The LVRPA has revealed its true colours at last. Let’s tell them how we feel.

Posted on 18 March 2020 by SLMAdmin

I appreciate there is a great deal going on at the moment, and that this is a time of great uncertainty for us all. But if you want to direct your anger and frustration somewhere, can I suggest the LVRPA deserve a shot across the bows…

Save Lea Marshes has been concerned for some time about the LVRPA’s intention towards the Waterworks meadow, the large area of land south of the Waterworks Centre and Nature Reserve. So, in June 2019, we wrote to Shaun Dawson, the Chief Executive to ‘request an opportunity to engage with the LVRPA on the future use of this area’. And, in July 2019, we were told that the Authority had commissioned an ecological consultant to carry out a habitat survey.

Although slightly suspicious of the LVRPA’s motives, we thought a habitat survey could only be a good thing, and we were cautiously optimistic about the results when we received the survey in January 2020. You can take a look at it here. We thought the findings sounded robust and we endorsed the management options. We said that we would look forward to the outcome of an internal meeting to review the site management options and to discussing the next steps. Our hope was, of course, that the whole site would improve as a result of the report.

They say hope springs eternal. It does. Now I ask myself if the hopeful are always foolish? When I first came to hear about the LVRPA in early 2012, when they were supporting the Olympic Delivery Authority to build a temporary basketball arena on Porter’s Field, Leyton Marsh, I advocated dialogue with the organisation. More experienced campaigners said it was a waste of time, but I doggedly met with Shaun Dawson every few months, patiently explained why people were so angry and asking the LVRPA to work more closely with local people to resolve our differences. And we have continued to try and engage with the LVRPA ever since. Most recently we asked them how we can trust the environmental promises they are making about the ice centre. But every time, every single time, we have been met with a wall of obfuscation and dissembling. Save Lea Marshes does not oppose the LVRPA because it likes to be in opposition. It opposes the LVRPA because of the LVRPA’s actions. This is a case in point…

While waiting to hear about the outcome of the internal meeting to review the site management options, we were blindsided by the horrific news that the LVRPA has agreed to rent the land to the Waterworks Festival. The site is next door to the Waterworks Nature Reserve and is designated as part of a Site of Metropolitan Importance for Nature Conservation (SMINC). If the noise and light pollution will be significant nuisance for human neighbours, it will be catastrophic for neighbouring wildlife, particularly birds. This is simply an inappropriate place to hold a one-off one-day music festival, let alone an annual three-day event.

And the LVRPA’s response? This from Shaun Dawson, the organisation’s Chief Executive:

Dear Abigail

I do hope that all is well with you.

I am writing on behalf of colleagues following our internal meeting on the subject of ‘rewilding’ of the golf course area last week. Cath and team have done some good work but it did strike us that the future management of the area and the approach the Authority adopts is very much dependent upon the WF’s Licensing Committee’s decision re: events on the site over the next few years. If the Licensing Committee gives us the green light then we are looking at a conservation management plan in that context. However if the Committee takes an alternative position, which I appreciate is the position that you and others that have submitted objections would like to see, we will then be looking at a different management regime.

We are keen to enhance the ecological value of the area but our objective is to achieve that in the context of part of the area being used for outdoor events. We shall await the outcome of the Licensing Committee meeting and then take the work forward. We will be in touch after the Licensing Committee meeting to arrange a discussion with you.

Best regards

Shaun

So, to paraphrase, Cath Patrick, the LVRPA’s Conservation Manager, has done some good work but we’ll ignore all of it if we can make some money from the site. From the mouth of the Chief Executive we have the clearest confirmation yet that the LVRPA cares about money more than the environment.

We should be angry about this. Very, very angry about this.

But let’s do a little bit more than just be angry… We have been delighted by the wave of opposition to the Waterworks Festival and to the number of objections to the premises licence that have been logged with Waltham Forest Council. I’d love to shine this beacon of common sense on the LVRPA now. So, will you help us by writing to Shaun Dawson and copying all the Authority Members? You can use the template below. Or you can write your own letter.

To:
sdawson@leevalleypark.org.uk
Cc:
paul.osborn@harrow.gov.uk; derrick.ashley@hertfordshire.gov.uk; david.andrews@hertfordshire.gov.uk; ken.ayling@ntlworld.com; john.bevan@haringey.gov.uk; frances.button@hertfordshire.gov.uk; rowena.champion@islington.gov.uk; cllr.ricki.gadsby@essex.gov.uk; david.gardner@royalgreenwich.gov.uk; cllr.mike.garnett@essex.gov.uk; cllr.christine.hamilton@enfield.gov.uk; cllr.r.houston@barnet.gov.uk; heather.johnson@camden.gov.uk; Cllr.Denise.Jones@towerhamlets.gov.uk; christopher.kennedy@hackney.gov.uk; graham.mcandrew@hertfordshire.gov.uk; cllr.valerie.metcalfe@essex.gov.uk; cllr.gn@broxbourne.gov.uk; nigel.quinton@btinternet.com; marysartin@yahoo.com; sydstavrou@hotmail.co.uk; cllr.simon.walsh@essex.gov.uk; john.wyllie@eastherts.gov.uk; Cllr.Terry.Wheeler@walthamforest.gov.uk
Subject:
A complaint about your approach to land management at the Waterworks

Dear Shaun

Save Lea Marshes has shared your recent email to Abigail Woodman and I wish to complain about your approach to land management at the Waterworks.

The nub of your position, quoting from your email, is as follows:

the future management of the area and the approach the Authority adopts is very much dependent upon the WF’s Licensing Committee’s decision re events on the site over the next few years.

This seems to be an astonishing approach for a statutory authority to adopt towards the environment, especially an authority whose primary function is to protect its environmental assets.

And, when you refer to a “different management regime”, we think you are saying that the Authority will wash its hands of the Waterworks site if it cannot generate revenue from regular events.

This is of course the first time you have formally flagged an intention to stage regular events “over the next few years” although we inferred from the start that this was the Authority’s intention.

Also, and we may have got this wrong, we think you are implying that it would be a realistic decision on our part to acquiesce in this licensing application, and encourage others to do so, if we want to see plans for the future management of the area that we would be content with.

We think it would be most helpful to the Authority’s understanding of the position if we spell out the reasons why the Faustian pact you appear to be proposing is wholly unacceptable:

  1. We are wholly opposed to pop festivals or other large events on the site and this position will not change.
  2. We have made it clear, over a long period, that we are open to discussing options for the management of the Waterworks estate and there has never been any reciprocation on your part. Your email, with this threat of an undefined “different management regime”, sees you continue your approach of keeping local people in the dark.
  3. It also seems very clear that you intend to bypass other stakeholders who ought to be consulted. Our understanding is that if the Park Authority intends to abandon or vary its plans for the Waterworks estate, as set out in its Area 2 Proposals, that is a variation of the Park Plan which requires certain consultative processes. We see no sign that the officers of the Authority are willing to share their plans with the democratically accountable Authority members, let alone wider stakeholders. How can you possibly justify that?
  4. We cannot overlook the obvious fact that the Authority defines its position on the Waterworks estate primarily in terms of raising money and not by reference to its duties to improve and preserve the Park. We are aware that it was the Park Authority’s initiative to sell off a large portion of the Waterworks estate as “enabling development” for the ice centre. Having abandoned the notion of enabling development, the Authority has nevertheless offered up much of the land in response to Waltham Forest’s call for sites, and we assume that much of the estate has been deemed to be no longer required for Park Purposes under your Corporate Land and Property Strategy. Now you are seeking a revenue stream, and no doubt a profit, before proposing a “management strategy” (which we have not yet seen) for the area. The Park Authority seems deaf to the fact that people here in Waltham Forest and Hackney want to see the Park better managed as connected and cherished green space and not as a source of revenue to keep the Authority’s show on the road.

