Objection to Planning Application: 2013/0550/ADV
Address: The Waterworks Nature Reserve & Golf Course Lammas Road
Leyton E10 7QT
Change of use
1. Land use change and setting a permanent precedent.
The core land use planning issue at the heart of this Application is the proposed change of use of
open recreational land in order to provide enclosed private visitor accommodation facilities.
Whilst the use may (or may not) operate seasonally, and may alternate between the three
‘sites’, the change of use is permanent; as visitor accommodation is the principal and
predominant use proposed.
The pony trekking route does not require planning permission and, in any case, this is not an
application to establish a bridleway, which might offer some guarantee of public access and
openness.
The Application should be judged on the basis of the almost total loss of open recreational
land and the provision of private visitor accommodation across the entire site. Considered in
this light, the scheme is clearly excessive and unbalanced.
Whatever the arguments in favour of visitor accommodation, they surely cannot justify the
almost total exclusion of all other park related facilities and amenities on these sites;
including open parkland.
The Application subdivides a coherent area of open land into a series of sites with distinct
boundaries for which separate application may be brought forward in the future.
Regarding the normal 28 day period for temporary uses: There is some confusion over this
subject, partly because, the Olympic camp exceeded twenty-eight days. The Camping and
Caravanning Clubs claim certain exemptions, but this is not crystal clear in law or guidance.
The next effect is that this Application allows the Park Authority to further exploit grey areas
in policy and guidance and to extend the period of operation and extend the area of the
camp without the need for further applications.
Environmental impacts
2. Landscape quality
The Park Development Framework calls for major improvements to landscape quality as a
whole, ‘especially to the south of Lea Bridge Road and adjacent to the industrial areas along the
eastern edge of the area’ in order to ‘better integrate these areas into the wider valley
landscape’. This policy applies specifically to the application site.
The proposals remove the open character of the landscape, to be replaced with an
enclosed private camping facility across almost the entire site. There are no other proposals for landscape quality improvements associated with the
application and no indication that any surplus will be invested in landscape improvements.
The overall effect will be a material diminution in the overall quality of the landscape,
completely conflicting with the Park Framework.
The Framework states a number of tests to be met, which the proposed development fails:
o Impact on Metropolitan Open Land;
o The openness of the Park;
o Ecological value; and
o The need to enhance landscape quality and views through to the rest of the Park.
3. Views
The Park Framework aims to: ‘Maintain and improve views to and out from and across the
Marshes’.
The proposals will enclose the open land with fencing and views across the Waterworks,
the River and the Marshes with be blocked by fences, toilet blocks motor homes and large
tents.
4. Habitat
The Park Frameworks states the Authority will: ‘Work with the Environment Agency to protect,
enhance and manage the River Lee Navigation and River Lea and associated waterside
environment along the western boundary of this area as wildlife corridors interconnected with
the wider ecological resource on Walthamstow Marshes and Middlesex Filter Beds. Support the
naturalisation of bank habitats along the Navigation including fish refuges, the installation of
fish and eel passes and improved conditions for public access.’
There are no proposals to do so in this Application, which relates to a key site for the
realization of this policy.
The Park Framework seeks to: ‘Establish new habitat margins along the southern and western
boundaries of the Thames Water Depot to complement the ecology of the waterways and
reinforce connections between Essex and Middlesex Filter Beds.’
The proposals provide no such habitat margins and any improvements on adjacent sites will
be diminished by the ‘broken link’ of the Waterworks.
5. River Lea Corridor
The Park Development Framework states: ‘Landscape improvements should support and be
sensitive to the biodiversity of key sites and heritage assets and aim to strengthen the river valley
corridor and its associated waterways, maintaining and creating views out, to and from the
valley.’
Fences, toilet blocks, camper vans and large tents will block views across open meadows and
Marshes. The proposals will weaken the river corridor by bringing development close to the edge,
enclosing the riverbank corridor in one of the very few areas where there is undeveloped
land with an open character on both sides of the Natural River Lea.
The proposed development represent an erosion of the principles set out in the Park
Framework and, by degree, will restrain the ability of planning authorities to apply these
principles to other private riverside sites, such as the Lea Bridge Thames Water site.
