More objections to the proposed Ice Centre on Lea Bridge Road

The following objection has been submitted to the LVRPA’s consultation on the new Ice Centre. Feel free to use any of these arguments in your own submission (and see the blog immediately after this one for further arguments).

I wish to object to the proposed new Ice Centre on the Lea Bridge Road.

The LVRPA has given its reasons for wishing to locate the Ice Centre on the Lea Bridge Road in the Minutes to the Additional Authority Meeting of 16th June 2016. This document discusses at length the results of the Feasibility Exercise, which examined the relative merits of the Lea Bridge, Eton Manor, Waterworks and Picketts Lock sites. It would appear that the main reason why the LVRPA has chosen the Lea Bridge site is that it scores higher in the Scoring Matrix than the other sites. The Scoring Matrix is designed to lend the exercise a spurious air of objectivity, by computing a numerical score for each site. But such a calculation can only be as reliable as the values that are input into it, and these values are themselves subjective. As I shall demonstrate, many of them are clearly wrong – some have always been wrong, and facts have changed since 2016 with the consequence that others are now also wrong. For brevity, I shall only consider the values for the Lea Bridge and Eton Manor sites.

  1. Accessibility from existing catchments. This appears to mean: How easy will it be for people visiting the existing centre to visit the new centre instead? It has a weighting of 12. Why such a high value? Why should it matter particularly to the LVRPA whether people visiting the new centre are exactly the same as those visiting the existing centre? Before the existing centre was built (in 1981), there was no “existing catchment”, so any “need” for skating facilities that now exists is entirely a consequence of the LVRPA’s decision to create the existing centre in the first place. As it happens, both the Lea Bridge and Eton Manor sites are similar distances from the same population centres, so they can be expected to attract much the same clientele.
  2. Adjacencies of other leisure uses. The Eton Manor site has a score of 3. The leisure uses adjacent to Eton Manor (which are mainly sporting) are exactly the sort of uses likely to appeal to patrons of a skating rink. It should have a much higher score.
  3. Access by cycle. The Lea Bridge site has a score of 4, and the Eton Manor site 3. The approach to Eton Manor by cycle is much easier than that to the Lea Bridge site. The score for Eton Manor should be at least as high as that for Lea Bridge.
  4. Access by car. This has a weighting of 15, whereas the criteria for access for cycle and for foot both have a weighting of 5. This cannot be justified. The London Boroughs of both Hackney and Waltham Forest have a strategy of prioritizing walking and cycling over driving. Therefore the weighting for driving must be lower than for walking and cycling. It is disgraceful that the LVRPA should need to have this pointed out.
  5. Access by public transport. Both sites have a score of 4. This is odd because, according to the LVRPA’s own figures, Eton Manor is worse served than Lea Bridge by public transport. However, these figures are themselves wrong, as I explain in Appendix B. In fact, Lea Bridge is worse served than Eton Manor by public transport, so its score should be reduced.
  6. Fit on site. The Lea Bridge site has a score of 5, and Eton Manor 4. According to the latest (2019) plan the footprint of the proposed new building has been considerably reduced, so both sites must surely now score equally.
  7. Ice centre and on-site parking. This has a weighting of 10; the Lea Bridge site has a score of 4, and Eton Manor 1. According to the latest (2019) plan the number of car-parking spaces has been considerably reduced, in line with transport policy. As a consequence of the transport policy, the weighting should be considerably reduced. And since the requirement for spaces is now less, the score for Eton Manor should be increased.
  8. Ability for other revenue-generating possibilities. The Lea Bridge site has a score of 4, and Eton Manor 2. This appears to refers to the financial viability of an on-site gym. The distance between the Lea Bridge and Eton Manor sites is about 2316m. Within a radius of half this distance of the Lea Bridge site, there are four gyms (shortly to be increased to five, by the addition of a gym at 97a Lea Bridge Road); within a radius of half this distance of the Eton Manor site, there are six gyms. This is not a significant difference (see Appendix C). So the difference in the competition for gym provision near to the two sites is not very significant. In any case, there are other possible means of generating revenue besides the provision of a gym. Therefore the score for Eton Manor should be increased.
  9. Grounds/landscape constraints. The Lea Bridge site has a score of 4, and Eton Manor 3. It is not clear why Eton Manor scores lower than Lea Bridge. Eton Manor is a fairly barren site close to a motorway, whereas the existing site is close to an SSSI. The latest (2019) plan entails felling a number of mature trees at Lea Bridge, whereas there are no mature trees at Eton Manor. It is also acknowledged that there are a number of buried services that constrain development at Lea Bridge. Therefore the scores for Lea Bridge and Eton Manor should be swapped round.
  10. Impact on business plan. The Lea Bridge site has a score of 5, and Eton Manor 3. This is an example of double-counting, since this issue has already been taken into account under “Ability for other revenue-generating possibilities” above.

Click here to see a copy of the Scoring Matrix. The LVRPA’s original scores and weightings are on the left. On the right the scores and weightings are corrected to resolve the issues described above. Where a value is increased it is coloured red; where it is decreased it is coloured green. As can be seen, the score for Lea Bridge reduces from 933 (75%) to 910 (73%), and the score for Eton Manor increases from 882 (71%) to 953 (76%), as a result of these modifications.