It would be very helpful to have your clear and prompt response to these points.

Yours sincerely

Posted in Uncategorized, Waterworks | Tagged , , | Comments Off on The LVRPA has revealed its true colours at last. Let’s tell them how we feel.

Want to oppose the ice centre planning application? Here’s how.

Posted on 3 March 2020 by pjm

The Lee Valley Regional Park Authority (LVRPA) wants to replace the current ice centre on Lea Bridge Road with a building that is almost twice the size. If planning permission is granted, it means we will lose precious Metropolitan Open Land (MOL).

The application can be found here: planning.walthamforest.gov.uk/application-search#VIEW?RefType=APPPlanCase&KeyText=194162. There are a lot of documents to wade through, so if you don’t have time to look at them here’s a sample objection you can use. Email it, with your name and address, to dmconsultations@walthamforest.gov.uk

And if you need a reminder why we are so dead set against the LVRPA’s plans, have a look at the post immediately following this one.

To whom it may concern

Lea Valley Ice Centre, Lea Bridge Road, Leyton, London, E10 7QL. Application ID: 194162

I wish to object to the planning application 194162 to build an ice centre 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’ to outweigh the harm to MOL. I have also made comments about biodiversity and contaminated land.

Metropolitan Open Land

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 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.

The LVRPA states that the VSC case and the benefits that will accrue as a result of the development of the replacement ice centre will clearly outweigh the harm to MOL [my emphasis]. Yet there is nothing clear about their case. Most of the circumstances the LVRPA has advanced are not reasons why the ice centre should be built on MOL that can contribute towards very special circumstances Many of them, in the LVRPA’s own words, are benefits that will accrue if the development goes ahead. The only circumstance that should be considered is the fact that the current ice centre will need to close if the development does not go ahead. The LVRPA argues that this means that the community will lose a sporting venue and all the benefits that go alongside it, but this is only the case if the LVRPA decides not to pursue another site for a larger ice centre. At this point, the LVRPA is claiming that there is no other site but this is not true; the Eton Manor site is a viable alternative. Consequently, the fact that the current ice centre will close is not sufficient to outweigh the harm to MOL. The LVRPA has not made a case for very special circumstances and the application should be denied.

Biodiversity

The Biodiversity survey and report (document 6D3) states that the development will provide more than the required 10% net gain in biodiversity. If the development goes ahead this should, of course, be welcomed. However, the ecological enhancements the applicant is proposing in the Design and access statement (documents 6D7) are not dependent on the development. They could – indeed should – have been done anyway and the LVRPA should be challenged on its fitness to manage the site in the future given its poor record to date. That the site currently supports largely common habitats of generally low ecological value (Design and access statement (documents 6D7)) is the fault of the LVRPA, no one else. Significantly, the architect and landscape architect employed by the applicant admit that it is nigh-on impossible to find a way to ensure the plans they develop – whether they be biodiversity plans, low-carbon plans, plans to use responsibly-sourced recycled materials during the build or plans to limit noise and light – are implemented in full. Any benefits described by the applicants are possible future benefits, possible future benefits that might not materialise, and they come at a cost to existing wildlife and to the local community. If the development were to be granted permission, it would be critical that robust long-term planning conditions were put in place to ensure the LVRPA keeps to its biodiversity promises given the way they have let the site deteriorate up till now. Similarly, it would be important that strong planning conditions were put in place to ensure the low-carbon, environmentally-sensitive design-and-build criteria that minimise light and noise pollution are not watered down by the contractor during the build.

Contaminated land

Many people enjoy spending time in open green space throughout the year and Porter’s Field, Leyton Marsh, adjacent to the site, is particularly well used by people of all ages. Given this, it is concerning that the Land contamination assessment (Documents 6DD) does not contain a category that encompasses these people. It states that there is a high risk of illness caused by ingestion, dermal contact and inhalation of asbestos fibres and dust during construction, and a high risk of onsite sources of contamination leaching through surface permeable soils and harming construction workers. Surely people walking close to the site during construction will be exposed to as much risk as construction workers? But, while risk to construction works can be mitigated from high to moderate with the appropriate use of PPE and implementation of CDM regulations, what happens to those using the area informally to walk their dogs and play football? How are they going to be protected? This issue is of particularly concern to local people given the cavalier way the Olympic Delivery Authority, working on the applicant’s land and with the applicant’s oversight, managed the very same situation when the temporary basketball training centre was built on Porter’s Field in 2012. Huge piles of contaminated soil were left uncovered for weeks, and the risks to health were constantly underplayed. This must not happen again. If the development were to be granted permission, it would be critical that robust planning conditions were put in place to protect everyone in the vicinity of the building site from harm.

If the development were to be granted permission, planning conditions should also be put in place that ensure the applicants not only monitor groundwater and gas throughout the build phase, but have a plan in place to fully mitigate any adverse effects of contamination quickly. The LVRPA, in part, justifies this development with reference to the increase in biodiversity that they claim will result. This will mean little if the development has caused significant damage to the environment as it is being built.

Posted in Uncategorized | Tagged , , , , , | 5 Comments

The Lee Valley Park: What went wrong? Nous accusons.

Posted on 3 March 2020 by pjm

In the beginning…

Three quarters of a century ago, as war was drawing to a close, the wartime coalition government published Professor Abercrombie’s Greater London Plan. Abercrombie saw the open spaces of the Lea Valley as a great opportunity for regenerative planning. He proposed joining together the green – and blue – open spaces into a ‘great regional reservation’ for the benefit of all Londoners.

More than 20 years later, Abercrombie’s dream became reality. A Regional Park and a Regional Park Authority were created, funded by the ratepayers of London, Essex and Hertfordshire, and stretching for 23 miles, from Stratford in East London to Ware in Hertfordshire. The Authority’s mission, set out in its founding Act of Parliament: to develop, improve, preserve and manage the Park as a place for the occupation of leisure.

The infant Park Authority set about its mission with a will, assembling holdings of land which, here in Hackney and Leyton, included Walthamstow and Leyton Marshes, the Waterworks site and Springfield Marina. Other sites, including the Middlesex and Essex Filter Beds, were added in the 1980s, forming a springboard to create the great regional reservation envisaged by Abercrombie.

Today, we see this vision of the Park threatened and beset from every quarter, from housing developments, land sales and laissez faire planning, and the worst of it is that most of the severe threats come from the Park Authority itself. Far from cohering the Park as a place for the occupation of leisure, round here the Park Authority seems more preoccupied with dismembering it.

What has gone wrong? And what needs to change? Before attempting to answer these questions, let us look at the three main threats to our part of the Lea Valley.

1) The ice centre

The present ice centre was built by the Park Authority in the 1980s. We in Save Lea Marshes do not, for one moment, dispute its role as a popular sporting facility, valued by novice skaters and experts alike, but it is a blot on the landscape. It has urbanised this section of Lea Bridge Road and encouraged house builders to push for development nearby. It is, however, coming to the end of its life.

The way forward, the Park Authority has decided, is a much, much bigger ice centre – two ice rinks side by side, one for elite skaters and one for general use – and they plan to build it on the site of the current building. A new ice rink will be broader and deeper, dominating more of Lea Bridge Road with its broader frontage, pushing back deeper into the Marshes and eating up more protected Metropolitan Open Land.

The Park Authority purportedly reached this decision after carefully scoring the Lea Bridge Road site against three other possible sites, including the Waterworks Centre and car park by Lea Bridge station, and unused land at Temple Mills adjacent to the Lee Valley Hockey and Tennis Centre at the northern end of the Olympic site.