Visitor accommodation planning
6. Visitor accommodation
The Framework considers a range of visitor accommodation options including ‘youth hostel style
facilities, pods and/or chalets to develop the site as a visitor base’ to encourage young people
and families to visit and complement visits to the Queen Elizabeth Olympic Park and the wider
Regional Park.
The Park Development Framework proposes the provision of visitor accommodation ‘as part
of’ the enhanced visitor offer at the Waterworks Centre’. This certainly does not indicate
that the entire golf area should be enclosed and dedicated to a private camping facility.
The Framework also states that: ‘Proposals for visitor accommodation would need to satisfy the
requirements of the sites designation as Metropolitan Open Land, and be of a scale and design
appropriate to the open character, ecological value and landscape quality of the Park’.
The proposals materially diminish the open character and landscape quality.
The Framework does envisage some visitor accommodation on the Waterworks site (including
the northern part of the No.2 Essex Beds). It does not:
o promote or specifically encourage campsites;
o direct that visitor accommodation facilities should be solely located on the
Waterworks, or that the use should occupy almost the entire site;
o encourage the loss of open recreation facilities in favour of private visitor
accommodation.
The Framework does, in fact, direct that the provision of accommodation should be
provided to support the facilities at the Waterworks, not result in their loss.
7. Alternative sites
The Framework promotes visitor accommodation on a number of sites in the area and across
the Park including:
o Essex Wharf
o Eastwood Wharf
o Thames Water Depot
These are private sites, not currently open to the public. They do not currently nor are they
planned to provide open recreation land. They are therefore more suitable for visitor
accommodation provision and should be considered first in any sequential test.Only when
these options are exhausted should the permanent loss of open recreational land be considered. The options have not been exhausted and the potential for these and other
private sites to provide visitor accommodation is significant.
It does not make sense for the Authority to exhaust it own reserves of open recreational
land whilst relieving the burden of mixed-use, park related development facilities on private
sites, as the Authority clearly failed to do at Essex Wharf.
The Park Authority claims camping generates a surplus. There is therefore no market failure
that would justify public intervention. The provision of these facilities should therefore be
left to the private sector and provided on private land.
Impact on access sport, recreation and other activities at
Lea Bridge
8. Learning and volunteering
The Park Framework states that the Waterworks is to be developed and promoted as the area’s
base for learning and volunteer related activity.
This policy will not be realised by providing visitor accommodation for pop festivals.
The events at the Olympic Park that Authority representatives claim are related to the
Waterworks proposals do not include learning and volunteer related activity.
9. Accommodating events at the Waterworks
The Park Framework aims is to: ‘Enhance the capacity of the existing facilities at the Waterworks
Centre, Riding Centre and Ice Centre to accommodate events, formal and informal learning and
arts related activities.’
The proposals result in the loss of the areas on which such events can take place, reducing
and removing capacity, and conflicting with the Framework.
10. Sport and recreation facilities at the Riding Centre
The Framework proposes to enhance the range of existing sport and recreation facilities
provided at the Riding Centre. This will include at the Riding Centre – ‘increased use of outdoor
areas for schooling and exercise and an expanded activities programme’.
The proposed private livery stables erode the land available and reduce the overall
capacity of the Riding Centre site to provide enhanced sport and recreation facilities for all.
The private liver stable facilities at the Riding Centre are to increase whilst the public,
community and educational riding activities are displaced to a sub-optimal site south of Lea
Bridge Road with limited facilities.
11. Sport and recreation facilities at the Waterworks
The Park Framework proposes to enhance the range of existing sport and recreation facilities
provided at the Waterworks Centre to include the development of playable space and play
provision at the Waterworks Centre. No such proposals are included in the application whilst opportunities for informal play and
recreation are substantially reduced.
The proposals result in a net loss of visitor facilities.
12.New leisure and recreation facilities within the Lea Bridge Road ‘visitor node’
The Framework proposes to develop new leisure and recreation facilities within the Lea Bridge
Road ‘visitor node’, including on land adjoining the Waterworks Centre.
The Framework also proposes other potential sites for such development include the Thames
Water Depot (see inset 2.A.6 .1), re-use of existing buildings at Connaught Close and
redevelopment of existing industrial land along the eastern edge of the Park.
Surely these sites should be considered first before existing recreation facilities in the area
are lost to camping?
