Restoration: Our Response to the Reinstatement Plan (Updated)

You can look at the Reinstatement Plan for Porter’s Field Meadow (Leyton Marsh) here:

Leyton Marsh Reinstatement Report (v250612 for Comms)

Draft STRI programme of works _for incorporation into Nussli Method Statement (v250612 for Comms)

Draft Leyton Marsh Profile (v250612 for Comms)

Appendix C – ConstMthState_Reinstatement_P02_v250612forComms

1.         Sports Turf Research Institute (STRI) do not have the necessary experience to carry out the reinstatement of Leyton Marsh and should be replaced by an organization that do have the required specialist knowledge.

STRI carried out the site condition survey and seem to be taking responsibility for the reinstatement of the turf, yet have no experience of managing this kind of project. On page 24 of Appendix C, it says that ‘STRI retain a reputation for being the world’s leading environmental consultants working in the sports and leisure sectors.’ Yet, a detailed examination of their website provides absolutely no examples of their involvement with environmentally complex projects. Instead, it tells us that STRI provides natural and artificial sports surfaces. Leyton Marsh is neither a playing field not a recreation ground.

STRI’s lack of experience working with this kind of habitat is evidenced by the flaws in the species list. The mistakes made with the Latin names have been corrected, but it needed members of Save Leyton Marsh to point them out. The survey itself is also inadequate. There is no information on where the plant surveys were done and over what area. They cannot show what was on the excavated areas because the surveys post-date the work on the site, and they were completed at only one point in the year and so cannot show the diversity of plant life across the year. They is also no mention of fungi or microorganisms despite the a statement on page 5 of the main reinstatement report saying, ‘There was lots of worm activity in the profile’ and paragraph 4.7.1 of the Atkins ecology report stating that the only chance fungi have to re-establish themselves is from spores in the topsoil as the actual mycelia are likely already dead.

2.         We would like the findings of previous surveys of Leyton Marsh to be taken into consideration.

On page 8 of the main reinstatement plan it states that the LVRPA have said that, ‘The surveys undertaken by STRI look to be comprehensive and should therefore supersede the previous surveys that have taken place on Walthamstow Marshes (dated 1970 and 2002) as there has been the opportunity for new species to have become established on site’. This reflects poorly on the LVRPA if this accurately reflects what was said, and indicates a lack of attention to the contents of the surveys and a failure to do their own checking. Park users who are not plant experts have been immediately able to identify species on site that are missing from the ‘comprehensive’ STRI survey, and it would have been reasonable to expect a park ranger to have checked the list on site to confirm its accuracy. It should be noted that the previous surveys are more comprehensive and include the limited range of species noted in the STRI survey, which therefore does not include any ‘new species’. Given the limited nature of the STRI survey, it is reasonable to assume that the valuable data contained in the previous surveys would be taken into account when preparing the reinstatement plan and we would like to see this happen.

3.         The seed specification appears incomplete. More than one seed mix must be developed, by an organization that has specialist knowledge of this kind of reinstatement works.

 

The rationale behind excluding relatively invasive species, such as daisy and dandelion, from the seed mix appears sound, but it is unclear why other species identified during the survey (for example, wall speedwell, thistle, ragwort, horn plantain and cinquefoil) have been excluded.

It is also misguided to propose reinstatement of the scrub grassland using the same turf and seed mix as the short mown areas. This proposal is based on the erroneous assumption that ‘their different appearance is due to their management and public uses’. The most cursory examination of the areas reveal that this is not the case, and this is in fact supported by the March STRI survey. Specifically, the 16 species in the replacement seed specification includes 8 not listed in the STRI rough grassland survey, while the survey records 13 species not included in the seed specification.

4.         Many questions surrounding the topsoil remain and we would like them fully answered.

 

On pages 5 and 10 of the main reinstatement report it says, ‘XX% of the topsoil has been found unsuitable for reuse because of contaminates’. The use of the past tense suggests this has already happened so the percentage should already be known. Why hasn’t it been included in the report?

How have you sorted the topsoil to determine what is safe to reuse and what isn’t? We are not aware of any testing being undertaken on the topsoil, have no knowledge of a practical way to separate contaminated topsoil from uncontaminated topsoil, no remediation strategy for dealing with topsoil has been submitted for planning approval in accordance with condition 12, and as far as we are aware no material has been removed from the topsoil stockpile at the time the subsoil/hazardous waste pile was removed.

While the main reinstatement report claims that some of the topsoil cannot be used, the Nussli Method Statement 21.10: Spreading of Topsoil states, ‘Where topsoil was removed, the existing topsoil was stored on site and is going to be replaced in situ’. It also states that, ‘Separately stored topsoil from the rough grass area adjacent to Sandy Lane will be used for refilling where the access and exit roads are located’, yet all the topsoil has been piled into an undifferentiated heap. These discrepancies are extremely concerning and demonstrate either a willful attempt to deceive or incompetence, and need to be resolved.

