Do We Really Need A New Town on A Flood Plain?

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.

Google Satellite image of New Spitalfields site

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:

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:

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: :

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

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:

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:  

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