Our Official Response to the New Local Plan: Direction of Travel

Dear London Borough of Waltham Forest,

We are writing in response to your ‘New Local Plan – Direction of Travel’ document and the response it has elicited from the Lee Valley Regional Park Authority (LVRPA).

We have not read the LVRPA’s final response to the consultation (which we urge you to publish on your website as soon as practicable), but we were able to see a draft of the letter at the LVRPA’s Regeneration and Planning Committee Meeting that took place on 14 December. In that draft, the LVRPA proposed submitting two sites in response to your call for sites. Both of these sites are Metropolitan Open Land (MoL) and we are writing to state that we object, in the strongest possible terms, to any use of the sites for development which leads to the loss of open land.

MoL must be protected and Save Lea Marshes objects to any attempts to remove the MOL designation from land within the Lee Valley Regional Park specifically and within the borough more generally. This position is supported by thousands of local people; and we refer you to the petition signed by over 5000 people in response to the first draft of the Lea Valley Eastside Vision, which called on the Council not to rezone the land around the Waterworks for housing (https://you.38degrees.org.uk/petitions/stop-the-council-s-plan-to-build-on-leyton-marshes).

We therefore are asking you to reject both sites.
Save Lea Marshes

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A personal response to the London Borough of Waltham Forest’s New Local Plan – Direction of Travel consultation

A local plan is a plan for the future development of the local area, drawn up by the Local Planning Authority. It guides decisions on whether or not planning applications can be granted. It is, in other words, the thing that the Council and developers refer to when deciding what to build and where to built it in Waltham Forest. Nipping bad ideas in the bud before they become part of the local plan will mean we have fewer battles against individual planning applications in the future. Well, that’s the theory anyway! The Council has put their ‘direction of travel’ for the new local plan out to consultation and I have just had a look.

The plan seems to suggest that the development of ‘affordable housing’ will help to ensure that all residents have ‘a decent roof over their head’. I completely endorse the Council’s desire to ensure that every resident in Waltham Forest has a safe and secure place to live, but selling off Council-owned land to developers to build so-called ‘affordable housing’ is not the answer. Developers consistently wriggle out of their commitments to the community. If Council-owned land is sold, it should only be sold for social housing; housing that people on the Council’s housing list will be able to move into.


Many residents are opposed to tower blocks in the borough because they are fundamentally changing what so many of us value: the low-rise Victorian and Edwardian neighbourhoods of family houses. To some extent, concentrating blocks of flats around transport hubs makes sense, theoretically reducing carbon emissions by reducing car ownership and – if built to high environmental standards – limiting water, electricity and gas usage through shared services. However, it is the height of these tower blocks that is causing so much anxiety. While a building of five or six storeys can, if well designed, blend into its surroundings, a 27 storey block is nothing more than a priapic reminder that local people have very little say in what happens to the places they call home. I also question whether developers after a quick buck are thinking about the long-term environmental sustainability of the homes they are building and I am saddened that, to date, the Council does not seem to have set high standards and insisted that developers making money out of our home meet these standards.


If, as many suspect, the drive to build expensive homes in the borough is the Council’s attempt to increase its revenue by increasing the number of people paying Council Tax, then let’s be honest about this. Let’s not pretend we are place making when, in fact, we are selling off our future to fund essential services now.


When I first moved to the borough in 2001, the different town centres – Leyton, Leytonstone, Walthamstow and Chingford – all had distinct identities but seemed to be equal. The Council acknowledges that Walthamstow has received significant investment over the last few years and people living in other parts of the borough are becoming more and more aggrieved. It is wrong to focus on making Walthamstow the major town centre in the borough. It would be far better to spread investment across the borough, or the Council risks setting one community against another. It would also be wise for the Council to remember that creativity emerges in edgelands; places where people can experiment and explore boundaries. There has been much creativity in the borough over the years, which the Council rightly celebrates, but the Council’s strategy risks destroying the very thing that nurtured this creativity. Tidy place-made places are rarely, by their very nature, creative.


