As we become ever more aware of the value of open green space to our well-being and the state of emergency for our wildlife, at the same time our local authorities seem intent upon the same course of damage and destruction, all in pursuit of outdated ‘growth’ models of development and progress. In the process, Nature is harmed and the public realm is impoverished, whilst Orwellian claims are made about ‘improvements’ that have no basis in fact, let alone public consent. The mountain of documentation that exists, in theory to legislate for improvements in biodiversity and quality of life, ends up gutted of all real meaning or outright ignored. Whilst there are both numerous and infamous examples of this happening at a national level, sadly we are seeing it happen time and again at a local level. Authorities such as the Lee Valley Regional Park Authority (LVRPA) and Waltham Forest Council, that are tasked with protecting our green spaces, end up collaborating in trashing them for profit and leaving us all worse off.
This familiar scenario, which we saw with the construction of the double-sized ice centre on Leyton Marsh, is once again being played out with the emerging plans for Eton Manor (Leyton) and the New Spitalfields site adjacent to Hackney Marshes. Plans are afoot to put increasing pressure on our remaining Metropolitan Open Land (MOL) which should have the same protected status as Green Belt. In the case of Eton Manor, the Lee Valley Regional Park are making efforts to remove its protected MOL status so the land can be ‘disposed of’ for the construction of private facilities. Waltham Forest Council is proposing building soaring high rises on the site at New Spitalfields, right next to East Marsh and the imperilled River Lea. What happens at these locations will have far reaching consequences, not just for the land in question, but for the whole Lee Valley Park. If development is not successfully challenged, precedent will be set for invalidating the statutory protections and privatising land across the Lee Valley.
New Spitalfields
New Spitalfields site (middle right on map, above East Marsh)
One of the most important areas of land, in terms of preserving the integrity of the marshes and local riparian wildlife, is New Spitalfields. Whist it is not protected land, this area, adjacent to East Marsh, has strategic importance for the Metropolitan Open Land at Hackney Marshes. The current ‘vision’ is for its future is blocks of flats up to 30 storeys! There will be huge impacts on the open space from population pressure and development at such scale.
Yellow stars on site map for New Spitalfields indicate proposed high-rise blocks
Despite these patent threats, it has now been revealed that the Lee Valley Regional Park Authority has lent its support to Waltham Forest Council in order to facilitate this vastly inappropriate development next to the Park. This could be a quid pro quo for the council’s planning approval and financial backing for the ice centre, or an attempt to curry favour for future commercial plans at Eton Manor and the Waterworks. As these developments will remove both land and property from free use and public ownership, the LVRPA is perhaps anticipating a negative public response and council opposition. It is reasonable to assume this is why it has lent its backing to a scheme from which it will derive no obvious benefit, but which will jeopardise the ecological health of the marshes and integrity of the Lee Valley Park still further. The LVRPA are fully aware of this, warning of these impacts in an internal report on the much smaller Lea Bridge Station development.
Waltham Forest Council is under pressure from the government’s Planning Inspectorate for its unjustifiably inflated housing targets. Instead of reforming its first version of the Local Plan by reducing the housing targets and removing unpopular proposals for high rises adjacent to Walthamstow Wetlands and Hackney Marshes, it has instead stuck with its original framework. This is where the LVRPA has come rushing to its aid. A joint letter by WF Council and the LVRPA to the Planning Inspectorate on 28th September, expresses “the strategic importance of the [Local] Plan to both authorities” and makes a clear declaration of “support for its adoption following a second stage of Examination in Public”. Whilst much of the language of the letter is obtuse and inaccessible to lay readers, it is nonetheless of great import to the public since the Local Plan will shape the future of planning in the borough. We can only hope that the City of London Corporation, who own and manage Epping Forest, and the London Wildlife Trust, who manage Walthamstow Wetlands, take a principled position and object to the Local Plan during its second stage.
Whilst the Planning Inspectors have not adequately considered the impact on the Lee Valley Park, they have concluded that Waltham Forest’s plan would have an adverse impact on the integrity of Epping Forest. At this stage they have rejected housing targets which will result in unacceptable impacts on the marshes – negative impacts the Lee Valley Regional Park Authority appear only too happy to facilitate. Although Waltham Forest Council is keen to build as many houses as possible, no doubt in large part due to the income generation from council tax revenue, it is hard to see how Hackney Council, who finance the management of Hackney Marshes, will stand to gain in any way from this inappropriate development. Will they side with the other local authorities or represent the public interest and defend Nature here?
Eton Manor
Eton Manor site (right)
Equally egregious are the plans for nearby Eton Manor. A local and regional authority as well as a London university appear to be privately collaborating to remove part of the Eton Manor site from public ownership, despite the site’s important historical role in providing free public access to sports. Eton Manor was purchased by philanthropists to provide sporting facilities for East Londoners, in particular for local boys’ sports, at the turn of the twentieth century. After the 2012 Olympics Eton Manor was supposed to be the new home for the Manor Gardens Allotments, also created by the same philanthropists, which were evicted from their home at Bully Point. That plan was scotched by their former landlords and owners of Eton Manor the Lee Valley Regional Park Authority (LVRPA), who didn’t want any allotments on their land at this location, even though the removal of the allotments from Bully Point was only agreed to on the clear understanding they would be re-located to this site, which already had planning permission, after the Olympics.
Marked in red: Site of potential private development
The LVRPA have been attempting to sell part of the Eton Manor site for a number of years for commercial development and floated the prospect of a 98 bed hotel, gym and associated car park on the market in 2018. Through the determined efforts of veteran campaigner Laurie Elks and our own Freedom of Information enquiries, we have recently discovered the conspiracy between the LVRPA and University College London to re-privatise and develop Eton Manor.
In April 2021 LVRPA Members were briefed that a “hotel is still very much part of the thinking in line with the procurement” and the Authority “was in discussions with UCL and had jointly commissioned a feasibility study and masterplan to look at options for development”.
