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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The Motion Towers as viewed from Walthamstow Marshes
Please help us avoid the awful spectacle of yet more high-rise towers crowding the marshes and ruining the open landscape forever.
Ideally please object to the planning application for the Lea Bridge Station Development, which is out for public consultation, by the end of 27th September. Relevant objections should be considered after this time.
Proposed tall towers situated next to the current Motion Towers
You can use any of our objection to support your submission. Here are some bullet points you may wish to include:
The Lea Bridge Framework is still under consideration and no planning application for this area should be brought forward until it is complete, otherwise it is rendered useless. Similarly, the application cannot rely on the Emerging Site Allocation because it is part of the Draft Local Plan and is yet to be fully scrutinised.
The Planning Statement states that the development will provide publicly accessibly green space yet it will destroy existing green space at Orient Way Pocket Park, home to 125 semi-mature and early-mature trees. If Waltham Forest Council is serious about its commitment to the climate emergency, then it should be safeguarding mature trees because of the important role they play in mitigating the effects of climate change. New trees are not a substitute for mature trees and new green space is not a substitute for existing green space.
The fact that there is no social housing planned is unacceptable.
The proposed development will have a detrimental impact on air quality during construction and, when complete, by increasing the number of people living in the area with cars and removing the mitigating effect of the trees in the Orient Way Pocket Park.
The Planning Statement says that the site is not affected by tidal flooding. However, the site is situated on the flood plain of the Lee Valley, which will be increasingly subject to flooding. The Planning Statement acknowledges that parts of the site are indeed at risk of fluvial flooding. Our floodplain should not be developed; it should remain undeveloped and permeable.
Building 23-story and 26-story tower blocks in this location constitutes significant over-development, especially as the location is not identified as a location for tall building development in the adopted Development Plan.
Astonishingly, the Planning Statement claims that these tower blocks will have a ‘moderately beneficial impact’ on the Lee Valley Regional Park and other open spaces. This is clearly contrary to any reasonable understanding of openness.
Waltham Forest Council has declared a Climate Emergency and this over-development on a flood plain runs contrary to combating climate change locally.
Save Lea Marshes Full Objection
To: Planning Department, Waltham Forest Town Hall, Fellowship Square, 701 Forest Road, Walthamstow, London E17 4JF
Re:Planning Application 212685 – Lea Bridge Station Sites
We object to the Proposed Development for the following reasons:
1. Lea Bridge Framework
1.1 The Planning Statement refers to the Lea Bridge Regeneration Masterplan which states that the development:
2.27 Delivers a mix of uses which align with the GLA and LBWF objectives for the Lea Bridge Regeneration Masterplan;
1.2 However, it makes no mention of the Lea Bridge Framework which is still under consideration. How is it possible to proceed with a major development in an area as yet without a Framework? How can any Framework, which is still being considered, have any point when plans for such a key section of the neighbourhood are already decided? Plainly any Framework is rendered pointless by this application. This is the most important site in the area already decided.
1.3 The Planning Statement later refers to the Emerging Site Allocation
7.13 LBWF’s vision for the Site is sought to be enshrined within planning policy through the emerging site allocation proposed within the draft LBWF Local Plan Part 2 (ref. SA07).
1.4 However, this reveals that not only is there no Framework for the area but the Local Plan on which this planning application is based is a Draft Plan. So in fact there is a lack of concrete agreed planning guidance available.
2. Pocket Park green space and biodiversity net gain in the development
2.1 The Planning Statement refers erroneously to the Orient Way Pocket Park, a green space with 125 mature trees, being ‘developed’.
7.9 It is important to note that the three sites have been identified for development by LBWF through a longstanding regeneration programme of the Lea Bridge area. This is sought be formalised through the emerging site allocation in the draft Local Plan Part 2. Therefore, to deliver the aspirations of the site allocation and wider policy designations such as the opportunity area and housing zone, development of the pocket park at site 2 is required.
2.2 The Pocket Park is not being developed, it is being demolished.
2.3 The Planning Statement goes on to say the development will provide a publicly accessible green space:
2.27 Provides publicly accessible green space for the wider community toutilise
2.4 However, there is already a publicly accessible green space for the community which the project will demolish.
2.5 The Planning Statement recognises there will be a loss of open space but seeks to reduce the significance of this space by referring to it as ‘undesignated’ and ‘informal’ and by referring to the trees in dismissive terms. Whether or not it is designated or informal makes precisely no difference in terms of its ecological value.
3.13 Site 2 measures approximately 0.62 hectares and is currently used as an informal open space with footpaths with an area of adopted public highway and road on the northern edge. It features some semi-mature and early mature trees. It is important to note that Site 2 includes one TPO tree, a Sycamore, number T72.
7.10 The Proposed Development will bring significant planning benefits to Lea Bridge and the wider borough which outweigh the loss of this undesignated open space. Furthermore, the proposals include more usable public realm and landscaping improvements including a net gain of trees across the Site which results in a substantial biodiversity net gain.
2.6 Plainly, if left to grow the existing semi-mature and early mature trees will become mature trees a lot more quickly than any newly planted trees.
2.7 The applicant claims there will be substantial biodiversity net gain.
7.271 The Proposed Development seeks to retain three existing plane trees along Orient Way (numbers T26-T28). There are currently 125 existing trees with 122 to be removed. It is then proposed to replant 144 new trees. Therefore, there is a significant net gain of new trees as part of the proposed landscaping scheme.