Save Lea Marshes argued that either of those sites, although each with their own issues, would have been better than the current site, less disruptive to the integrity of the Park, more convenient for users and less likely to cause congestion. But the Park Authority chose the present site, using a scoring system that contained many curious assumptions and, most importantly, contained absolutely no weighting for environmental impact. If it had, the ice centre would not be planned for the present site.

We now know that the Authority is working to sell, lease or develop those alternative sites. The Authority will say that it had absolutely no thought of raising money from these sites when it scored them as possible locations for the new ice centre and only looked at raising money from them after they were ruled out. However, we think the facts strongly suggest the Authority had it in mind to sell off those sites all the time.

A small, curious but interesting fact: one reason why the Authority rejected the Temple Mills site was that it was within the blast zone of the storage facilities for the hydrogen-powered buses stationed nearby. That, apparently, made the site a no-no for an ice rink. The Authority is now busily negotiating to raise money by leasing the site – more Metropolitan Open Land – for a hotel. Guests can be assured that the Authority no longer considers the blast zone a danger!

Meanwhile the Park Authority has been working, full steam ahead, on the current site and it has already spent a fortune on planning and on consultants.

The Park Authority, with its duty to preserve and manage the Park, appears focused on desecrating Metropolitan Open Land.

2) The Waterworks

Back in the 1980s and 1990s, when governance of the Park was better, the Authority acquired the defunct Essex Filter Beds from Thames Water, creating a much-cherished nature reserve and building the Waterworks Centre as an interpretation centre to serve the Reserve and the Authority’s adjacent pitch-and-putt golf course.

Twenty years or more later, the Authority has closed the pitch-and-putt course and has all but abandoned the Waterworks Centre, which is now rarely open and is virtually devoid of activity. And it has been trying to sell the land for housing.

The land is Metropolitan Open Land and, as such, is protected from inappropriate development. However, the Park Authority has been lobbying Waltham Forest Council to de-designate the land as Metropolitan Open Land and rezone the Waterworks Centre, car park and a huge swathe of land behind the building for housing.

Local people discovered the Park Authority’s plans when Waltham Forest Council launched its Lea Valley Eastside Vision in December 2016. The idea that a great chunk of parkland would be sold off to the highest bidder to raise capital to build the new ice centre, leaving the Waterworks Nature Reserve hemmed in by housing, caused a public outcry.

Today, Waltham Forest’s Draft Local Plan shows the area as Metropolitan Open Land and does not list it as a possible site for development. The Park Authority has publicly drawn back, for the moment, from plans to sell off the Waterworks site and now says it does not need the money from the land sale to pay for the new ice centre. But, critically, the Park Authority appears to have more-or-less abandoned any interest in the Waterworks site except to raise money by hiring it out for events. It has also offered up much of the Waterworks site in response to Waltham Forest Council’s call for development sites. And it has been touting the land to developers. We believe the Authority is biding its time until a new opportunity to sell off the site arises.

The Park Authority, with its duty to preserve and manage the Park, is focused on selling off protected Metropolitan Open Land.

3) The ex-Thames Water Depot site

Walking down Lea Bridge Road from the Waterworks and towards Hackney, we come to the secret and secluded ex-Thames Water Depot: the site, until the 1980s, of filter beds forming part of the Lea Bridge Waterworks and the site, too, where the Lea Valley Park project was launched at an event addressed by the Duke of Edinburgh in 1964.

Thames Water filled in the filter beds in the early 1980s and subsequently used the site as an operational depot until it no longer needed it and sold it – for £33.3 million + VAT – to the Secretary of State for Communities and Local Government acting on behalf of what is now the Education and Skills Funding Agency (ESFA), which brought forward a plan to build two academy schools. In a bold and principled decision, Waltham Forest Council rejected the ESFA’s planning application as incompatible with the site’s status as Metropolitan Open Land and the ESFA has not appealed the decision. The future of the ex-Thames Water depot is up for grabs.

The Park Authority is now, in one sense, the main player in this saga. However, it did have the opportunity to acquire the site for nothing back in 2011 as compensation for land given up to the Olympic Park Authority. With the lack of vision typical of the Park Authority, it turned down the offer because it could not work out a way of turning the site to ‘good account’.

While the Park Authority purports to care about the future of the site (as part of its statutory planning process, the Park Authority firmly committed itself to supporting ‘Park compatible uses’ for the site), it seems reluctant to step forward and defend the openness of the site. Perhaps Save Lea Marshes’ bold vision for it as a place for wild swimming and a place where people learn to live harmoniously with nature through small-scale food growing or sustainable foraging will capture the Park Authority’s imagination as it seems to be capturing the imagination of local people. We can live in hope anyway!

In the meantime, we continue to be disappointed that the Park Authority failed to snap up the site when it had the chance and thereby failing in its statutory duty to preserve the Park.

The Corporate Land and Property Strategy

Back in 2017, the Authority approved a new Corporate Land and Property Strategy. According to the Authority’s own documents, a mysterious and secretive group called the Land and Property Working Group:

has identified broadly areas of land for potential disposal which could be considered as land not required for regional park Purposes […] we will aim to dispose of those parcels of land over the next 10 years when market conditions are appropriate to ensure best capital receipt of revenue income. [emphasis added] (www.saveleamarshes.org.uk/DocumentSearch/display.php?Document=59)

The Park Authority has steadfastly resisted disclosing where these areas of land are. In the meantime, the landholdings the Park Authority has identified as ‘no longer required’ are undoubtedly being left fallow and offered up for development whenever the local riparian councils issue calls for development sites. This is why we strongly suspect, even though the Park Authority won’t say so, that the Authority’s estate at the Waterworks site is on the list for ‘potential disposal’.

This is a strange carry-on. When a strategic authority such as the Park Authority is set up to protect and manage open space, it should focus on strategic land assembly in order to carry out its purposes. That is the way other great open spaces, such as Epping Forest and Hampstead Heath, have been built up.

Yet the Park is engaging in an underhand policy of dismemberment.

We accuse the Park Authority

The statutory duties of the Park Authority are clear, and it is failing to exercise it powers and use its resources to protect and enhance the Park as it is required by law to do.

The Park Authority finds itself in a bind, certainly, one which affects many public bodies when political pressures force it to choose between its own institutional survival and fulfilling its purpose. The political pressure, in this case, comes mostly from Conservative-run councils in South London who are determined to drive down the taxes paid to fund the Park by cutting costs, selling land and building venues they hope will be profitable. In the meantime, the green spaces of Abercrombie’s vision are up for grabs to the highest bidder.

We accuse the Park Authority of defaulting on its purpose: reneging on its commitments and covering up its intentions. We deserve much better.

Posted in Uncategorized | Tagged , , , , , , | Comments Off on The Lee Valley Park: What went wrong? Nous accusons.

Object to unparalleled noise next to the Waterworks Nature Reserve

Posted on 21 February 2020 by SLMAdmin

Object to a loud dance music festival at the Waterworks!

If you think, like we do, that a festival that aims to ‘deliver the volume and sound pressure proper dance music deserves’ is inappropriate next door to a nature reserve then we encourage you to object to the licence application made by Waterworks Ltd by 10th March.

You can see the licence application here: https://drive.google.com/file/d/19-1i5VBpBtNURWx29IQ7C3rScYmH0_Hj/view.

You can use the sample objection below or you can write an objection of your own. If you do the latter, please remember to focus on the four key grounds on which the licence will be decided, namely:

  1. The prevention of crime and disorder.
  2. Public safety.
  3. The prevention of public nuisance.
  4. The protection of children from harm.

