The group alleges it was “denied access to LVRPA’s ecological data”, which the authority contests, and that “much of the data that does exist is outdated or limited in scope”.
A park authority spokesperson said they hoped to work with the group on surveys, as “it would be a waste for them to spend money doing something [the authority] have already done”.
Both the statements by the LVRPA were untrue. A member of Save Lea Marshes made an Environmental Information Request on 23rd March 2020 asking for all surveys on the Waterworks Meadow and Nature Reserve and had not received a reply to this request by the time this article was written in the second week of July. It was not an allegation but a fact.
In addition, the claim by the LVRPA that it would be a waste of money doing something [the Authority] had already done was also untrue. The LVRPA had only done one survey, a botanical survey, on the Waterworks Meadow. Given that this was the case, SLM’s statement that much of the data that does exist is out of date or limited in scope was true and also not an allegation.
Plainly a journalist cannot be blamed for false statements by an authority. However, good journalism requires a degree of scepticism when it comes to official pronouncements and a willingness to check stories with those affected. Ms Munro failed to contact us before publishing her story.
A predictable result of us being accused of wasting money was that our crowdfunder would suffer a slowdown in donations, which did indeed happen.
We pointed this out, first to Ms Munro on twitter and then to the editors, Ann Yip and Robert Collins, in an online comment followed up by an email, asking that they print a correction. Ms Munro refused to take responsibility and accused us of harassing her. The editors noted that the LVRPA had acknowledged the error regarding the surveys but failed to take any action to put matters right. We followed up this failure to respond with a suggestion they might like to do a feature on our present projects which often involve collaborations with other reputable organisations to undo the harm. The editors failed to respond.
We think local journalism matters. Of course the East London Guardian is a part of a large media corporation, NewsQuest Media Group https://www.newsquest.co.uk/news-brands, so maybe local journalism is a misnomer in this case. However, any journalism which treats authorities as unimpeachable sources, which fails to communicate with people affected by stories and is careless with a ‘scoop’ which is likely to cause damage, offers little to the communities it claims to serve.
Hundreds of people took the trouble to write in with objections to the use of the Waterworks Meadow for a music festival. The Licensing Officer said he had never seen the like of it. Ms Munro also managed to misreport details of that story, wrongly attributing a quote from us to a third party and failed to contact us at all for the article. The project to prevent further attempts to use the Meadow for events of this kind also matters to large numbers of local people with 106 donations to date. Failure to correct inaccurate reporting is a slap in the face to those committing themselves to campaigns like these.
We are grateful to those who have continued to donate despite the inaccurate information circulated by the East London Guardian. Fortunately, campaign groups no longer have to rely so much on local newspapers to publicise their activities. You can find accurate information about our campaigns and the organisations we work with, as well as the professional surveyors we have recruited on this website or by following us on Twitter and Facebook.
We hope you will share our crowdfunder Re-wild the Waterworks Meadow! organized by Caroline Day and support our work in organising these surveys and our plans to rewild the Waterworks Meadow as part of our invaluable green lung, the Lea Valley Park.
This week’s featured objection to the Lee Valley Ice Centre being situated at Leyton Marsh is focused upon the superior benefits of enhancing rather than reducing green space at this location. It is written by Caroline.
Area of Leyton Marsh that will be lost to planned new facility
To: dmconsultations@walthamforest.gov.uk
I wish to object to the planning application 194162 to build ‘Two x 30m x 60m Olympic-sized ice pads with 500 seating capacity and additional 300 spectator standing, cafe space, 100 station fitness centre, ice garage and plant room’ on Lea Bridge Road.
My objection centres on the fact that the proposal constitutes inappropriate development on Metropolitan Open Land (MOL) and the applicant has not made out the case for ‘very special circumstances’ that outweighs the harm to MOL.
The LVRPA have not made the argument that there are ‘very special circumstances’ regarding location, transport, physical characteristics or policy that merit the development planned.
The applicant has stated that the Lea Bridge Road site benefits from its ‘strategic appeal & profile/ visual prominence on Lea Bridge Road’. If the Ice Centre were re-located then Leyton Marsh and Walthamstow Marshes would be more visually prominent which would both welcome people onto the marshes, increase connectivity of the marshes east and west of Lea Bridge Road and be more aesthetically pleasing. A re-location of the ice centre to another site such as Eton Manor would provide the opportunity for the footprint of the current LVIC to be re-wilded. This would be a greater strategic asset for the Lee Valley Park, re-linking the marshes together creating a continuity of landscape, to the benefit of people and wildlife. The benefits of viewing green space and trees has been shown to assist health and well-being, the same case has not been made for viewing large building structures. One of the primary features of the Regional Park must be to protect and enhance open parkland and one of the key reasons Metropolitan Open Land has such a designation is the recognised feature of ‘openness’. This development will degrade rather than enhance such openness.
The LVRPA argue that its choice of Ice Centre location ‘benefits from proximity to existing and planned communities’ however these existing and planned communities can benefit most from opening up the landscape and providing greater accessibility and visibility for the free activity of walking for leisure to more people in the community. Walking in green space is a leisure activity that reaps significant benefits and Leyton Marsh is a popular location for the community to walk for leisure. This is particularly important to residents in the immediate community, such as those adjacent to the site at Essex Wharf and those living in the new high-rise buildings on Lea Bridge Road, who do not have gardens. Research by the charity Mind finds that ‘71 per cent report depression decrease after green walk, 22 per cent report depression increase after urban walk’ https://www.mind.org.uk/news-campaigns/news/go-green-to-beat-the-blues/ therefore it is important that in areas of high population density, green open space is available for such an activity. The development of a large and prominent structure will urbanise and thus degrade the available green open space for the community and for the purpose of walking for leisure.
During times when we are experiencing increasing rates of mental illness as a society, enhancing the provision, visibility and accessibility of green space available for walking for leisure outweighs the LVRPA’s argument for paid leisure activities; research shows that it is the former which is patently more beneficial for both mental and physical health of a greater number of the population than elite sporting venues for athletes and spectators.
Consideration should be made of the research findings comparing the outcomes of indoor leisure activity in a building with outdoor activity; these findings clearly indicate the benefits of green exercise outweigh those of indoor leisure activity in terms of improving mental health. Mind’s research study (referenced above) details the views of people who regularly partook in green activities run by Mind’s network of local Mind associations: ‘90 per cent said it was the combination of nature and exercise that had the greatest effect on them’ and ‘94 per cent said that green activities had benefited their mental health, lifting depression.’
The ninety percent figure is very revealing, it’s not just the activity of exercise but exercise in a natural environment that is so beneficial to people’s health and well-being. The LVRPA have not proven that the provision of enhanced elite facilities for ice-skating, other pay-to-use leisure activities such as a gym and associated infrastructure such as the 200+ space car park constitute the ‘very special circumstances’ which outweigh the necessity to provide enhanced opportunities for walking in green space for residents in nearby and increasingly high-density residential communities.
Mind’s report ‘Ecotherapy: the green agenda for mental health’ presents the findings of the first ever study looking at how green exercise specifically affects people with mental health problems. A walk in a country park was compared with a walk in an indoor shopping centre. The results are startling:
71 per cent reported decreased levels of depression after the green walk
22 per cent felt their depression increased after walking through an indoor shopping centre and only 45 per cent experienced a decrease in depression
71 per cent said they felt less tense after the green walk
50 per cent said their feelings of tension had increased after the shopping centre walk
90 per cent had increased self-esteem after the country walk
44 per cent said their self-esteem decreased after window shopping in the shopping centre.
Whilst the applicant is not seeking permission to construct an indoor shopping centre, it is nonetheless seeking to replace green space on Metropolitan Open Land with indoor leisure activities for customers only. This will provide a lesser benefit to a smaller number of people than if it sought to extend the opportunities for ‘eco-therapy’ to the larger regional population who enjoy the marshes as part of a Regional Park. A forward-looking Authority would both assess and explore the potential for eco-therapy on Leyton and Walthamstow Marshes: Mind is unequivocal about the potential benefits of rolling out eco-therapy in appropriate places, “Hundreds of people have benefited from the green projects run by our local Mind associations but if prescribing ecotherapy was part of mainstream practice it could potentially help the millions of people across the country who are affected by mental distress.”
Parks and green spaces are a key component of social infrastructure; ‘the physical places and organisations that shape the way people interact’ (Klinenberg, 2018, p.5). A recent evidence review commissioned by National Lottery Heritage Fund and the National Lottery Community Fund, conducted by Sheffield Hallam University and The University of Sheffield includes a peer review of 385 studies. It highlights the social benefits of parks and green spaces (predominantly in the UK, Europe, the US and Australia) and underlines the potential of parks to deliver ‘multiple health benefits for the local communities and support long term mental and physical health’ (Dobson et al, 2019). Facilitated visits to green spaces improved the self-esteem, mental well-being and social lives of people with disabilities (Jakubec et al., 2016). Improving accessibility to Leyton Marsh from Lea Bridge Road could more positively impact those with disabilities than providing an accessible leisure venue.