2.8 The first thing to note about this alleged biodiversity net gain is it will depend on the trees actually surviving planting. The reality is many newly planted trees die a short time after being planted.
2.9 More than that, planting an extra few trees does not overcome the damage done by removing a large number of trees as the gain from retaining and allowing existing mature trees to continue to grow will last for years whereas the alleged gain from new planting will take years to be realised and may never occur; damage to small newly planted trees is a frequently reported occurrence.
2.10 Moreover, the nature of the green space will change. It will lack the same mass and density. The new trees will be separated and scattered which will also make them more vulnerable to damage.
2.11 If Waltham Forest is looking for significant biodiversity gain from this development the easiest way to achieve this would be to improve the planting and habitat in the existing Orient Way Pocket Park. It is precisely by failing to properly maintain or improve the existing green space that Waltham Forest is able to try to claim Biodiversity gain in the first place as this makes it possible to claim a replacement can better what is already there.
2.12 However, it is totally at odds with sense that a developer can claim biodiversity gain by demolishing an existing green space and replacing it with new trees which will take years, decades even, to grow when existing trees will continue to mature and the woodland of which they are part can be improved more easily and effectively by leaving that green space in place. The existing space’s capacity to provide biodiversity gain for the development as a whole is completely ignored.
2.13 It is worth noting that policy on Biodiversity includes making ‘improvements to existing natural environments’:
7.277 Emerging Local Plan Part 1 Policy 81 (Biodiversity and Geodiversity) states that: • All development should maximise opportunities to create new or make improvements to existing natural environments, nature conservation areas, habitats or biodiversity features and link into the wider green infrastructure network;
2.14 Maximising these opportunities will best be achieved by retaining and improving the existing Pocket Park green space and this is consistent with policy.
2.15 It is also the case that the benefits in terms of climate change, an emergency supposedly declared by Waltham Forest Council, of a denser area of woodland will greatly outweigh even a few extra scattered trees, assuming they survive, which will take years to grow, whereas an existing green space can be improved and further trees can be planted.
2.16 The demolition of this Pocket Park makes no sense in any of these respects.
3. Affordable Housing
3.1 The Planning Statement contains the following:
7.90 Policy H6 of the London Plan states that in order to satisfy the threshold approach to affordable housing on a habitable room basis 30% should comprise genuinely affordable homes, 30% intermediate homes and 40% to be agreed with the Borough.
7.91 At a local level, LBWF Development Management Policy DM3 (Affordable Housing Provision) stipulates a tenure split of 60% social/affordable rented units and 40% intermediate housing units.
7.93 The scheme does not meet the requirements of the adopted or emerging Local Plan as a tenure split of 50% shared ownership and 50% London affordable rent is proposed.
3.2 The development does not provide any genuinely affordable housing and will not assist those in housing need in Waltham Forest.
3.3 When trying to encourage people to agree to its constantly repeated ‘vibrant’ neighbourhood Waltham Forest tried to set the need for ‘affordable housing’ against people’s concerns over height, see screenshot below. Plainly if people ‘voted’ for lower towers, even if they had good reasons to be concerned, such as they considered they would have a negative effect on the neighbouring Marshes, they were put in the position of being against ‘affordable’ housing.
Section from the ‘consultation’
3.4 However, the reality is the development does not produce genuinely affordable housing so the consultation was misleading.
4. Air Quality
4.1 The development will have negative effects on the Marshes. One of these will be in terms of increased traffic and thus congestion and pollution on Lea Bridge Road.
7.249 of the Planning Statement references air quality but fails to record that the development at Lea Bridge Station is likely to draw more traffic on to Lea Bridge Road where it passes Leyton Marsh and the Ice Centre, further increasing congestion and air pollution on that section of Lea Bridge Road.
4.2 There is no discussion of how this development will combine with the development of a double size Lee Valley Ice Centre at Leyton Marsh. The development of a double size ice centre complex, which intends to bring skaters and visitors from across the nation and not just the region, will further add to the flow of traffic through the area, even if the Lea Valley Regional Park Authority says it wishes to reduce car usage. The reality is the poor public transport connections in the area and the fact that Ice Centre users do not use train services, as evidenced in the LVRPA’s own travel plan documents, will mean more people will travel by car to the Lea Bridge area from further afield.
5. Flood risk and Climate Change
5.1 The Planning Statement states: 7.293 A Flood Risk Assessment (FRA) prepared by Waterman accompanies this Application. The site is not affected by tidal flooding, but parts of the site are at risk of fluvial flooding.
5.2 This statement is incorrect. The River Lea Valley is in danger of tidal flooding depending on the management of the Thames given the likelihood of sea rise. Climate Central has produced a map showing that a part of this site would be in danger of tidal flooding in ten years time. This does not take into account a longer time scale, see here
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.
5.4 Note the statement that extensive development has reduced the level of protection. That extensive development continues and will be further exacerbated by these developments.
5.5 The Planning Statement adds: 7.294 Due to a range of constraints pumped outfalls would be required on all three sites. Runoff will be discharged to the Thames Water public sewer network. Attenuation will be provided in the form of below ground tanks and permeable paving.