While the reuse of a minimal scrape of topsoil was a fundamental (and misleading) claim used to facilitate the granting of planning permission, there has been a failure to follow good practice for management of soil. This is set out in DEFRA’s Construction Code of Practice for the Sustainable Use of Soils on Construction Sites. For example, the grass turf was not separated but has been buried in the stockpile. No Materials Management Plan or Soil Resource Plan has been produced for this project to ensure correct handling and storage. It was also not established at the planning stage whether excavated topsoil was sufficiently free of contamination to be suitable for reuse. How can we be confident that the reinstatement will not be plagued by similar bad practice?

5.         Discussion of the sub-base is conspicuously missing from the reinstatement plan and it should be included.

 

The reinstatement report focuses on the topsoil but what about the sub-base? How will the volume of rubble removed from the site be replaced? This being done well will be critical to the long-term health of the turf. The report states that the turf will be re-laid if it fails, but what will happen if the sub-base isn’t laid properly? What precautions are being put in place and what working methods will be established to ensure the land won’t turn to bog, subside or collapse in the years to come?

6.         The turf specification is wholly inadequate and needs revising.

The impression was given, at the resident’s meeting of 15 May 2012, that custom turf was to be grown to attempt to accurately replicate the pre-existing grassland. However it appears from the reinstatement plan that the turf will be selected from stock (page 11: ‘The turf farm shall be visited to identify the required turf’) and augmented with some additional seeding. This is referred to as ‘intraseeding’ though we believe the correct term is ‘interseeding’.

There is a lack of information in the STRI survey about the relative percentages of different grasses and, even if this information was available, it is unclear whether this could be easily achieved with a customised off-the-field product.

The information regarding species mix on pages 11 and 12 of the reinstatement plan states that turf will be selected with a ‘generally even blend of Lolium perenne, Festuca rubra and Poa pratensis with no more than 15% Poa annua’. However, the seed specification on pages 12 and 13 lists 10% Lolium perenne, 25% Festuca rubra, 25% Poa pratensis and no Poa annua. This is a significantly different mix and is perhaps intended to adjust the proportions although this is not at all clear. The discrepancy is all the more worrying, when you add to it the fact that the STRI category has Poa pratensis in the ‘few’ category, yet it seems there will be at least 25% Poa pratensis in the final turf.

If the amenity grassland turf is used to replace the roadways through the scrub area, the density of grasses (95% of the mix) will prevent other species re-colonising and the turfed areas, if left to grow, will remain indefinitely entirely different to their surroundings.

Finally it seems as if many of the decisions about the turf are yet to be made. These are fundamental to the reinstatement plan and should be incorporated in the report, for consultation and to help LBWF make their decision.

7.         The timetable of works is unrealistic and should be revised to accurately reflect the time needed for full reinstatement.

 

The timeline provided on page 16 is unrealistic and indicates that no attempt has been made to accurately plan the reinstatement works. It simply indicates ‘lay turf’ over a three-week period apparently beginning on 15 September. With the removal works starting Monday 10 September, following the end of the Paralympics, there is no way that it will be possible to strip out, dismantle and remove the buildings and infrastructure, break out and remove the roadways, and remove the fill and replace the soil in one week. It is unlikely to take less than four weeks, and it should be noted that Nussli’s Project Programme R07 of Feb 2012 shows a 30 day allowance for ‘Removal of Temporary Venue’, from 11 September to 10 October, followed by two days ‘Making Good of Site’.

The Nussli Reinstatement Method Statement notably fails to include any start date or duration for any of the subtasks. Why is this, given that the size of workforce is stated and the scope of the works is accurately known? We suspect this is because it would be immediately apparent that the works cannot be completed within the timescale promised in the planning application.

 

Furthermore, surely the timetable of works should start after permission has been given by LBWF? If, in fact, work has already begun on the turf (which, if it has, makes a mockery of the process of consultation and planning permission) then we would like to see the results of the analysis that should already have taken place and which is currently missing from the reinstatement plan.

8.         The site area is inaccurate and should be amended.

The site marked up in Appendix C is much larger that the area fenced off by the development. Why? We would like to be reassured that you won’t be re-turfing areas that haven’t been affected by the development.

9.         The reinstatement plan fails to tackle the issue of logistics and should be amended accordingly.

The reinstatement plan ignores the logistics of managing stockpiles of incoming soil, waste arising and vehicle deliveries. It needs to be explained how this is to be managed without impacting either on areas already reinstated or encroaching on areas outside the licensed land causing further damage.

10.       The reinstatement plan should explain how the reinstated land will be rich in fungi, earthworms and other organisms and confirm that no pesticides or fertilizers will be used on the land.

 

On page 12 of the reinstatement report it says, ‘and is regularly tested for harmful pests and diseases’. What is the definition of harmful? And how will you be eradicating harmful pests and diseases without damaging microorganisms? We are concerned that non-native species, which might not be considered harmful, will be introduced to the marsh and that microorganisms that are required for a healthy soil structure will not be reintroduced with the turf.