Crucially, parks and green spaces enable people to connect with nature, which in turn benefits wellbeing. Recent surveys reflect the earlier findings of the Mind reports; a ‘sense of connectedness to nature is linked with greater psychological well-being’ (Cervinka et al., 2011; Howell et al., 2011)
Studies show that children and young people appreciate being asked to have their say on park design and use (Derr and Tarantini, 2016; Malone, 2012; Gallerani et al., 2017). There is no evidence that the LVRPA conducted a wide consultation with the community about the role and design of Porter’s Field Meadow (Leyton Marsh); its consultation was skewed towards those who use the present site for paid-for leisure activity, i.e. ice-skating.
Multiple reviews suggest that physical health, wellbeing and life satisfaction are enhanced through access to and use of parks and green spaces. Studies on obesity levels among children showed ‘levels are lower when there is more nearby green space to their residence’ (Dadvand et al., 2014). Proximity to green spaces is associated with reduced anxiety and mood disorder (Nutsford, Pearson and Kingham, 2013).
The Heritage & Society report of 2019 also finds that the main source of pride for adults is ‘countryside and scenery’ at 53% (more than any other category). This finding reflects the importance of conserving and preserving open landscape and scenery; properly assessing the impact of natural heritage on residents and the wider community in order to best locate leisure venues within the Regional Park.
The applicants have over-estimated the role and impact of paid-for indoor leisure activity and underestimated the value of natural heritage in their assessment of the LVIC site and have therefore not proven very special circumstances in terms of location.
Leyton and Walthamstow Marshes provide a place where thousands of people find peace, solace and well-being, even helping individuals to overcome addiction. This is referenced in this recent and extremely popular article in The Guardian which goes into detail about the therapeutic effect of Nature, specifically including Walthamstow Marshes SSSI (adjacent to Porter’s Field Meadow/ Leyton Marsh, the proposed development site): https://www.theguardian.com/lifeandstyle/2020/feb/25/ecological-grief-i-mourn-the-loss-of-nature-it-saved-me-from-addiction
“So I started walking, wandering daily on Walthamstow Marshes in north-east London to watch the kestrels, caterpillars and the shaggy old heron. It made me feel safe and secure. Gradually, I realised that my mind needed these walks and I grew to rely on them. The natural world had become a kind of rehab: it soothed my rawness and patched me back together.” The author Lucy Jones goes on to state, “I hadn’t realised that the essence of nature – the geometry, the scents, the sounds, the colours, the textures, the chemical makeup – could have such a life-changing power but, quite quickly, this became apparent.” Whilst the benefits of being in open green space are by nature difficult to capture, the report findings combine with individual testimony to create a compelling case that ‘very special circumstances’ exist for preserving rather than developing MOL for very large leisure facilities at this location.
Instead of a large-scale building project, the LVRPA should be increasing climate resilience with natural infrastructure such as SINCS, re-wilded areas, flood plains and extended buffers for special protection sites such as Walthamstow Marshes SSSI.
The vital role of green space for walking within Nature demonstrates that there is not a ‘very special circumstance’ for reducing green space for a built structure, quite the opposite, and this is also re-enforced by policy guidance. The site of the proposed ice centre is MOL and it is settled law that MOL has the same protections in law as Green Belt. Section 143 of The National Planning Policy Framework (2019) states that ‘inappropriate development is, by definition, harmful to Green Belt and should not be approved except in very special circumstances.’ Local authorities are directed, at Section 145 of the NPPF, to regard the construction of new buildings as inappropriate in Green Belt except in a number of exceptional circumstances.
The proposed development does not meet the requirements of any one of the exceptions and is, therefore, inappropriate development on Green Belt. In order to persuade the planning authority to grant planning permission, the applicant must, therefore, prove that ‘very special circumstances’ exist. It does not do so and the proposed development is consequently contrary to the NPPF, as well as Policy 7.17 of the London Plan, Policies G2, G3 and G4 of the Draft London Plan, Policy CS5 of the Waltham Forest Local Plan and Policy 84 of the Draft Waltham Forest Local Plan.
Transport
The applicant states that the ‘desired footprint can be comfortably provided on the existing site, has room for 200 parking spaces (plus potential ability to also use the immediate surrounding area for parking if necessary)’. Firstly, the footprint can only be ‘comfortably provided’ by extending further onto protected land. Secondly, encouraging cars on to the edge of Leyton Marsh has an effect of urbanising this green space further, especially as the applicant is referencing its future ability to extend car-parking on site. It runs counter to current policy focused on increasing sustainable transport and reducing carbon emissions, as well as running counter to the measures aimed at reducing air pollution. For this reason, many developments, even though not being constructed on MOL, are designed to be car-free or at the very least to minimise car-parking spaces, in order to actively encourage sustainable transport modes by visitors.
The choice of the Lea Bridge Road site may offer a large enough desired area for an expandable car park of 200+ spaces on MOL, however it is not best situated as regards cars accessing the site. The Lea Bridge Road is a single lane carriageway which is currently heavily congested at peak times.
Air pollution
Air pollution levels will increase as a result of the new development being designed to attract a large number of visitors using cars. The document 6D2 acknowledges that ‘the scheme exceeds the transport emissions benchmark.’
There are significant limitations to the off-setting proposed to counteract the effect of transport emissions from the proposed development. Some of those suggested are clearly beyond the remit and ability of the LVRPA, including: Support and promotion of car clubs; contributions to low emission vehicle refuelling infrastructure; provision of incentives for the uptake of low emission vehicles; financial support to low emission public transport options; and improvements to cycling and walking infrastructures.
The document advises that the applicants ‘implement a Travel Plan that supports and encourages sustainable staff travel (public transport, cycling, walking, and car-sharing)’. However, providing a very large car park of 200 spaces, with the provision of more if necessary, encourages unsustainable car use by visitors, rather than sustainable transport modes.
LBWF has declared an AQMA for nitrogen dioxide and PM10 that encompasses the whole Borough. The Council has developed an Air Quality Action Plan for 2018 – 2023 (LBWF, 2018). This sets out to “manage the impact of future growth of the borough, support healthier lifestyles for residents, reduce the impact of traffic on air quality and congestion as well as reducing our own impact on air quality.” By increasing traffic use, particularly car use, on the already congested Lea Bridge Road, the application is incompatible with this policy.
Improvement of cycling and walking infrastructure has taken place with the Mini-Holland scheme, with a new pedestrian path and cycleway being installed outside the current LVIC. However, the encouraging of vehicular traffic across these paths is antithetical to the goals of the scheme, which is to provide a safer and healthier route for cyclists and pedestrians.
There are significant limitations to the data presented for PM10 and PM 2.5 concentrations; pollutants that are acknowledged as hazardous to human health and therefore a precautionary approach should apply. Document 6D2 states, ’There are no nearby PM10 or PM2.5 monitors. It has therefore not been possible to verify the model for PM10 or PM2.5.’ Another limitation of the Air Quality assessment is that ‘there is currently no straightforward way to take account of the effects of the 2017 Plan or 2018 Supplement in the modelling undertaken for this assessment; however, consideration has been given to whether there is currently, or is likely to be in the future, a limit value exceedance in the vicinity of the proposed development.’ As has been stated, this scheme ‘exceeds’ such a benchmark for transport.
The assessment of sustainable transport for alternative sites under consideration was also completed before a main bus route serving the current LVIC, the 48, was withdrawn. The withdrawal of the 48 bus route limits more sustainable transport options for both visitors and staff at the Lea Bridge Road site.
The application should be refused on the basis that it does not comply with the relevant policies.
This is the third is our series of objections to the LVRPA’s plans for a new ice centre on the Lea Bridge Road. It has been written by Julian.
Part 1
10/03/2020
dmconsultations@walthamforest.gov.uk
Dear Sir/Madam
I wish to object to this planning application Lea Valley Ice Centre, Lea Bridge Road, Leyton, London, E10 7QL. Application ID: 194162.
I consider the present site is unsuitable for the expanded Ice Centre.
I have to note the cynicism of the Lea Valley Regional Park Authority (LVRPA) in submitting two applications, presented by professional staff paid out of public funds, for the Waterworks music event at the same time as this one, thereby creating difficulties for those members of the community taking time out from their everyday lives to object. Any authority worth its salt should aim to facilitate consultation and participation in decisions of this kind. The LVRPA fails, yet again, to measure up.
The LVRPA owns an alternative site at Eton Manor. It is fully aware of the existence of that site and has attempted to argue that it is less suitable than the site at Leyton Marsh. I do not see how such an argument can be sustained.
Both sites are Metropolitan Open Land (MOL). In principle this means that neither site should be developed unless there are Very Special Circumstances.
The LVRPA has failed to show any Very Special Circumstances for the Leyton Marsh site.
Interestingly the LVRPA is trying to develop the Eton Marsh site, despite it being MOL, as a hotel.
If it is the case that the Eton Manor site can be considered suitable for a hotel, despite it being MOL, then plainly it must be suitable for a sports centre.