Please note that you must include your full postal address for your objection to be considered.

Sample Objection

Licensing Service
3 The Square
London,
E10 5NR
licensing@walthamforest.gov.uk

To whom it may concern,

I should like to make a representation in response to the application for the grant of a Premises Licence at Lammas Road, Leyton, London, E10 7NU, by Waterworks Event Ltd. The reference number for the application is WAT1613773.

I live in [Walthamstow] but spend much of my spare time in the vicinity of the Waterworks Centre, the ‘premises’ in question.

I wish to object to the application and to request that the application is turned down. My objection is on three grounds:

The prevention of crime and disorder

Under Section 1 (5) of the Wildlife and Countryside Act 1981, it is an offence to intentionally or recklessly disturb any wild bird included in Schedule 1 of the Act while it is building a nest or is in, on or near a nest containing eggs or young, and it is an offence to intentionally or recklessly disturb dependent young of such birds. There is no doubt that the noise from the festival will disturb the birds at the Waterworks Nature Reserve. The Lee Valley Regional Park Authority states on its website that the following birds, all listed in Schedule 1, can be seen at the Waterworks Nature Reserve: Green Sandpiper, Wood Sandpiper, Black-tailed Godwit and Kingfisher: (https://www.visitleevalley.org.uk/en/content/cms/nature/nature-reserve/waterworks-nature-reserve-midd/wildlife/).

The Lovebox Festival held in Victoria Park in 2012 – one of whose organizers (Julian Butterfield) is also an organizer of the Waterworks Festival – had an average of 192 police officers and drug detection dogs on duty each day. Yet, according to the Metropolitan Police, despite the large number of police and private security personnel and resources used to police Lovebox […] there were 452 recorded offences over the three days of the festival. This represents an unacceptable level of crime that cannot be tolerated. Most of the offences related to theft and drugs:

  • One of the reasons for the increase in the number of thefts is the targeting of festivals in general and Lovebox in particular by international criminal gangs. Their sole intention when coming to these festivals is to steal as many mobile phones and other high value items as possible. They arrive in London prior to festivals taking place where they are provided with tickets before entering the venue and start to commit thefts on an industrial scale.
  • Lovebox attracts drug users and where there are drug users there are people that supply then. This means that drug dealers will attend Tower Hamlets with the sole intention of selling drugs to those attending Lovebox. Drug dealers will not limit their selling of drugs to those attending Lovebox, they will sell to anyone who wants to buy them. With one of the largest youth populations in the country this represents an unnecessary risk of drugs bring [sic] sold in Tower Hamlets.

There is nothing to suggest the Waterworks Festival will be immune from the criminal gangs that targeted Lovebox, as the two festivals are very similar in nature. (Quotes from http://democracy.towerhamlets.gov.uk/documents/g4248/Public%20reports%20pack%2011th-Jun-2013%2018.30%20Licensing%20Sub%20Committee.pdf?T=10, pages 61–72 of the PDF.)

It is unlikely that ticket holders will want to stop partying at 23:30 and with so much green space nearby there is a very real danger of informal and illegal raves springing up on nearby Hackney Marshes, Leyton Marshes and Walthamstow Marshes. These will carry on late into the night, will cause significant damage, will be a magnet for the drug dealers and other criminals already at the festival as well as local opportunists, and will be difficult to police given the lack of lighting and CCTV cameras.

Many ticket-holders are likely to leave the festival and head home along the canal towpath. There have been a spate of serious muggings along the canal in recent years and people have also been raped on the marshes. These are serious offences that will have a long-term effect on the victims. While many people would normally avoid the canal towpath and the marshes at night, alcohol, drugs and the fact that they have spent the night enjoying themselves on the marshes may cause revellers to let their guard down and put themselves at significant risk.

Section 18 of the application form asks the applicant to describe the steps they intend to take to promote the four licensing objectives. Yet the application seems to do nothing more than state the current legislation regarding the licensing objectives. It does not explain, for example, how it will manage ‘door supervision’ at a site that does not have any doors. It does not explain how ingress and egress will be managed and how theft will be prevented. It does not say how many staff will be at the entrances and exits or how organisers will ensure that no one under the age of 18 is served alcohol and that beverages purchased on the premises are not consumed outside the premises.

It seems to me that Waterworks Ltd has given little or no thought to any of these issues. This is in marked contrast to the detail they have provided about the genres of music that will be playing. This suggests that the applicant is focused on the music and not on managing the event to ensure crime and disorder are prevented, that there is no public nuisance and ticket-holders are kept safe at the event and afterwards.

The prevention of public nuisance

The application is for a period of three years, from 22/8/2020 to 28/8/2022, and sets a precedent for turning an open green space used by local residents into ‘premises’ for live music. If one application is granted, more could follow, and the impact of the noise and light pollution on local residents will be significant.

In its event advertising, Waterworks Ltd says, Unlike many other London locations we are remotely situated in relation to our nearest residential neighbours which will allow us to achieve unparalleled sound quality. It also states that it will, deliver the volume and sound pressure proper dance music deserves; we are confident of levels that are unparalleled in east London. The implication is clear: the organisers want this event to be very loud indeed. And it will need to be if music from five different stages is to be heard by five different audiences in such a small space. Yet the site is not remote and many, many people will be disturbed by the music. The one-day Holi Festival that took place on the site in 2018 was extremely distressing for local residents, who spent a day disturbed by loud music and DJs swearing. It is also quite common for people living in Walthamstow to hear concerts taking place in the Queen Elizabeth Olympic Park if the wind is blowing in a certain direction. Sound travels in this part of London, and this particularly loud event will disturb a huge catchment area for three days each summer. Instead of spending three days with the windows open enjoying time outside in nature on the marshes, many local people will be shut inside their homes with their windows closed.

The application mentions a wind down music policy, but gives no details as to what this might be. 14,999 people will take some time to leave the site and there will be considerable noise continuing well into the night as a result. This will have a significant disruptive effect on the sleep patterns of local residents, who can expect to be disturbed into the early hours of the morning as rowdy and drunken revellers head home. It is also likely that ticketholders will litter and urinate on their journeys home, spreading the nuisance behaviour well beyond the immediate vicinity of the site.

Looking at the map submitted with the application, the boundary of the ‘premises’ appears to abut the eastern, southern and western boundaries of the site blocking the well-used public footpaths used by walkers and cyclists. It is unclear, from the application, how many days people will have to find alternative – and perhaps more dangerous – on-road routes to go about their business.

In a borough that has declared a climate emergency, it would seem sensible to extend the definition of ‘public’ to the environment. The site is next door to the Waterworks Nature Reserve and is designated as part of a Site of Metropolitan Importance for Nature Conservation (SMINC). If the noise and light pollution will be significant nuisance for human neighbours, it will be catastrophic for neighbouring wildlife, particularly birds. This is simply an inappropriate place to hold a one-off one-day music festival, let alone an annual three-day event.

The Walthamstow Marshes Site of Special Scientific Interest (SSSI) is very close to the proposed ‘premises’ and birds particularly will be seriously impacted by the noise coming from the event. Walthamstow Reservoirs, another Site of Special Scientific Interest (SSSI), a RAMSAR site and part of the Lee Valley Special Protection Area (SPA), is not in the same close proximity but birds will be affected by the noise and light emanating from the event. An SPA is a protected areas for birds, classified under the Wildlife and Countryside Act 1981 (as amended) and the Conservation of Habitats and Species Regulations 2010 (as amended) in England, Scotland and Wales, and an event that is likely to cause significant harm to a protected site, as this event surely will do, should not be permitted.