Beyond the Scoring Matrix, much has been made of the idea that the Lea Bridge site can “provide a gateway to the Lee Valley Regional Park” and a “wider visitor offer with its central location and visibility on the road frontage”, and it is claimed that the latest plan will result in “opened up views on to the marsh”. This is absurd. It is proposed that a large building should be replaced by an even larger one. How can this open up views? And why is there a need to provide a “gateway” and a “wider visitor offer” in any case? The marshes are already visited by large numbers of people. They go there to seek isolation from the hurly-burly of London. Any increase in visitor numbers can only be detrimental to that experience, quite apart from the damage that more people will do to the ecology of the marshes. If the LVRPA really feels the need to trumpet its presence to passers-by, it could do so less harmfully at Eton Manor.

Finally, there is another good reason to put the new Ice Centre at Eton Manor. When the Olympics came to London, the allotments at Bully Point were destroyed, and an area of Marsh Lane Fields was fenced off and converted into temporary allotments for the holders who had been displaced. It was clearly stated at the time that this was only a temporary measure, and that after the Olympics were over, the allotments would be moved to a permanent site in the new Olympic Park at Eton Manor, and the temporary site on Marsh Lane Fields would be restored to public open space. But that never happened. The allotments that were supposed to be temporary have become permanent. So the result is that a precious area of open space has been lost to the public. Now is a chance to put right that injustice. If the new Ice Centre is built at Eton Manor, the site of the current Ice Centre at Lea Bridge can then be cleared and returned to open space. That would go a considerable way to compensating for the loss of open space on Marsh Lane Fields.

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Save Lea Marshes objects to the LVRPA’s plans to build a new ice rink

Save Lea Marshes will be submitting the following objection to the LVRPA’s consultation about their plans to develop a new ice rink. Please feel free to use some or all of what follows as your own submission to the consultation, which should be emailed to LVIC@communitycomms.co.uk or posted to https://leevalleyicecentre.commonplace.is/overview by the end of August 2019.

To whom it may concern

I am writing on behalf of Save Lea Marshes – a group of local people who campaign to keep the marshes of the Lower Lea Valley open, green and free from development – to object to the LVRPA’s plans to develop a new ice rink on the site of the current Lee Valley Ice Centre on Lea Bridge Road.

The objections can be summarised as follows, and each objection is dealt with in more detail below:

  1. A new ice rink should be built at Eton Manor, within the Olympic Park, and not on Lea Bridge Road.
  2. The land just behind the current ice centre, which will be swallowed up by the proposed development, is home to hedgehogs, an iconic species that is under significant threat.
  3. The LVRPA has not made the business case for a twin-pad ice centre in this location.
  4. The LVRPA has a history of breaking its promises. If the development does go ahead, there is nothing in the proposal to guarantee that the LVRPA will keep its promises to ensure the building has zero carbon emissions and is made of responsibly-sourced and environmentally-sound materials, and the high-quality environmentally-sensitive landscaping is both delivered and maintained.

The marshes are a very special place for a lot of people, for the old and the young, for the healthy and the troubled, and for everyone in between. Far more people find joy and solace in the marshes than will ever set foot in an ice rink. And, of course, the marshes are also home to plants, birds, insects and small mammals.

I would like the land the current ice rink is built on to be returned to green open space. To achieve this, it would be acceptable to build a new ice rink in the Olympic Park. The disturbance caused by the development and by the loss of some of Leyton Marsh will have a devastating impact on those who value the peace and quiet to help them navigate the ups and downs of life. Not to mention the dangerous precedent it sets for the gradual nibbling away of Metropolitan Open Land.

A new ice rink should be built at Eton Manor, within the Olympic Park, and not on Lea Bridge Road

The site of the current ice rink is Metropolitan Open Land and it should be protected from development. The current ice rink should be removed and the land returned to green open space, increasing connectivity between Walthamstow and Leyton Marshes, the Waterworks and Middlesex Filter Beds Nature Reserves, and Hackney Marshes.

Eton Manor is a much more appropriate site for a new ice rink. The LVRPA compared a number of sites in 2015 and decided that Lea Bridge Road was the most appropriate, but many of the reasons for choosing Lea Bridge Road over Eton Manor were, or have since become, invalid. To take some of the LVRPA’s objections to the Eton Manor site in turn:

“as a result of the poorer public transport provision it is estimated that the skating income will be lower at Eton Manor compared to the Lea Bridge Road sites”

The Lee Valley Ice Centre (LVIC) is served by two bus routes: 55 and 56 (the 48 is due to be withdrawn in a few months). Eton Manor is also served by two bus routes: 308 and W15. It is true that the LVIC has Lea Bridge Railway Station nearby, but Eton Manor is served by Leyton Underground Station which is only about two minutes’ walk further away from Eton Manor than Lea Bridge Railway Station is from the LVIC. Furthermore, Leyton Underground Station has far better and more frequent connections than Lea Bridge Railway Station. There is also a proposal to create a railway station at Ruckholt Road, which would be almost next door to a new ice centre built at Eton Manor. And, of course, Eton Manor is reached via fast trunk roads while the Lea Bridge Road is one of the most congested local roads in London.