Given that the site is next to an existing sports centre, the Hockey and Tennis Centre, also owned by the LVRPA, this should make this site an instant shoe-in if the LVRPA is serious about its claim to be serving the public by providing facilities. In no way does building a hotel fit with that mandate.
I consider the arguments for the suitability of the Eton Manor site to be overwhelming and that the relocation of the Ice Centre to that site will produce important benefits for Leyton Marsh and the surrounding area, benefits which will also be spread to other parts of the boroughs of Waltham Forest and Hackney.
Waltham Forest Council has itself, on occasion, commented on the undesirability of the present Ice Centre. Both Waltham Forest Council’s ‘Green Belt and Metropolitan Open Land Review’ and the ‘Waltham Forest Focussed Green Belt and Metropolitan Open Land Assessment’ have considered the present Ice Centre to be an inappropriate development and that it would not have been granted permission if brought forward for permission now.
Waltham Forest Council’s ‘Green Belt and Metropolitan Open Land Review’ even says, see para. 5.16, ‘it supports such relocation as this would provide an opportunity to rationalise the land uses in MOL3 and enhance the sense of openness, particularly views north-south along the Lea Valley’.
The most important reason for finding Eton Manor a more suitable site for the Ice Centre is the radically different transport opportunities available at that site by comparison with the present location. There is simply no comparison in this respect between the two sites.
Improved transport connections would be a massive benefit to the Ice Centre itself as they mean it can attract a much larger user group from a much wider catchment area.
To understand these greatly improved transport connections available at Eton Manor that site has to be understood in terms of its connection to the Stratford Regional Station and the two bus stations in Stratford Town Centre and at Stratford City.
Stratford is one of the best connected train stations in London and actually in Britain, listed 7th in the UK see link below. Stratford links the Overground, the Central Line, the District and the Hammersmith and City Lines (one stop away at Mile End), the Jubilee Line, the DLR from Canary Wharf and beyond, the mainline up into Hertfordshire and out to Essex and into Liverpool Street https://en.wikipedia.org/wiki/List_of_busiest_railway_stations_in_Great_Britain. The figures are collected by the Office of Rail and Road. In addition, the International Station also runs out into Kent and through the Tube network Stratford is linked to all London’s mainline stations.
Stratford Station and the two bus stations are linked to Eton Manor by the 308 bus. Almost anyone wanting to get to Eton Manor can do so easily by getting to Stratford by train or tube and taking the 308. If there was a need for a further transport connection, which there should not be, the LVRPA could run a mini bus service from Stratford to its Eton Manor facilities and to the Velopark just as Here East does.
The 308 runs from Wanstead to Clapton, see 308 bus route, and also connects with the Stratford International train station.
In addition, Eton Manor is also served by the W15 bus route which in turn is only a short walk to connect with the Central Line at Leyton, see the map in this link Leyton High Road / Leyton Station.
Bus Routes 158, 58 and 69 all connect with the W15 where they intersect near Leyton Tube station, connecting areas in Waltham Forest up to Chingford and east out to East Ham and south to Plaistow and other parts of Newham.
If it is situated at Eton Manor the Ice Centre remains a local facility easily accessible to local users. If anything it becomes easier for people in East London to access as Stratford and its wider bus network makes it easier for people to get to Eton Manor than to Leyton Marsh.
The present Ice Centre is served by two minor railway stations, which cannot in any way compare to either Stratford station or Leyton Tube station, and the buses connecting those stations to Lea Bridge Road. The numbers travelling using those stations are minuscule by comparison with those using Stratford station. Leyton Tube station is also an important stop on the Central Line.
In addition, the Lea Bridge line goes to Stratford and the 308 bus goes to Clapton so both of those starting points for the Leyton Marsh site are covered by connections to Stratford and, in the case of the 308, directly to Eton Manor.
These connections mean public transport becomes a much easier and more sensible way to get to the Ice Centre if it is located at Eton Manor thus reducing car use and the associated problems of congestion and pollution.
So not only does Eton Manor favour the use of public transport, which is a benefit in itself, but the LVRPA is likely to get far more users attending at Eton Manor as public transport connections via Stratford open the centre up to a much larger catchment both inside and outside London.
Regarding access by car Eton Manor is of course also much closer to the M/11/12/A12 link meaning that distance traffic will be much less disruptive to the local area as it can move easily in and out of the area without impacting on local roads, also meaning pollution and congestion will be eased.
The plans for the Ice Centre on its present site are simply unsustainable. The current use of the Ice Centre stands at 279,000 a year. Of these only a third are Waltham Forest and Hackney residents. The intention is to double capacity. Given that this will mean a lot more people coming from outside the area it is imperative to provide much better public transport connections.
It is simply impossible to achieve these at the present location given the extremely limited bus and train services available. The result has to be greatly increased car use with much worse congestion and pollution in Lea Bridge Road and neighbouring streets and areas.
Eton Manor, on the other hand, can provide these public transport improvements.
For both Waltham Forest and Hackney, moving the Ice Centre has benefits for traffic on Lea Bridge Road in terms of the reduction in traffic congestion and pollution on that road and removing traffic, and thus congestion and pollution, from other connected Waltham Forest and Hackney streets. The reduced traffic will also improve the flow of public transport in Lea Bridge Road and connected streets.
The relocation of the Ice Centre will also provide more open space for people to enjoy at Leyton Marsh with its associated benefits for the health and well being of people in the area.
The benefits of enjoying nature for people’s physical and mental health are well documented. Walking is the easiest and most popular form of exercise. Opening up this space will help develop and protect the Lea Valley Park in this area of London as the Green Lung it is supposed to be.
Other sports centres in the Olympic Park like the Tennis and Hockey Centre and the Velopark facilities already belong to the LVRPA so having the Ice Centre there will allow for synergies making it possible for the LVRPA to efficiently plan better access for all its centres and create link ups between programmes for the different centres in order to increase usage, all things the LVRPA should be seeking to do now with its existing sports centres in the Olympic Park.
Taking the planning restrictions on development on MOL into account and the immense benefits to the Ice Centre in moving it to Eton Manor in terms of access and the synergies such a move creates there is really no comparison between these two sites. Eton Manor outclasses Leyton Marsh in every respect.
Taking into account the benefits of removing the Ice Centre from Leyton Marsh in terms of the reduction in pollution and congestion in Lea Bridge Road and neighbouring streets, the provision of more open space and the associated benefits to the health and well being to local people, and the protection of the Marshes as north-east London’s green lung Eton Marsh has to be considered by far the more desirable location for this facility.
Planning permission for this application should be refused.
Yours faithfully
Julian Cheyne
Part 2
Dear Sir/Madam
Planning application Lea Valley Ice Centre, Lea Bridge Road, Leyton, London, E10 7QL. Application ID: 194162
I wish to add to my objection regarding the application by the Lea Valley Ice Centre, as in my previous email.
Car park
First, I consider the applicant is being misleading in their description of the car park they intend to create. They refer to 155 spaces for cars. However, their description of the size or capacity of the car park is actually 200 parking spaces with capacity for more, an extra capacity which is not defined but it seems could be considerably greater.
4.5 of the planning statement refers to “The desired footprint can be comfortably provided on the existing site, has room for 200 parking spaces (plus potential ability to also use the immediate surrounding area for parking if necessary)” https://planning.walthamforest.gov.uk/civica/Resource/Civica/Handler.ashx/Doc/pagestream?cd=inline&pdf=true&docno=9414897. This doesn’t provide an actual figure for how many cars could be parked there but it seems it could be considerably more than 200 and far more than 155.
Amendment
Please note the document https://planning.walthamforest.gov.uk/civica/Resource/Civica/Handler.ashx/Doc/pagestream?cd=inline&pdf=true&docno=9414897 includes a diagram at 3.11 which shows the car park has 220 spaces. So this is actually the starting point. The area in which the car park can expand is in addition to that area as the space made available for parking in this diagram is set out in the diagram. It is not declared to an ‘immediate surrounding area’. So the applicants have actually produced three numbers for the size of the car park. How can any of this be relied on?
As things stand they say the Ice Centre is operating at 100% capacity. Regarding parking it has a total of 307 spaces. “To the west of the building is a car park formed of hardstanding which provides for 177 spaces. The area immediately to the front of the ice centre is currently used as an overflow car park and provides an additional 130 parking spaces. In total, the ice centre is served by 307 car parking spaces.”
It is unclear whether operating at 100% capacity means the car park is also 100% full. However, the Ice Centre is claiming it will be able to reduce car usage by just under 50%, based on these two figures of a reduction from 307 to 155 spaces.
However, in reality it has a much greater capacity, a capacity which is not actually made plain.
It has to be asked whether they will be able to meet their target reduction to reduce parking to 155 spaces or whether they will be obliged to use the extra capacity.
In fact it has be asked whether they will be able to achieve any reduction at all.
Increase in activities and visitors
Second, it seems the Ice Centre expects an increase in numbers using the facility. I have not found an analysis of expected future usage. It may be there. There are a lot of documents to get through.