Although the licensing process is not directly impacted by the London Plan, it is important to note that Policy 7.19D of the current London Plan makes it clear that proposals should give the highest protection to sites with existing or proposed international designations (SSSIs, SPAs and Ramsar sites) and give strong protection to sites of Metropolitan Importance for Nature Conservation (SMINCs). Granting a licence for a loud music festival would be at odds with this strategic proposal.

Public safety

There is nothing in the application that suggests Waterworks Ltd has given robust consideration to the issue of public safety, particularly whether the site is large enough to accommodate 14,999 people. The map shows five stages squeezed into a relatively small area, presenting a very real danger of overcrowding and consequent crush injuries.

For these compelling reasons, we kindly request that you refuse to grant a licence to this application.

Regards,

[Your name and full postal address, with postcode]

Posted in Waterworks | Tagged , , | 3 Comments

East London Waterworks Park

Posted on 23 November 2019 by SLMAdmin

Campaigners reveal vision for wild swimming in Waltham Forest

Save Lea Marshes and CPRE London have joined forces to campaign to transform the historic filter beds on Lea Bridge Road, once used by Thames Water, into a place for wild swimming.

Campaigner Harry Hewat said, I’ve always been shocked by how dislocated this landscape is, with so many barriers and fences that detract from the natural beauty of the area and the ability to roam. This site is the missing piece of the jigsaw. Opening it up will stitch together Leyton and Walthamstow Marshes to the north, the Waterworks Centre Nature Reserve to the east, Hackney Marshes and Middlesex Filter Beds to the south and the river and towpath to the west to create a huge urban park. We’re calling it the East London Waterworks Park!

Abigail Woodman of Save Lea Marshes said, We want people to sign our petition. The site is Metropolitan Open Land and should be returned to the people of East London as a place for wild swimming and a place where people learn to live harmoniously with nature through small-scale food growing or sustainable foraging. It should be rewilded, with the built environment reclaimed by nature in some places and landscaping and planting in others.

Peter Mudge, a local resident, said, Retaining and enhancing the site’s historic structures, including the unusual octagonal sluice building, gives us an opportunity to showcase the area’s industrial heritage.

Campaigner and architect/landscape architect Kirsty Badenoch said, In our time of environmental crisis, chances to protect and reclaim areas of inner-city Metropolitan Open Land have never been more important. This currently under-utilised site has a strategic position within the Lea Valley Regional Park and this is a rare opportunity to reconnect the wider ecologies and provide valuable community green space.

Alice Roberts of CPRE London said, The site is currently owned by the Education and Skills Funding Agency (ESFA) and is within the Lee Valley Regional Park, and we call on Waltham Forest Council to work with the ESFA and the Lee Valley Regional Park Authority to take full advantage of this once-in-a-lifetime opportunity to create a unique park uniting Waltham Forest and Hackney.

Posted in Thames Water site, Waterworks | Tagged , , | Comments Off on East London Waterworks Park

East London Waterworks Park

Posted on 23 November 2019 by SLMAdmin

Save the Lea Bridge Waterworks

Hidden behind high fences, trashed by Thames Water, sold without consultation. There has been a conspiracy of silence to rob the people of East London of the Lea Bridge Waterworks, a site of huge historical significance, and a vital link between the green spaces of the Lee Valley Park.

The history of the site

Until the 1960s the Thames Water Site was part of the Lea Bridge Waterworks, providing water to the people of London. A complex of 25 filter beds were served by an aqueduct bringing water from the Walthamstow reservoirs further north. The plan shows the site as it used to be:

(Source: the view from the bridge)

The site was closed after the new Coppermill Water Treatment Works were opened. The Lee Valley Park Authority eventually agreed to take over the Middlesex Filter Beds (after first suggesting they should be filled in to make football pitches!) and later took on the Essex and Leyton Filter Beds.

Today, the Middlesex and Essex Filter Beds are beautiful, important and secluded nature reserves. They show what can be achieved when industrial sites are sensitively managed to return to nature.

The whole of the site was designated as Metropolitan Open Land in the 1970s. Looking at this plan it is easy to understand why.

The trashing of the Lea Bridge Waterworks

In the 1980s, the so-called Essex Number One Beds were retained by Thames Water as an operational site. Originally, Thames Water obtained planning permission to fill in the beds to create a temporary pipe store. From that starting point, Thames Water have gone on to occupy the site for a succession of uses including the project with Clancy Docwra to replace the East London water mains. In the process they have completely trashed the site without any regard for its status as Metropolitan Open Land. All this has gone on invisibly behind the high fences surrounding the site.

Thames Water also demolished the old engine houses although there are some characterful buildings surviving close by the Lea Bridge Weir, including the Sluice House.

All mouth and no trousers – neglect by the Lee Valley Regional Park Authority

The plan shows that the Thames Water site could be a connecting thread between Leyton Marshes and Hackney Marshes to make the open spaces of the Lea one continuous whole.

The Lee Valley Regional Park Authority is supposed to act as the Park’s custodian, threading the different parts together to make a playground for London, and indeed the Authority frequently claims to have done precisely this. However, the reality is very different. In plan after plan they have committed to protecting the site as Metropolitan Open Land, but they have done absolutely nothing about it.

This is what the Park Authority propose in their current Park Plan:

Work with Thames Water, London Borough of Waltham Forest and other stakeholders to identify options for a development at the Thames Water Depot site that will bring this site into a Park-compatible use. Appropriate uses would include (but are not restricted to) one or more of the following:

  • A waterside visitor hub incorporating leisure-related uses
  • A biodiversity-based and/or heritage-related visitor attraction
  • Accommodation serving visitors to the Park
  • ‘Community’-related activity and uses as defined by the Authority’s adopted Thematic Proposals
  • New recreational or sporting facilities.
The type, scale and design of any development would need to be appropriate in term of the site[‘]s designation as Metropolitan Open Land and its location within the heart of the Regional Park.

The Park Authority even had the opportunity to realise its plan back in 2011, when it was offered this site as compensation for land that it was required to give up for the Chobham Manor housing development adjacent to the Olympic Park. It decided to take cash compensation instead; cash that has been spent on its large leisure facilities and not on improving the landscape. It then stood back and did nothing while the site was purchased for a purpose that is anything but Park-compatible use.

Corporate greed wins the day

Thames Water used to be a publicly owned utility, owned and operated for the public benefit. As we know to our cost, Thames Water has, since privatisation, had a series of owners bent on loading the company with debt and extracting as much money as they can.

When the last Walthamstow Planning Strategy – the so called Core Strategy – was being adopted, Thames Water lobbied for the site to be re-designated for a “commercially viable” development. They were unsuccessful. The Inspector at the Public Enquiry confirmed that the site’s status as protected Metropolitan Open Land should continue.

Undaunted, Thames Water found a willing, perhaps even gullible, buyer in the Secretary of State for Communities and Local Government acting on behalf of the Education Funding Agency (now the Education and Skills Funding Agency and hereafter “ESFA”) who paid the vast sum of £33.3 million + VAT to acquire the site for a pair of free school academies.

ESFA must have been aware that the site was MOL but must have been (and still be) confident that a pliable Planning Inspector will approve the change of use.

Not wanted here

Waltham Forest Council were clearly not consulted about ESFA’s plans and do not support the proposed free schools. The site is far from those parts of the borough needing more school places and in effect, every pupil from Waltham Forest attending the school would have to travel down Lea Bridge Road, one of the most congested roads in London. It is just about the worst place in Waltham Forest to build a new school. At the Planning Committee meeting on 25 March 2019, Waltham Forest Council rejected the application to build two free schools on the site, confirming its status as Metropolitan Open Land and making it very clear that the schools were inappropriate development for Metropolitan Open Land.

