This objection is in response to one of the documents that the Lea Valley Regional Park Authority submitted to the Waltham Forest Planning Committee after the consultation period for the proposed new Ice Centre was supposed to have closed. It is written by Peter.
Further Objection to Planning Application 194162
Lee Valley Ice Centre, Lea Bridge Road, Leyton, London E10 7QL
23rd September 2020
Since my original objection to the planning application for a new ice centre on the Lea Bridge Road, some further documents have been submitted by the LVRPA (the applicant). I wish to object to one of these documents in particular, the Alternative Site Assessment Process Addendum.
This document sets out to explain why there is no possible alternative to the Lea Bridge Road site for the new Ice Centre. It does so by giving details of 59 alternative sites, all within the bounds of the Lea Valley Regional Park, together with the reasons why every one of these sites is deemed unacceptable.
It must be clearly understood that this whole exercise is based on a false premise. There is no requirement that the new ice centre needs to be located within the Regional Park. The 1966 Lee Valley Regional Park Act states, in section 15 clause 1:
The Authority may acquire by agreement, whether by way of purchase, lease or exchange, any land, whether within, or without the park, which they may require for the purpose of, or in connection with any of their functions. [my emphasis]
The “functions” mentioned here are those that enable to Authority to carry out its primary duty of
the development, improvement, preservation and management of the park as a place for the occupation of leisure, recreation, sport, games or amusements…
as explained in section 12 of the Act. In this conjunction, section 25 should also be noted:
Any land outside the park acquired by the Authority by virtue of this Act for the purposes of section 12 (General duty of park Authority) or section 13 (Ancillary powers of Authority) of this Act shall for the purposes of this Act be deemed to be part of the park.
So for this exercise to be useful, it should be based on a list of alternative sites covering a much wider area than the Regional Park.
Most of the 59 alternative sites in the list are nothing more than straw men, whose sole purpose is to distract our attention from the shortcomings of the Lea Bridge site.
This is most obviously the case with the large number of sites that are too small. If a site’s total surface area is less than the total surface area that the new building will occupy then there is no point wasting our time in giving it any consideration.
Similarly, several of the sites contain listed buildings. One should like to hope that no one is seriously suggesting that it would be acceptable to demolish a listed building to make way for an ephemeral skating rink. On the one hand, it is reassuring that the Authority apparently agrees; on the other hand, it is depressing that the Authority should feel the need to say so explicitly.
A third category is of sites that consist entirely or almost entirely of major infrastructure, such as large road junctions, rivers, and even (in one case) half of the Olympic Stadium. Again, these sites are so obviously impractical that it is a waste of time even to consider them.
As already mentioned, the overall area of a site must be greater than the total area that the new building would occupy for it to merit consideration. However, although this is a necessary condition, it is not a sufficient condition. The document states that the building’s area will be 7000m2. If a site is long and thin, it may still not be possible to fit the building into it even if its total area is sufficient. It will depend upon how the building is configured. The document states that each of the two rinks will measure 60m × 30m, so that in principle should determine how narrow the building could be made (say 40m). However, in none of the cases of a long and thin site (in other words, a site that is over 7000m2 in area, but is rejected because the building will not fit) does the document give any details of the site’s dimensions. So we cannot assess whether the rejection is justified: we must just take the Authority’s assessment on trust.
Once we have cleared away all of the statements of the bleeding obvious that are characteristic of the straw men, we are left with a number of other reasons for rejection that are very revealing of the LVRPA’s topsy-turvy reasoning, mainly concerned with local authorities’ land designations.
Several sites are rejected because they are on designated Open Space. The Lea Bridge Road site is on Metropolitan Open Land, which is a similar type of designation but much stronger. And yet it is the latter that the Authority wishes to put the new building on! Such double standards should not be countenanced.
More sites are rejected because they are in designated Industrial Areas. However, this is exactly the sort of area that would be most suitable for a large building like an Ice Centre. The design of the proposed new building was influenced by the design of the Ice Centre at Sheffield. If you use Google Earth to view the Sheffield Ice Centre (https://firstname.lastname@example.org,-1.4231941,666m/data=!3m1!1e3?hl=en-GB), you will see that, although there are some sporting facilities on one side of the building, the other side is characterized mainly by industrial premises (truck dealership, welding supplies, brewery services, to name just a few). This is a very different view from the view of the Lea Bridge Road site, surrounded as it is with green space on all sides.
However, the most common reason for rejecting sites is: “The site is a significant distance from the existing Lee Valley Ice Centre and therefore is likely to have poor accessibility to the existing user catchment.” This is tantamount to saying “This site is unacceptable because it is not the Lea Bridge Road site.” It just goes to show that the whole document is nothing more than an exercise in confirmation bias.