“a fitness gym is a vital component of the business model. The Eton Manor site sits within a Queen Elizabeth Olympic Park development area which has a significant number of gyms.”

The distance between the LVIC and Eton Manor is about 2316 m. Within a radius of half this distance of the LVIC, there are four gyms, five if you count the proposed 24-hour gym at 97a Lea Bridge Road. Within a radius of half this distance of Eton Manor, there are six gyms; not a significant difference.

“the Eton Manor site currently has 140 parking spaces which are all needed at evenings and weekends; they will become a premium as the centre develops its programme. A new twin pad ice centre will need circa 220 parking spaces but there is insufficient space to accommodate this amount of ‘onsite parking’. Even if additional space could be found it is unlikely that the London Legacy Development Corporation would agree to this land being used because of their policy of traffic restraint.”

Waltham Forest Council also have a policy of traffic restraint and the current proposal for the new ice centre appears to suggest that the existing 140 car parking places at the LVIC will be retained or reduced, so the LVRPA’s previous requirements for car parking spaces have been downgraded and there is parity between the number of spaces available at Eton Manor and the number of spaces available at Lea Bridge Road. The LVRPA should not be undertaking activities that increase car usage anywhere and, consequently, it makes sense to cluster sporting venues at a sporting campus rather than spread them out and encourage more people to travel down the already crowded and polluted Lea Bridge Road. Major events at more than one of the venues at the same time are also likely to be very rare, so the perceived pressure on the existing spaces at Eton Manor is unlikely to materialise.

“continuity of provision is seen as key”

It will obviously be impossible to deliver continuity of ice if the Lea Bridge site is developed, but perfectly possible if Eton Manor is chosen.

“issues related to the Eton Manor site included: … – the blast zone”

It is assumed that this relates to the proximity of the bus depot on Ruckholt Road, where hydrogen is stored. However, it is clearly not a serious issue, because at the Authority Meeting on 25 April 2019, the LVRPA proposed building a hotel at Eton Manor; a hotel with a gym one might add!

“the indicative footprint for a new ice centre on the existing site was within the curtilage of the existing site”

According to the plans released as part of this consultation, the footprint of the proposed development will extend far beyond the curtilage of the existing ice centre and is going to be almost twice the size of the existing building. This is despite the fact that the LVRPA has reduced the footprint of the proposed build between 2016 and 2019. There is no reason why the proposed building will not fit on the Eton Manor site, a site that is far less ecologically sensitive than the Lea Bridge Road site. The Eton Manor site is fairly barren with no mature trees and close to a motorway, whereas the Lea Bridge Road site is close to an SSSI and a number of mature trees will need to be felled to facilitate the development. There are also a number of buried services that constrain development at the existing site; something that is not a factor at Eton Manor as far as we are aware.

The quotes are taken from the LVRPA report number A/4228/16, which can be read here: www.saveleamarshes.org.uk/wp-content/uploads/2019/07/Add20160616.pdf, and the minutes from the Authority Meeting where the report was discussed which can be read here: www.saveleamarshes.org.uk/wp-content/uploads/2019/07/AGM20160707.pdf.

The land just behind the current ice centre, which will be swallowed up by the proposed development, is home to hedgehogs, an iconic species that is under significant threat.

Hedgehogs are a priority species under the UK Biodiversity Action Plan and data gathered during a survey in October 2016 proves that hedgehogs have made the strip of land behind the ice centre, where the mown grass meets dense scrub and trees, their home. Subsequent anecdotal evidence from dog walkers supports this evidence. This is land that will disappear inside the curtilage of the proposed development presenting us with a stark choice: would you like hedgehogs or an ice centre?

The hedgehog population in the UK is under increasing pressure, with surveys by citizen scientists in 2018 showing that hedgehog numbers have fallen by about 50% since the turn of the century (www.britishhedgehogs.org.uk/pdf/sobh-2018.pdf). Attempts to relocate hedgehogs away from the proposed site of a car park for HS2 and further into Regent’s Park have failed, demonstrating how territorial hedgehogs are (www.royalparks.org.uk/managing-the-parks/conservation-and-improvement-projects/hedgehogs/hedgehog-research-reports). These two facts combine to demonstrate that the proposed development will result in the eradication of hedgehogs from this part of Leyton Marsh. This is unacceptable, even more so if it is at the behest of an organisation that has a statutory obligation to conserve habitats and species and claims to value biodiversity. The LVRPA should be developing a Species Action Plan to support the population of hedgehogs on Leyton Marsh not destroying it.

The LVRPA has not made the business case for a twin-pad ice centre in this location.

The LVRPA claims that the LVIC “attracts around 279,000 visits a year”and that the “new venue would welcome 557,000 visitors a year, making it financially viable long into the future”(https://leevalleyicecentre.commonplace.is/about). Where is the evidence that supports these claims?