If the Authority’s proposals for the Waterworks are approved, how can we then turn to
Thames Water and say do as we say, not as we do?
13.Waterways and recreation
The Park Framework seeks to: ‘Ensure opportunities for informal recreational activity are
available throughout the area, particularly on Leyton Marsh and alongside the waterways.’
The proposals remove formal recreation activities (golf) and limit informal recreation, such
as walking along the open banks of the Lea.
The provision of a pony trekking circuit, limited to the margins of only one of the three sites;
with only one shed provided; detached from the stables and facilities on the north side of
the Lea Bridge Road, is hardly a serious attempt to compensate for this loss.
Major events, the Olympic Park and Hackney Marsh
14.Olympic Park continues to benefit at local Lea Bridge costs
The proposals will result in a permanent net loss of amenities, facilities and future capacity at
Lea Bridge. This is in order to serve the Olympic Park, whose qualities and amenities are
protected at the loss of those at Lea Bridge. This is inequitable, particularly because the creation
of the park was partly dependent on the temporary and permanent loss open spaces in the Lea
Bridge area:
o Leyton Marsh (temporary closure, permanent harm)
o Marsh Lane Fields (temporary closure for allotments, now permanent)
o East Marsh (temporary loss, still to be re-opened
o Etc.
The relegation and dismissal of local community priorities and needs in favour of the
provision of amenities intended to favour and serve a region should not be permitted
wholesale. LBWF is the local planning authority. It is not necessarily bound to favour a strategic or
regional view, and it should ensure at least ensure that a balanced approach is taken. This
scheme strikes no such balance and Park Authority officers clearly state that it does not
consider local community interests. This does not represent the ‘good planning of the area’
and is a clear reason for refusal.
The Park Authority defines impacts and benefits only on a regional scale. It should be
remembered that a regions is a collection of many communities and the impact of the
proposal upon this community is therefore of material concern in any process of regional
planning.
The ultimate test should be; ‘ will refusal of this campsite application materially harm plans
to hold public events at the Olympic Park’. If it doesn’t, then the permanent loss of open
recreation land and facilities at Lea Bridge is unjustified.
The Olympic Park is modest in scale an represents only a like for like compensation for
existing open spaces and MOL given up to facilitate the temporary Olympic events.
Notwithstanding this, it continues to be the tail that wags the dog of the wider interests of
the Park. It has a distorting effect, with negative impacts increasingly northwards up the
Valley in order to safeguard the park for private events and the amenity of Olympic
residential and commercial neighbourhood.
It should be remembered that the Olympic Park is subject to a Development Corporation
that is its own planning authority and regeneration powers and considerable funding. LBWF
should not act to assist in the realisation of that authority’s aims, at the expense of the good
planning of LBWF plan area.
15.Hackney Marsh Events
LVRPA officers claim their proposals are unrelated in any way to the Hackney Marsh megaevents proposals.
This is surely disingenuous. The proposed camping will benefit hugely from any event on
Hackney Marsh which is likely to result, on police advice, to the full closure of a great swathe
of this part of east London from Lea Bridge to the Olympic Park and from Orient Way to the
Navigation. These effects should be considered as a whole and authorities should to be
permitted to progress individual pieces of a larger co-ordinated commercial plan.
Park planning
16.Ad hoc temporary development is not good planning.Nor is creeping intensification
Park Authority Officers state the campsite will only operate for two years and state they cannot
clarify future plans beyond that.
This should firstly point to a justification only for temporary two-year permission.
More widely, this highlights the fact that planning for the park and it facilities is ad hoc and
pro tem. Is this a sound basis for LBWF to allow the precedent of the loss of open
recreational land and what may lead to a permanent enclosure and creeping intensification? Should more be expected of a regional body and a plan making authority such as LVRPA than
this?
Creeping net loss of open recreational land is in conflict with the founding aims of the Park,
which sought to safeguarded and extend the open character of the land, the defining quality
of any Park. If it cannot do this with its own open land, how can it succeed in its aim to guide
private land owners and developers to provide open recreation and public space?
Funding and viability
17. Funding and viability
In light of the many conflicts with policy, it is important to consider what benefits might arise
from the proposals. Authority officers claim a £60,000 surplus from the Olympic campsite (a very
different proposition from the one now proposed with a different operator).
