Lea Marshes

Basketball building on Porter's Field   
The New Lammas Lands Defence Committee sent a very powerful letter protesting against the construction of a basketball practice court on Porters Field.

See Oympisstake video web site.

New Lammas Lands Defence Committee

c/o Hornbeam Environmental Centre, 458 Hoe Street, Leyton Green, London E17 9AH
Chairman: Mr. Joseph Ward Co-Chair and Planning Liaison Officer: Ms. Katy Andrews
Vice-chair: Mr. Laurie Wortley Co-vice-chair and Membership Secretary: Ms. Cath Rasbash
Hon. Secretary: Mr. Chris Hill Treasurer: Mr. John Gilbert

A. Boris Johnson, Esq.,
The Mayor of London,
Greater London Assembly,
City Hall, The Queen's Walk,
SE1 2AA.
and via e-mail to: mayor@london.gov.uk
26th January 2012

Dear Mr. Johnson,
re: LBWF Planning Application No: 2011/1560
Formation of temporary basketball venue at Leyton Marsh E10 7QL
(former Lammas Lands on northern part of Leyton Marshes).
Applicant: Messrs. Arup Ltd. on behalf of "London 2012"

I write regarding the above Application on behalf of the New Lammas Lands Defence Committee, a local interest group based in Waltham Forest which also draws part of its membership from the Borough of Hackney. NLLDC represents the interests of local residents of the Lower Lea Valley concerned to maintain the green and open character of, and our continuing free access to, all the former Lammas Lands of Hackney, Leyton and Walthamstow Marshes.

We are particularly concerned with preserving the precious and historically fascinating Lammas Lands of Leyton Marshes - Marsh Lane Fields being vested in the Borough of Waltham Forest (the successor to the Leyton Urban District Council) under the 1905 Leyton Corporation Act, and almost all of the rest having been acquired, through Compulsory Purchase, by the Lee Valley Regional Park Authority. All of this area (most of which is within the boundary of the Lee Valley Regional Park, established in 1967) is designated as Metropolitan Open Land, and much of the former Lammas Lands of Leyton and Walthamstow Marshes has other designations also, either as playing fields, SSSIs or as part of an extensive Site of Metropolitan Importance for Nature Conservation.

A Planning Application has been made to the London Borough of Waltham Forest by the Olympics Delivery Authority (ODA), the London Organising Committee of the Olympic Games (LOGOC) and the Olympic Park Legacy Company (OPLC) - collectively known as "London 2012" - for planning permission for "a temporary basketball training venue comprising two 11metre high modular court buildings, tented reception facility, access road, drop off area, car park, plant storage containers, perimeter fencing … between 1st March 2012 and 15th October 2012." This was submitted by Ove Arup in November 2011, and the proposal has unsurprisingly met with widespread opposition from local residents, conservationists and amenity groups.

The proposal would involve three tall, large and visually unattractive buildings and a very large marquee being erected on the Porter's Field meadow, which is a wide, flat area of Metropolitan Open Land at the northern end of Leyton Marshes adjacent to the River Lea, for a period of some 7-8 months over the Spring and Summer. This is not a short-term temporary event, such as a gymkhana or a weekend "countryside comes to town" exhibition (such as the field has been used for in the past), nor is it a use that would be

of any benefit to local communities in the area. In fact - in terms of amenity, access to public open space and views across the flat, open semi-rural marshes - it would be an obvious disbenefit. There would be no public access to a large amount of Porter's Field, several informal and well-used footpath and horse-riding routes would be severed by

the usage, and there would be increased pressure from people, horses and dogs on the environmentally-sensitive rough meadow-grass areas around the perimeter of the field.

The whole of the Lea Valley marshes, according to the WF Biodiversity Action Plan 2010-2020 (page 6), is of international importance. In addition, the Lea Valley Marshes are also designated as a Special Protection Area (SPA) for birds and a

Special Area of Conservation (SAC) under European wildlife and habitats legislation. Walthamstow Marsh Nature Reserve, which begins about 150m north of the site, is

a Site of Importance for Nature Conservation and Site of Special Scientific Interest (SSSI) and is therefore supposed to be legally protected from damage through development. Additionally, the whole of Waltham Forest is supposed to be treated as an Integrated Biodiversity Delivery Area, the only London Borough to enjoy this status. The central tenet of English Nature's IBDA designation is that biodiversity should be looked at in a broad, landscape-scale context, in which case it is the whole of the Lower Lea Valley marshes with Waltham Forest – including the UN Ramsar designated site half a mile to the north, that should be regarded as the setting for

the proposed 3-storey development, and not simply the immediate surroundings of Porter's Field and the River Lea Navigation.

The Porter's Field area of Leyton Marshes, whilst not itself benefiting from specific nature conservation protected status (although surrounded by and partly within the M071 SINC), nonetheless forms an important and irreplaceable part of a large natural wildlife corridor along the Lower Lea Valley, which Natural England intends will become part of a regional "Thames and Tributaries" Integrated Biodiversity Delivery Area. It is an integral part of the extensive Regional Park stretching the length of the Lea Valley from the Thames to Ware, all the open spaces of which should be to some extent protected by that status.