A detailed breakdown of attendance figures has never been provided, nor has a methodology demonstrating how the proposed increase in visitors has been calculated. The projected figure appears entirely hypothetical and a convenient doubling of the current number of visits, while it is unclear how many of the current 279,000 ‘visits’ a year represent people paying to skate and how many represent, for example, parents waiting around for their children’s classes to finish or people popping into the centre to use the toilets. Local residents with a view of the entrance also confirm that the number of visitors appears to be significantly lower than 764 per day required to reach 279,000 visitors per year.

Data released by the new Sapphire Ice & Leisure Centre in Romford would seem to suggest that the number of people actually ice skating at the LVIC each year is at least 70% less than the LVRPA claims. The Sapphire Ice & Leisure Centre is in a busy central location near the station, has an ice rink of the same size and a similar number of public skating hours as the LVIC, plus a resident ice hockey team and it claims 76,650 people used the ice in the past year (www.havering.gov.uk/news/article/522/first_year_of_success_makes_sapphire_sparkle).

It would be tragic if we were to lose irreplaceable green open space to a white elephant.

The LVRPA has a history of breaking its promises. If the development does go ahead, there is nothing in the proposal to guarantee that the LVRPA will keep its promises to ensure the building has zero carbon emissions and is made of responsibly-sourced and environmentally-sound materials, and the high-quality environmentally-sensitive landscaping is both delivered and maintained

This is not the place to rehearse a list of promises the LVRPA has made and broken; suffice it to say that many of us are aware that the LVRPA plays fast and loose with the undertakings it makes to local people if it believes it will benefit financially. Those with long memories will, however, remember the planting promises the LVRPA made when the current ice centre was built in 1981, which never materialised and now enable the LVRPA to justify the current development because the land being swallowed up has, in their words, ‘little ecological value’!

The ecological enhancements the LVRPA are proposing are not dependent on the development. They could – indeed should – be done anyway. However, if they are contingent on the development of a new ice centre, what is the LVRPA doing to stop the contractor they employ weaselling out of its commitments? Even the architect and landscape architect employed by the LVRPA admit that it is nigh on impossible to find a way to ensure the plans they develop are implemented in full. It’s not hard to look a few years into the future and see a very big building filling up a large stretch of Lea Bridge Road, built from a material that makes it stand out and not blend in with the few trees left standing, completely blocking any view of the green open space behind it, surrounded by mown rye grass, filled with carbon-intensive plant equipment and promoting a sport that has come to be seen as increasingly anachronistic in the UK in the age of climate emergency.

This nightmarish vision of the future becomes even more likely when the proposals are scrutinised. For example, the LVRPA’s landscape architect told us that only seven trees will be cut down (five in the car park, one in front of and one behind the current ice centre), but a walk around the building shows that this cannot be true. There are at least four trees directly within the curtilage of the proposed building and it is impossible to understand how the line of trees – including willow, cherry, ash and poplar – to the north of the current building will survive given their proximity to the proposed boundary of the new ice centre. If they are not actually within the curtilage of the new building, it is difficult to see how they will not be removed to facilitate construction. We are similarly struggling to see how the leisure pad will be built within the space designated on the plan while the existing building continues to operate; there doesn’t appear to be room to fit it all in. Mistakes and obfuscations like this make it even harder to trust that the LVRPA will deliver on its promises.

Abigail Woodman
on behalf of Save Lea Marshes

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LVRPA caught misleading the local community AGAIN

Let me explain…

Earlier this week I sat down to review the papers for Thursday’s LVRPA meetings. These are the meetings in which officers of the LVRPA brief members of the LVRPA (councillors who, theoretically, represent the interests of their constituents) on what has been happening over the last month or the last quarter.

The papers for the Executive Committee Meeting contained an item on the proposed new ice rink on Lea Bridge Road. Looking at Appendix A of Paper E/618/19, I was shocked to discover that there are plans to take a bite out of Leyton Marsh to build the new ice rink. Whatever your feelings about the new ice rink – crave it or despise it – what’s distressing is that the LVRPA is proposing to do something it promised it would not do.

The minutes of the Annual Authority Meeting that took place on 7 July 2016 state:

the new ice rink, the temporary ice rink and any associated works will be limited to land south of the northern perimeter of the current ice rink. Nothing connected with the new ice rink will encroach north further onto Leyton Marsh

However, the plans clearly show that the intention is, indeed, to encroach further onto Leyton Marsh.

So I decided to attend the Executive Committee Meeting and raise this issue with officers and members. Perhaps they would consider rejecting the proposed orientation of the new ice rink because of their previous promise? A vain hope perhaps, but worth the effort…

In response to my comments, Dan Buck, Head of Sport and Leisure, said that he and his team have always taken the ‘perimeter’ to be the edge of the land leased to Vibrant Partnerships and that this is further north than the northern wall of the ice rink. Neither the Chair, Paul Osborn, nor the Chief Executive, Shaun Dawson, nor any of the members present said a word. Eeek, I thought, did we make a catastrophic mistake when we secured the promise in 2016? Did we fail to recognise that ‘perimeter’ was open to interpretation, that it could be read as anything other than the perimeter of the building itself?

Knowing that I had another opportunity to speak at the Full Authority Meeting in the afternoon, I scuttled away with two colleagues from Save Lea Marshes and over lunch we discovered the perfidy.