University College London (UCL) is now collaborating with the LVRPA’s project to build a hotel on this area of Metropolitan Open Land (MOL) and in return it hopes to attain its own private sporting facilities on 2.35 acres of the site deemed by the Authority as ‘no longer required for Park purposes’. So instead of environmentally compatible allotments at Eton Manor, if UCL and the LVRPA have their way, we will end up with a luxury hotel, and sports facilities only for UCL students. This on land originally bought by philanthropists to enrich the public realm and enable local people to take part in sports. The site for the proposed hotel would have been a much more sensible location for the new double-size ice centre now crowding out Leyton Marsh; we believe the only reason it was not chosen was the then-secret plan for its privatisation and sale.
No plans for the site have ever been placed in the public domain and the only information that has been attained derives from Environmental Information requests, released in redacted form only.
It has recently been revealed that it is not only UCL who are collaborating with the LVRPA in their commercialisation plans, but that Waltham Forest Council are getting into bed with them too: “LBWF and the LVRPA have therefore worked proactively togetherto align our ambitions for this site through collaborative work on the Leyton Mills Development Framework and new SANG Strategy. Both parties agree to continue to work together to deliver the opportunities presented by this site.”
The deciding planning authority is currently the London Legacy Development Corporation (LLDC) which will wind up at the end of 2024. Its position on the future of the Eton Manor site remains unknown. However, if the organisation which turned down having allotments (that the public could apply to cultivate) then favours a private built development on site, it will amount to yet another betrayal of local people. We suspect discussions between the LVRPA, UCL and LLDC, in which the public will have no input, are already underway. Waltham Forest Council seems to hint that it may be the deciding planning authority by the time planning applications come to the fore:
“The Lee Valley Hockey and Tennis Centre at Eton Manor, a site owned by LVRPA, is a key site in the spatial and growth plans found in the Waltham Forest Local Plan (Part 1), and presents a significant opportunity…for future investment in sports and leisure facilities.Although it is currently under the planning remit of the London Legacy Development Corporation (LLDC), planning powers will revert to LBWF on 1st December 2024.”
What makes these collaborations particularly dangerous, as well as galling, is that they take place behind closed doors. Valuable information on the proposed future of public spaces is only attained once detailed private development plans have been drawn up and the outcome for their delivery already put in motion. Nonetheless, this is why individuals and groups such as ours spend such a great deal of time attempting to access vital and concealed planning information. Whilst the odds are stacked against us in stopping the commercial juggernaut flattening our green spaces for private gain, previous victories in defending the marshes give us some grounds for optimism in the coming battles.
We are sharing the WFCS Campaign against Waltham Forest Council’s excessive housing targets and request you take part in the actions suggested if you are a Waltham Forest resident:
The Council’s proposed Local Plan sets a “requirement” of 1800 new dwellings to be built each year.
The Plan is intended to apply for 15 years, making a total of 27,000 new dwellings in Waltham Forest. The requirement imposed on Waltham Forest by the Government and the London Plan is 1264 new dwellings per year. The excess (536 extra new dwellings each year for 15 years) is being chosen by the administration of Waltham Forest Council.
The Planning Inspectorate has refused to approve the proposed Local Plan, questioning the target of 1800 new dwellings per year. The Council intends to submit a revised version in mid-September, but with the same target of 1800 per year.
The months between now and September are an opportunity for residents to persuade elected Councillors to reject the higher target and for the Council to adopt the lower target of 1264.
Why does this matter?
The Council’s proposals involve allowing developers to build tower blocks on almost every possible site in Waltham Forest.Belowis a map which the council intends to submit with its revised version in September: it shows the locations where tall buildings (10 storeys or more) would be allowed:
Studies by academic engineers say that tower blocks are much less environmentally friendly than blocks of mansion flats of 6 or 8 storeys.
The “Skyline Studies” published by Waltham Forest Council with Part 2 of the draft Local Plan show that many of the tower blocks are intended to be 14 or 18 storeys high. The new tower blocks would:
loom over the town centres of Leyton and Leytonstone, and intrude on the settings of historic buildings and conservation areas
be built along the edge of the Lea Valley, walling in the Walthamstow Wetlands and the open land of the Marshes (you can see the plans that affect the marshes in detail here). The worst impact will be from the New Spitalfields site, adjacent to Hackney Marshes and the River Lea, where there will be blocks of flats up to 30 storeys high!
be built next to Epping Forest land by the Hollow Ponds (“Leyton Flats”) and at Wanstead Flats, intruding on the views from the open land, and they would not allow for gardens or for enough green space for the residents to sit out in, so that the Forest land would be overcrowded and overused.
There may be too little capacity on the main roads within the Borough to take the cars and vans servicing so many extra residents.
Air quality in the borough is already poor and the extra vehicle movements would make it worse.
The Victoria Line and Central Line, and the railway from Chingford to Liverpool St, would not have capacity to take the extra commuters into Central London.
The new tower blocks would destroy the character of the borough. What would be built would be flats that people would not choose to live in, in a borough that they – and the existing residents – would move out of as soon as they could.
Please support the WFCS campaign by sending the following text as an email to your ward councillors – you can find contact details for them by entering your postcode on the Council’s website at:
Dear Councillors I am a resident in your ward at [ADDRESS AND POSTCODE]. I am concerned about the difference between the housing target imposed on Waltham Forest by the London Plan and the higher housing target in Waltham Forest Council’s draft Local Plan and the likely consequences of the higher target for the character of the Borough as a place to live. Partly because of Covid, the Council has not yet consulted residents properly about its proposal to adopt the higher target. I am writing to call upon you to hold a ward forum to discuss this proposal with your constituents, in good time before the Council re-submits its draft Local Plan in September this year. Yours sincerely, [YOUR NAME].
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.
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.
In 2020, we successfully crowdfunded for wildlife surveys of the Waterworks Meadow. We did this in order to reveal the biodiversity of the meadow, with the aim of convincing the Lee Valley Regional Park Authority to ‘rewild’ the area, to maximise its potential for wildlife.
Thank you again to everyone who donated.
At the end of last year, these surveys were completed and, after submitting all the findings to the Lee Valley Regional Park Authority, GiGL and Waltham Forest Council, we would now like to share the key findings and recommendations with you.
Brown-banded Carder bee by Russell Miller
The Waterworks Meadow will be assessed for inclusion on the list of Sites of Importance for Nature Conservation (SINCs) by Waltham Forest Council in the coming year. We are still awaiting the outcomes of the Lee Valley Regional Park’s own surveys and its assessment of the area.
