Essex & Eastwood Wharf   
Lea Marshes
Essex Wharf
This is a thin strip of land formerly a recycling depot, on the Waltham Forest side of the Lea Navigation, next to the road bridge across the Lea. Although it was certainly not beautiful, it was certainly a much less obtrusive use than the proposal to put an enormous number of housing units on the site, if only because the recycling depot operated for limited hours.

Surely as additional parcels of land become available, they should be added to the regional park authority not massively over developed to compromise the integrity of the Lea Marshes? According to the Regional Park Authority's Plan of 2000 the idea was to use Essex & Eastwood Wharf for some kind of waterside leisure facility. See Abercrombie Report.


See Hackney Council Planning Committee report about this application.
Details Page for Planning Application - 2009/1515
See architects drawings
See new images July 2010


Site AddressEssex Wharf Lea Bridge Road Leyton London E5 9RL
Application Registered04-12-2009
Comments Until04-12-2009
Application Number2009/1515
Site AddressEssex Wharf Lea Bridge Road Leyton London E5 9RL
Application TypeFull planning
Development TypeNew Build
ProposalResidential redevelopment - Demolition of existing buildings and construction of four separate blocks (ranging from 5-9 storeys in height). Comprising 144 residential units (30 x 1 bed, 94 x 2 bed, 18 x 3 bed and 2 x 4 bed). Provisions for car parking, vehicular access, new cycle and pedestrian routes.
Current StatusREGISTERED
ApplicantEssex Wharf Homes LLP & A2 Dominion (London) Ltd
AgentMr Luke Emmerton
WardsLea Bridge
Location Co ordinatesEasting 535500 Northing 186677
ParishesLeyton, E10
Appeal Submitted?No
Case Officer / TelMr J Price 020 8496 6714
Planning OfficerMr J Price
Existing Land UseNot Applicable
Proposed Land UseDwelling houses




This is one letter of objection
re: Application ref. 2009/1515 Essex & Eastwood Wharf, Lea Bridge Road, Clapton, E5 9RL (LB Waltham Forest).
The main issue here is the intensity of use. Lea Bridge Road is already totally over-used and it is difficult to see how capacity could be increased without renewing the bridge over the Lea (totally impossible until after the Olympics in 2012) and/ or building a new road across the marshes. Even if ways could be found to restrict the use of Lea Bridge Road this development would pose a threat to the marshes. For example the olympics authority has an objective to increase access to the marshes, but since Lea Bridge Road is currently at capacity, this would not be possible if Essex Wharf was given the go ahead, adding 144 units, and increasing the stress on Lea Bridge Road to breaking point at some times of day. It would also prevent the Lee Valley Park from introducing any new leisure facilities on the marshes since once again Lea Bridge Road has reached capacity and with Essex Wharf making matters worse it would not be possible to increase access to the marshes at all.
Although there are several housing developments on the Hackney side of the Lea Navigation there are none on the Waltham Forest side between the bridge and the old Lea Bridge Station. As a result even the most sympathetic development, which this is not, would be out of character.
Substantial housing development might lead to restricted use of the ice rink and the adjoining fields, which are often used for major events. These events can be extremely noisy and can take place outside conventional hours, for example circuses have been known to go on until midnight. A large concentration of housing at this location would be unreasonable since it would lead to pressure to control these uses in one of the few areas in north east London currently suitable for such events.
The area of the marshes closest to Essex Wharf has a very interesting ecology and species that habituate it include bats (probably of a common species but who knows?) and woodpeckers. There is little doubt that the much more intensive use of this area implied by this development (more cars, more noise, more disturbance, people around 24 hours a day) will upset the ecological balance in a way that occasional events do not, because this development would be permanent. Bats or woodpeckers are not seen on the Hackney side of the Lea Navigation where there is a lot of housing.
Given the fragile nature of the ecology in an area that is already showing signs of stress (if only from the intense traffic on Lea Bridge Road), a development of this size and intensity should not even be considered without an environmental impact assessment.


 
This is the NLLDC objection.
New Lammas Lands Defence Committee
 


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

Mr. Jon Price,
Planning Control Department, LBWF,
Sycamore House,
Waltham Forest Town Hall,
Forest Road,
LONDON
E17 4JF.
21st December 2009

Dear Mr. Price,

re: Application ref. 2009/1515 Essex & Eastwood Wharf, Lea Bridge Road, Clapton, E5 9RL (LB Waltham Forest).

I write on behalf of the New Lammas Lands Defence Committee, a cross-borough amenity group based in the Borough of Waltham Forest but drawing a considerable proportion of our membership from the Clapton area in the Borough of Hackney. We are concerned to preserve the former Lammas Lands of Walthamstow and Leyton Marshes as green open space, and believe the above proposed housing development at Essex and Eastwood Wharf would have severe consequences for the recreational, ecological and visual amenity of Walthamstow and Leyton Marshes and of North Millfields recreation ground, all of which are former Lammas Lands and within the boundary of the Lee Valley Regional Park. Indeed, we feel that the impact of these proposals would be even more detrimental than the previous Planning Application which was refused planning permission in September 2008 and dismissed on Appeal by a Planning Inquiry in February of this year. We are therefore writing to object to the Planning Application and to request that you also turn this proposal down on these grounds.