However, taking it that the Centre says is already operating at 100% capacity and is therefore apparently bursting at the seams the whole plan is presented on the basis that a larger facility is needed to cope with this level of demand. Therefore it is based on the premise that the Centre needs to be larger to accommodate more users.
The Centre refers to the growth of populations in the Boroughs and areas from which it draws users. In the Planning Statement https://planning.walthamforest.gov.uk/civica/Resource/Civica/Handler.ashx/Doc/pagestream?cd=inline&pdf=true&docno=9414890 it states “10.27 To put this ‘need’ further into context, since the current ice centre was consented in 1984, London’s population has increased by 1.5 million (22%) and the boroughs of Waltham Forest and Hackney have seen a population increase of 27%. In this time, the ice centre has accumulated a large interest group and is a well-known establishment for providing ice related activities and opportunities.” Again the point is there is a growing population to cater for and the Ice Centre is a well known facility in the region likely to attract visitors from this growing population.
Paras 6.11 to 6.13 make similar points about rising numbers of visitors to the LVRPA’s facilities and rising populations in relevant Boroughs.
Para 10.5 makes similar points about the need for an “expansion of services and ice activities” all of which implies an increase in the numbers of visitors; “The operational capacity of the existing ice centre is a key driver of the need to replace the current facility, as in order to provide an expansion to the services and ice activities currently provided, additional ice space would be required which can only be delivered by the provision of an additional ice pad.” Another ice pad will not just help to meet existing demand but will allow for an expansion of services meaning it will draw in new users, new visitors.
Para 10.55 of the Planning Statement provides further detail on how the second pad will provide further opportunities to enable more members to join hockey and skating clubs and to expand their activities, such as hockey practice: “Having a second pad will allow the hockey and skating clubs additional hours across the two pads. This will create capacity that will enable those on club waiting lists the opportunity to join. The indicative timetable at Appendix 8 demonstrates how, across the two pads, the number of days able to offer hockey practice, particularly junior hockey, will increase. There is also an enhanced ‘Learn to Skate’ programme and more patch ice time.”
Para 10.57 refers to the opportunities to accommodate new ice sports: “Providing a second ice pad will also allow for opportunities to accommodate other ice sports such as speed skating, sledge hockey and recreational curling. British Ice Skating (BIS) and the English Ice Hockey Association (EIHA) have confirmed that there is significant latent demand for these uses, with potential for a new twin pad to meet a wider strategic need beyond London.”
This section refers to meeting a wider strategic need “beyond London”. Plainly this implies further visitors travelling from greater distances, almost certainly by car. Accommodating new sports suggests a major expansion in usage.
Para 10.58 reinforces the point referring to a “strong potential to grow” youth hockey and the Centre having a “strong hockey development market”. “The EIHA is the governing body responsible for the administration of all ice hockey in England and Wales. It is responsible for senior divisions below Elite League level, British Universities Ice Hockey Association, women’s ice hockey, recreational ice hockey and junior ice hockey. The EIHA have confirmed that the proposed replacement ice centre would have a strong hockey development market. It also suggested that it has strong potential to grow youth hockey system, currently limited by a lack of ice time.”
Para 10.59 goes even further declaring a second pad “would deliver on a national requirement”. “Being able to accommodate additional ice sports would fulfil the Park Authority’s remit by increasing the regional profile, but this cannot be achieved without the addition of a second ice pad. Furthermore, by creating a second fully accessible Olympic twin pad in the UK would deliver on a national requirement.” It seems the Ice Centre envisages its expanded facility attracting users from across the nation.
More visitors, reduced parking – how does this add up?
Third, taking all these statements into account the Ice Centre is expecting an expansion in users, it could be said a considerable expansion given not just the expansion in local populations but taking into account its ambitions to reach out to new sports and that these sports would not just be in its traditional catchment areas but “beyond London” and even “across the nation”.
It has to be asked how the Leyton Marsh location can meet the travel needs of an expanding number of visitors or how the Ice Centre will be able to reduce the number of car parking spaces when it expects more people to visit and with new visitors to be coming from further afield, almost certainly by car.
It seems optimistic, to say the least, for the Ice Centre to accommodate a greater number of visitors on its existing car park, let alone on a smaller car park.
It has to be expected that Centre will have to make use of the real capacity of the car park at over 200 and will almost certainly have to expand onto the extra space referred to to cope with the demand.
The figure of 155 car parking spaces is simply unreliable on the basis of the plans put forward by the applicant.
Travel Plan
Fourth, it has to be asked whether the Ice Centre has any realistic plans to meet the challenge set out above.
increase the proportion of trips made to/from the Development by walking, cycling and public transport;
reduce the total proportion of trips made to/from the Development by private car, which would also include a shift from single occupancy car use towards multiple occupancy car use;
So essentially the Ice Centre’s plan is an education programme to encourage users to change their ways of getting to the Ice Centre.
The first point that has to be made is they produce no evidence to show how effective such an education programme is likely to be.
Most education programmes of this kind are run by public authorities or those with the power to influence behaviour in a number of ways, by increasing the availability of public transport, levying fines, increasing prices, running events to introduce people to cycling and such like. The Ice Centre has only one of these at its disposal, increasing prices for parking at its car park. It will produce leaflets and talk to users in the hope of persuading them to change their mode of transport but this is likely to be a pretty hit and miss project. No doubt some will want to make the effort to share their car but whether this can happen will depend on a variety of circumstances about when they travel, how easy it is to arrange, etc. It is hard to see that much reliance can be placed on such a programme to achieve more than limited results.
Public transport. The Ice Centre has no control over the availability of public transport. If it does not meet users needs then no amount of urging its use will help.
Buses. The first thing to note is that the options for public transport have decreased with the closure of the 48 bus route. Buses are used by a considerable number of users, but the loss of one service will reduce the numbers able to travel by this means.
Trains. The second point is to note the findings of the traffic surveys that virtually no-one has been using trains to get to the Ice Centre and predictions from their surveys are that this is not going to change. If trains do not reach the areas from which people are travelling then no amount of urging people to use them is going to help. It seems trains are not a viable option for nearly all users.
Given that public transport options have worsened the Centre will have to persuade more to walk, cycle or car share.
Walking and cycling are only an option for those living relatively closely to the Centre. It is likely the Centre will be able to persuade a few more people to take up cycling as it is an increasingly popular means of getting about. But there are limits on how far people can cycle and a fair number will already be doing this so it is unlikely that there will be a great expansion of numbers.
The Centre emphasises it will be increasing the number of cycle parking spots. While this may encourage some who have been worried about securing their bikes the reality is people are used to securing their bikes to any number of different kinds of railings and other street furniture. It is unclear that this in itself will lead to a great expansion in the number of cyclists.
Walking is even more dependent on closeness. It is likely, simply to save money, that most of those who can get to the Centre by walking are already doing so.
Car use. The Centre is anticipating an increase in the number of users, both in line with the rising populations of the different boroughs and because it plans to expand the number of events. This expansion is expected to include areas outside London and even nationally. It seems likely that most of this expansion will be in areas further away from the Centre as it is well known locally and has probably reached most of those likely to attend in that area. Given that these extra users are likely to be travelling from a greater distance and given that trains do not seem to meet the needs of those travelling to the Centre it can be expected that most, if not all, of these new users will be coming by car.
The Centre could impose severe price rises on parking to discourage car use. There is no indication they intend to do this. Plainly if they did and users did not have other options to get to the Centre then this would simply put people off coming, the exactly opposite of what they are trying to achieve.
One irony is that the LVRPA has another car park within walking distance at the Waterworks which is free so users who were prepared to complete their journey with a short walk could simply park there. This would not reduce car usage and pollution but might hide it in their statistics.
So the only real means of reducing car usage available to the Ice Centre is to encourage car sharing. They provide no evidence that education programmes by a Centre of this kind will produce any meaningful change in behaviour. Even if there are some who will make the effort, and I have to assume there will be some even if because they may be able to save some money by sharing costs, such efforts will depend on a wide range of factors such as times of travel, how easy it is to pick up those getting a lift, etc. There is no real indication that such a programme will make a significant dent in the numbers travelling by car.
This is an unresearched plan with no evidence to show it will or can be effective. In addition it is put forward when the numbers using the Centre are expected to rise considerably.
Given the wholly unsatisfactory nature of this travel plan and the problems it reveals it cannot be expected that the Ice Centre will be able to reduce the number of cars parking at the Ice Centre in the ways suggested.
This brings me back to the car park. The car park as described is misleading. The real car park is set out in the section referred to at the start: “The desired footprint can be comfortably provided on the existing site, has room for 200 parking spaces (plus potential ability to also use the immediate surrounding area for parking if necessary)”. The car park has at least 200 spaces. The “potential ability to use the immediate surrounding area” fails to describe how many more spaces this will provide. However, given that the present car park has 307 spaces on the basis of present numbers and as it seems likely given that more people will be travelling from further afield the chances are even this “extra surrounding area” will be inadequate to meet the demand.