Future profits, if any, will not be channelled into the Lea Bridge area and may not result in
any direct proportionate investment elsewhere.
The Authority claims that golfing is not profitable and can give no undertaking that the
facility at Edmonton will also close soon.
Pony trekking is also not profitable, neither is parkland, the waterworks nature reserve, the
river Lea, Hackney Marshes football pitches etc. What will be the future for these facilities
and why has golf been picked for closure?
18. Profit
The Park Authority increasingly plans to close valued public facilities that do not return a
profit, and replace these with private profit making facilities.
Such a plan should be published and consulted upon. The community (whether local,
London or sub regional) deserve to know what may need to be given up for what gain and
what are the limits of these closures and the extent of commercialisation and privatisation.
There is no Park Framework or LBWF planning policy that states cross subsidy and enabling
development should be permitted at the cost of facilities, in order to limit the withdraw of
community facilities and amenities. This is a race to the bottom – allow commercialisation
and privatisation or we will withdraw and close even more community facilities and close
more open spaces.
This can only work if there is an overall net increase in benefits and contributions to the
good planning of the area, and the benefits and costs are distributed equitably.
19. Livery stables – creeping commercialisation with no clear cross-subsidy and no clear
limit on privatisation of public facilities
There seems to be a creeping displacement of community horse-riding facilities from the
stables to north of Lea Bridge Road in order to provide capacity (not just stabling) for private
livery. If there is a cross –subsidy argument in favour of this development, it cannot be at the
expense of the community access to riding, pushed to a peripheral site with minimal facilities and displacing other valued community recreation facilities. In any case, no direct
cross subsidy appears to be offered, just banking into the Parks funds.
Access
20. Footpaths- new routes
The Park Framework proposes ‘enhancement and maintenance of a network of all weather
shared use paths between visitor facilities, open spaces, and the strategic routes; the Lee Valley
Pathway and Lea Valley Walk along the towpath, to provide access for all abilities and users.’
The proposals include no such enhancements.
The proposed fence enclosures, close up to the boundaries of the few public footpaths
across the site, with materially harm the quality of these routes. They will be converted from
pleasant routes through open land to narrow corridors with high fencing on either side. This
clearly conflicts with the Park Framework.
The Framework also states the Authority will: ‘Work with the London Boroughs of Hackney and
Waltham Forest to promote connections from the Park to local open spaces, to existing route
networks and communities adjoining the Park.’
The proposals do not provide additional routes and cut off future options for routes along
the river, to the south beside the railway, and across the River Lea to Hackney Marsh.
21.Horse trails/ bridleways
The Framework seeks: ‘Protection of routes used by horse riders and an exploration of the
options to extend these south onto Hackney Marsh and through to Olympic Park in association
with the operation of the Lee Valley Riding Centre.’
The proposed pony trekking circuit is an incoherent proposal, which seem to be an
afterthought, or perhaps an overflow facility from the stables to the north, possibly
displaced by the growing needs of private livery stables there.
Park Authority officers state that horses will be led across the Lea Bridge Road at peak hour
and then through to the south alongside walkers, cyclists, tents and camp site vehicles. This
seems to be a highly unsatisfactory arrangement with safety and traffic implications.
The proposals contain no plans to extend routes southward.
On Hackney Marsh, the Framework sees to maintain strategic routes; Lea Valley Walk and the
Lee Valley Pathway and to: ‘Explore with the London Borough of Hackney and other stakeholders
the options for a horse riding route, clearly demarcated, onto Hackney Marsh and through to
Olympic Park in association with the operation of the Lee Valley Riding Centre.’
The proposals contain no such plans.
The Framework proposes enhancing and creating new crossing points as key features of the
‘Park road’ to ensure priority is given to park visitors. New pedestrian crossings should provide
safe access directly to Park facilities and visitor nodes such as the Waterworks centre.’ No such proposals are brought forward whilst the intensification of the use of the site will
lead to more car movements and greater congestion at the junction of Lammas Road with
Lea Bridge Road.
Crossing the road at this point, where there are no crossings, is highly dangerous with
vehicular accesses on either side and a ‘ghost island’ often driven over at speed by queue
jumping traffic traveling eastward.