On 27 July 2017, the LVRPA responded to an Environmental Information Regulations request from Save Lea Marshes with a map of the land managed by Vibrant Partnerships. It clearly shows the northern boundary of the ice rink to be further south than the boundary that is now being claimed, only a few metres north of the northern wall of the current ice rink. In other words, exactly where we always believed it to be.

Have a look at the two images yourself. The first image shows the perimeter of the land managed by Vibrant Partnerships in 2017 and the second image is taken from the papers discussed at Thursday’s meeting:

It is clear to me that the boundary of the land leased to Vibrant Partnerships has been moved to justify the proposed orientation of the new ice rink. Yet no one in the Executive Committee Meeting was prepared to admit this.

It wasn’t until I presented the evidence I had unearthed at lunchtime that things began to shift. Dan Buck repeated his earlier statement, that he and his team have always taken ‘perimeter’ to be the edge of the land leased to Vibrant Partnerships and that is considerably further north than the northern wall of the ice rink. But the LVRPA member for Hackney, Councillor Chris Kennedy did, however, point out that this now appeared not to be the case and that the boundary had moved. The Chair then admitted that it had. Both had said nothing at the Executive Committee Meeting earlier in the day.

It’s a known known that parameters change as a project moves through the planning stages but I do call out a public body that makes a promise – because that’s what the statement in the 2016 minutes was – and then denies making that promise; I call out a public body that makes fundamental changes and then denies making those changes; and most of all I call out this organisation for failing to apologise when it gets caught out misleading the people it purports to represent.

We have, however, been here before with the LVRPA.

[Abigail Woodman]

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BEATING THE BOUNDS 2019

Save Lea Marshes (SLM), is organising a walk following the ancient tradition of “Beating the Bounds”. Revived in the 1990s, by the New Lammas Lands Defence Committee, “Beating the Bounds” involves blessing the boundaries of the area following pagan and Christian rites, and more recent traditions. If you don’t know about this part of our history, come along, find out and enjoy the fun.

WHEN: SUNDAY 26th MAY.  We will be doing the traditional “stripping of the willows” (cutting the bark off willow branches), from 1.30 pm and the walk will be departing at 2.00 p.m.

WHERE: Gathering on the tow path by the Princess of Wales pub, E5 9RB

We will be walking around the perimeter of Leyton and Walthamstow Marshes, pointing out the places where walking rights have been eroded and sites which are threatened by development.

Bring your friends and family, learn about local history, and enjoy a good walk with some musical accompaniment, a song or two and good company.  There will be stopping- off points for those who do not wish to go the whole route.  Wear sensible shoes.  Bring water.  Dress colourfully if you like (fancy dress particularly for children is encouraged).  Parts of the walk may pose difficulties for those with buggies and wheelchairs – we will try and assist with alternatives on those sections.  Dogs welcome.

We will meet on the tow path outside of the Princess of Wales and recommend you eat lunch beforehand or bring a picnic.  We will end up for more refreshments at the Hare & Hounds pub E10 7LD

SLM is reviving the tradition of this walk following in the footsteps of local historian and activist Katy Andrews. She sadly passed away nearly four years ago but we know she will be with us in spirit and very much present in the history of the area that she studied for many years and in the hearts and minds of all who knew her.

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Green Blot Award 2019

We at Save Lea Marshes are often maddened and saddened by the things that happen on or near the marshes. Such precious places should, we think, stay as wild and as unencumbered by the permanent presence of humans as possible.

We are also maddened and saddened by the Green Flag Award. How can the Award be an independent mark of quality when organisations pay to have the green spaces they manage judged and the judges ignore local people who point out that Award winners are failing to meet the Award’s criteria?

So we decided to do more than be mad or feel sad. We decided to launch the Green Blot Awards!

You are cordially invited to vote for the biggest crime against open green spaces in the London Boroughs of Waltham Forest and Hackney in 2018. Voting is open until the end of April, and we’ll think of a suitably gnarly way of celebrating the infamous winner later in the year.

Just click on “Green blots” on the menu bar above.

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Not Shining a Light on our Wildlife

While no-one is suggesting a city such as London should be without the necessary light required for access and safety, the amount of unnecessary light is increasing and this is a serious issue for our wildlife.

Guidance on artificial lighting from the Bat Conservation Trust is intended to raise awareness of the impacts of artificial lighting on bats but also the potential solutions to avoid and reduce this harm.

The new 2018 guidelines supersede the previous 2009 guidance about lighting levels, now detailing the colour and temperature impacts on different bat species.
Not only bats, but also birds and mammals are adversely affected by artificial light as it interrupts breeding, migration and hunting patterns. Humans are also affected by the effect of the suppression of melatonin on our biological clocks. White-light sources (including LEDs) must be used with caution since, “These lights emit high levels of blue-ish light that not only interferes with our night vision and our own health, but also with the well-being of animals. Other types of lighting, such as incandescent or high-pressure sodium vapour lamps, produce high levels of reddish or even infrared light. Their spectra interfere with the well-being of many types of plants.” No living species ever evolved for continuous lighting so we should not be surprised that no species truly benefits from it.

