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