5.6 So, in recognition that the sites are vulnerable extra measures are required on a site which will become more vulnerable as time passes.
5.7 The Climate Emergency, which doesn’t seem to be specifically mentioned in these documents, despite being declared by Waltham Forest Council, is beginning to kick in.
5.8 This is a floodplain, another term seemingly avoided in this section of the document. Flood plains will be of vital importance in alleviating the longer term effects of climate change.
5.9 7.302 of The Planning Statement – the APZ (on archaeology) defines an area associated with the River Lea valley and its tributaries and is an area characterised by alluvial deposits which have been shown to preserve important archaeological remains dating from the Prehistoric period and later.
5.10 How curious that floodplain turns up in the section on archaeology, where reference is made to alluvial deposits.
“Alluvium, material deposited by rivers. It is usually most extensively developed in the lower part of the course of a river, forming floodplains and deltas, but may be deposited at any point where the river overflows its banks or where the velocity of a river is checked—for example, where it runs into a lake” https://www.britannica.com/science/alluvium
5.11 Climate change is considered in the Environmental Statement Part 1. This document makes the extraordinary statement that future climate conditions will have no bearing on this development:
2.66 The likely projected future conditions for each of temperature, precipitation, wind speed and cloud cover have been considered. It is considered that the magnitude of impact and resultant nature and scale of the effects of the Proposed Development during the operational phase will not be changed under the future climate conditions.
2.67 Overall, the likely effects of the Proposed Development are unlikely to change as a result of climate change
5.12 Considering the likelihood of severe weather conditions occurring as the Climate Emergency gathers pace and the location of this development in the Lea Valley floodplain, which also faces the possibility of tidal flooding arising from rising seas, these assertions seem extraordinarily dismissive of possible risks.
6. Gateways and tall buildings and the Lea Valley
6.1 Curiously, the Planning Statement admits the location is not identified as a location for tall building development.
7.144 In summary, the Proposed Development is not identified as a location for tall building development within the adopted Development Plan.
6.2 Of course, this is then explained away. However, it remains the case that the existing guidance is that the site is not identified as a location for tall buildings. The further guidance in the remains in draft form.
6.3 The Introduction to the Design and Access Statement repeats the refrain so often found in Waltham Forest’s planning applications:
“Marking the Gateway to Waltham Forest with elegant new buildings which signpost the new Lea Bridge station“
6.4 Over and over terms like ‘Gateway’ and ‘landmark’ buildings appear in these documents as if tall buildings have some inherent value as territorial markers.
6.5 Waltham Forest uses a tree as its logo yet nowhere does one find any kind of reference to, recognition or appreciation of its green spaces, most particularly the Marshes, as a marker of the Borough’s boundaries, as a welcoming place to a Borough bearing the name of Forest.
6.6 Indeed later on Waltham Forest declares:
“the Lee Valley occupies a strategic position in the London-Stansted Cambridge-Peterborough growth corridor and provides a range of development opportunities for higher density development including growth at Lea Bridge and Lea Bridge Roundabout”.
One might be forgiven for forgetting there is a green lung somewhere in this ‘corridor’.
6.7 Likewise the statement of Site Opportunities endlessly repeats this refrain
3.49 The Proposed Development Site does however have a number of opportunities through redevelopment to establish the area as a new ‘place’ and destination:
• Gateway to Waltham Forest and the Lee Valley Regional Park. A visible and high-quality designed scheme can serve as an identifiable gateway to these areas and act as an attractor for further footfall and investment;
• Station identity on Site 1 – A tall building within Site 1, adjacent to the adjacent Lea Bridge Station entrance, can act as an identity for the new local centre, accentuating the station and its new public realm setting within the wider area;
• Views into the Lee Valley Regional Park – Taller buildings with residential uses located at this Proposed Development Site can take advantage of long vistas into Lee Valley Regional Park to the west.
6.8 Not only an identifiable gateway to Waltham Forest but also to the open spaces of the Lee Valley Park and of course, to the benefit of developers, vistas over those open spaces.
6.9 Once again Waltham Forest repeats its obsession with landmark buildings marking a gateway. Waltham Forest uses a logo of a tree to trademark itself yet at no point does the Borough take pride in its green spaces and take advantage of them as landmark features welcoming visitors to the Borough.
6.10 Everywhere the emphasis is on height. Yet this site is not identified as a location for tall buildings.
7. Description of the Marshes
7.1 The Planning Statement, while it makes mention of NPPF guidance, makes no mention of NPPF 133, which states:
“The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence”(our emphases).
7.2 The term Green Belt applies to the Marshes, as Metropolitan Open Land has the same legal status as Green Belt.
7.3 Indeed, from what I have read this guidance is never mentioned in this application.
7.4 Leyton Marsh, which is not named and was recently described by the Chair of the Planning Committee as a ‘pretty scrubby, desperate piece of Metropolitan Open Land, it’s not like it’s a beautiful green meadow’, Walthamstow Marshes, the Waterworks Nature Reserve, the Waterworks Meadow, also not mentioned, will all be affected by the two towers being built on Site One. Hackney Marshes will also be affected. The Committee chair is welcome to her opinion of Leyton Marsh, although it is not one shared by those who enjoy the Marshes.
7.5 However, it reveals much about how Waltham Forest Council views the Marshes.
7.6 During the ‘consultation’ the same approach was adopted in describing the Marshes as an “apparently natural landscape” and “largely man-made”, see screenshot below.
