Dear Board Members,

Following our email to the Board on 14^th March 2022, we received a reply on 25^th 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.

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

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.

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.

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.

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 lake” https://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:

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.

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

Video: Severe flash flooding occurred in London, UK, due to heavy rain earlier today. pic.twitter.com/4tX13FdljB

— PM Breaking News (@PMBreakingNews) July 25, 2021

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