The International Dark Sky Association has some useful tips for all of us on how to reduce our own unnecessary interior or exterior lighting. We can install motion sensors on all outdoor lights; turn off any lights at night that are not motion-sensing and install window coverings that block out as much light as possible. The latter is particularly important for the increasing number of flat and house dwellers who live around the edges of our parks and waterways, many of whom follow the fashion for large windows without blinds or curtains, without apparently thinking about the consequences for river-dwelling wildlife.

Light pollution is one of the concerns that Save Lea Marshes (SLM) and other local groups have about the increasing development and commercialisation of our marshes and Metropolitan Open Land (MOL). One particular concern is the prospect of two free schools and a nursery being built on land adjacent to the Middlesex and Essex Filter Beds, close to Walthamstow and Hackney Marshes, which already suffer from light spillage from all directions.

I took a walk around the Middlesex Filter Beds in the dark, as near to closing time as possible, to assess and photograph the amount of light pollution that is already creeping in, notably from relatively recent bright lighting on the Thames Water Depot site (which also shines out over the River Lea), and from the cranes on the 97 Lea Bridge Road development some distance along the Lea Bridge Road. It is already at an unacceptable level. The proposal to build free schools on the Thames Water Site adjacent to the Nature Reserve is likely to seriously exacerbate the harms to the very wildlife the Waterworks Reserve seeks to encourage and preserve.



To explore the potential of light spillage from schools, you need look no further than Mossbourne Academy on Hackney Downs; the levels of light coming from this site are bad enough on a public park but would constitute a serious threat to an area such as the former Thames Water Depot which is adjacent to a nature reserve, particularly if they are left on all night for security reasons.


The Lee Valley Regional Park Authority, its rangers and its volunteers, in cooperation with other agencies, undertake regular monitoring of bats, birds and other mammals within the park area, and its public website www.visitleevalley.org.uk has information on activities such as the “Go Batty” walk which took place in August. The website also has an area where anyone can report sightings of rare and unusual species in the park. One such area is the Filter Beds, a set-aside area which also includes an area where the public are not permitted, in order to promote the sustaining of wildlife. Why then, has the LVRPA not been more active in protecting this part of their remit particularly when they are aware of the species within the reserve? Recent bird sitings in and around the Filter Beds include: Teal, Little Grebe, Common Sandpiper, Sparrow Hawk, Kingfisher and Kestrel.

My online searches of specific investigations into the wildlife in the Middlesex Filter Beds came up with a Field Survey carried out by the London Bat Group, with the cooperation of the LVRPA in 2011, citing an historical database that was created in 1985, and last updated in 2010. (However, maybe due to my lack of diligence, I have been unable to find a subsequent similar survey of this particular area of the park. There has, however, been a recent volunteer walk carried out by a park ranger in the Coppermill area of Walthamstow Marshes as featured in the latest “Musings from the Marsh”). It includes a map of the areas walked and a summary of the species of bat recorded since 1985. These were: the Common Pipistrelle, Soprano Pipistrelle, Nathusius’ Pipistrelle, Noctule, Daubenton’s, Leislers, Serotine and Brown Long-eared. Out of these, the Nasthusius’ Pipistrelle, Noctule and Daubenton’s seem to be the ones that have been most recorded recently. The various types of Pipistrelle were recorded on two occasions, 21st and 27th of September 2011. The Brown Long-eared Bat was last recorded in 1996 and none since.

The Bat Survey of 2011 (4.2) comments on urban light levels surrounding the Waterworks Nature Reserve: “Overall urban light reflected off clouds into site raises levels significantly above levels expected in rural areas. Direct light spill from adjacent works, highways and residential areas limited to west and northern edge of sites. Worst affected stations are 6 and 9 [both points are within the Essex Filter Beds adjacent to the current Thames Water Depot, where the schools are planned]. Levels at these points are likely to impact light-intolerant species such as Daubenton’s but not Pipistrelles”. It should be noted that 2011 was pre-Olympics and the increased levels of development involving large light-producing structures that can now be viewed around the perimeter, particularly from the Olympic park side of Hackney Marshes. Also, it predates the latest findings of the Guidance from the Bat Conservation Trust mentioned earlier. I would argue that we should not be making matters worse by deliberating parking another set of highly illuminated buildings and school grounds adjacent to the Nature Reserve.

What examples are we giving to the next and future generations? Our planet and our local eco-systems are being increasingly threatened. We may not have the power to individually influence world issues but individually and collectively we can and should democratically object to developments which affect us locally. The schools planned for the Lea Bridge Road site are not schools planned or needed by the local authority and are, in effect, private enterprises, being plonked by national government on an important local nature area. It is time to say “no”.

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More on the Thames Water site

We have all had great difficulty trying to work out what the differences are between the latest version of the plan for developing the Thames Water site and the original version. We have now at last been provided with a document that (supposedly) lists all of the differences. You may find it here: FS0467-JW-00-XX-RP-A-0005_DASPermanentAddendum_P05.

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Thames Water site – last chance to object to the plans

After 18 months of tinkering and shenanigans, it now seems likely that the extraordinary plans to build the “Athena  Primary Academy” and “Barclay Secondary Free School” on the Thames Water site, Lea Bridge Road, will soon go before Waltham Forest Council’s Planning Committee for approval.