Huge appreciation to our surveyors – Annie Chipchase, Alison Fure, Ian Phillips, Rob Sheldon and Russell Miller.
Here are some very brief highlights – you can download the full survey collation here.
Key findings
Six bat species were recorded during the surveys. Common (Pipistrellus pipistrellus), Soprano (Pipistrellus pygmaeus) and Nathusius’ (Pipistrellus nathusi) Pipistrelle Bats, as well as the occasional commuting Noctule Bat (Nyctalus noctula) and one Serotine (Eptesicus serotinus) commuting pass. There was a Daubenton’s Bat (Myotis daubentoni) commuting at the culvert during the first survey and two Daubenton’s foraging at the Waterworks nature reserve lake.
Two species of amphibian (Common Toad Bufo bufo and Smooth Newt Lissotriton vulgaris) and one species of reptile (Grass Snake Natrix helvetica) were recorded, including young individuals of Smooth Newt. Common Toad and Grass Snake are UK Biodiversity Action Plan (UK BAP) species.
Six species of terrestrial mammal were also recorded including Red Fox Vulpes vulpes, Grey Squirrel Sciurus carolinensis and Rabbit Oryctolagus cuniculus.
Small mammals recorded during surveys of the Waterworks Meadow included Common Shrew, Short-tailed Vole, Wood Mouse and Muntjac Deer.
The wide range of families and species suggests that the Waterworks Meadows provides an important habitat for a diverse assemblage of invertebrates. Twenty bee species were recorded confirming the diversity and abundance of nectar and pollen resources available on site. Possibly the most important species recorded was the Brown-banded Carder bee Bombus humilis which is a priority species for England.
Within the Waterworks Meadows the mosaic of scattered trees, flower-rich grassland and proximity to water provide larval and adult habitat for a wide diversity of species.
Overall, a total of 166 plant species were recorded across the site with the Central and Eastern Grassland areas being the most diverse with 109 and 92 species respectively.
The area as a whole is relatively diverse from a botanical perspective with a good mixture of herbaceous plants, trees and shrubs.
A total of 69 bird species were recorded across the 2 sites (including flyovers), with 53 species in the Meadows and 59 species in the Waterworks Nature Reserve.
There were 30 species that are classified as Birds of Conservation Concern according to the latest review of bird populations in the UK, of these 7 are red-list species and 21 are amber-listed.
Of the red-listed species, three singing male Greenfinch Carduelis chloris were recorded on the Meadows, and singing males were also recorded for amber-listed Whitethroat Sylvia communis, Wren Troglodytes troglodytes, Song Thrush Turdus philomelos and Dunnock Prunella modularis. Song Thrush was confirmed breeding in both the Meadows and the Reserve.
The regular presence of a Kingfisher Alcedo atthis along the River Lea, including during the nesting season, suggests breeding nearby (and this has been witnessed and recorded by local birdwatchers this season).
Key recommendations
The Meadows is a relatively small area rich in wildlife and habitats that provides connectivity to other neighbouring areas such as the Waterworks Reserve and Hackney Marshes. Providing such connectivity within fragmented urban landscapes is an essential way of helping mitigate the future effects of climate change.
Future management of the Meadows should take into account the cumulative impact of other developments within the Lee Valley Park that have seen a reduction in green space and important wildlife habitat.
Sites rich in biodiversity, such as the Meadows, should be prioritised for habitat management and enhancement rather than activities such as large mass-participation events that will damage habitats and associated biodiversity.
Introduce low-level cattle grazing to the Meadows to help diversify vegetation structure and provide niches for seed germination etc. Such management will be beneficial for a wide range of invertebrates that will have positive impacts higher up the food chain for a range of taxa including bats and birds.
Work with neighbouring landowners and businesses to mitigate the effects of light pollution on foraging and roosting bat species.
Undertake habitat improvements to maximise ecological niches for the widest possible range of species. Features such as log piles, excavation of small ponds and targeted scrub planting will provide enhancements for many of the species currently recorded as well as offer opportunities for colonisation from neighbouring areas and habitats.
Additional surveys should be undertaken to further improve knowledge of the biodiversity of the Meadows and inform ongoing management.
The Waterworks Centre could be utilised as a focal point for public engagement about the wildlife in the surrounding area. Its integrated use as a visitor centre, managed holistically alongside the Meadow and Reserve, could be most helpfully modelled on the successful Fishers Green Wildlife Discovery Centre.
No building on, or adjacent to, the Waterworks area.
Threats to the Marshes – building and inappropriate uses on open spaces
This is the second of our articles on the threats to the Marshes and other green open spaces. In our first article we dealt with the threats posed by the growing number of tower blocks lining the eastern side of the Marshes and the scale of developments at sites like New Spitalfields, Lea Bridge Station and Blackhorse Lane, their impact on the openness of these vital open spaces and the greatly increased population pressures they bring. Green open spaces have a crucial role to play in improving the physical and mental health of people, particularly those living in over-crowded and deprived areas like South Waltham Forest.
However, not only are there threats from developments on the edge of the Marshes; there are also ever-present threats from development on the open spaces themselves, including from schemes to build sports facilities and other developments like hotels, entertainment events, poor management of open spaces and the lack of awareness on the part of the public about the damage they can do with thoughtless fun.
Developments on open space
The Ice Centre
The LVRPA is building a greatly expanded double pad ice centre at Leyton Marsh, a wholly unsuitable site which has poor public transport connections and is situated on a narrow congested road. It should have been put at Eton Manor, as argued by Save Lea Marshes, where it would have been close to the extraordinarily well connected Stratford Station, now the busiest rail station in the UK and about to add yet another connection with the advent of Crossrail. However, the LVRPA has its greedy eyes on the open space at Eton Manor as a site for a (probably not) money-spinning hotel, so this is the reason why it has had to put the Ice Centre on Leyton Marsh instead.
Just as with the Olympics, when Waltham Forest gave permission for the damaging temporary Basketball Arena, which was barely used, Waltham Forest has viewed the Marsh with disdain. During the hearing into the Ice Centre application, the Chair of the Planning Committee declared Leyton Marsh to be a “desperate, scrubby, piece of Metropolitan Open Land”. Of course, it is the LVRPA which is responsible for the state of this MOL, so if she has such a low opinion of this piece of land it is the LVRPA she should hold responsible. Instead of insisting on proper care of the Marsh Waltham Forest uses the LVRPA’s mismanagement as a reason to agree to its plans.