What happens next?

We all know – too well – the script ESFA are following. They will go to appeal, supported in the background by the Government (which has paid a grotesque sum for the site), and will expect the inspector to overturn the Council’s decision. It has happened already at the Olive School site in Hackney.

But it doesn’t have to be this way. Save Lea Marshes is confident that the case for two new schools is so weak that the ESFA are deluding themselves if they assume they will eventually get planning permission.

There is another way and we have to make the case to protect this site.

  • The Lea Bridge Waterworks is Metropolitan Open Land and its status as such should be protected.
  • The Lea Bridge Waterworks plays a critical role in connecting the marshes of the Lower Lea Valley.
  • The Lea Bridge Waterworks backs on to one of the most beautiful and unspoiled sections of the River Lea, the haunt of kingfishers, stretching from the mighty Lea Bridge Weir to Friends Bridge.
  • The Lea Bridge Waterworks contains significant remnants of its industrial heritage, adjacent to the weir, which can be interpreted to promote understanding of this important historical site.
  • The Lea Bridge Waterworks can be linked to the Essex and Middlesex Filter Beds and managed and re-wilded over time.

There is also a point of principle to protect. Thames Water have knowingly destroyed the site. The ESFA have knowingly overpaid for this site, expecting compliant authorities to give them what they want. The Lea Valley Regional Park Authority has knowingly stood by, wholly disregarding its own Park Plan and making not the slightest attempt to protect the site, in dereliction of its duties to protect the Park.

Don’t let them get away with it.

Support Save Lea Marshes in calling for the Lea Bridge Waterworks to be protected from development and opened up to public access.

Posted in Thames Water site, Waterworks | Tagged , , | 2 Comments

Help Make Lea Bridge Waterworks a Wild Haven – with swimming pond!

Posted on 26 September 2019 by SLMAdmin
Kings Cross Pond (www.travelstay.com/attractions/kings-cross-pond_Hotel_List.htm#search)

After a really successful community meeting at the Waterworks on 16th September, we are delighted to announce our vision for the Lea Bridge Waterworks site (formerly the Thames Water Depot): a place protected from development and opened up to public access, re-imagined as a place for wild swimming and community horticulture, with the vital habitat along the river designated as a nature reserve and connected to the neighbouring Middlesex Filter Beds Nature Reserve, with other parts of the site left to ‘re-wild’.

To help us try and achieve this vision, the first step is to respond to the Waltham Forest Local Plan:

  1. Write to planning.policy@walthamforest.gov.uk by 30 September 2019 giving your name and address. If you are writing from outside the borough please underline that MOL and Green Belt are important for neighbouring boroughs and all of London.
  2. A suggested short response is set out below. You can of course adapt this or make your own suggestions for the site.
  3. If you would like to know more, the consultation document can be found here. A map of the borough’s protected land is here.

Dear Sirs,

Response to Waltham Forest Local Plan Consultation

The Lea Bridge Waterworks (currently Thames Water Depot) should categorically not be considered for development as it is a critical part of the wider area of Metropolitan Open Land and the Lea Valley Regional Park, and any development outside of the existing footprint would seriously impact on its permanence and openness.

This site should be protected from development and opened up to public access, re-imagined as a place for wild swimming and community horticulture, with the vital habitat along the river designated as a nature reserve and connected to the neighbouring Middlesex Filter Beds Nature Reserve, and other parts of the site left to ‘re-wild’.

  • The existing concrete slab could easily be removed in some areas to reveal the buried filter beds below.
  • A pond area should be created from a section of the old filter bed, re-imagined as a place for wild swimming.
  • The site should be re-wilded, allowing nature to reclaim the built environment naturally in some places with replanting and landscaping in others.
  • The site should be a space for people to learn how to live harmoniously with nature, perhaps through small-scale good growing or sustainable foraging or a social enterprise or community garden centre like Growing Concerns in Tower Hamlets or Living Under One Sun sites in Haringey.
  • It should be a place to showcase the area’s industrial heritage by retaining and enhancing the site’s historic buildings.
  • It is a valuable part of the “green lung”, linking the Middlesex Filter Beds and the Essex Filter Beds, and should be reconnected to the surrounding sites. Retaining an area of public hard landscaping would complement the surrounding area.

Yours faithfully,

Posted in Thames Water site | Tagged , | Comments Off on Help Make Lea Bridge Waterworks a Wild Haven – with swimming pond!

Public Meeting

Posted on 6 September 2019 by pjm

PUBLIC MEETING

to launch a campaign
to call for the Lea Bridge Waterworks
 (the Thames Water Depot site on Lea Bridge Road)
to be protected from development
and opened up to public access

7:30-9:30pm, Monday 16th September 2019
at the Waterworks Centre

Everyone is welcome!

Organised by Save Lea Marshes
 in association with the London branch of
the Campaign to Protect Rural England

Posted in Thames Water site | Tagged | Comments Off on Public Meeting

More objections to the proposed Ice Centre on Lea Bridge Road

Posted on 14 August 2019 by pjm

The following objection has been submitted to the LVRPA’s consultation on the new Ice Centre. Feel free to use any of these arguments in your own submission (and see the blog immediately after this one for further arguments).

I wish to object to the proposed new Ice Centre on the Lea Bridge Road.

The LVRPA has given its reasons for wishing to locate the Ice Centre on the Lea Bridge Road in the Minutes to the Additional Authority Meeting of 16th June 2016. This document discusses at length the results of the Feasibility Exercise, which examined the relative merits of the Lea Bridge, Eton Manor, Waterworks and Picketts Lock sites. It would appear that the main reason why the LVRPA has chosen the Lea Bridge site is that it scores higher in the Scoring Matrix than the other sites. The Scoring Matrix is designed to lend the exercise a spurious air of objectivity, by computing a numerical score for each site. But such a calculation can only be as reliable as the values that are input into it, and these values are themselves subjective. As I shall demonstrate, many of them are clearly wrong – some have always been wrong, and facts have changed since 2016 with the consequence that others are now also wrong. For brevity, I shall only consider the values for the Lea Bridge and Eton Manor sites.

  1. 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 the Lea Bridge and Eton Manor sites are similar distances from the same population centres, so they can be expected to attract much the same clientele.
  2. Adjacencies of other leisure uses. The Eton Manor site has a score of 3. The leisure uses adjacent to Eton Manor (which are mainly sporting) are exactly the sort of uses likely to appeal to patrons of a skating rink. It should have a much higher score.
  3. Access by cycle. The Lea Bridge site has a score of 4, and the Eton Manor site 3. The approach to Eton Manor by cycle is much easier than that to the Lea Bridge site. The score for Eton Manor should be at least as high as that for Lea Bridge.
  4. 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.
  5. Access by public transport. Both sites have a score of 4. This is odd because, according to the LVRPA’s own figures, Eton Manor is worse served than Lea Bridge by public transport. However, these figures are themselves wrong, as I explain in Appendix B. In fact, Lea Bridge is worse served than Eton Manor by public transport, so its score should be reduced.
  6. Fit on site. The Lea Bridge site has a score of 5, and Eton Manor 4. According to the latest (2019) plan the footprint of the proposed new building has been considerably reduced, so both sites must surely now score equally.
  7. Ice centre and on-site parking. This has a weighting of 10; the Lea Bridge site has a score of 4, and Eton Manor 1. According to the latest (2019) plan the number of car-parking spaces has been considerably reduced, in line with transport policy. As a consequence of the transport policy, the weighting should be considerably reduced. And since the requirement for spaces is now less, the score for Eton Manor should be increased.
  8. Ability for other revenue-generating possibilities. The Lea Bridge site has a score of 4, and Eton Manor 2. This appears to refers to the financial viability of an on-site gym. The distance between the Lea Bridge and Eton Manor sites is about 2316m. Within a radius of half this distance of the Lea Bridge site, there are four gyms (shortly to be increased to five, by the addition of a gym at 97a Lea Bridge Road); within a radius of half this distance of the Eton Manor site, there are six gyms. This is not a significant difference (see Appendix C). So the difference in the competition for gym provision near to the two sites is not very significant. In any case, there are other possible means of generating revenue besides the provision of a gym. Therefore the score for Eton Manor should be increased.
  9. Grounds/landscape constraints. The Lea Bridge site has a score of 4, and Eton Manor 3. It is not clear why Eton Manor scores lower than Lea Bridge. Eton Manor is a fairly barren site close to a motorway, whereas the existing site is close to an SSSI. The latest (2019) plan entails felling a number of mature trees at Lea Bridge, whereas there are no mature trees at Eton Manor. It is also acknowledged that there are a number of buried services that constrain development at Lea Bridge. Therefore the scores for Lea Bridge and Eton Manor should be swapped round.
  10. Impact on business plan. The Lea Bridge site has a score of 5, and Eton Manor 3. This is an example of double-counting, since this issue has already been taken into account under “Ability for other revenue-generating possibilities” above.