7.7 This statement only reveals the ignorance of those seeking to diminish the importance of the Marshes as both a natural environment and a vitally important place of recreation.
7.8 Every landscape in Britain, including the Highlands of Scotland, is ‘largely’ man-made. The Highlands were covered in forest until people cut them down. Much of the present wilderness is the result of the eviction of cultivators in favour of sheep farming, new forestry or grouse shooting.
8. Impacts on the Marshes
8.1 Extraordinarily, in the Planning Statement, it is claimed that these towers will have a moderately beneficial impact on the Lea Valley Park and other open spaces
7.132 The significant likely effects will be to the visual receptors in the following views:
8.2 Towers will increase the sense of being enclosed which runs directly counter to the idea of open space, making nonsense of these claims.
8.3 The discussion about sites refers to the value of landmark buildings in terms of impacts on neighbouring open spaces. It has to be pointed out no NPPF guidance is cited for this claim. The guidance is entirely the opposite, that such buildings will negatively impact on neighbouring open space.
9. Visual amenity
9.1 The Environmental Statement Vol 2 Part 1 considers the impact of the development on local open spaces. It notes that some developments are visible, so the argument seems to run that as some are already visible why not some more? In fact it fails to mention that there are considerably more towers available both in Lea Bridge with the Gas Works Development and further north, as in the photo below, as already made known to Waltham Forest in the previous Save Lea Marshes Gas Works objection.
I also attach the objection from Save Lea Marshes to the recent Gas Works development which includes photographs from a number of different locations showing how those earlier developments have already had an impact on the visual amenity of the area.
9.2 Now two more, even taller buildings will be added to the list.
9.3 The applicant describes how existing existing blocks are visible and form “part of the surrounding in which this area is experienced”.
6.22 The location and open nature of Walthamstow Marshes, Lee Valley Park and Hackney Marshes affords a number of views towards the Site, the wider Lea Bridge area and Stratford. In views towards the Site, the existing Motion Development (Beck Square) is visible and forms part of the surrounding in which this area is experienced. In longer views, tall and large buildings marking the location of Stratford are visible and are characterised feature in views further south.
9.4 So as existing blocks are part of the surrounding in which this area is experienced some more blocks are ok? The wedge has already been driven in. Now it can be pushed in a bit further.
9.5 View 11 below is from the edge of Leyton Marsh and Walthamstow Marsh in the Lea Valley Park.
9.6 The applicant is 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
9.7 The development would be “perceptible in the backdrop of the view” and “introduce several new blocks”. So there are already blocks there. A few more will be “perceptible” and “introduced”. The context is of “existing” tall and large developments.
9.8 There is already tall development. Once the wedge is in the door can be pushed open further;
9.9 The point is made explicit in the 10.172 ‘this will not change the character of the backdrop of the view’.
10.172 The Proposed Development will form a new feature for the visual receptors, although this will not change the character of the backdrop of the view, which already includes tall development. The proposals will be seen over some distance which will contribute to reduce visual impact of the Proposed Development.
9.10 An attempt is made to moderate the impact. Distance will reduce the visual impact.
9.11 However, a further statement shifts back to the idea that tall landmark buildings will, in fact, ‘improve the visual impact’.
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.
9.12 Then the cumulative view, see screenshot above, reveals another block, partly conveniently hidden by a bush, so now a line of blocks with the latest seriously altering the skyline. But no matter…
10.177 Where visible the cumulative development does not introduce a change to the visual receptors, nor does it change the magnitude of impact arising from the proposals. As a result, the likely effect would remain at Moderate Beneficial. These effects would be direct, long-term, permanent and is not significant.
9.13 So despite the arrival of new blocks there is apparently no change to the visual receptors on the Marshes nor any change to the magnitude of impact.
9.14 It has to be remembered that at one time there were no blocks here at all. The visual receptors are most definitely impacted and are steadily more impacted as new blocks are added.
9.15 All this is then repeated when referring to View 13 of the towers from Hackney Marshes, see screenshot below.
9.16 The blocks are now “an interesting feature” and have become “complementary”.
10.202 When viewed from this location, the form and massing of the blocks is simple and attractive, which creates an interesting feature on the skyline. The scale of the development varies across the Proposed Development Site with blocks varying in height between, 5, 11, 23 and 26 storeys. The height of the volumes is complementary to the adjacent Motion development, echoing the stepping effect of the existing building on the skyline. The slender volumes of Towers 1 and 2 rise to 23 and 26 storeys and mark the location of the development, Lea Bridge Road and the associated station.
9.17 Once again “perception”.
10.203 Over this distance, the observer will be able to readily perceive the architectural quality of the proposals. The façade of the blocks is primary formed of brickwork, whilst the crown of each building uses a mix of brick and concrete. The use of brick throughout the blocks ensures the development reads as one, although changes in their colour, band and detailing creates variation, further distinguishing the volumes from one another and reducing the overall perception of mass.
9.18 This is entirely fanciful. I very much doubt anyone will be able to make out the architectural quality, the brickwork, and changes in colour, banding and detailing of the towers from Hackney Marshes. They will simply be able to see a block of some kind rising above the tree line.
9.19 The argument then shifts to the idea that the blocks will only be “perceived” as part of an “existing backdrop” the impacts of which distance will reduce.
