WALTHAM FOREST
CIVIC SOCIETY
A CALL FOR
ACTION AGAINST THE COUNCIL’S PROPOSED LOCAL PLAN
Local Plan Proposed Sites
Local Plan Policies
Local Plan Examination by Government Inspectors
The Council’s proposed Local Plan sets a “requirement” of
1,800 new dwellings to be built each year. The Plan is intended to apply for 15
years, making a total of 27,000 new dwellings in Waltham Forest. The
requirement imposed on Waltham Forest by the Government and the London Plan is
1,264 new dwellings per year. The extra (536 extra new dwellings each year for
15 years) is being chosen by the administration of Waltham Forest Council.
(The Homebase development is for 583 flats and Coronation Square is 750 flats))
The Planning Inspectorate has refused to approve the
proposed Local Plan, questioning the target of 1,800 new dwellings per year. The
Council intends to submit a revised version in mid-September, but with the same
target of 1,800 per year. The months between now and September are an
opportunity for residents to persuade elected Councillors to reject the higher
target and for the Council to adopt the lower target of 1,264.
Why does this matter?
·
The Council’s proposals involve allowing developers
to build tower blocks on almost every possible site in the Borough. Below is a map which the Council intends to submit with its revised version
in September: it shows the locations where tall buildings (10 storeys or more)
would be allowed.
·
Studies by academic engineers say that tower
blocks are much less environmentally friendly than blocks of mansion flats of 6
or 8 storeys.
·
The “Skyline Studies” published by the Council
with Part 2 of the draft Local Plan show that many of the tower blocks are
intended to be 14 or 18 storeys high. The new tower blocks would:
o
loom
over the town centres of Leyton and Leytonstone and intrude on the settings of
historic buildings and conservation areas (similar to the curent tower blocks at Tottenham Hale)
Proposed development on the Leytonstone Tesco site
o
be
built along the edge of the Lea Valley, walling in the Walthamstow Wetlands and
the open land of the Marshes (similar to the huge tower blocks beside the Woodbeery Wetlands)
Woodberry Downs Wetlands
o
be
built next to Epping Forest land by the Hollow Ponds (“Leyton Flats”) and at
Wanstead Flats, intruding on the views from the open land, and they would not allow
for gardens or for enough green space for the residents to sit out in, so that
the Forest land would be overcrowded and overused.
Hylands adjacent to Epping Forest
·
There may be too little capacity on the main
roads within the Borough to take the cars and vans servicing so many extra
residents.
·
Air quality in the Borough is already poor and
the extra vehicle movements would make it worse.
·
The Victoria Line and Central Line, and the
railway from Chingford to Liverpool St, would not have capacity to take the
extra commuters into Central London.
·
The new tower blocks would destroy the character
of the Borough. What would be built would be flats that people would not choose
to live in, in a Borough that they – and the existing residents – would move
out of as soon as they could.
Please
support our campaign by sending the enclosed text as an
email to your ward councillors – you can find contact details for them by
entering your postcode on the Council’s website at
https://democracy.walthamforest.gov.uk/mgFindMember.aspx
PLEASE SEND THIS AS AN EMAIL TO YOUR COUNCILLORS
Dear Councillors ...................
I am a resident in your ward at [ADDRESS AND POSTCODE].
I am concerned about the difference
between the housing target imposed on Waltham Forest by the London Plan
and the higher housing target in Waltham Forest Council’s draft Local Plan and
the likely consequences of the higher target for the character of the Borough
as a place to live. Partly because of Covid, the Council has not yet consulted
residents properly about its proposal to adopt the higher target. I am writing
to call upon you to hold a Ward Forum to discuss this proposal with your
constituents, in good time before the Council re-submits its draft Local Plan
in September this year.
Yours sincerely,
INSPECTOR's FINDINGS
Waltham Forest Local Plan (LP1) ‘Shaping the Borough’
Examination
Inspectors - Mrs S Housden BA (Hons) BPl MRTPI &
Mrs C Jack BSc (Hons) MA MA(TP) MRTPI
Programme Officer – Ms Andrea Copsey
copseyandrea@gmail.com
07842 643988
Ms S Parsons
Assistant Director
Waltham Forest Borough Council
SENT BY EMAIL
27 May 2022
Dear Ms Parsons,
Waltham Forest Local Plan Part 1 Examination
Thank you for your letter of 11 May 2022.
We have no further comments on the Council’s response but in order to
assist the development of a work programme and to inform future
timescales, we have outlined below the various work streams that we
consider need to be actioned going forward. We have listed them in order
of the priority that we consider will be necessary to ensure a logical
sequence of events to address the issues raised in our post hearing letter.
1. Undertake a strategic level, Borough-wide Sequential Flood
Risk Test.
2. Undertake further Sustainability Appraisal work to assess
reasonable alternatives, including the 10 year target for net
completions in Waltham Forest set out in Table 4.1 of the
London Plan.
3. Update the latest version of the Air Quality Study in
accordance with Natural England’s requirements and liaise
with Natural England, the Conservators of Epping Forest and
other organisations as necessary to finalise the Air Quality
Management Strategy in response to any updated modelling.
4. Liaise with Natural England, the Conservators of Epping Forest
and other organisations as necessary to revise the draft
Suitable Alternative Natural Greenspace Strategy to provide
further clarification of the capacity, quality and deliverability
of the proposed sites, and to confirm whether any additional
sites would be needed.
5. Housing Delivery
• Update of the trajectory in the Housing Position
Statement, including updating completions,
commitments, updated timescales for delivery and
evidence of consultation with site promoters for key
sites, in addition to the Follow Up items from Matter 3.
• Update the evidence of the five year housing land
supply position over the Plan period.
6. Evidence and justify the proposed changes to the approach to
Tall Buildings, including any implications for the strategic
approach to housing growth and delivery. Also, evidence and
justify the areas mapped and identified as appropriate for tall
buildings.
7. Main modifications to Appendix 2 and a change to the Policies
Map and Figure 9.1 to deal with the changes to Blackhorse
Lane Strategic Industrial Location.
We would be pleased to receive a realistic assessment of when these
various work streams could be completed by in order that we can
establish a timescale for the future progress of the Examination.
Given the varied topics and nature of the work streams and the evidence
that underpins them, the Council should produce a Topic Paper
summarising how the issues identified in the post hearings letter have
been addressed and outlining the evidence base that underpins the
approach taken. This could also include an indication of where any further
Main Modifications will be necessary for soundness, in addition to those
included in the Follow Up Lists.
We propose that in order to avoid any duplication of public consultation,
the various evidence base documents for the above work streams and the
Topic Paper form the basis for the Matters, Issues and Questions for
Stage 2 of the Examination. The evidence base documents and Topic
Paper would be made available for consultation and comments/responses
on them would be sought through our Matters, Issues and Questions.
Given that some of the potential changes to the Plan may be significant,
the scope of notification on the Topic Paper, accompanying evidence base
and Matters, Issues and Questions should be broad eg including everyone
who was notified at the Publication stage for a period of 6 weeks.
Stage 2 hearings would be convened to cover the matters in the Topic
Paper, the evidence base and responses to the Matters, Issues and
Questions. A timescale for those hearings will be established in due
course.
We are not seeking comments from anyone else on the contents of this
letter, but we would be pleased to receive the Council’s response and any
comments on the way forward for the Examination proposed above.
Yours sincerely
Catherine Jack and Sarah Housden
INSPECTORS