Click here to see a copy of the Scoring Matrix. The LVRPA’s original scores and weightings are on the left. On the right the scores and weightings are corrected to resolve the issues described above. Where a value is increased it is coloured red; where it is decreased it is coloured green. As can be seen, the score for Lea Bridge reduces from 933 (75%) to 910 (73%), and the score for Eton Manor increases from 882 (71%) to 953 (76%), as a result of these modifications.

Beyond the Scoring Matrix, much has been made of the idea that the Lea Bridge site can “provide a gateway to the Lee Valley Regional Park” and a “wider visitor offer with its central location and visibility on the road frontage”, and it is claimed that the latest plan will result in “opened up views on to the marsh”. This is absurd. It is proposed that a large building should be replaced by an even larger one. How can this open up views? And why is there a need to provide a “gateway” and a “wider visitor offer” in any case? The marshes are already visited by large numbers of people. They go there to seek isolation from the hurly-burly of London. Any increase in visitor numbers can only be detrimental to that experience, quite apart from the damage that more people will do to the ecology of the marshes. If the LVRPA really feels the need to trumpet its presence to passers-by, it could do so less harmfully at Eton Manor.

Finally, there is another good reason to put the new Ice Centre at Eton Manor. When the Olympics came to London, the allotments at Bully Point were destroyed, and an area of Marsh Lane Fields was fenced off and converted into temporary allotments for the holders who had been displaced. It was clearly stated at the time that this was only a temporary measure, and that after the Olympics were over, the allotments would be moved to a permanent site in the new Olympic Park at Eton Manor, and the temporary site on Marsh Lane Fields would be restored to public open space. But that never happened. The allotments that were supposed to be temporary have become permanent. So the result is that a precious area of open space has been lost to the public. Now is a chance to put right that injustice. If the new Ice Centre is built at Eton Manor, the site of the current Ice Centre at Lea Bridge can then be cleared and returned to open space. That would go a considerable way to compensating for the loss of open space on Marsh Lane Fields.

Posted in Eton Manor, Ice Centre, Leyton Marsh, Marsh Lane Fields | Tagged , , , | Comments Off on More objections to the proposed Ice Centre on Lea Bridge Road

Save Lea Marshes objects to the LVRPA’s plans to build a new ice rink

Posted on 6 August 2019 by SLMAdmin

Save Lea Marshes will be submitting the following objection to the LVRPA’s consultation about their plans to develop a new ice rink. Please feel free to use some or all of what follows as your own submission to the consultation, which should be emailed to LVIC@communitycomms.co.uk or posted to https://leevalleyicecentre.commonplace.is/overview by the end of August 2019.

To whom it may concern

I am writing on behalf of Save Lea Marshes – a group of local people who campaign to keep the marshes of the Lower Lea Valley open, green and free from development – to object to the LVRPA’s plans to develop a new ice rink on the site of the current Lee Valley Ice Centre on Lea Bridge Road.

The objections can be summarised as follows, and each objection is dealt with in more detail below:

  1. A new ice rink should be built at Eton Manor, within the Olympic Park, and not on Lea Bridge Road.
  2. The land just behind the current ice centre, which will be swallowed up by the proposed development, is home to hedgehogs, an iconic species that is under significant threat.
  3. The LVRPA has not made the business case for a twin-pad ice centre in this location.
  4. The LVRPA has a history of breaking its promises. If the development does go ahead, there is nothing in the proposal to guarantee that the LVRPA will keep its promises to ensure the building has zero carbon emissions and is made of responsibly-sourced and environmentally-sound materials, and the high-quality environmentally-sensitive landscaping is both delivered and maintained.

The marshes are a very special place for a lot of people, for the old and the young, for the healthy and the troubled, and for everyone in between. Far more people find joy and solace in the marshes than will ever set foot in an ice rink. And, of course, the marshes are also home to plants, birds, insects and small mammals.

I would like the land the current ice rink is built on to be returned to green open space. To achieve this, it would be acceptable to build a new ice rink in the Olympic Park. The disturbance caused by the development and by the loss of some of Leyton Marsh will have a devastating impact on those who value the peace and quiet to help them navigate the ups and downs of life. Not to mention the dangerous precedent it sets for the gradual nibbling away of Metropolitan Open Land.

A new ice rink should be built at Eton Manor, within the Olympic Park, and not on Lea Bridge Road

The site of the current ice rink is Metropolitan Open Land and it should be protected from development. The current ice rink should be removed and the land returned to green open space, increasing connectivity between Walthamstow and Leyton Marshes, the Waterworks and Middlesex Filter Beds Nature Reserves, and Hackney Marshes.

Eton Manor is a much more appropriate site for a new ice rink. The LVRPA compared a number of sites in 2015 and decided that Lea Bridge Road was the most appropriate, but many of the reasons for choosing Lea Bridge Road over Eton Manor were, or have since become, invalid. To take some of the LVRPA’s objections to the Eton Manor site in turn:

“as a result of the poorer public transport provision it is estimated that the skating income will be lower at Eton Manor compared to the Lea Bridge Road sites”

The Lee Valley Ice Centre (LVIC) is served by two bus routes: 55 and 56 (the 48 is due to be withdrawn in a few months). Eton Manor is also served by two bus routes: 308 and W15. It is true that the LVIC has Lea Bridge Railway Station nearby, but Eton Manor is served by Leyton Underground Station which is only about two minutes’ walk further away from Eton Manor than Lea Bridge Railway Station is from the LVIC. Furthermore, Leyton Underground Station has far better and more frequent connections than Lea Bridge Railway Station. There is also a proposal to create a railway station at Ruckholt Road, which would be almost next door to a new ice centre built at Eton Manor. And, of course, Eton Manor is reached via fast trunk roads while the Lea Bridge Road is one of the most congested local roads in London.

“a fitness gym is a vital component of the business model. The Eton Manor site sits within a Queen Elizabeth Olympic Park development area which has a significant number of gyms.”

The distance between the LVIC and Eton Manor is about 2316 m. Within a radius of half this distance of the LVIC, there are four gyms, five if you count the proposed 24-hour gym at 97a Lea Bridge Road. Within a radius of half this distance of Eton Manor, there are six gyms; not a significant difference.