Where the Council should be directing their energies is into making sure that the buildings that are built in the borough are well-designed. Good design is, of course, subjective but there is a strong desire amongst residents for buildings that integrate with the Victorian and Edwardian character of the borough. The concept of designing out crime is also challenging. Resilient communities, where people know their neighbours and collectively take responsibility for each other, work together to prevent crime. Until recently I lived in a block of flats in Walthamstow and young people used to hang out in our communal garden. They left litter and made noise and, when they disturbed me, I went out to chat with them. They were unfailingly polite, often not realising the impact they were having and just wanting a place to relax and hang out. They often apologised at the inconvenience they were causing. At a local community forum I shared this insight and was told, in no uncertain terms by the Police officers there, that they can never recommend people talk to each other because it can be dangerous. I can categorically say, that over the course of a decade, I never once felt afraid; in fact I felt happier connecting with the people I was living alongside. Encouraging people to call the Police when others, particularly young people, do something irritating, rather than talking to them, is how young people become alienated and criminalised. Far from designing out crime, beginning with the idea that crime is ever present and must be eradicated creates fearful, polarised communities where truly criminal behaviour has the space to flourish.


The Council rightly celebrates the fact that Waltham Forest is one of London’s greenest boroughs. Access to nature is critical for social, emotional and physical well-being and must, therefore, be a priority for the Council. Nature is, as my seven-year-old nephew said to me today, ‘love, peace and unity for all’; that’s not just all people, that’s all living things. So I completely oppose the Council’s plan to bring public wifi to Walthamstow Wetlands. The wetlands should be a place where people can get away from the speed of modern life, where they learn to reconnect with nature and put the needs of birds and other wildlife ahead of their own needs. We should be encouraging people to watch the light play on water or watch the way birds nest and feed, not pollute the atmosphere will tinny music played from mobile phones. The Council must acknowledge the importance of the borough’s green spaces and the role they play in making life worth living, and make a firm, unshakeable commitment to protect all green spaces. Metropolitan Open Land and Green Belt must be protected.


I welcome the Council’s plan to plant 50,000 new trees, but I call on the Council to protect the trees already growing in our borough and do more to prevent developers cutting down or damaging mature trees. It is, after all, mature trees and not saplings that do the most to mitigate the effects of climate change.


The Council must also acknowledge that its drive for efficiency through technology disadvantages those in the community that cannot or will not use computers. Many prefer to talk to a real person who can sympathise and advise them on what to do next when they have a problem. Emails often go unanswered and, when you log an issue through the Council’s portal, you are not sent the text you entered, just a computer generated reference number, so you cannot follow up an issue that is not dealt with because you do not have a written record of the complaint you made. The Council says that it wants to create jobs; perhaps fully trained staff able to liaise with residents to resolve problems is a good place to start.


The Council rightly celebrates the William Morris Gallery, but must not forget that it wanted to close the Gallery and it was a hard-fought campaign by local people that secured its future and helped turn it into what it is now. Just sometimes residents do know best…

You can have a look at the New Local Plan – Direction of Travel document here: http://walthamforest-consult.limehouse.co.uk/portal/pp/newlp/dot.

Comments are required by 5pm on 22 December 2017.

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Cow Bridge, Hackney Marshes: An Accident Waiting to Happen?

Back in 2011/2012, before they were given permission to build the new pavilion at Hackney North Marsh, Hackney Council carried out two ‘risk assessments’ at Cow Bridge. In fact they only chose to assess the risk at the Millfields Road end of the bridge. Bridges do have two ends so this was remiss, as we will show:

In their assessments they identified a number of different hazards:

1. Risk of pedestrians or vehicles colliding with a recycling bin which had been sited directly on the pedestrian desire line across the junction. It transpired that it was not affixed to the footway surface and as a result could be moved.

2. Risk of side swipe accidents arising from large vehicles having to straddle the central line markings to negotiate the corner at Millfields Road and Mandeville Street.