The Ice Centre simply fails to explain how it is going to cope with the numbers it expects to attract with an expanded Centre providing new events and facilities for an expanded catchment area and an expanding population on a confined site.
This objection is supplementary to the points made in my earlier objection which highlighted the vastly greater public transport connections and, indeed, road connections at Eton Manor. One point I forgot to mention in that objection is that Stratford also provides an enormous parking overflow capacity at Westfield, so if there is any shortage of parking at Eton Manor people can park at Westfield and take the 108 bus to the Ice Centre.
This is the second in our weekly series of objections to the LVRPA’s plans to build a new Ice Centre on Leyton Marsh. This one is from Peter. His argument focuses on the question of building on Metropolitan Open Land (MOL). Because the building is to be on MOL, and there are very specific rules about building on MOL, it is sufficient to demonstrate that the rules have been breached to prove that the LVRPA’s plans must be rejected.
Objection to Planning Application 194162
Lee Valley Ice Centre, Lea Bridge Road, Leyton, London E10 7QL
8th March 2020
I wish to object to the planning application for a new ice centre on the Lea Bridge Road.
The applicant is the Lee Valley Regional Park Authority (LVRPA). The plan entails demolishing the existing building and replacing it with a new one, approximately twice the size. The site is Metropolitan Open Land (MOL). In paragraphs 7.3 to 7.5 of the Planning Statement the LVRPA admits that the development would be “inappropriate”, as defined by the National Planning Policy Framework (NPPF); and explains in paragraph 5.7 of the same document that as a consequence such a development can only be allowed if there are very special circumstances (VSC) that outweigh the harm caused by building on MOL.
Very special circumstances (VSC)
The LVRPA claims that the following considerations constitute VSC. In this section, all paragraph references are to the Planning Statement.
The LVRPA’s “duty”. Paragraph 16.21 states that the LVRPA “has a statutory duty to develop sports and leisure facilities in the Regional Park. Since 95% of the Park is Green Belt or MOL, it is likely that some new facilities will be developed on protected land.” But this is misleading and a non-sequitur. The LVRPA has a “statutory duty” to do many things under the 1966 Act, as spelt out in paragraph 2.5 – the provision of sports and leisure facilities constitutes only one part (and not necessarily the most important part) of its functions. But, more importantly, there is nothing in the 1966 Act that suggests that the need to provide such facilities entitles the LVRPA to override other considerations. As for the statement that “some new facilities will be developed on protected land”, this has no basis at all. The 1966 Act gives no details about the minimum provision of any particular facilities; therefore it must follow that such provision should be subject to all other relevant constraints. There is no basis for arguing that the need to provide a specific facility constitutes a VSC. The fact that the LVRPA currently provides skating facilities to the public does not place any obligation on it to go on doing so. Until 2012, the LVRPA provided golfing facilities at the Waterworks. When it stopped doing so, this was not because of any lack of demand from the public; rather it was because it thought that it could make more money by using the Waterworks site for other purposes.
The need to have an operational ice centre. The present ice centre is nearing the end of its life, and will soon no longer be able to function. The LVRPA argues in paragraph 10.15 that the need to replace it before it expires is a VSC, because it is inconceivable that there should come a time when such a facility should not be available in this part of London. But this dependence is entirely of the LVRPA’s own making: if the LVRPA had not built the current ice centre (in the 1980s), then there would be no particular demand to build a bigger and better one now. Nevertheless, it is very possible that the London Borough of Waltham Forest (LBWF) would wish to have an ice centre somewhere within the borough, but there is no a priori reason why it should be on LVRPA land, or indeed why it should be provided by the LVRPA. When considered from this point of view, it is clear that there is no VSC involved here.
There is no other twin-pad ice centre in London. The LVRPA asserts in paragraph 10.42 that this is a VSC, but does not explain why.
Increased usage. In paragraphs 10.43 to 10.56, the LVRPA explains how a larger ice centre will result in more availability to the public and more availability to sports clubs – which will better enable it to fulfil its “duty” (as described earlier) and so this is also a VSC. But a closer reading of paragraph 10.48 shows that this is just a way of saying that the LVRPA will earn more revenue from a larger facility. Such a commercial argument cannot constitute a VSC.
Community benefits. In Section 11, the LVRPA describes the benefits that would accrue to the community from the new ice centre and claims them as a VSC. Many of these may indeed be genuine benefits, but the suggestion that they constitute a VSC depends crucially upon the premise that there is no other possible location for the new ice centre. It is also worth noting that these are benefits that could accrue only to some subsections of the “community”. No consideration is given to harm that the presence of the ice centre might cause to other subsections of the community.
Health benefits. In Section 12, the LVRPA describes the health benefits that may result from the new ice centre and claims that they also constitute a VSC. The situation here is analogous to the community benefits described above. They may be genuine benefits, but they could only be considered to be a VSC if there is no other possible location for the new ice centre. And again, while the presence of the ice centre may be beneficial to some people (those who patronize it), it will have the opposite effect on other people (those who would enjoy this area of Leyton Marsh if it were undeveloped).
As explained above, the LVRPA’s case is founded upon a number of premises:
That there must be an ice centre. This is not a foregone conclusion. It is up to the LBWF not the LVRPA to decide how important it is that there should be an ice centre in the borough.
That the ice centre must be provided by the LVRPA. This has not been demonstrated. The LVRPA has a duty to provide some sporting and leisure facilities, but there is obviously no duty to provide facilities for every single possible sport and leisure use. Before the 1980s the regional park did not have an ice centre – and there are any number of sports and leisure uses that the park does not cater for now and probably never will.
That the new ice centre must be located at the Lea Bridge Road site. If it could be located elsewhere, then it cannot be argued that its benefits (being general, not site-specific) constitute a VSC for the Lea Bridge Road site. I shall discuss this point more fully in the following section.
Alternative location
The LVRPA has explained that it originally considered four possible sites – the Waterworks (WW), Pickets Lock (PL), Eton Manor (EM) and the existing site (LVIC) – for the new ice centre. It used a scoring matrix to determine which was the best site. The results of this were LVIC 74.6%, WW 72.6%, EM 70.6% and PL 65.1%.; and so this is the reason why the existing site was chosen as the preferred location for the new ice centre. However, such a scoring system can only be as reliable as the values that are input into it, and these values are themselves subjective. Even at the time the original scoring matrix was drawn up in 2016, several of these values were clearly wrong. If these erroneous input scores were adjusted to more appropriate values, LVIC’s overall score would reduce to 73% and EM’s would increase to 76%, thereby making EM the preferred choice.
The LVRPA has now revised the scoring matrix, and submitted this revised version in this planning application. This has been done because certain facts have changed in the three years since the original matrix was drawn up. It includes two new sites: Broxbourne (B) and the Thames Water depot (TW). In this version the results are LVIC 77.66%, TW 75.84%, PL 62.82%, EM 62.78%, WW 60.8% and B 51.76%. However, this version is just as problematic as the previous version, as I shall demonstrate. For brevity, I shall consider only LVIC and EM.
Accessibility from existing catchments. This appears to mean: How easy will it be for people visiting the existing centre to visit the new centre instead? It has a weighting of 12. Why such a high value? Why should it matter particularly to the LVRPA whether people visiting the new centre are exactly the same as those visiting the existing centre? Before the existing centre was built (in 1981), there was no “existing catchment”, so any “need” for skating facilities that now exists is entirely a consequence of the LVRPA’s decision to create the existing centre in the first place. As it happens, both LVIC and EM are similar distances from the same population centres, so they can be expected to attract much the same clientele. In any case, the methodology behind this assessment is objectionable, because it is based upon an estimate of 30 minutes’ drive-time. The LBWF should assess facilities according to the requirements of users of sustainable transport not car drivers.
Adjacencies of other leisure uses. Both sites have been given a score of 4. This is plainly absurd. There are several leisure uses adjacent to EM of a sporting type, which are exactly the sort of uses likely to appeal to patrons of a skating rink; whereas next to LVIC there is only the Riding Centre. Consequently EM should have a higher score. The LVRPA claims that some leisure uses are “complementary” to skating whereas others are not, but this distinction seems to be entirely arbitrary.
Sporting authority stakeholder support. This refers to how supportive other sporting bodies will be to the new ice centre. EM scores much lower than LVIC, because England Hockey is located next-door to EM and would therefore be prevented from undertaking activities that might have an effect outside its precincts, for example excessive car-parking at peak periods. But this is unacceptable. There is contention for space all over London, and organizations must learn to live within existing constraints. One organization should not be able to dictate to another organization where it can locate merely because it is unwilling to submit to the additional discipline that that would entail. This is particularly pertinent in the case of car-parking. Given the declaration of a climate emergency, organizations should be reducing the use of cars, not allowing it to increase. Therefore the weighting for this item should be reduced.
Community stakeholder support. From the narrative accompanying the new matrix, it is apparent that the “community” here consists of those people who responded to the LVRPA’s consultation. The vast majority of these will be users of the existing ice centre; so inevitably the scores will be biased in favour of LVIC.