We are also concerned that the "temporary" usage would be unenforceable, as it could be indefinitely extended once the MOL designation has been removed. It could also open the floodgates to yet more building on Metropolitan Open Land within the Lea Valley, once a precedent has been set.

Indeed, the 'Leyton MarshEcology Report on ProposedTemporary Basketball TrainingVenueOlympic Delivery Authority' (January 2012),produced by Atkinsmentions specifically (page 5) the possibility that the basketball courts may not be temporary, stating :"If the proposal alters or consideration is given to the retention of this feature inthe longer term, further ecological assessment will be required."

We have therefore strongly urged Waltham Forest's Planning Officers that it be refused planning permission, and we would also urge you to refuse the claim of "exceptional circumstances" which London 2012 are making (and about which we understand that you have already been contacted by Arup Ltd. on their behalf) in seeking your permission to allow this development to go ahead on green Metropolitan Open Land.

The Application is contrary to just about every piece of Planning Guidance and legislation there is, from European wildlife and habitat Directives, through National planning policy guidance and environmental legislation, through the London Plan 2011 right down to the Lee Valley Regional Park Plan (and the provisions of the Lee Valley Regional Park Act) and the Borough of Waltham Forest's own Unitary Development Plan and emerging LSF.

Policy 7.17 of the London Plan 2011, on Metropolitan Open Land, begins from the following Strategy base-line:

A) The Mayor strongly supports the current extent of Metropolitan Open Land (MOL), its extension in appropriate circumstances and its protection from development having an adverse impact on the openness of MOL.

With regard to Planning Decisions, the London Plan requires that:

B) The strongest protection should be given to London's Metropolitan Open Land and inappropriate development refused, except in very special circumstances, giving the same level of protection as in the Green Belt. Essential ancillary facilities for appropriate uses will only be acceptable where they maintain the openness of MOL.

In order to get around the fact that the proposed use is completely unacceptable on Metropolitan Open Land, which according to the London Plan has equivalent status to Metropolitan Green Belt Land, the Applicants ("London 2012") are claiming that because the facility is to provide a games-time training venue for Olympic Games basket-ball players, this makes the application a mater of "national importance" sufficient to constitute "exceptional circumstances" that would allow the provision of Section 7.17 of the London Plan to be set aside.

The New Lammas Lands Defence Committee, and other interested parties, do not agree with his assertion. Nor is it borne out by the fact that by Arup's own admission no venue for this facility had been identified as late as Summer 2010 - in other words the mater was hardly considered to be particularly important until then - and there is no evidence whatsoever that a proper site assessment has been carried out to identify other, possibly more suitable sites within a reasonable driving distance of the Olympic Village. It appears that they considered only three sites that were "offered to them" for possible uses in 2009 by the Lee Valley Regional Park Authority, and apart from that considered a disused warehouse in the Hackney Wick area. The lack of any methodical, sequential search does not suggest a thorough search for facilities supposedly of "national importance".

It seems that the ODA have not even contacted the London Borough of Waltham Forest to enquire about possibly venues owned by the Borough (such as the huge Ive Farm Sports Centre, about 500m from the Olympic Site, which has been lying unused and derelict since its former operators went into liquidation many years ago, or the adjacent Score Project Sports Centre, which boasts massive indoor tennis and basketball facilities which were purpose-built to enable wheelchair users to play).

In view of the clear lack of any attempt to find alternative venues, which would not involve the long-term loss of amenity on designated Metropolitan Open Land, we do not believe that this attempt at further purpresture of public green, open space by London 2012 can be justified, on spurious grounds of "national importance" or any other similar grounds. The Olympic Games may well be nationally important, but the taking of yet more land at Leyton Marshes - most of which will be taken up by the Lee Valley Riding Centre, the Camping and Caravanning Club (for a campsite on the Golf Course), the Eton Manor Gardening Society's temporarily relocated allotments on Marsh Lane Fields and extensive works at Marsh Lane and Seymour Fields (for replacement of a sports pavilion and children's play areas and construction of a new car-park) - cannot be justified for the provision of a training venue for basketball teams.

In view of the serious opposition to this proposal locally, we urge you to please exercise your discretion to refuse permission to set aside the provisions of the London Plan, and ask the ODA/LOCOG to carry out a proper search for facilities elsewhere - in a more suitable venue that does not involve the loss of our precious open spaces or Metropolitan Open Land.

Yours faithfully,

Ms. Katy Andrews, BA, MSc,

Co-Chair and Planning Liaison Officer, New Lammas Lands Defence Committee.

cc: Lea Valley Federation, Waltham Forest Civic Society, The Riverside Association, Leyton Marsh Users' Group, Friends of Walthamstow Marshes, The Hackney Society (Clapton Conservation Area Advisory Committee)