Even if the stored topsoil is re-useable, the site will still suffer a net loss of valuable soil resource together with its indigenous population of fungi, earthworms and other organisms. To apply 1 ha of 30mm thick turf requires removal of an equivalent volume of topsoil, ie. 300 m3 or around 450 tonnes. This represents a considerable loss to the local environment as well as potentially entailing high disposal costs.

We do not want to see any pesticides or chemical-based fertilisers used on the land. In fact, It is unclear why fertiliser should be applied in these circumstances as we are not aware that fertiliser has ever been used on Leyton Marsh.

11.       The statements regarding the consultation are flawed and we would like them to be rewritten.

 

On page 9 of the main reinstatement report it states that, ‘The ‘thick’ turf option was also supported by the majority of the Residents engaged with’. This is a completely disingenuous reading of local people’s opinions. There is little, if any, support for the ‘thick’ turf option. We recall residents trying to point out that promising to give Leyton Marsh back to us by 15 October 2012 AND returning it in the state it was in before the vandalism began is absolutely impossible; that the only way you could return it to us in a useable state by 15 October 2012 was to use the ‘thick’ turf roll and that we were therefore being offered a choice that wasn’t really a choice at all. This statement must therefore be changed to ‘Residents are unhappy about the options presented to them and do not feel that any of them will return the land to its original state.’

 

It is also cynical to suggest that the attendance of thirty people at the meeting was in any way indicative of lack of support, which is what you imply. The ODA did little to ensure a greater number of people were able or willing to attend: the event was overrun with uniformed and plain clothes policeman which was extremely intimidating, the room was very small and the omission to invite anyone at all from Leyton to a discussion about Leyton Marsh speaks for itself. Similarly, the 15th May LM Resident’s meeting document is also missing many of the individual discussions attendees held with representatives of the ODA and the LVRPA, and cannot be considered a true reflection of the concerns raised by residents. We believe the section on the consultation should be rewritten to better reflect the true nature of the conversation with local residents.

 

We also feel that the draft reinstatement plan would benefit from an introduction that puts the need for reinstatement into context. Without this, it is difficult for anyone to judge the detail in the plan effectively. We feel the following key points should be included in any introduction:

  • Six months ago, when Leyton Marsh was a green field, the ODA submitted a proposal to Waltham Forest to skim 15cm of topsoil from the land in order to use it for the construction of a temporary basketball training venue.
  • Evidence of the contamination in the land was known about in January 2012 but did not appear in the information presented to the Planning Committee in February.
  • The extent of the contamination and the nature of the uncrushed rubble that was excavated was not known before excavation began because an Environment Assessment had not been completed. When it became apparent, a revised construction plan had to be drawn up.
  • Excavation in excess of the 15cm was made across the site in advance of obtaining an amendment to the planning conditions for the purpose of the revised construction plan.
  • For two months, contaminated mounds of rubble were heaped on the south side of the site. For many weeks these mounds were uncovered. This was in direct contravention of the original planning application granted.
  • There has been, and continues to be, huge and vocal opposition by local people, not only about the construction of the basketball courts themselves but also about the environmental damage being caused.

Local people think it is extraordinary that plans for reinstatement of the site, which is a critical part of a project in such a sensitive location, should have been left until now to be hastily considered. Use of the site was agreed with the LVRPA over 18 months ago and so there has been ample time to consult, research and plan in detail the method of reinstatement. The choice of a date of 15 October by which the land would be ‘reinstated to its original state’ appears to have been entirely arbitrary and little more than a ‘planning fiction’ and unrelated to any proper consideration of the process and practicalities.

Local people also believe it is reprehensible that the concealment of the intention to excavate beyond 15cm of topsoil in order to facilitate planning permission led to damage to an additional ~1000m2 of grassland necessitating its removal together with a layer of topsoil, in addition to the other impacts of the hazardous waste stockpile. Had this subsoil excavation been acknowledged in the first place and responsibly planned it could have been removed as it was excavated and this additional damage prevented.

12.       The appendices are missing and without them we cannot fully judge the reinstatement plan.

Why are many of the appendices missing? What do they contain?

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2 Responses to Restoration: Our Response to the Reinstatement Plan (Updated)

  1. Not sure if it’s the same in the UK as it is here in the US, but often times so called environmental consulting firms are hired not based on their competency and experience but sometimes based upon whether or not they are politically well-connected (read have given campaign contributions to a given town’s elected officials).

    For what it’s worth, I checked out Wikipedia to see if they had anything about the Sports Turf Research Institute and all it said was that the STRI was a “…consultancy and research organisation” with absolutely nothing about them providing environmentaI consulting services

  2. Pingback: Reasons to demonstrate on July 28; number 5: the loss of green spaces « lives; running

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