Access by car. This has a weighting of 15, whereas the criteria for access for cycle and for foot both have a weighting of 5. This cannot be justified. The London Boroughs of both Hackney and Waltham Forest have a strategy of prioritizing walking and cycling over driving. Therefore the weighting for driving must be lower than for walking and cycling. It is disgraceful that the LVRPA should need to have this pointed out.
Access by public transport. The LVRPA gives LVIC a score of 3 and EM a score of 2. The narrative explains that this is because LVIC has a higher PTAL rating. For the original version of the scoring matrix the LVRPA drew up a list of typical destinations together with journey times between each destination and the ice centre. If you calculate these journey times now (in March 2020) using the TFL Journey Planner (https://tfl.gov.uk/), you will find that on average the times from LVIC are 2 minutes higher than those from EM. (These calculations may be found in Appendix B.) For that reason, the score for EM should be at least as high as that for LVIC.
Fit on site. The LVIC has a score of 5, and EM 4. However, the narrative admits that the new building will fit onto both sites. EM is given a lower score because it will provide less scope for the “public realm and landscape opportunities”. But this should be treated as irrelevant. EM is right next to a busy road, not in a location that people are going to visit except to go to the ice centre. By not building the ice centre at LVIC there will be plenty of scope for the LVRPA to spend money on the “public realm and landscape opportunities” at the vacated LVIC site. Therefore EM should have the same score as LVIC.
Ice centre and on-site parking. This has a weighting of 15; LVIC has a score of 5, and Eton Manor 1. Firstly, the weighting is far too high: the LBWF should be doing everything possible to reduce reliance on cars, so it is very wrong to allow policies to be driven by the needs of car-drivers. Secondly, there are plenty of car-parking spaces in the vicinity of EM. It is only because of a willingness to acquiesce to the hegemonic demands of England Hockey next-door that there is felt to be a shortage of spaces. In any case, one wonders whether the LVRPA genuinely considers that there is a shortage of parking at EM, in light of the fact that it is proposing to build a hotel on the site. Clearly the score for EM should be increased.
Grounds/landscape constraints. LVIC has a score of 4, and EM 2. The narrative explains that EM’s low score is because it “is known to have poor ground conditions, that will likely result in significant piling of the site”. However, this should be taken with a pinch of salt. The LVRPA is currently proposing to build a hotel at EM. Such a building, consisting of several storeys, would exert far greater pressure on the ground than the proposed ice centre, with only two storeys and containing a lot of empty space. In any case, no mention is made of the facts that: firstly, EM is a fairly barren site close to a motorway, whereas LVIC is close to an SSSI; and secondly, if the ice centre is built at LVIC this will entail felling a number of mature trees, whereas there are no mature trees at EM. Therefore the score for EM should be at least as high as that for LVIC.
Cost and ability to develop the scheme. LVIC has a score of 3, and EM 2. The narrative explains that EM has a lower score because the above-mentioned need for piling will increase the building cost. But it does not mention the additional cost that will incurred at LVIC by the complications of staging the building work, in other words scheduling it in such a way that skating facilities remains available to the public for as long as possible while the building is going on. This additional cost would not apply to EM.
Impact on business plan. The LVIC has a score of 5, and EM 3. LVIC has a higher score because it is reckoned that a gym at LVIC would be more profitable than one at EM. This is because, according to the narrative, there are more gyms already in the vicinity of EM. However, the copy of Google Earth at Appendix C shows that the numbers of gyms near the two sites are exactly equal (3 within a radius of half the distance between the two sites, and 9 within a radius of the distance between the two sites). So the two sites should have the same score. (Incidentally, it is obvious that the LVRPA does not sincerely believe that the proximity of gyms is a relevant consideration, since it is proposing that the hotel at EM should itself include a gym. See paper RP/38/20 paragraph 15 in https://www.saveleamarshes.org.uk/DocumentSearch/display.php?Document=338)
Continuity of service. LVIC has a score of 1, and EM 4. The LVIC’s low score is a reflection of the fact that there will be a period between closing down the old ice centre and the first phase of the opening of the new ice centre during which there will be no skating possible. However, there is no reason why EM’s score cannot be 5, since in its case the first phase of the opening of the new ice centre can take place before the old ice centre is closed down. The narrative explains that the ice pad at the old centre will be transferred to the new centre in the second phase, but there is no reason why that should cause an interruption in service at the new centre.
Accordance with local plan policies. LVIC has a score of 3, EM a score of 1. EM has a lower score because it “is allocated for another use, as a designated playing field, and is identified for five a side football in the LLDC Local Plan”. But again, one wonders how relevant this is, since it does not seem to present an obstacle to the afore-mentioned plans to build a hotel on the site, nor to the afore-mentioned objections from England Hockey.
Accordance with Green Belt MOL policy. LVIC has a score of 2 and EM a score of 1. The narrative explains that LVIC “is largely previously developed land, and the development would have less than significant impact on openness compared to the current existing site [presumably existing building is meant]”, and that EM “would have significant impact on current openness as there are no existing structures on the site”. This is plainly absurd. Firstly the new building is twice the size of the old one, so it will certainly have a significant (detrimental) impact on openness. Secondly, if the new building were located at EM, then the site at LVIC could be cleared, thereby resulting in a significant improvement in openness. So the question boils down to whether openness at EM is more or less valuable than at LVIC. In view of the remarks about MOL above, it follows that it is more valuable at LVIC. Therefore the scores should be swapped round.
Regeneration benefits. LVIC has a score of 5 and EM a score of 4. This is because LVIC is within 3 areas designated in the London Plan, whereas EM is in only 1 such area. However, the narrative does not explain why that entitles LVIC to a higher score than EM. The one thing that is certain is that the area around LVIC needs less development, not more.
Planning potential. LVIC has a score of 4 and EM a score of 2. This is simply a reflection of the fact that the LVRPA reckons that LVIC has a greater likelihood of being approved than EM. That is of course an entirely circular argument: you should grant planning permission for the new ice centre at LVIC rather than at EM because we think you are more likely to grant planning permission for it at LVIC than at EM!
At Appendix A there is a copy of the Scoring Matrix. The LVRPA’s scores and weightings are on the left. Where a value has increased from the original (2016) matrix it is coloured red; where it has decreased it is coloured green. (The original matrix is not shown, to avoid confusion.) On the right the scores and weightings are corrected to resolve the issues described above. Where a value has increased from the LVRPA’s value it is coloured red; where it has decreased it is coloured green. As can be seen, the overall score for LVIC reduces from 971 (78%) to 912 (73%), and the overall score for EM increases from 785 (63%) to 964 (77%), as a result of these modifications.
Conclusion
The new ice centre cannot be built on the site of the existing ice centre unless Very Special Circumstances (VSC) can be demonstrated. Most of the points that the LVRPA present as VSC are not valid. It might be possible to argue that some of the benefits (community and health) are VSC. However, these benefits are general, not specific to any one location. Therefore, if there are alternative possible locations for the new ice centre, these benefits cannot be counted as VSC either. I have demonstrated, using the LVRPA’s own methodology, that at least one other site (Eton Manor) is at least as acceptable as the existing site. Therefore there are no VSC for the existing site. Therefore it must be rejected.
Peter Mudge, on behalf of Save Lea Marshes
Posted inIce Centre|Comments Off on Objection of the week
As the LVRPA have been lobbying the local council and encouraging local people to support their application, every week for the next few weeks we will be sharing an objection to the new Lee Valley Ice Centre being sited at Leyton Marsh.
Each of these objections have been made on different grounds. You can still submit a relevant objection to the planning department at Waltham Forest Council.
First up is Celia who focuses on the industrial nature of a twin pad ice centre on Leyton Marsh – Metropolitan Open Land and some of the reasons it would be better situated at Eton Manor:
Development Management & Building Control London Borough of Waltham Forest The Magistrates, Town Hall Complex 1 Farnan Avenue London E17 4NX
Re. Application No. 194162FUL Lee Valley Ice Centre
Dear Sir/Madam
I am writing to comment on the above proposal. Having fully read the document prepared by WSP/Idigo on behalf of the Lee Valley Ice Centre, and indeed been involved at various stages of the ‘consultation’ process, I am writing to formally object to the building of the ice centre on the MOL site of Leyton Marsh.
There are many reasons why the building should not go ahead on this site but for the purposes of this objection letter I am going to reluctantly confine myself to just two.
There are insufficient good reasons to have chosen this site rather than the site of Eton Manor and a number of bad reasons, not least the building on MOL on less than ‘very special circumstances’.
My first point is to address both the practicality and the environmental damage that continuing to operate the old rink whilst developing a new one on the same site instead of building a new one on Eton Manor, whilst being able to keep the old one not only operational for a longer period but also to minimise the disruption to the creatures that inhabit the site and the people who currently use it. Building work is always more disruptive to land than anticipated because of footfall and machinery over grass and supplies left around. In this case there would be even more disruption as mentioned under paragraph 14.57 of the report as this also includes the provision of temporary buildings.