3. Risk of collision with raised kerb as there was no street furniture to highlight the presence of the vehicle splitter island.

4. Risk of trip hazard as the splitter island is close to pedestrian crossing line and may result in pedestrians, particularly the visually impaired tripping on the raised kerb of the island.

5. Risk of right turn accidents because a prohibition of right turn sign from Mandeville Street which had been erected at a location where the forward visibility of the sign was reduced by virtue of the horizontal alignment of Mandeville Street and the foliage that was present on the adjacent boundary wall.

In fact there is now no prohibition of right turn sign, it has been removed. In addition there are no road markings indicating a no right turn.

6. Risk of pedestrian slip hazard because water may have formed a pond in the vicinity of the pedestrian crossing point resulting in the creation of a potential slip hazard, particularly during periods of cold weather.

7. Risk of injury to cyclists and pedestrians because when the barrier is in the closed position the bracket to enable use of a padlock protrudes into the potential path of cyclists and powered two wheelers.

8. Risk of shunt type collisions because the signal head is located on the offside of the exit road from the changing room car park. In addition a second access road forms a junction with the Cow Bridge access road between the signal head and the bridge structure. The audit team was of the view that the operation of the Cow Bridge access road will not be clearly understood by visitors to the site and this may result in vehicles attempting to exit the site without waiting for a green signal. In addition, the side road is not currently under signal control. If the above situation occurs it may result in head-on type collisions on the structure or it will be necessary for vehicles to reverse. This may result in vehicles reversing back into the highway on Millfields Road into the path of oncoming vehicles.

The ‘access road’ referred to is actually a second entrance/exit at the bridge off Millfields Lane. Two potential entrances or exits could indeed cause confusion.

This bizarre rigmarole of accidents came closest to describing the real hazards at Cow Bridge. However, they only assessed the risk at one end of the bridge. The real hazards occur on the bridge itself and at the Marshes end, as revealed in the pictures and video below, and were not examined in this ‘exhaustive’ investigation.

First, the nature of the bridge, its steep slopes and narrow roadway with high walls on both sides, means drivers’ view as they reach the summit is restricted – the 20mph speed limit in the first picture above no longer applies!

Having reached the top of the bridge, as has been repeatedly observed, many drivers are going too fast, which along with the restricted views make it harder for them to properly assess what is going on in front of them before they embark on the downward slope.

Second, the bridge is used by cyclists and by pedestrians, including children, sometimes accompanied by animals, usually dogs. The assumption is that pedestrians will use the pedestrian bridge on the side but many pedestrians prefer to use the bridge and cyclists are obliged to do so because they are prohibited from cycling on the side bridge. In many instances drivers will not be able to see these other users until they are virtually on top of them. There are no pedestrian or cyclist signals to warn drivers or to protect pedestrians and cyclists.

Third, on the Marsh side of the bridge the road is crossed by a pedestrian and cycle path which takes these users right in front of the bridge meaning drivers will only see them at the last moment as they come down the bridge.

Their view of pedestrians, cyclists or runners coming from either side is obscured by the wall of the bridge.

This cycle and pedestrian path which crosses right in front of the bridge is used by cyclists, pedestrians and runners and is not controlled by signals.

All these hazards passed unnoticed by the inspection team. However, that is not to say Hackney Council would not have been aware of them. At the public inquiry into the pavilion in 2015 objectors from Save Lea Marshes pointed out these hazards and played a video before the assembled witnesses and representatives from Hackney, which exactly demonstrated all these hazards. It is worth noting that the inspection team thought it possible visitors might not understand the traffic signals. What they did not reckon with was drivers coming from the pavilion car park understanding the traffic signals but deliberately driving through a red light and with them queueing up at the traffic signal on the wrong side of the road!