22. Lea Bridge Road
Clustering increasingly intense leisure activities and uses along the Lea Bridge Road,
combined with commercial development such as Essex Wharf, is leading to increased
pressure for more capacity along the Road which may inexorably lead to main road widening
and side-junction throat widening.
Clustering road and parking dependent uses and activities along a constrained arterial road
is a recipe for the Lea Bridge Road to become a widening slash across the park and a greater
barrier to north south movement.
Combined with the infilling of the sites lining the road, this is inexorably leading to a
throttling of the valley into two halves, north and south of the road.
The Park Authority as a plan making body, should be set against contributing to or
permitting this effect, as the Park Framework requires, not the first to set this undesirable
precedent and the agent of such demonstrable harm.
Consultation and engagement
23. Engagement –Golfing Community
The Framework states engagement with a wide range of organisations, user groups and
community groups is fundamental to the successful management and development of the Park.
There has been a failure to engage with the golfing community and the Authority has in fact
acted in way, whether intentionally or not, to mislead and divert golfers and silence their
voice.
The temporary Olympic Camp site was promoted on the basis that the Golf centre would reopen after the games. It did not.
Until recently, an April re-opening date was given. Authority Officers simply explain that this
was a change of mind, with no reasons why the undertaking was given in the first place and
then withdrawn, and with no apology.
Until a week ago, signs inside the Waterworks and staff stated that the golf course was
closed ‘for the foreseeable future’. This changed a week ago to ‘will not be re-opening’.
In the mean time, all signage on the Lea Bridge Road remains in place, so that few are aware
the centre is closed and is planned for redevelopment. Is this to damp down opposition from
golfers?
Golfers are being redirected to Edmonton, which is ‘only six miles away’. It is clear that a proper survey of the needs and interests of the golfing community should
be undertaken before this application is determined. No such survey has been submitted,
whilst the Authority self-interested makes claims about low demand.
24. Engagement - local community
The Framework states that engagement with a wide range of organisations, user groups and
community groups is fundamental to the successful management and development of the Park.
Planning Application - 2013/0410
Site Address Lee Valley Riding Centre & Grazing Land 71 Lea Bridge Road Leyton E10
This is a formal objection to this planning application. I walk past this site on a regular basis and would like to use this land since it is part of LVRPA and MOL.
LVRPA illicitly used this public open space for business purposes (livery) for many years without the benefits of planning permission.
In August 2009 LBWF imposed strict conditions on the expansion of this commercial use, instructing LVRPA to only use about a third of the additional stables it was seeking permission to build, for commercial purposes (livery).
| 191.Application 2009/0244 Lea Valley Riding Centre, 71 Lea Bridge Road, Leyton E10 PDF 28 KB Minutes: Subject to the addition of the condition set out below, planning permission granted for Application 2009/0244 in line with the recommendations set out in the main report for the erection of a stable block and spectator viewing galleries at the Lea Valley Riding Centre in Lea Bridge Road E10. Additional Condition 3. No more than seven out of the nineteen stables hereby approved shall be used for livery with the remaining to be used for the stabling of horses directly related to the operation of the riding school, unless otherwise agreed by the Local Planning Authority. Reason 3. In the interests of retaining an appropriate balance and mix of stabling for the benefit of a range of users and to comply with polices ENV4, ENV5 and ENV13 of the adopted Unitary Development Plan (2006). |
This application is an attempt by LVRPA to drive a coach and horses (an unusually apt metaphor) through the conditions imposed by LBWF on LVRPA in 2009.
The riding centre is increasingly becoming a gated community for the horsey community. This is not an appropriate use for MOL. It is certainly not an appropriate use for public park land.
It is also clear that LVRPA is using planning by stealth. It developed a clear plan several years ago, but realising that it could not possibly get permission for such a radical change to public open space, it has been using the strategy of incremental development, hoping that smaller developments will be given the benefit of the doubt.
It is equally clear that if this application is given the go ahead, it will not be the last, since there is a final corner of the oblong of stables to be completed.
This application should be dismissed because of the intensification, private stables imply horse moving vehicles etc. etc., apart from the sheer bulk of the development (unique in scale on Lea Marshes). It should be rejected because it is completely contrary to the spirit of MOL to run a business on public park land.
Jonathan Brind
519 Lea Bridge Road,
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