Eton Manor would also be preferable during the time of construction, as the Olympic site is still currently undergoing development and the road infrastructure for commercial vehicles would be less impactful than on the Lea Bridge Road and surrounding districts (as witnessed during the building of the temporary Olympic Basketball Training Facility).
The ‘robust’ examination of other available sites in Appendix 1, does not provide sufficient argument to warrant going ahead with the Leyton Marsh site. If Eton Manor isn’t suitable, the arguments against Pickets Lock being effectively ‘too far to walk’ (20 to 30 minutes) could also be questioned (a) from the point of view of the levels of fitness the LVRPA aims to promote and (b)what of the other facilities currently based there including a cinema?
I would conclude that the fundamental reason for choosing Leyton Marsh over the other sites is because it is seen in terms of the potential for expansion. If planning permission is granted under ‘special circumstances’, who can say, that future expansion would not be justified? Just as the current argument is made that a ‘building is there already’, even though, this building arrived before the current MOL status.
The building is inappropriate for a green space site, despite the efforts to ‘dress’ it as a more environmentally friendly building.
Having researched other ice centres (most, like the LVRPA one proposed are in fact ‘Leisure Centres’). I conclude that the proposed ‘twin pad’ most closely resembles Ice Sheffield (see photo 1 and compare the design for the Lee Valley Twin Pad, photo 2). This is an industrial building based on an Industrial Estate with a mixed occupation of industrial business and leisure buildings – not on MOL. If you take away the external enhancements of the Lee Valley Scheme and concentrate on the sheer size and scale of the building, the similarity is evident.
In London (as mentioned under pages 37-40 of the Planning Statement), the examples of Streatham and Romford are included. Both of these ice/leisure centres are positioned in town centre urban environments (see photos of Streatham an Olympic sized rink nos. 3-5). Again, the sheer size and scale of the building can be imagined on Leyton Marsh and blocking the openness of the area, which is heavily used as a place for walking and escape by local people and visitors to the area – many more than would use the ice centre.
Romford – which used to have very similar ice rink before the new Sapphire Centre was built – a new facility is also located in the town centre (see photo 6), near to transport links.
As paragraph 1.53 of Appendix 1 states: “As a leisure facility, the proposed ice centre falls within the definition of a ‘main town centre use’ as defined by the NPPF.”
There would seem to be a difference of opinion on what the LVRPA considers to be near town centre and what local people consider to be open space. The Regional Park Authority lends more weight to its own internal needs e.g. not to conflict with the Hockey Centre at Eton Manor, than to the value of the MOL at Leyton Marsh to taxpayers and local residents.
While not strictly a ‘planning issue’ the very fact that the LVRPA’s unique organisational structure is a contributing factor in making its decision making difficult. It must, on the one hand, balance its arguments for justification across all the cash-strapped, London boroughs and increasingly need to make a profit from developments. This, set against the other requirements of its founding principles as regards the park, as set out in para. 2.5 (1) of the Planning Statement. The originators of the Lee Valley Act did not for-see the dilemmas we currently have in terms of lack of land; climate change and the effect on the environment as well as austerity cuts to local authorities. The overriding issue now must be climate emergency and the need to make sure our flora and fauna can survive in our green spaces. Such spaces are even more vital in conjunction with increased housing but smaller dwellings in the area, particularly as we now know that access to green space aids our health and mental health.
In conclusion, the justification of putting an industrial building on MOL adjacent to an SSSI is not proven, given as the report states there are other rinks “20 or 30” minutes by car away and a new Olympic ice centre, currently being built in Cambridge. They may not all be twin- pads but certainly most of the London ones offer similar sporting activities including Ice Hockey (e.g. the Sobell Centre). Many of the ice centres are also run by GLL, offering similar facilities (not, for some reason mentioned in the Planning Statement). Therefore the ‘uniqueness’ of the Lee Valley Ice proposals have been overplayed and should be weighed against stark environmental facts (e.g. 95 per cent of meadow land lost since WWII), not ‘greenwash’. If Leyton Marsh could be improved – why hasn’t the body responsible for it done enough before deciding to take away a large area of the land for development and so-called ‘enhancement’?
Save Lea Marshes are excited to announce that in the last few days Caroline has launched a crowdfunder on behalf of the group in order to re-wild the Waterworks Meadow!
All funds raised will be received into the Save Lea Marshes bank account and will go directly to 5 independent ecologists.
We would like to introduce our experts to you:
Annie Chipchase
“My interest in the natural environment and urban ecology was spurred by plants and botany has been a major feature in my paid and voluntary work for 30 years. My work has been concentrated in London where I have carried out habitat surveys for the GLA, for a consultancy and on a freelance basis. The vegetation of our cities is what make them liveable and never fails to surprise me.”
Rob Sheldon:
Rob will be carrying out ornithological surveys of the whole Waterworks area and will also be responsible for a professional collation of the report findings.
“I’ve been involved in bird surveys and research work for almost 30 years. After 12 years working with the RSPB and several years working in the Middle East, I’ve been working as a freelance conservation consultant since 2014. I’ll be undertaking surveys of breeding and non-breeding birds as well as assessing the potential for habitat management to attract new bird species.”
Russell Miller
Many of you will know Russell from his amazing work locally with the Tree Musketeers.
Here’s Russell’s introduction: “I’ve been an arboriculturalist and ecologist for 20 years and have lived in Hackney for 30 years. I will be surveying for invertebrates especially native bees. Invertebrates are extremely diverse and usually overlooked. Many nationally scarce or even rare species may occur on the Meadow because of its mosaic of habitats including: old trees, deadwood, open water, bare sandy ground, scrub and open grassland.”
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It is an unfortunate fact that much of the material that we post on this site consists of negative comments on the work of the Lea Valley Regional Park Authority. So you may feel rather a weary sense of déjà vu on coming across The Lee Valley: time for a rethink by Laurie Elks. But you shouldn’t — because this document was written 40 years ago! I do urge you to read it and, as you do so, ask yourself how many of the criticisms it contains are just as valid today as they were when they were written. (And it also gives a very useful brief history of the first decade and a half of the Lea Valley Regional Park after its creation in 1965.)
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The Gas Works development will have a negative impact on the openness of the Marshes and Jubilee Park and it will add to the feeling of overcrowding and being overlooked in those using these spaces.
The Marshes are Metropolitan Open Land. The references to Green Belts in the NPPF and case law below also apply to Metropolitan Open Land. NPPF 133. 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. Waltham Forest Council’s own ‘Green Belt and Metropolitan Open Land Review’ says, regarding the Ice Centre at Leyton Marsh, see para. 5.16, ‘it supports such relocation as this would provide an opportunity to rationalise the land uses in MOL3 and enhance the sense of openness, particularly views north-south along the Lea Valley’.
Plainly Waltham Forest considers ‘sense of openness’ to be an important issue when it comes to the impact of large scale developments like the one at the Gas Works and others planned for the future.
2. Visual impacts do harm to the openness of such important green spaces.
NPPF 144. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations”
“Whether, in the individual circumstances of a particular case, there are likely to be visual as wellas spatial effects of the openness of the Green Belt , and, if so, whether those effects are likely to be harmful or benign, will be for the decision-maker to judge. But the need for those judgments to be exercised is, in my view, inherent in the policy.” [38] Samuel Smith “In my view, therefore, when the development under consideration is within one of the five categories of paragraph 90 and is likely to have visual effects within the Green Belt, the policy implicitly requires the decision-maker to consider how those visual effects bear on the question of whether the development would “preserve the openness of the Green Belt”. [40] Samuel Smith
The visual dimension of openness was considered in Turner v. SSCLG Sales LJ interpreted the concept of openness as one which was “not narrowly limited to [a] volumetric approach” but “is open-textured and a number of factors are capable of being relevant when it comes to applying it to the particular facts of a specific case” [14].
3. The developers seem to have made no serious assessment of the visual impacts on the neighbouring open spaces. They say:
14.6 “The completed Development will provide views of the taller buildings (Block D and E) which will assist in signposting Leyton from the wider area and will bring a positive use of a previously derelict site. The Development will have direct moderate to minor beneficial effects on TCA 1 Leyton Fringe as well as indirect moderate to minor beneficial effects on TCAs 2 and 3. Quod | LeaBridge Gasworks | Environmental Statement, Volume 1 | March 2020
2914.7 The completed Development will have no adverse effects on representative views of the Site, with the majority of effects considered to range between moderate to minor beneficial. Whilst there will be a noticeable change from a number of viewpoints, it is considered that overall, the Development will have a beneficial effect on the surrounding townscape. There will be no effect on Viewpoints 5 Lea Bridge Road, 9 Hackney Marshes Pavilion and 11 River Lea Towpath.
14.8 There is potential for cumulative effects on views from the east and south-east of the Site overlooking Leyton Jubilee Park (Viewpoints 2, 6 and 7). During the construction phase, effects will remain moderate adverse from these viewpoints and during the operational phase there will be moderate beneficial effects.