The new Ice Centre has expanded onto and towers over the Marsh and has already involved the destruction of trees and habitat, particularly an area known to have provided a home for hedgehogs, a species increasingly under threat in the UK. The image below, taken from a video shot by contractors Buckingham Group https://www.youtube.com/watch?v=Yc9sgH0yms4, shows the area taken by the development.
Ian Phillips described these impacts in a video filmed after planning permission was granted https://www.youtube.com/watch?v=WM5_cyW5pb4. Unfortunately ecologists employed by bodies like the LVRPA are there to progress their employer’s plans and these ecologists were no different. The image below shows land at the rear of the old Ice Centre cleared for the development.
The image below, taken by Kimberley Rowley in mid January, shows how the Ice Centre dominates the Marsh.
The LVRPA made specious claims about Biodiversity Net Gain at the Ice Centre https://www.saveleamarshes.org.uk/2021/05/31/biodiversity-net-gain-at-the-ice-centre/, the latest officially sanctioned trick up the sleeves of developers whereby an area is run down so the developer can later claim an ecological improvement when they come to demolish an existing amenity.
The site lacks good public transport connections so despite claims it will reduce car usage it will actually encourage car use. The Ice Centre includes a 155 space car park. The idea is that the Centre will host national events. In fact, it is likely the Centre will fail in this objective as the LVRPA has already had to reduce the amount of seating to save money, which makes it less attractive for important events. For the same reason, it also had to abandon its plans to keep the Centre open while the new Centre is constructed, thus breaking promises made to skaters, who were encouraged to write in in support of the plans.
Whether or not it succeeds in its national ambitions, the Centre will be trying to attract users from wider afield and given the poor public transport links this will mean more people travelling from distance by car. Consequently there may well be overflow problems onto local streets, particularly at weekends when such events are likely to be held.
The Ice Centre will have long-term impacts on the Marshes and, most particularly, on the Oxbow Island, discussed below.
The Oxbow island
Another vulnerable site is the Oxbow island, next to the Ice Centre. The LVRPA has failed to approach the development of the Centre in a holistic way. The Ice Centre will include a cafe, which will also have an outdoor platform where people can consume food.
Save Lea Marshes participated in meetings at the time of the demolition of the Ice Centre and tried to discuss the future of the Ice Centre in the context of the Oxbow and the Marsh. The LVRPA refused to discuss the Oxbow in those meetings.
After considerable argument the LVRPA agreed to hold a separate meeting on the Oxbow but then spent most of that on presentations of what they were doing, which caused considerable frustration for those waiting to discuss the project. Their proposals included two bridges across to the island. The discussion became heated and a further on-site meeting was proposed. However, before that on-site meeting could happen the LVRPA announced it was going ahead with construction of a new land bridge and culvert, see image below. No further discussion or meetings would occur.
Save Lea Marshes had proposed that the island be restored as an island without any bridges so that it could be a unique environment and wildlife haven on this stretch of the River Lea. We do not think the LVRPA’s plans for access are compatible with the ‘island’ being a nesting site for swans and a site for an otter holt.
The Oxbow is a relatively short distance from the Ice Centre and its cafe. The Ice Centre cafe will not just serve skaters and visitors to the Centre but also members of the public using the Marshes. People driving to the Marsh will be able to park for free if they spend money in the cafe. It is not hard to envisage that people will see the Oxbow as a pleasant location to take food to and enjoy as a hangout with all the implications this has for disturbing and harming that environment and the wildlife.
The Oxbow channel will be receiving the melt water from the Ice Centre rinks. This is supposed to be filtered and cleaned in reed ponds in front of the Ice Centre before entering the river at the Oxbow channel. Plainly it is to be hoped this will work and not cause problems for that channel and the river. The creation of water features at the front entrance of the Ice Centre raises concerns that flooding may occur in the future.
To create a flow of water from the River Lea to ensure this melt water is carried away, the existing land bridge and collapsed culvert had to be dug out. Instead of leaving the restored channel open, thus recreating an island, the LVRPA and the Canal and River Trust simply went ahead with building a new bridge and culvert, thus failing to take the opportunity to create a unique environment and wildlife haven on this stretch of the Lea.
Lee Valley Riding Centre paddocks
A decade ago Waltham Forest Council Planning Committee acceded to the LVRPA’s planning application to allow it to create a set of livery stables for use by private owners of horses at the Lee Valley Riding Centre, another money-making venture. A large area of land had already been appropriated by the Riding Centre as paddocks at the back of the Centre, removing that land from use by the general public. The owners of horses using the livery stables have been given access to these paddocks, meaning public land is being used by private owners of horses, rather than for a public service as was previously the case.
It is worth noting that Waltham Forest Council and the LVRPA had prevented the Manor Gardens Allotments from returning to the Olympic Park at Eton Manor on the grounds that this would represent the private use of public land. So, while they disputed the right of the allotments to return to land which might be considered their home Waltham Forest and the LVRPA had no compunction about allowing the private use of public land at the Riding Centre.
Livery riders also get to use the public space of the Marshes to exercise their horses. They are supposed to keep to prescribed routes but the Riding Centre does not take responsibility for monitoring their activity and the routes are poorly marked, meaning they can come into conflict with other users.
Another small paddock was created at that time on the Waterworks meadow for a failed pony-trekking project. This area remains fenced off even though the pony-trekking project failed years ago.
It is virtually impossible for Riding Centre staff to oversee such a large area of paddocks. In recent times they have faced the problem of people feeding horses. It is indeed inappropriate for members of the public to feed the horses in any way, but the result has been that the Riding Centre has had to double up the fencing and the fear is further controls over public access to this area may be instituted.
This is a public space now being used inappropriately to serve a private purpose. The irony is that the location of the Riding Centre next to the Marshes provides an added attraction for people coming to the Marshes to look at the horses. The location of the paddocks is therefore bound to be problematic. In reality what needs to happen is for the Riding Centre to hand back this large area of paddocks and stop the provision of livery services.