10.204 The significant separating distance between the marshes and the Site would further reduce the magnitude of the visual impact and the Proposed Development would be perceived as part of the existing backdrop. The magnitude of impact to receptors would be Low.
9.20 Then in the next breath the argument shifts back to the blocks being an “attractive” skyline feature and will “improve” the visual amenity.
10.205 The Proposed Development would form an attractive skyline feature and will improve the visual amenity of the view with high quality architecture. In our professional judgment, for the reasons above, the Proposed Development would give rise to a Minor Beneficial effect. These effects would be direct, long-term, permanent and not significant.
9.21 Interestingly the language used seeks to mirror the references in the NPPF guidance, which it has failed to quote. Words like ‘visual amenity’ and ‘permanent’, although not “openness” find their way into the text.
9.22 The applicant then turns to consider the problem of this being yet another block surrounding the open space of the Marshes. The solution is to return to the idea of landmark buildings. The buildings mark out Lea Bridge and Leyton when being viewed from Hackney Marshes. It is assumed this is a good and necessary thing.
10.206 In the cumulative context, the black wirelines demonstrate further tall and largedevelopment in the backdrop of the view, and marks the location or development at Lea Bridge and Leyton.
9.23 And of course, “in the cumulative context” being among “further tall and large development” makes these blocks of less significance as they are now just a couple among several.
9.24 The applicant then moves into technical speak…
10.207 From this location, the visible cumulative scheme at Lea Bridge Gas Works (application ref. 201329) would contribute to the increased height datum in the backdrop of view and reduce the prominence of the Proposed Development within the view.
9.25 The “visible cumulative scheme” at the Gas Works adds to the ‘increased height datum in the backdrop of view’. In other words because there are (will be) blocks at the Gas Works the new blocks at Lea Bridge Station are just part of a development process which is leading to ever higher buildings towering over the Marshes and because these other blocks have already increased this ‘height datum’ everything is ok as they won’t be as prominent as they would have been if the Gas Works blocks weren’t (they aren’t yet) there.
9.26 Except of course it is now possible to see yet more cumulative and clearly defined sets of blocks rising over the treeline, where originally there were none, plainly greatly adding to the sense of intrusion and reducing the visual amenity and sense of openness of the Marsh.
9.27 No doubt the next towers will achieve a further ‘increased height datum in the backdrop of view’ which will in turn ‘reduce the prominence’ of the next set of blocks to be added to the jumble of blocks around the Marshes.
9.28 It is interesting to note that the applicant is prepared to provide images of the view of the new development when they are contained within the “existing townscape” as below, although even then the image is obscured by a tree which could easily have been avoided, but not to transpose those images to show how they will appear on the Marshes.
9.29 To provide some idea of how these blocks will intrude on the Marshes I attach some images from an earlier objection by Save Lea Marshes to show how the Motion development appears from some viewpoints on the Marshes. These new towers will have a much greater impact than appears in the rather flimsy representations presented.
9.30 Existing view above of the Motion blocks from Leyton Marsh. The Station development will tower over the Motion development.
9.31 Existing view of the Motion blocks from Walthamstow Marsh
9.32 Existing view of the Motion blocks from the Waterworks Meadow, showing where the Gas Works blocks will be behind the FedEx warehouse. The Station blocks will tower over the Motion blocks
9.32 Above, the existing view of the Motion blocks from the Waterworks Nature Reserve.
9.33 Existing view of the Motion blocks from behind the Waterworks cafe
9.34 If these statements are taken to their absurd logical conclusion then the Lea Valley Park will be improved by more and more towers until it is surrounded by them, assuming of course these towers are of ‘high quality architecture’. How this fits with the NPPF guidance as quoted above is anyone’s guess:
Waltham Forest’s plans to build a small town within spitting distance of the Marshesis 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.
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: https://geosmartinfo.co.uk/wp-content/uploads/2020/03/BEB15-Waltham-Forest-Level-2-SFRA.pdf :
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.
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: https://theboar.org/2021/02/why-is-londons-population-in-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: sarah.custance@walthamforest.gov.uk
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We have joined up with the wonderful Plastic Free Hackney to clean-up the increasingly popular Waterworks Meadow on Sunday 27th June from 10am.
Plastic Free Hackney is a not-for-profit campaign group committed to creating a cleaner and greener environment for everyone, and we’ve been really impressed with their clean -ups of the River Lee Navigation and Hackney Marshes.
If we would like to join us in a joint Pollution Pick of the Waterworks area, you will need to sign up in advance here
Pollution at the Waterworks Meadow
We will meet between 10am and 12 noon at the Princess of Wales E5 9RB for staggered starts to keep everyone safe.
Plastic-Free Hackney’s Pollution Picks are designed to be Covid Safe – with groups limited to 6 people, physical distancing and staggered time starts.
Please come dressed in robust outdoor clothes with appropriate footwear (no open toed shoes). If it is hot (chance would be a fine thing), bring some water, sunscreen and a sunhat. We also request that all volunteers wear face coverings.
Public loos are not readily available. We advise that you ‘go’ before you arrive 😉
If you’d like to pick for the full 2 hours, make sure you book a ticket for the 10am slot!
You can do so directly with this QR code:
We hope to see you on Sunday!