To say the Development will have ‘no adverse effects’ on views simply fails to address the harms described in the NPPF and case law. The applicants refer to the tall towers ‘signposting Leyton’. Protecting the Marshes and their openness for the well being of the residents of Leyton and other parts of Waltham Forest is of infinitely greater importance than a tall building marking its territory. This is a snapshot from their Planning Statement showing how the towers will overlook Jubilee Park:
The applicants refer to ‘potential for cumulative effects on views’ at Jubilee Park during construction but then they say this will be beneficial on completion. How can this be described as beneficial? It is totally at variance with the need to preserve the sense of openness of the open space affected.
Below is a diagram showing the towers overlooking Jubilee Park. It is hard to see how this is anything other than oppressive when it comes to the openness of the open space.
On page 33 of their Planning Statement the applicants include one diagram suggesting visual impacts on Hackney Marshes from the pavilion at North Marsh. They do not provide any diagrams showing the impact from the south of Hackney Marsh or any diagrams showing the impact on the Marshes further north, at the Waterworks, Leyton Marsh or Walthamstow Marsh. Context is needed to show how the proposed development will fit with other construction in the area. No context is provided in the application. The reality is construction is steadily encroaching on the views from the Marshes thereby reducing their openness.
Above is a view of the Motion towers from Porter’s Field during construction. The two tall Gas Works towers are similar in height to the tallest Motion tower. Porter’s field is a similar distance from Motion as the Waterworks is from the Gas Works. Other examples below show how construction is intruding on the Marshes. The Gas Works will add to this intrusion.
Above is a view of the Motion towers from just south of the Waterworks cafe, below is a view from the Waterworks Nature Reserve:
Below, view from the Waterworks Meadow, the tallest Gas towers are the same height as the tallest. Motion tower and will be behind the FedEx warehouse.
A more specific view of the FedEx warehouse, the Gas Works towers will be behind the warehouse:
The same applies to Walthamstow and Leyton Marshes where towers are ever more visible. Above, view of Motion towers from the Aqueduct Path behind the Riding Centre.
Above, view of Motion towers from Walthamstow Marshes.
Below, view of Motion towers from Leyton Marsh:
Context of construction, view looking north from between Walthamstow and Leyton Marshes:
Above, view from Leyton Marsh showing future location of Gas Towers. The pylon on the right is on the Waterworks Nature Reserve. The Gas Works towers will be between the two pylons.
The Gas Works development will also be visible from Hackney Marshes. Picture below taken from south end of Hackney Marsh, the Gas Works will be to right of Motion tower.
The view above is not included in the applicants’ documents even though the view from the south of Hackney Marsh is supposed to be included. But then neither is the context of construction around the Marshes included anywhere.
Below is a view of the various constructions from the pavilion at Hackney North Marsh, the only location from which a projected view is provided.Increasingly the Marshes are becoming surrounded by towers.
The Gas Works towers will further impact on the openness of the open spaces on the Marshes and at Jubilee Park. This will cause harm to those spaces and to the benefits people derive from them.
4. Preventing harm to green open space is important for people’s health and well being.
The construction of such tall towers so close to important green open spaces will seriously detract from the enjoyment of those spaces and their usefulness as places of relaxation. Open space has increasingly been recognised as having important social and health benefits. It is important to ensure any construction near such spaces is appropriate and does not visually impact on those spaces in such a way to reduce those benefits.
Mind’s report ‘Ecotherapy: the green agenda for mental health’ presents the findings of the first ever study looking at how green exercise specifically affects people with mental health problems. A walk in a country park was compared with a walk in an indoor shopping centre. The results are startling: ● 71 per cent reported decreased levels of depression after the green walk ● 22 per cent felt their depression increased after walking through an indoor shopping centre only 45 per cent experienced a decrease in depression ● 71 per cent said they felt less tense after the green walk ● 50 per cent said their feelings of tension had increased after the shopping centre walk ● 90 per cent had increased self-esteem after the country walk ● 44 per cent said their self-esteem decreased after window shopping in the shopping centre. ● 71 per cent reported decreased levels of depression after the green walk ● 71 per cent said they felt less tense after the green walk ● 90 per cent had increased self-esteem after the country walk It is interesting to note that a ‘country’ walk has even more impact than a ‘green’ walk. It is worth noting that the Marshes represent a very substantial area of green space, wilder than an urban park, more closely resembling what might be called a country walk. Mind is unequivocal about the potential benefits of rolling out eco-therapy in appropriate places, “Hundreds of people have benefited from the green projects run by our local Mind associations but if prescribing ecotherapy was part of mainstream practice it could potentially help the millions of people across the country who are affected by mental distress.”
Recent surveys reflect the earlier findings of the Mind reports; a ‘sense of connectedness to nature is linked with greater psychological well-being’ (Cervinka et al., 2011; Howell et al., 2011).
Studies on obesity levels among children showed ‘levels are lower when there is more nearby green space to their residence’ (Dadvand et al., 2014). Proximity to green spaces is associated with reduced anxiety and mood disorder (Nutsford, Pearson and Kingham, 2013). A recent evidence review commissioned by the National Lottery Heritage Fund and the National Lottery Community Fund, conducted by Sheffield Hallam University and The University of Sheffield includes a peer review of 385 studies. It highlights the social benefits of parks and green spaces (predominantly in the UK, Europe, the US and Australia) and underlines the potential of parks to deliver ‘multiple health benefits for the local communities and support long term mental and physical health’ (Dobson et al, 2019). Facilitated visits to green spaces improved the self-esteem, mental well-being and social lives of people with disabilities (Jakubec et al., 2016).
It found that the main source of pride for adults is ‘countryside and scenery’ at 53% (more than any other category). Parks and green spaces are a key component of social infrastructure; ‘the physical places and organisations that shape the way people interact’ (Klinenberg, 2018, p.5).
Crucially, parks and green spaces enable people to connect with nature, which in turn benefits well being.
5. Impact of new populations on existing open spaces The policy of building large scale high density housing developments near to open spaces will inevitably place greater stress on that open space. While new housing may well be needed the appropriateness of its location, size, scale and impact on existing resources has to be taken into account. Others have commented on the lack of adequate rail transport, doctors’ surgeries, schools and the impact on roads, even by a supposedly car free development, as not only will residents still have cars but they will also need delivery, repair and maintenance services and such like.
Open spaces do not exist simply for the benefit of developers who can then advertise the desirability of the location for future residents and make a profit out of these public resources. These open spaces, particularly the Marshes, serve a much wider community than those living in the immediate vicinity of Lea Bridge. This development will be added to developments already built and others being planned. It is worth noting the judgement in Turner as below:
“The openness of the Green Belt has a spatial aspect as well as a visual aspect , and the absence of visual intrusion does not mean that there is no impact on the openness of the Green Belt as a result of the location of a new or materially larger building there.” – Sales LJ in Turner
Source of legal information used:
Recent events at the Waterworks have shown how vulnerable open spaces are to inappropriate and damaging events. Waltham Forest Council sensibly refused an application to allow a music festival to take over that space. The events following that refusal, when people held barbecues and parties leaving behind quantities of litter for others to remove, showed that open space is not an unlimited resource. Care has to be taken to ensure it will remain available for future generations. Open spaces like Jubilee Park and the Marshes are of much greater value than the presence of a tower signposting an urban destination, Allowing large scale developments to make unsustainable demands on these spaces will help to destroy such an important resource. It is imperative to avoid these harms.
A red kits soars over the Waterworks Meadow. Image by Giles Greenwood.
Save Lea Marshes are delighted that the destructive Waterworks Festival will not go ahead on the wildflower meadow adjacent to the Waterworks Nature Reserve. The location was always patently inappropriate for such a large-scale commercial event and we are relieved that the Licensing Committee have recognised the detrimental impact the festival would have on wildlife and local communities.
We are grateful to every single one of the 350+ objectors and all the organisations and residents we collaborated with to achieve this result!
The Waterworks Festival was opposed by Save Lea Marshes, Love Lea Bridge, Hackney Council, London Wildlife Trust, Hackney Marshes User Group, Manor Garden Allotments, Ive Farm Community Garden, Plastic Free Hackney and the Lea Bridge ward councillors in both boroughs, as well as countless local people. Waltham Forest Council have made the right decision to protect this precious area of the marshes for the enjoyment of all and for Nature.
If you objected to the licence for the Waterworks Festival, you should have received an official notification from Waltham Forest Council telling you that the licensing hearing will take place online (using Microsoft Teams) at 14:00 on 12th May, together with a number of documents. If you wish to attend the online meeting (either to speak or just to listen) please get in touch with us at leamarshes@gmail.com, and we will let you know how we recommend that you should complete the Acknowledgement document. You will need to send the completed document to licensing@walthamforest.gov.uk in order to attend the meeting.
If you have not submitted an objection, particularly if you have only just become aware of the festival, we advise that you send a request to Marc.Witham@walthamforest.gov.uk if you wish to attend or speak at the hearing.
