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:
- A new ice rink should be built at Eton Manor, within the Olympic Park, and not on Lea Bridge Road.
- 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.
- The LVRPA has not made the business case for a twin-pad ice centre in this location.
- 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.
on behalf of Save Lea Marshes