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Last autumn the Lee Valley Regional Park Authority submitted a planning application to the London Borough of Waltham Forest to double the size of the Ice Centre on the Lea Bridge Road. This site is Metropolitan Open Land (MOL), so the Authority needed to have very compelling arguments amounting to ‘Very Special Circumstances’ to support the application. Foremost among these arguments was the claim that the development would produce a large “biodiversity net gain” (BNG).
Paragraph 170 of the National Planning Policy Framework (NPPF, 2019) states that
Planning policies and decisions should contribute to and enhance the natural and local environment by … providing net gains for biodiversity.
This is interpreted to mean that any development should aim to produce a Biodiversity Net Gain of at least 10%. To enable developers to estimate net gain, the Department of Agriculture Food and Rural Affairs (DEFRA) has provided a calculation tool. It is actually an Excel workbook, and may be downloaded from Natural England’s website at http://nepubprod.appspot.com/publication/5850908674228224 .
The Lee Valley Regional Park Authority used the calculation tool to demonstrate a Biodiversity Net Gain of 30%. This is 3 times more than the minimum expected. Such an impressive result must have had an important influence on the Planning Committee’s decision to grant permission for the development. Were they misled by the data?
In order to assess this let’s look at how the calculation tool works. In general terms, it is very straightforward:
Calculate the “baseline” biodiversity score – that is the site’s current biodiversity value, before the development has taken place.
Divide up the site into parcels of different habitat types (e.g. woodland, tarmac, buildings, short grass, rough grass, open water, etc.), and input their characteristics into the tool. The tool assigns a biodiversity “rating” to each type, in biodiversity units per hectare. (How it does that is quite technical, and we needn’t go into it here.)
Measure the area of each parcel, and input the areas into the tool. The tool multiplies the area and the biodiversity rating of each parcel to get its biodiversity score.
The baseline biodiversity score is the sum of the scores of all of the parcels.
Do exactly the same thing for the “post-development” biodiversity score. In other words, divide up the site into parcels according to the habitat types that the site is expected to consist of after the development has taken place, and input their characteristics and areas into the tool. The tool calculates the score of each parcel, and the sum of these scores is the post-development score.
The Biodiversity Net Gain (BNG) is simply the difference between the baseline (pre-development) and post-development scores.
The results that the LVRPA obtained for the ice centre development are:
An important feature of the development is that the built-up area will increase from 0.39 to 0.7029 ha. Buildings have a biodiversity rating of zero. So how is it possible to achieve such a large BNG, when so much habitat is being lost? The answer lies in the areas coloured yellow in this map.
The habitat type of the yellow areas is “Urban – amenity grassland”. It has a very low biodiversity rating, just 2 habitat units per hectare. The yellow area at the north-east end of the building will disappear under the new building, but the much larger area at the front of the site (0.769 ha) will be enhanced to become “Grassland – other neutral grassland” and “Heathland and shrub – mixed scrub”. These have much higher biodiversity ratings, of 7.86 and 9.79 habitat units per hectare respectively.
So in effect the LVRPA is proposing to achieve a gain in biodiversity by making changes to parts of the site that are actually irrelevant to the development. The urban amenity grassland has such a low biodiversity value because it has been kept short by regular mowing. Why is this happening? We have repeatedly requested that the mowing regime should be relaxed to benefit biodiversity. Surely the LVRPA should be in the business of promoting biodiversity, not impeding it. Previously it has claimed that it was essential that the area be managed as closely mown ‘amenity grassland’, but without explaining why.
Here are a couple of views of the mown grass in question.
At the side of the current Lee Valley Ice Centre, mown late May 2021In front of the Lee Valley Ice Centre, mown last week of May 2021
If the LVRPA were genuinely interested in promoting biodiversity, it would have enhanced the urban amenity grassland many years ago. And it is possible to use the calculation tool to work out what the consequence of doing so would be. If all of the “Urban – amenity grassland” were enhanced to the same combination of “Grassland – other neutral grassland” and “Heathland and shrub – mixed scrub”, but without any of the rest of the development, this would result in a score of 23.22, and hence a BNG of 7.64 (= 23.22 – 15.58) or 49.07% (= 7.64 ÷ 15.58). This is much better than the 30.92% that will be achieved by the development. Indeed the consequence of imposing the development on the site after this enhancement to the grassland would be a reduction in the biodiversity score to 20.39 – in other words a biodiversity loss of 2.83 (= 23.22 – 20.39) or 12.17% (= 2.83 ÷ 23.22).
Here is a view of the same area, unmown.
So there is a simple lesson to be drawn from this exercise. If you want to get planning permission for a development that will cause a loss of biodiversity:
degrade the surroundings of the site as much as possible beforehand, so as to minimize its biodiversity;
include in your plans for the development details of how you will restore the biodiversity of the surroundings once planning permission has been granted.
If net gain were made mandatory, there could be a stronger incentive for some developers and landowners to degrade their land in advance of seeking permission to develop it. There are reported cases of suspected pre-consent habitat degradation under the current planning system, although it is not known whether this is a regular occurrence. These include cases of vegetation clearance and the disturbance of protected species. Landowners may be incentivised to degrade their land to reduce environmental obligations long in advance of its sale for development. In a mandatory net gain policy this risk could be mitigated by […] clear guidance for developers and planning authorities on the relevant assessment baseline including how to take account of recent or even historic habitat states where there is evidence of deliberate habitat degradation.