“the Eton Manor site currently has 140 parking spaces which are all needed at evenings and weekends; they will become a premium as the centre develops its programme. A new twin pad ice centre will need circa 220 parking spaces but there is insufficient space to accommodate this amount of ‘onsite parking’. Even if additional space could be found it is unlikely that the London Legacy Development Corporation would agree to this land being used because of their policy of traffic restraint.”

Waltham Forest Council also have a policy of traffic restraint and the current proposal for the new ice centre appears to suggest that the existing 140 car parking places at the LVIC will be retained or reduced, so the LVRPA’s previous requirements for car parking spaces have been downgraded and there is parity between the number of spaces available at Eton Manor and the number of spaces available at Lea Bridge Road. The LVRPA should not be undertaking activities that increase car usage anywhere and, consequently, it makes sense to cluster sporting venues at a sporting campus rather than spread them out and encourage more people to travel down the already crowded and polluted Lea Bridge Road. Major events at more than one of the venues at the same time are also likely to be very rare, so the perceived pressure on the existing spaces at Eton Manor is unlikely to materialise.

“continuity of provision is seen as key”

It will obviously be impossible to deliver continuity of ice if the Lea Bridge site is developed, but perfectly possible if Eton Manor is chosen.

“issues related to the Eton Manor site included: … – the blast zone”

It is assumed that this relates to the proximity of the bus depot on Ruckholt Road, where hydrogen is stored. However, it is clearly not a serious issue, because at the Authority Meeting on 25 April 2019, the LVRPA proposed building a hotel at Eton Manor; a hotel with a gym one might add!

“the indicative footprint for a new ice centre on the existing site was within the curtilage of the existing site”

According to the plans released as part of this consultation, the footprint of the proposed development will extend far beyond the curtilage of the existing ice centre and is going to be almost twice the size of the existing building. This is despite the fact that the LVRPA has reduced the footprint of the proposed build between 2016 and 2019. There is no reason why the proposed building will not fit on the Eton Manor site, a site that is far less ecologically sensitive than the Lea Bridge Road site. The Eton Manor site is fairly barren with no mature trees and close to a motorway, whereas the Lea Bridge Road site is close to an SSSI and a number of mature trees will need to be felled to facilitate the development. There are also a number of buried services that constrain development at the existing site; something that is not a factor at Eton Manor as far as we are aware.

The quotes are taken from the LVRPA report number A/4228/16, which can be read here: https://www.saveleamarshes.org.uk/DocumentSearch/display.php?Document=74, and the minutes from the Authority Meeting where the report was discussed which can be read here: https://www.saveleamarshes.org.uk/DocumentSearch/display.php?Document=75.

The land just behind the current ice centre, which will be swallowed up by the proposed development, is home to hedgehogs, an iconic species that is under significant threat.

Hedgehogs are a priority species under the UK Biodiversity Action Plan and data gathered during a survey in October 2016 proves that hedgehogs have made the strip of land behind the ice centre, where the mown grass meets dense scrub and trees, their home. Subsequent anecdotal evidence from dog walkers supports this evidence. This is land that will disappear inside the curtilage of the proposed development presenting us with a stark choice: would you like hedgehogs or an ice centre?

The hedgehog population in the UK is under increasing pressure, with surveys by citizen scientists in 2018 showing that hedgehog numbers have fallen by about 50% since the turn of the century (www.britishhedgehogs.org.uk/pdf/sobh-2018.pdf). Attempts to relocate hedgehogs away from the proposed site of a car park for HS2 and further into Regent’s Park have failed, demonstrating how territorial hedgehogs are (www.royalparks.org.uk/managing-the-parks/conservation-and-improvement-projects/hedgehogs/hedgehog-research-reports). These two facts combine to demonstrate that the proposed development will result in the eradication of hedgehogs from this part of Leyton Marsh. This is unacceptable, even more so if it is at the behest of an organisation that has a statutory obligation to conserve habitats and species and claims to value biodiversity. The LVRPA should be developing a Species Action Plan to support the population of hedgehogs on Leyton Marsh not destroying it.

The LVRPA has not made the business case for a twin-pad ice centre in this location.

The LVRPA claims that the LVIC “attracts around 279,000 visits a year”and that the “new venue would welcome 557,000 visitors a year, making it financially viable long into the future”(https://leevalleyicecentre.commonplace.is/about). Where is the evidence that supports these claims?

A detailed breakdown of attendance figures has never been provided, nor has a methodology demonstrating how the proposed increase in visitors has been calculated. The projected figure appears entirely hypothetical and a convenient doubling of the current number of visits, while it is unclear how many of the current 279,000 ‘visits’ a year represent people paying to skate and how many represent, for example, parents waiting around for their children’s classes to finish or people popping into the centre to use the toilets. Local residents with a view of the entrance also confirm that the number of visitors appears to be significantly lower than 764 per day required to reach 279,000 visitors per year.

Data released by the new Sapphire Ice & Leisure Centre in Romford would seem to suggest that the number of people actually ice skating at the LVIC each year is at least 70% less than the LVRPA claims. The Sapphire Ice & Leisure Centre is in a busy central location near the station, has an ice rink of the same size and a similar number of public skating hours as the LVIC, plus a resident ice hockey team and it claims 76,650 people used the ice in the past year (www.havering.gov.uk/news/article/522/first_year_of_success_makes_sapphire_sparkle).

It would be tragic if we were to lose irreplaceable green open space to a white elephant.

The LVRPA has a history of breaking its promises. If the development does go ahead, there is nothing in the proposal to guarantee that the LVRPA will keep its promises to ensure the building has zero carbon emissions and is made of responsibly-sourced and environmentally-sound materials, and the high-quality environmentally-sensitive landscaping is both delivered and maintained

This is not the place to rehearse a list of promises the LVRPA has made and broken; suffice it to say that many of us are aware that the LVRPA plays fast and loose with the undertakings it makes to local people if it believes it will benefit financially. Those with long memories will, however, remember the planting promises the LVRPA made when the current ice centre was built in 1981, which never materialised and now enable the LVRPA to justify the current development because the land being swallowed up has, in their words, ‘little ecological value’!

The ecological enhancements the LVRPA are proposing are not dependent on the development. They could – indeed should – be done anyway. However, if they are contingent on the development of a new ice centre, what is the LVRPA doing to stop the contractor they employ weaselling out of its commitments? Even the architect and landscape architect employed by the LVRPA admit that it is nigh on impossible to find a way to ensure the plans they develop are implemented in full. It’s not hard to look a few years into the future and see a very big building filling up a large stretch of Lea Bridge Road, built from a material that makes it stand out and not blend in with the few trees left standing, completely blocking any view of the green open space behind it, surrounded by mown rye grass, filled with carbon-intensive plant equipment and promoting a sport that has come to be seen as increasingly anachronistic in the UK in the age of climate emergency.

This nightmarish vision of the future becomes even more likely when the proposals are scrutinised. For example, the LVRPA’s landscape architect told us that only seven trees will be cut down (five in the car park, one in front of and one behind the current ice centre), but a walk around the building shows that this cannot be true. There are at least four trees directly within the curtilage of the proposed building and it is impossible to understand how the line of trees – including willow, cherry, ash and poplar – to the north of the current building will survive given their proximity to the proposed boundary of the new ice centre. If they are not actually within the curtilage of the new building, it is difficult to see how they will not be removed to facilitate construction. We are similarly struggling to see how the leisure pad will be built within the space designated on the plan while the existing building continues to operate; there doesn’t appear to be room to fit it all in. Mistakes and obfuscations like this make it even harder to trust that the LVRPA will deliver on its promises.

Abigail Woodman
on behalf of Save Lea Marshes

Posted in Ice Centre | Tagged , , , | Comments Off on Save Lea Marshes objects to the LVRPA’s plans to build a new ice rink