While Hackney Council did reduce the speed limit from the absurd level of 20 mph to 5 mph after Save Lea Marshes raised objections, it did not occur to the Council to revisit its risk assessment and examine any of the other issues at the Hackney Marshes end of the bridge in light of the information we presented at the enquiry. Hackney Council paid no attention to the testament to appalling driving presented to them and the full range of hazards it revealed with pedestrians, cyclists and runners all crossing the bridge or the roadway while we filmed before the queue of cars took off on a red light having lined up on the wrong side of the road.

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London Borough of Waltham Forest is preparing a new local plan

A local plan is a plan for the future development of the local area, drawn up by the Local Planning Authority. It guides decisions on whether or not planning applications can be granted. It is, in other words, the thing that the Council and developers refer to when deciding what to build and where to built it in Waltham Forest. Nipping bad ideas in the bud before they become part of the local plan will mean we have fewer battles against individual planning applications in the future. Well, that’s the theory anyway!
The Council has put their ‘direction of travel’ for the new local plan out to consultation and I’m urging you to have a look and to respond. The details of the proposal can be found here: http://walthamforest-consult.limehouse.co.uk/portal/pp/newlp/dot
Comments should be send to planning.policy@walthamforest.gov.uk by 22 December 2017.
We’ll try to have a look at it and post our observations in the next week or so, but please do have a look yourselves if you get the chance. The image above shows the four sites being considered for development in the Lea Bridge area – three of them currently green space.
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Wetlands Licence

Whilst we look forward to the upcoming opening of the Wetlands, we are disappointed to hear that the application for an extensive entertainment licence has been granted there and we expect the London Wildlife Trust to put wildlife before human pleasure and to protect bats and birds on this protected RAMSAR site.

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Help Crowd Fund Legal Case to Stop Waterworks Sell Off


Text below from the Crowd Justice page, by Abigail Woodman, on behalf of SLM.

The Lee Valley Regional Park Authority (LVRPA) is planning to sell the Waterworks Centre and surrounding open green space for development. This is wrong, and I am asking for your help to fund a court case to stop them.

What are we hoping to achieve?

The marshes of the lower Lea Valley are a beautiful, amazing, unique open green space, a place for people to reconnect with nature and let their imaginations run wild right in the heart of the city. We want to make sure the marshes are there for future generations to enjoy. To do this, we must protect them from development. If the Lee Valley Regional Park is allowed to sell this patch of green open space, where will they stop?

I have spent the last five and a half years encouraging the LVRPA to recognise that they manage the Lee Valley Regional Park on our behalf, and asking them to respect our vision for our green open spaces. Again and again, the LVRPA have demonstrated that they are more interested in building an empire of large leisure venues than looking after our green lung. Now they are planning to sacrifice precious Metropolitan Open Land to pay for an ice rink that should be self-financing if it is a viable proposition. This is not acceptable, and I want to send a message to the LVRPA and others who want to develop Metropolitan Open Land: We will stand up for what we believe in. We will not tolerate attempts to rob us of our green open spaces. We will fight to protect them.

What are we planning?

With the help of Leigh Day, we are planning legal action to prevent the LVRPA from selling or developing the Waterworks Centre and surrounding land.

At the moment, we are waiting for the LVRPA to make its next move and we will need to be ready to act quickly when they do. We are therefore asking, at this stage, for your help to raise £1750. This will enable us to explore the viability of a case and pay court fees. If the case proceeds, we will need to raise additional money.

The Waterworks Centre and surrounding land provide a buffer to protect the Waterworks Nature Reserve, and the birds and animals that call it home, from noise and light pollution:

The Waterworks Centre provides facilities that enable people to enjoy green open space in one of the most densely populated cities in the world:

Save Lea Marshes enjoying a picnic on part of the site designated for development by the Lee Valley Regional Park Authority:

The Lower Lea Valley, with the land under threat highlighted:

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Community Picnic 20th August

Join us for a picnic!
Save Lea Marshes is organising a picnic on Sunday 20 August, from midday, on the open green space in front of the entrance to the Waterworks Centre.
Leave your barbecue at home and bring food, drink and a picnic blanket, and help us celebrate our wonderful open green spaces.
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