.

Taking these points on board is in keeping with wider policy and should form part of Waltham Forest’s thinking on such critical sites.

If you have any thoughts on these plans, the Walham Forest officer in charge of masterplanning these sites is Sarah Custance: sarah.custance@walthamforest.gov.uk  

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