The Council have asked for submissions by 29th October 2018 so if you haven’t yet sent an objection to dcmail@walthamforest.gov.uk please do it now – however short and simple. Include the application reference  171408 and  site address  150A Lea Bridge Road, London E5 9RJ.

The developers are continuing to show misleading ‘before and after’ images on their promotional site http://www.leabridgedepot.co.uk/ , which show the existing dense vegetation of mature woodland along Lea Bridge Road retained in an identical state, and screening the site from the view of those passing on Lea Bridge Road.

However further plans submitted in the past month disclose that over 50 trees will be felled and the woodland paved over.  The present linear woodland that provides such welcome relief from the urban grimness of the main road will be replaced with tarmac, a 2.4m fence and stark views onto the car park and vast school buildings beyond.

Here are the main planning issues that could be included in objections:

  • The site is Metropolitan Open Land which has the strongest protection from development and which the London Plan clearly states should not be developed unless there are “special circumstances”. MOL sites are of strategic importance for all of London. The proposed development is not acceptable under current planning policy.
  • There are no “special circumstances” which could justify the proposed development: the pressure for new school places is a generalised pressure not a special circumstance, just as it is for housing or other infrastructure such as hospitals. In any event the pressure for school places is elsewhere in the borough.
  • The revised plans propose that almost all the existing woodland habitat with its mature trees along the Lea Bridge Road frontage will be removed, with an unacceptable negative impact on openness and visual amenity from the viewpoint where the largest number of people will be affected.
  • The site is flood plain and unsuitable for a school.
  • The site should be returned to the Lea Valley Park as intended and re-established as a vital part of the park: losing it would put a huge obstruction in the middle of an otherwise continuously wide green corridor and compromise the green chain both now and in the future, because the development of the site could lead to future attempts to develop in and around it.
  • The activity, noise and lighting associated with the schools will be harmful to the sensitive surroundings of wildlife habitat and Nature Reserves.
  • Though the applicant says there will be more green space as a result of the development, this will not be true green space but rather school playing fields of limited biodiversity value to which the public will be denied access. Were the site returned to green space parkland, this would be entirely green space and accessible to the public.
  • The Travel Plan is fundamentally flawed: it seeks to reduce local traffic impacts to an acceptable level, but this depends upon the assumption that all parking, dropping off and picking up will take place at the school and on the road outside, both of which will be restricted. However immediately opposite the proposed site the Ice Centre provides free parking for 30 minutes and will be ideal for parents dropping off and picking up, rendering ineffective the restrictions at the school itself. Five minutes’ walk away, unlimited free parking is available at the Waterworks and Riding Centre. It therefore grossly understates the increase in traffic that will be generated and associated congestion and pollution.
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The LVRPA and community enagement

Back in June I shared a letter I had written to Shaun Dawson, Chief Executive of the Lee Valley Regional Park Authority, about the Authority’s lack of community engagement. You can see the letter here: https://www.saveleamarshes.org.uk/2018/06/29/open-letter-to-lvrpa-re-lack-of-community-engagement/

In the spirit of fairness, I think I should also share Shaun’s response, which I received just under three weeks after I sent my original letter. I’m sorry it has taken me so long to do so; no excuses, I’ve just been really busy.

Shaun said, and I quote directly:

I am writing in response to your email of 28th June in which you set out a range of concerns in relation to the Authority’s approach to community engagement in the south of the Park. Authority Members received your letter and it was discussed at the Authority meeting on the 5th July. Members resolved to look at how the Authority engages with the many user groups and key stakeholders up and down the Lee Valley and this will be looked into in the coming months. My response below addresses the specific points that you raised in your letter.

The Ranger service continues to manage the range of Authority owned sites to a high standard and deliver local community engagement though various means in the Park. Please see attached a list of the community engagement activities and communication mechanisms in the south of the Park since January 2018 and also planned future events and activities for 2018/19.

The Lower Lee Valley sites continue to receive high scores for both Green Flag and London in Bloom, and in the latter case achieved best Conservation Area for London for the past 2 years. The awards are assessed by external judges from both the Green Flag and London In Bloom awards and we have fulfilled their community engagement criteria.

In addition the Authority consults local groups and the wider community on its Park Development Framework (PDF) proposals for the Regional Park as these are developed. Currently the Authority is consulting on draft strategic policies and a landscape strategy for the whole Park and area proposals for specific areas of the Regional Park which lie north of the M25 motorway. All of these documents are available on the Authority’s website (www.leevalleypark.org.org.uk) or can be seen in hard copy at several venues across the Regional Park.

Public consultation has recently taken place on the draft Lee Valley Regional Park Biodiversity Action Plan, the outcome of this will be published soon. Comments from Save Lea Marshes have been noted through this process. The Authority will continue to work with a range of stakeholders to develop and deliver the specific action plan targets.

The previous user forums in the south of the Park were not always well attended. We therefore decided to look at a more effective approach to community engagement. The workshops were created to focus the meetings on specific aspects of site management and to better inform the public about the Park’s rationale for its management regimes. Natural England attended the grassland workshop to provide a clearer understanding of the Park’s grassland management regime. During the workshops we discussed how and why we managed all of the different habitats present on site as well as other site operational issues, which was the specific aim of the workshops from the beginning. The workshops were an opportunity for members of the public to raise questions and provide feedback relating to the topics discussed on the agendas. During the workshops suggestions, questions and opinions were invited for consideration, were responded to and if appropriate were implemented.