Further threats to open spaces
Eton Manor, hotel and UCL/LVRPA masterplan
The LVRPA is persisting with its abominable plans to build a hotel on Metropolitan Open Land at Eton Manor. We also hear it has linked up with University College London (UCL) to develop a masterplan for the area. This ‘master’ planning explicitly includes the hotel project so it seems UCL is backing the LVRPA’s abominable project.
According to responses to Environmental Information Requests, UCL wants to build sports facilities for its students at Eton Manor. From UCL’s perspective its investment in the site will be to help the university “attract and retain students”. Once again the use of public land is being discussed in terms of its benefits for private users.
While the need to take account of the interests of a variety of stakeholders are mentioned, including the ‘commercial partner’ for the hotel project, no mention is made of any public use of the facilities.
So far neither of these august bodies has allowed the public any part in this exercise. UCL is a newcomer to the area and why it thinks it has some right to intervene on this site – originally the “Wilderness”, provided and dedicated by philanthropists to meeting the needs of local people – is anyone’s guess.
A hotel at Eton Manor is an absurdity and an offence. Eton Manor is Metropolitan Open Land and thus unsuitable for development in general. Special circumstances could be argued for it to be used for a sports centre such as the Ice Centre, after all Eton Manor already has sports centres on it. However, by no stretch of the imagination can a hotel be considered a special circumstance. To get around this the LVRPA is trying to persuade the London Legacy Development Corporation (LLDC) to change the designation of the land to ‘white land’, land on which development can occur. The LLDC is prone to making unprincipled decisions so this cannot be ruled out.
As mentioned above, the Manor Gardens allotments were supposed to move to Eton Manor after the Olympics, having been evicted from their site in the Olympic Park. First, the site was reduced to half the original size and a second site at Pudding Mill was designated for half of the Manor Gardens allotments. Then the LVRPA and Waltham Forest Council conspired to overturn the planning permission already granted by the LLDC for the remaining allotments site at Eton Manor. The LLDC went along with this underhand scheme http://www.gamesmonitor.org.uk/archive/node/2136.html.
This alleged guardian of the so-called Olympic Legacy is supposed to be ensuring that this legacy benefits the ‘existing population’ of East London. Yet, once again an elite institution is muscling in on public land, and private interests are taking precedence in development projects.
Eton Manor is in the Borough of Waltham Forest and Waltham Forest Council is preparing a Framework for the area. It is unclear what discussions the Council has had with the LVRPA, although the LVRPA claims its plans have been welcomed by the Council. Waltham Forest has said publicly it opposes development at Eton Manor, so who knows what is going on.
However, at the moment the planning authority is the LLDC. Given that the LLDC turned down a set of allotments at Eton Manor, a green development and open to local people to apply to use, it is hard to see how it can agree to a hotel, not green and very definitely private and with no discernible connection to the mandates governing the LVRPA. But then with public authorities of this kind it is sadly hard to know which way they will turn next. Enter University College London! Why and who next?
Hostel/Housing at The Waterworks Centre and car park
The LVRPA has long had its eye on part of the Waterworks as a site for housing development and still dreams of getting Waltham Forest to agree to change the site’s designation to allow for housing. Fortunately, Waltham Forest has resisted this. An earlier attempt to develop the northern part of the site, including part of the old golf course along with the Waterworks Centre and car park, was fought off by Save Lea Marshes, which raised a fighting fund to take the matter to court should the LVRPA persist in its plans. The LVRPA tried to combat hostility by restricting their plans to the Waterworks Centre and car park but this also failed.
However, the LVRPA is persistent. Instead of doing what it should and developing the Waterworks Centre as a genuine resource for the local community it has continued to run it down. A recent programme of ‘engagement’ by the LVRPA with Save Lea Marshes to discuss the future of the Centre went nowhere.
It seems obvious to us that the Centre and the Waterworks Meadow should be treated as a whole when planning for the future. In fact, we understood Shaun Dawson, CEO of the LVRPA, had agreed at a meeting of the Board that the Centre and the Waterworks Meadow would be treated as a whole when planning their future. Of course, when this was brought to his attention he denied ever making such a declaration.
As things stand the LVRPA now has longer-term plans to develop the Waterworks Centre as some kind of hostel. There has to be a concern that this will prove to be a wedge to move on to plans for a larger residential development. Of course, the LVRPA will deny it has any such designs. But then this is an organisation that wanted to turn Walthamstow Marshes into a quarry, mooted the idea of a hotel in front of the Ice Centre, definitely wants to build a hotel at Eton Manor and most certainly wanted to turn this site into a housing development.
The Waterworks Centre should be developed for use by the community, as argued by Save Lea Marshes and others in the area like the Markhouse Corner and Lea Bridge Road Residents Association, which successfully applied for it to become an Asset of Community Value. The Waltham Forest Civic Trust is now applying for the ACV status to be extended.
Waterworks Meadow
The Waterworks Meadow is seen by the LVRPA as another money-making asset rather than a valuable natural open space. It was originally a well used mini golf course, which meant it remained a green open space. However, at the time of the Olympics the LVRPA scented an opportunity to make money by hiring it out as a camp site. It persisted with this usage for a number of years before turning to another money-making scheme, music festivals.
More recently, it ran into massive public resistance https://www.saveleamarshes.org.uk/2020/05/18/application-for-the-waterworks-festival-refused/ when it tried to host a music festival in 2020 although this plan languished with Covid. Fortunately Waltham Forest Council Licensing Committee turned down that application. However, that the LVRPA wishes to continue with these events was made plain in its Landscape document which did not just refer to future events but to investment in infrastructure to enable it to host larger events there in the future.
The potential for harm from such events has recently been highlighted by the extraordinary damage done at another LVRPA music festival site at Three Mills Green in Newham last summer (see photo taken in mid January below) despite a warning from their own staff that such an event would do damage. The Green was fenced off so it was not available for the community to use from the end of July. It was then left in such poor condition that it was unable to recover and it will plainly continue to be so for months to come. The LVRPA remains silent on the damage it has done.
Although Waltham Forest refused permission for the event at the Waterworks it gave permission for a similar event by Secret Cinema at Low Hall Fields to take over most of that open space for most of the summer of 2021, a decision only overturned by the intervention of Sport England which objected to this use of sports fields. The former leader of WF Council, Councillor Coghill, who has since resigned as Leader and become Vice-Chair of a property company associated with the Lea Bridge Station development, failed to respond to residents’ concerns over that Secret Cinema event.