If grassland is frequently mown this is surely a clear example of “vegetation clearance” leading to “deliberate habitat degradation”.
It is the Local Authority, Waltham Forest Council, who made the decision to grant permission for the new ice centre. The poor state of the development site was referred to by the Chair of the Planning Committee, Jenny Grey, who stated: “It’s a pretty scrubby, desperate bit of Metropolitan Open Land, it’s not like it’s a beautiful green meadow.” It is a pity she did not ask herself why the applicant had allowed the site to become ‘desperate’ in the first place, or whether the same applicant could be trusted with making substantial improvements to the area that should have been carried out many years ago without the addition of a large new building.
Are there any other areas of the Marshes where the land appears to be unnecessarily degraded? If there are, perhaps they are also in the LVRPA’s sights for possible future development.
We’re continuing our virtual version of Beating the Bounds on Leyton Marshes, compiled for those that couldn’t take part in person on Rogation Sunday.
Map of Beating of the Bounds route 2021
From Stop 7, we’ve followed the route around the outskirts of the former Pitch & Putt course – the Waterworks Meadow, crossed the Orient Way footbridge and walked down Orient Way to Stop 8. Here’s the clue:
“Allotments once at Manor Gardens stood, But then in twenty-twelve Olympics came. They shoved them here, so now this neighbourhood Has less green space: disgraceful, evil, shame!“
The language here is strong – but if you learn about the history here, you may feel the same way:
🥀 Manor Garden Allotments
Manor Garden Allotments were established in 1924 by Major Arthur Villiers, philanthropist and director of Barings Bank, to provide small parcels of land for local people in that deprived area to grow vegetables. In keeping with conditions of Villiers’ bequeathal that the allotments be maintained in perpetuity, the 80 individual plots were tended for over a century by a tight-knit community. Many members belonged to long-standing East End families, with some individuals present since the 1920s.
Allotment plot 4 by Martin Slavin
The allotment gardens occupied 4.5 acres between the River Lea and the Channelsea River in Hackney Wick until they were demolished to make way for the Olympic site in the autumn of 2007.
Manor Garden Allotments being demolished, 2007
The London Development Agency (LDA) were committed, both by planning condition and commitments made during the Compulsory Purchase Order process, to provide an alternative site to relocate the plot-holders to before development work commenced and the plots demolished.
The LDA claimed Marsh Lane Fields was the only possible location, but organising the construction was chaotic and delayed. Waltham Forest Council then refused planning permission, leaving no time to revise the plans and reapply and if successful, construct the replacement allotments prior to the scheduled start of the Olympic construction work. They then sought to renege on their obligations and and evict the plot-holders with no guarantee of when or if the replacement site would be available.
The Manor Garden Allotments had to apply to the High Court for Judicial Review with the help of the Environmental Law Foundation. Only in the face of this did the LDA agree to arrange for the remaining plot-holders to continue to have access by special minibus to their allotments, now marooned within the secured Olympic construction site, until the Marsh Lane site was completed.
Len & Mary Loft survey their allotment, destroyed for a footpath through the Olympic site
After having much of their equipment trashed by LDA contractors or stolen, the allotments were finally relocated here to Marsh Lane Fields, now renamed Leyton Jubilee Park, after an appeal against the original refusal of planning permission was successful. The site was waterlogged and badly prepared.
Waterlogged new site at Marsh Lane Fields
The planning permission was granted by Waltham Forest Council on the strict condition that this was to be a temporary relocation and the allotments were to return to the Olympic Park. Not all the allotments mind you. The LDA refused to treat the allotments as a society, which it was, only agreeing to the return of those individual allotment holders who had moved from the original site.
Demonstration against the closure of Manor Garden Allotments
This first plan was then revised so that the allotments would be divided between two sites, one next to the Eton Manor Sports Complex, land also originally bought by Villiers and other philanthropists for the Eton Manor Sports Club, the other on the south of the Olympic Park at Pudding Mill, south of the mainline from Liverpool Street next to the City Mill River.
Pudding Mill Lane allotments
However, Waltham Forest and the Lea Valley Regional Park Authority (LVRPA) then objected to this plan to return the allotments to Eton Manor even though the London Legacy Development Corporation (LLDC) should have been bound by a planning decision to do this. Waltham Forest and the LVRPA concocted an agreement to overturn that decision with the connivance of the LLDC. Waltham Forest Council granted permission for a permanent site at Jubilee Park while the LLDC changed the use of the site at Eton Manor to make it into a general amenity and recreation space, which has remained unused ever since.
Closed forever: Manor Garden Allotments, gifted in perpetuity to people of the East End
The LVRPA had only received the allotments land as part of a gift from the Villiers Trust on condition they hosted the allotments. The allotments were effectively evicted twice and the LVRPA took control of land it had no right to without the presence of allotments.
LLDC document outlining the objections to the re-location of the allotments
The New Lammas Lands Defence Committee had campaigned fiercely to retain the open space at Marsh Lane and only accepted the allotments on the basis that they would be temporary but, as many predicted, once established the allotments were never removed after the Olympics.
Not only was open space lost but promised environmental measures to screen the allotments have never been carried out. Jubilee Park will also now suffer far worse visual impacts from towers being built on the site of the former Gas Works and in the vicinity.