We also took the decision to run a series of site management walks, inviting members of the general public as well as local user groups to attend and discuss relevant management issues with the Ranger while on site. In addition to this we continue to run several Ranger ‘drop in’ sessions each year. We have engaged with many more users through this format of community engagement and receive a greater level of response and insight into the views of the visitors to the Marshes than through the previous forum meetings. The Ranger ‘drop ins’ and walkabouts are in our opinion a more efficient and effective form of community engagement. The participants of the former workshops/ forum continue to be contacted via a mailing group, updating them on site management of the marshes, as well as receiving a quarterly newsletter. All FOI requests received have been responded to. Furthermore the site Ranger for the Marshes has always shown a willingness to meet informally around prearranged walks to discuss any management issues they may arise.

Our events and activities are advertised on the Visit Lee Valley Website, What’s On guide, Information Boards and via Lee Valley Regional Park social media. The site Ranger also regularly tweets information regarding the Park and events and has 840 followers and growing. Events and activities are mentioned in the mailing group and the events and activities are also included in the quarterly newsletter which the mailing group receive.

In your letter you also made reference to the £75k investment which was borne out of the temporary use of Leyton Marsh for the 2012 Olympics. I am advised by officers that SLM were involved in the process for determining how the investment was to be spent including being part of the panel that approved the artist and artwork for the mural.

The Authority does, it believes, devote significant time and energy to engaging the many interested parties in the south of the Park, as the attached list illustrates. That said it is important that we review how we do engage and look at ways to be more effective. Over the coming months we shall carry out such a review.

It was heartening to hear that the Authority is taking our concerns seriously, although we have heard absolutely nothing on the matter in the last three months, and so I can’t help thinking this is another hollow promise.

What was disappointing, although perhaps not surprising, is the fact that the LVRPA continues to argue that what we have experienced, what we have witnessed, what we know to be true isn’t true. For example, while it is absolutely true that members of Save Lea Marshes were involved with the underpass mural project, it is not true to say that we have been ‘involved with the process for determining how the [ODA] money was spent’, and this blog post will explain why: https://www.saveleamarshes.org.uk/2018/02/07/what-happened-to-our-money/.

As for his comments about the forum, workshops and ranger drop-ins, here’s what one friend, who used to attend the forum and the workshops, says in reponse:

“It’s so convenient for them to keep saying that all the good stuff happens on the ranger drop-ins, when there is no documentation, no reporting, no follow-up. The LVRPA can say anything it wants about what is said by people who happen to pass along during the drop-ins. The forum was for all about having proper discussions about issues and attempting to have some input into LVRPA policy. Obviously, the LVRPA prefers the drop-ins because they aren’t for that at all. The forum was all about consultation, the drop-ins are not.”

I am conscious that different optics produce different perspectives but surely the only way for any organisation to better serve its customers or clients is to listen to them? And I’m very clear in my mind that the LVRPA exists to manage the land within the Park on our behalf; that the LVRPA does work for us. I just wish it behaved as if it did sometimes, and listened to us.

Abigail Woodman

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Too much littering on the marshes

Hackney Council does a wonderful job in clearing up the litter from Hackney Marshes. Goodness knows how much it costs.

However, if you are out walking after the sports sessions, before the council has done its magic, the scene that confronts you is appalling. Litter everywhere and a great deal of single-use plastic. I find it hard to ignore and often find myself disposing of it in the nearest bin.

Last Monday (September 3), my anger reached boiling point. Having picked up some detritus such as half-full plastic water bottles, I walked towards the new green carbuncle (sorry, sports pavilion), to be confronted by a practically empty bin, surrounded by about 20 plastic food containers and cutlery left within a hand’s distance from the nearest bin outside the pavilion.

I am therefore appealing to the participants and organisers of sports activities to do something about these thoughtless, wasteful, bad habits.

Sports people should be able to set a better example and have the motivation and energy to put things in bins or take them home. Clubs should be advising their members of the need to reduce plastic and use reusable cups and bottles and not leave empty and in many cases half-full bottles of water and energy drinks on the pitches. Teams leaders could organise a collection after matches finish and/or bulk order some reusable cups and bottles for their teams.

As Hackney Council is so generous as to give free parking to sports people including visitors from outside the borough, perhaps it could re-coup some of the huge amount of money spent on building the new facilities on the marshes by fining any club from booked areas that leave significant waste behind.

I can hear people saying that it is not just sports people, but anyone who visits the marshes after the weekend will notice a significant increase in the nature and level of stuff left behind, including nonrecyclable cups that clearly come from the nearby Hackney Marshes
Sports Centre cafe concentrated on or around the pitches.

The marshes are a shared resource, not only by other users but also by wildlife. So please sports and any other people eating and drinking on the marshes and other green spaces, take your rubbish with you or put it in the bins!

[Celia Coram: Letter in Hackney Gazette, 13th September 2018]

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