Following the defeat of the music festival application Save Lea Marshes raised £5,000 to carry out ecological surveys of the Meadow https://www.saveleamarshes.org.uk/2020/07/10/crowdfunder-launched-to-re-wild-the-waterworks-meadow/. These surveys demonstrated that a broad range of species utilise the meadow, including locally and nationally rare species, advancing the case that this land should be protected as a green space and be reserved for the recreation of local people. The Meadow is bordered by the Old River Lea and we consider at least part of it, most particularly the river bank, should be given the status of a Site of Importance for Nature Conservation (SINC), a designation which already applies to the Hackney side of the river.
In the past Hackney has allowed a large music event on Hackney Marshes, an event which also met with opposition from Sport England. Plainly it is necessary to remain vigilant about these threats as local Councils and the LVRPA cannot be relied on to protect their open spaces but see them as opportunities to make money.
The Old River Lea
The Old River Lea, as it runs past Hackney Marsh, is a Site of Importance for Nature Conservation (SINC), along with other areas along the River and the canal both north and south of the Marsh. Both sides of the River Lea, south of Friends Bridge at Hackney Marshes and the Waterworks Meadow, have now come to be treated as picnic and party venues. We have even had to contend with newspapers like the Guardian, which published misleading photographs by a local photographer who claimed to be an environmentalist, suggesting it is an idyllic wild swimming location https://www.saveleamarshes.org.uk/2021/04/09/the-guardians-response-to-our-letter-our-reply/. The Guardian even repeated the offence despite letters from Hackney Council and others warning against this activity.
Considerable damage has been done by people partying or paddling in the river, leaving large quantities of litter and lighting barbecues and playing loud music as in this video https://www.youtube.com/watch?v=E1ec46hO3Uc. This resulted in severe damage to the river bank, the cutting down of a tree after someone was injured using it as a swing, and harm to bird life to the extent of causing Little Owls to abandon their nests.
Hackney Council and the LVRPA have started taking steps to tackle the problem, although their effectiveness was not fully tested as the weather later in the summer was not as hot and the stresses of the pandemic were not so great as earlier in the year. However, banners put up by Hackney Council were torn down and thrown away and it is plain there are still plenty of people who continue to regard this area as a playground rather than an important natural habitat or SINC to be respected.
The river also suffers from severe industrial and sewage pollution which is an added and serious concern, ironically also for those who wish to use it to swim. Save Lea Marshes has taken part in discussions with Hackney Council and the LVRPA, and joined with other local campaigns like London Waterkeeper to get action on this serious harm to the river. We have also been carrying out our own testing of river water for phosphates which are an indicator for sewage pollution. The readings, which we regularly post on our Twitter account, have been extremely disturbing.
While it is urgent that this pollution should be stopped, the continuing failure of Thames Water, the Environment Agency and the UK government to get to grips with this problem means this is unlikely to be sorted out in the near future.
Instead of being able to rely on these public and private bodies, volunteers from other key campaigns like Plastic Free Hackney play a crucial role in cleaning up litter and waste matter from the river itself and the river bank as seen in the video below by Ian Phillips https://www.youtube.com/watch?v=oARMNJrwkJg.
Middlesex Filter Beds
Several years ago the generator powering the pump which fills the Middlesex Filter Beds with water was stolen. Since then the Filter Beds have been allowed to dry out, in contravention of the agreement the LVRPA has with Natural England for the maintenance of the Beds. The ecology of the Beds has been drastically altered and will take a considerable period of time to recover once water is finally pumped back into them. The LVRPA appears to be edging towards action but while it is able to find millions to finance pointless and harmful projects like the Ice Centre and a hotel it seems unable to rustle up the much smaller amount of money needed to carry out a task it has an agreement with a regulator to manage in keeping with its mandate to protect the Park.
Lack of consultation with the community
The Lea Valley Park exists for the benefit of the communities living nearby, and their needs and opinions should be at the heart of how it is managed. The one thing that has been highlighted by these cases is the lack of any ongoing consultation by the LVRPA with the community about the management of the Marshes. At one time there were regular forums with proper agendas, discussion and minutes. These were replaced by less formal ‘workshops’ and then by walkabouts with Rangers with no structure or follow up. When ‘consultation’ or engagement does occur, as with the Ice Centre and the Oxbow, it is highly managed and takes the form of presentations of what the LVRPA intends to do rather than discussion of what might be done. Save Lea Marshes complained some time ago to Green Flag about the lack of consultation. Green Flag wrote to the LVRPA to ask if they consulted the public and were told, yes they did. End of Green Flag’s ‘enquiry’.
The LVRPA faces little or no scrutiny by Local Authorities who treat it as a ‘partner’ organisation. Instead of fulfilling its role to protect and improve our vital Green Lung the LVRPA treats this part of the Park as a money-making asset with little or no regard to the needs or opinions of the communities that use it. We have written an open letter to Shaun Dawson, CEO of the LVRPA to highlight this failure https://www.saveleamarshes.org.uk/2022/02/16/an-open-letter-to-the-lvrpa/.
So far no response has been received to this letter.
We received the latest letter from the LVRPA informing us that work on the Oxbow island would proceed without further discussion bringing an end to our recent attempts to engage with the LVRPA and CART.
We would like to point out that there is now no ongoing engagement or consultation with the community of any kind. Some years ago there were regular forums, which at least allowed for some exchange of views. This was then cut back to ‘workshops’ which emphasised presentations by staff rather than consultation but at least included agendas and minutes. These were then replaced by informal walkabouts of a few individuals with rangers with no agendas or minutes and no structured discussion or means of following up issues .
The recent engagement on the Ice Centre was presented as a kind of favour to the community. However, the terms of engagement and the agendas were strictly limited by the LVRPA. SLM members attempted to hold more holistic discussions regarding the relationship between the Ice Centre and the surrounding Marshes, notably the Oxbow island. We were particularly concerned at the implications of including a cafe as part of the Centre and the possible impacts of this on the Oxbow island. This was firmly resisted by LVRPA staff. After vigorous discussion a concession was made to allow a separate discussion on the Oxbow.