Lea Bridge Gas Works and other industry in the 1952
You can read more about the very sorry tale of the destruction of the Manor Garden Allotments on Games Monitor
We’re continuing our virtual version of Beating the Bounds on Leyton Marshes, compiled for those that couldn’t take part in person on Rogation Sunday.
We’ve now reached 🦉Stop 7! Thank you for ‘travelling’ this far with us.
Map of Beating the Bounds route 2021
After following the path around the outskirts of the Waterworks, you find yourself at Stop 7, here is the clue:
“This was a place where wildlife lived in peace, But now it features litter, noise and grime. The birds and vegetation all decrease When crowds arrive. This is a wildlife crime.“
🦉 The Old River Lea, by the Waterworks Meadow
The name of the River Lea was first recorded in the 9th century, although is believed to be much older. Spellings from the Anglo-Saxon period include Ligean in 880 and Lygan in 895, and in the early medieval period it is usually Luye or Leye. It seems to be derived from a Celtic root meaning ‘bright or light’ which is also the derivation of a name for a deity, so the meaning may be ‘bright river’ or ‘river dedicated to the god Lugus’. A simpler derivation may correlate with the modern Welsh “Li” pronounced “Lea” which means a flow or a current.
Before the 10th century, the estuary of the river came as far as Hackney Wick, crossed at Old Ford. Marsh Road, the continuation of Homerton High Street, led to the marshes, and thence to Temple Mills.
The Romans appear to have built a significant stone causeway across the marshes here; a periodical, the Ambulator of 1774, noted:
“there have been discovered within the last few years the remains of a great causeway of stone, which, by the Roman coins found there, would appear to have been one of the famous highways made by the Romans“
The river forms a natural boundary, so in AD 527 it formed the boundary between the Saxon kingdoms of Essex and Middlesex. In around AD 880 a treaty was drawn up dividing Anglo-Saxon Wessex from Danelaw (the part of Anglo-Saxon England colonized by invading Danish armies) along the same river boundary. On the Wessex side, people spoke a different language, obeyed different laws and worshipped different gods to those under Danelaw, on what is now Hackney Marshes!
Around AD 894 the Danes tried to invade further into Anglo-Saxon territory, sailing Viking longships up the river Hertford, and in about 895 they built a fortified camp, in the higher reaches of the Lea, about 20 miles (32.2 km) north of London, at Ware, where the Lee Valley Regional Park now comes to an end. King Alfred the Great diverted the River Lea into a newly cut channel. This lowered the depth of the river, leaving the Vikings stranded. They were forced to abandon their ships and flee on horseback.
Painting of a Viking longship by Daniel R Blunt
In the Middle Ages attempts were also made to control the flow of water through the marshes.
Painting of a Medieval Watermill
Mills were established including the Knights Templar Mill at Temple Mills. Much of the marsh was owned by the Templars and used for pasture. The Domesday Book (1086) shows that during the Middle Ages there were at least eight water mills in the local area, producing flour for City bakers. A number of the mills were actually tidal as the tidal estuary stretched as far north as Hackney Wick.
Around 1770, the river was straightened by the construction of the Hackney Cut, now forming the western extent of the marsh. The natural watercourse passes to the east over the Middlesex Filter Beds Weir, just below Lea Bridge Road. The Waterworks Nature Reserve occupies the former Middlesex Filter Beds on the island between the two watercourses.
In January 1809 the lower River Lea burst its banks in several places following a deluge that dumped two inches of rain in the space of 24 hours. The rain abruptly ended a snowy cold spell that had begun over a month before in the middle of December. “It is likely that up to half a metre of snow had fallen in the previous weeks in the upper parts of the surrounding countryside with only slight thawing. With the frozen ground unable to absorb any of the rapidly melting snow and rainfall the amount of water flowing downstream must have been immense.” Read more from an eye witness account from factory owner Luke Howard ‘When the River Lea was a mile wide‘ here.
At the end of the 19th century Hackney was beset by increased demand for building land, both for housing and to extend the factories in Homerton. The marshes continued to suffer periodic flooding from the Lea but with the introduction of mains sewerage, a flood relief sewer was constructed beneath the marshes. Most common and Lammas lands were then preserved by an Act of Parliament and passed to the control of the Metropolitan Board of Works, but the marsh remained excluded from the MBW scheme because many of the Lammas rights were still exercised, predominantly grazing. This was a period of increasing arguments between landowners eager to build, and groups seeking to preserve the open spaces for recreation.
In 1890, 337 acres of the marshes were preserved by the London County Council, by a purchase of the rights and landowners’ interests for £75,000. The marshes were opened to the public in 1893 and were formally dedicated in 1894. The LCC undertook further flood prevention, straightening some of the bends in the River by introducing four ‘cuts’, the old channels being retained to form islands.
Despite this, encouraged by the fashion for open water swimming, glamourised national media coverage and lack of information about the scale of the pollution, hundreds of people frequented the river banks in 2020.
The impact from vastly increased human disturbance led to kingfishers deserting their nest and a pair of little owls tragically abandoning their babies. As a result of local intervention, action by Hackney Council and improved education, we hope for a more positive outcome in 2021.
Little Owl on the Waterworks Meadow
Main source: Wikipedia. All other sources linked for reference and further exploration.