However, when this happened it was set up as a series of presentations, not as a discussion about what could be done with the island. It was even claimed the meeting was never intended to be a discussion of the relationship between the Ice Centre and the island when in fact that was the precisely the reason it was called. Time was limited meaning a key presenter had to leave. This resulted in a degree of passion on the part of those participating in their attempts to be heard, which has in turn led to unfair criticism by the LVRPA of those attending.
A follow up meeting onsite was promised but then, following our further attempts to ensure this included discussion on the possibility of creating an island habitat at the Oxbow, this was called off by the LVRPA. The opportunity to create an island wildlife haven was provided by the need to dig out the channel to restore river flow to the Oxbow ‘lake’ to help carry away the melt water from the Ice Centre.
Save Lea Marshes attempted to engage in good faith to examine the possibilities and risks for the Oxbow island. We still consider this was a unique opportunity to separate the island from the Marsh and create a vital wildlife haven and are sad that this opportunity has been lost. We do not think the possible impacts of the Ice Centre cafe have been properly considered. We fear the island will become a hangout spot for those using the cafe.
This process has revealed the underlying lack of effective consultation with the community. Essentially there is now no consultation with the community and when some kind of discussion is launched it is carefully controlled and limited to agendas set by the LVRPA. The model for these meetings is one of presenting what will be done rather than consultation on what could or should be done.
Members of SLM have been raising similar concerns with you and your colleagues over the years. Will things ever change?
There are many emerging threats to the Marshes (and Wathamstow Wetlands) from planned large-scale developments at Lea Bridge, New Spitalfields and elsewhere in Waltham Forest.
Save Lea Marshes have now been campaigning for a decade to keep our vital green spaces wild, open and free for all. Come to our online event to find out how you can make your voice heard in the Local Plan consultation and join the discussion about what we can do to protect the Marshes from inappropriate development and ensure they are preserved to the benefit of local people and wildlife.
Here is a link to the presentation that we gave on 19th January 2022:
There are a number of ongoing threats to the Marshes and the wider Lea Valley environment, including the River Lea itself. Sadly, many of these threats come from the very public bodies which are entrusted with the protection of the Marshes: notably the Lea Valley Regional Park Authority (LVRPA), the body charged with protecting the Green Lung; Waltham Forest Council as the principal planning authority; and, in the case of the river, Thames Water, the Canal and River Trust and the Environment Agency.
The LVRPA in particular sees this southern section of the Lea Valley Park as an area from which to raise revenue. It has expanded the Ice Centre and the Riding Centre, created moorings on the River Lea, held music events, hosted camping sites and other ventures, planned to build houses and is planning to build hotels on its land; all to raise funds. Not only that but the LVRPA cannot be relied on to defend the Marshes from inappropriate developments on its fringe which will harm the open space.
Waltham Forest has, for the most part, backed the LVRPA’s projects, with the notable and admirable exception of the music festival at the Waterworks. In addition, it has pursued a policy of building tower blocks along the eastern side of the Marshes. In the first of three blogs we discuss the threats from tower blocks.
New Spitalfields
The largest and most significant threat to the Marshes is the proposal to develop the New Spitalfields site. As far as we know Waltham Forest is continuing with its plans to build a small town on the site of the present New Spitalfields Market. Its latest thinking appears on this website https://wfreg19south.commonplace.is/en-GB/proposals/sa02/step1.
As can be seen from the two stars, Waltham Forest still plans to build tower blocks on the site. It also still plans to build a new bridge across a very sensitive part of the Old River Lea, posing a real threat to the river bank and the Site of Importance for Nature Conservation on the Hackney side of the river. In addition, it plans to build a cycle track north of the site through an untouched piece of land despite earlier showing an interest in saving this for wildlife. Waltham Forest has paid almost no attention to anything said to it. Consultation seems to be a complete waste of time. In every respect this remains an extremely harmful development.
New Spitalfields is right next to East Marsh and across the River Lea from Hackney main Marsh. Waltham Forest has indicated in its original site allocation it intends to build blocks of 18-30 storeys and 10-13 storeys on the site, so given the close proximity of the Marshes it is inevitable they will tower over the adjacent open spaces. No amount of tree planting will make any difference.
While Waltham Forest acknowledges there are sensitivities around height in its latest site allocation https://wfreg19south.commonplace.is/en-GB/proposals/sa02/step1 – ‘05.5.4 Sensitivities: The following elements of the surrounding context would be sensitive to increased height: – the River Lea and adjacent green / amenity space, which may be vulnerable to overshadowing’ – it continues to press ahead with these tower blocks. However, regardless of this, it is claimed in the plans for Lea Bridge Station, as is discussed below, that tall buildings will actually enhance the visual aspect of the Marshes and provide beneficial views for those on the open spaces.
It is interesting to note that as usual Waltham Forest focused on creating ‘new high quality landmarks’ which would define Ruckholt Road as a ‘gateway’, gateways and landmarks being constantly repeated themes in Waltham Forest planning applications, which it thinks justifies building blocks near open spaces. Height at the eastern edge of the site will ‘complement development at Leyton Mills’. When this site was first presented for consultation Waltham Forest produced the following statement in the skyline document referred to above about the opportunities the site offered:
05.5.3 Further opportunities include: – defining Ruckholt Road as a gateway to the borough with new high quality landmarks, – improving accessibility to the area’s green amenity offer, – capitalising on views to Hackney Marshes and the Queen Elizabeth Park, – clustering height at the eastern edge of the site to complement development at Leyton Mills retail park – potential for investment in sustainable transport infrastructure
The creation of a major population centre will also greatly increase the pressure on the neighbouring open spaces. This is not considered in the plans as presented so far. Given the size of the town to be built and its immediate proximity to the Marshes it is inevitable East Marsh and the Old River Lea will become playgrounds for this new population. These are public spaces for the benefit of the wider community but being so close to New Spitalfields will mean the Marshes will be at risk of being overwhelmed by its new neighbour.
Waltham Forest’s attitude towards these neighbouring open spaces is exploitative. The project will provide benefits by ‘improving accessibility to the area’s green amenity “offer”, – “capitalising” on views to Hackney Marshes and the Queen Elizabeth Park’. However, it isn’t Waltham Forest but Hackney that will bear all the costs of this development and none of the benefits. Hackney Council seems not to have understood the scale of the problem as Waltham Forest is pushing ahead with its developer fest regardless of any concerns or objections.
This is an inappropriate site for housing development under any circumstances, as it is part of the Lea Valley floodplain and will be seriously affected by climate change in terms of both river flooding and rising sea levels. We have already raised our concerns in another pointless consultation with Waltham Forest, as set out in this blog https://www.saveleamarshes.org.uk/2021/07/27/do-we-really-need-a-new-village-on-a-flood-plain/. Plus ça change…
Temple Mills Bus Depot
The Temple Mills Bus Depot site is an adjunct to the New Spitalfields site, on the other side of Ruckholt Road. It is also part of the flood plain and as vulnerable to flooding as the New Spitalfields site.
Once again, from what is known so far, Waltham Forest is planning to build tower blocks on this site. This site did not feature in the South Waltham Forest allocations document so there is no skyline survey. It also doesn’t feature in the latest Common Place web page.
However, as far as we know the blocks are likely to be built on top of the bus depot, which will make it a very cramped site. It is expected to host a new station, which appears on the New Spitalfields Common Place page mentioned above. This will also serve New Spitalfields, so there will be considerable flows of people moving to or from this site across or under Ruckholt Road.
Tower blocks built on this site will further extend the line of blocks running down the east side of the Marshes and add to the impact of the New Spitalfields site on East Marsh. The Bus Depot site is next to the open space at Eton Manor, which is a fairly small space. Any blocks built there will severely affect that space which will also be overshadowed early in the day.
The extra new population at this second site, a village to be added next to the town at New Spitalfields, will further add to the massive pressures on the Marshes.
Lea Bridge Station
To the north of these two sites is the development planned at Lea Bridge Station. Of the projects which have reached the planning stage this is the closest to the Marshes and will have the tallest tower blocks. The highest block on this site is planned to be 26 storeys.
Instead of challenging this development as it should, even though it recognises it will have negative impacts on the Marshes, the LVRPA has chosen not to object but to accept a feeble Section 106 payment, as shown in an LVRPA document below – this is Lea Valley danegeld!
The height of the two towers on Sites 1 and 3 are of concern in terms of their intrusion upon the open landscape character of the Regional Park and the current visitor perception of openness and removal from the surrounding urban area. The proposal has undergone a lengthy design review process to arrive at its current configuration. Amendments to the scheme have been discussed with London Borough of Waltham Forest and it is the case that significant reductions to the height of the development are unlikely, as the number of stories has been determined by the level of affordable units required, together with the considerable costs of dealing with the site constraints and commercial viability. In addition, intensive development adjacent to train stations is accepted policy nationwide.
The development, given its size and location, will generate a regular and sustained increase in footfall to the Park. The potential impacts of this are not considered within the supporting planning documents, although the benefit of the proximity of these green spaces is recognised in terms of recreational facilities available to residents. Whilst the Authority welcomes visitors to its open spaces it needs to be able to manage access to, around and through sites to maintain, protect and enhance the open spaces and key biodiversity features for which they are valued. 5106 contributions are being sought to help reduce the impact on the Regional Park and a package of proposed mitigation measures is under discussion with officers at the London Borough of Waltham Forest; these will be presented at committee. They would be secured via Planning Obligations/S106 contributions as part of any permission, if the Council were minded to grant consent.
Tower blocks built on this site will further extend the line of blocks running down the east side of the Marshes. The image below, taken from the planning application, gives an idea of how the two blocks, one tastefully concealed behind a tree, will dwarf the existing Motion blocks.
The scale of the two towers is shown in this graphic taken from the planning application.
The second graphic, also taken from the Lea Bridge Station planning application, shows the two Lea Bridge Station blocks, as seen from Leyton Marsh, along with the cumulative effect achieved with the Motion blocks and the Gas Works development, which is also tastefully partly concealed by a bush.
Waltham Forest is brazen about its desire to build tall buildings. As elsewhere, the draft skyline document emphasised the creation of “landmark buildings that complement the taller heights already introduced nearby”. In other words, existing tall buildings need more tall buildings around them! The document goes on to say “The following elements of the surrounding context would be sensitive to increased height: – residential houses to the east of the site”, no mention of the Marshes to the west.
In the planning application the applicant was 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
Not only does the applicant not feel embarrassed about these developments close to the Marshes, it now brazenly makes the ridiculous claim that these developments will be beneficial and will actually improve the visual amenity the Marshes. Are we supposed to take this seriously?
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.
During the consultation Waltham Forest’s agents declared the Marshes were only ‘apparently natural’ as they were man-made! The reality is all landscapes in the UK are man-made, even the Highlands of Scotland. And being man-made doesn’t mean they shouldn’t be protected from development in their current form.
Applications of this kind, as at the Gas Works, have already been accepted by Waltham Forest and are plainly pitched to fit in with the Council’s approach. According to the Lea Bridge Station planning statement the site is not even indicated for tall buildings and won’t comply with policy on delivering social housing yet they feel able to put plans of this kind forward for approval.
This aggressive approach suggests they know perfectly well that the whole point of open space is the sense of openness experienced by those using the space and that putting tall buildings on the edge of open spaces defeats the whole purpose of having open spaces, which is to allow people a feeling of freedom from the restrictions of the city and give them a place where they can enjoy nature. The benefits of green spaces for mental and physical health are now well established. Pouring enormous amounts of concrete is both harmful to that enjoyment and harmful to the environment.
Should these developments happen, the Marshes will be ringed on their eastern side by a line of blocks with: the Motion development already built; the Gas Works sites in Lea Bridge and the Score Centre in Oliver Road already granted permission (https://www.london.gov.uk/what-we-do/planning/planning-applications-and-decisions/planning-application-search/score-centre); Lea Bridge Station awaiting discussion at planning committee; the Bywater site at the south end of Orient Way, Leyton, along with New Spitalfields and the Bus Depot, all at an early stage of planning; and completed developments further south in the Olympic Park and further north towards Tottenham. The developments already built at the Motion site and those further north and south are shown below.
The Motion blocks as seen from the back of the Riding StablesDevelopments to the north of the MarshesDevelopments to the south in the Olympic Park
This latest round of developments at Lea Bridge Station and New Spitalfields and the Temple Mills bus depot will be the most damaging of all and need to be strenuously opposed.
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.
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