We do not propose to comment at this stage upon planning gain, traffic flow, flood risk or the suitability and density of proposed living accommodation, as we do not regard these issues as our main concern. As before, our objection is to the adverse impact of the bulk and especially the height of the proposed development - in which regard the current Planning Application is certainly even worse than the previous one - on the surrounding Metropolitan Open Land at Millfields, on Leyton Marshes and particularly on the nearby Walthamstow Marshes Nature Reserve within the Lee Valley Regional Park.

In January-February of this year, several members of the New Lammas Lands Defence Committee (NLLDC) attended an Appeal by the previous Applicants regarding a proposed change of use of the Essex Wharf site from commercial to residential; this was in support of the Borough of Waltham Forest, whose Planning Control Department had refused the Planning Application on 12th September 2008 (without it having been sent to the Council's Planning Committee). The site is entirely within the boundary of the Regional Park. Until about 15 years ago the site was within the Borough of Hackney, having once been the bridgehead for a ferry across the River Lea, and it is mainly Hackney residents who would be affected on a daily basis by any development of this site. The refusal of permission by Waltham Forest was also supported by the Lee Valley Regional Park Authority and the London Borough of Hackney, who are statutory consultees - indeed the then Speaker (Leader) of Hackney Council attended the Inquiry in person.

For your ease of reference, I enclose a copy of our original objection letter dated 24th January 2008 and of our written submission to the Planning Inspectorate dated 24th October 2008. We are pleased at the reduction in proposed car-regional park authoritying space, but all of our objections made then still apply in whole or in part to the current Planning Application.

Our main concern was and remains the appearance and visual impact of high-rise, high-density housing blocks on this site, described (paragraph 7) by the Planning Inquiry Inspector in February 2009 as "land at an important location - it is within the Lee Valley Regional Park, it is highly visible from Lea Bridge Road and Millfields recreation Ground and it is at a prominent ‘gateway' into the Borough" and (in paragraph 10) stated: "It is not disputed by any of the parties at the Inquiry that the appeal site is important in many ways. The site is prominently located at a main gateway into the borough and is very prominent from Millfields Recreation Ground and surrounding properties on the western side of the river."

We presume that issues regarding Section 106 Planning Gain agreements, transport and traffic impacts and the increased pressure on educational, leisure and social facilities in the area have been addressed since the dismissal of the Appeal in February 2009, and it appears that the Lea Valley Regional Park have come to some arrangement regarding the use of their road as an access to the site (and may possibly be less unsatisfied with the proposed narrow sight-lines through the blocks between Millfields and Leyton Marshes). However, these objections were not the deciding factors; the Planning Inquiry Inspector, Mr. Roland Punshon, concluded (paragraph 36) "I have concluded on the first main issue that THE PROPOSAL WOULD BE HARMFUL TO THE CHARACTER AND APPEARANCE OF THE AREA. FOR THIS REASON I CONCLUDE THAT THE APPEAL SHOULD BE DISMISSED" [our emphasis].

The Planning Inspector did not dismiss the Appeal on the grounds of Section 106 or traffic issues, but on the grounds that such a development would be harmful to the character and appearance of the area. We are therefore incredibly surprised that this new proposal has come forward with an even worse suggestion for even higher buildings, now threatening seven and nine storeys in height, completely disregarding the Planning Inquiry Inspector's clear conclusion.

We are also convinced that the new Planning Application (2009/1515) remains in clear breach of the Borough's Unitary Development Plan, and in particular of Policy SP1. As you know, this states that:- "The Council will seek to maintain and enhance the natural and built environment of the borough. In particular it will: A) Ensure that new developments or changes of use enhance rather than detract from their surroundings." The intrusion and loss of visual permeability of such a large high-rise scheme would obviously detract severely from the semi-rural open aspect of the surrounding area, as well as creating an unpleasant canyon-like feel around the meander between the Latham's timber-yard site and the oxbow wildlife and nesting area, and we therefore argue that planning permission should again clearly be refused.

Section D) of SP1 states that the Council will "Continue to protect the Green Belt and Metropolitan Open Land from incompatible development;" Section E) states that the Council will "Conserve and enhance open spaces within the urban area which have an important role to play whether for amenity reasons, for nature conservation or for recreation and community purposes;" and F) that the Council will "Protect and enhance green chains and promote borough biodiversity." We believe the proposals are quite unsatisfactory in these regards as well.

The buildings now proposed would still dominate the skyline from the Lea Valley Marshes in a way that the previous river-based commercial usage never did. An in-filled oxbow immediately to the north has recently been opened up and the areas around it restored as a wildlife habitat. The present Applicants have falsely claimed in their Planning Application that there are no mature trees of any significance nearby; in fact there are two mature Black Poplar trees (a nationally relatively rare native species) within this oxbow. Several large, high buildings placed in a such a visually imposing position would dwarf these two Black Poplars and also detract significantly from the important landscape feature of the newly-restored oxbow at the meander.

It remains our belief that the height of new buildings should not exceed that of the average surrounding existing built environment, which is a difficult consideration to apply since the site is surrounded almost completely on all sides by flat open space. Riverside Close, on the more urbanised Clapton side of the River Lee Navigation, consists of 2- and 3-storey residential units; the new Latham's timber-yard development is of predominantly 4-- and 5-storey housing; and north of Millfields are three 5-storey housing blocks set back some distance from the river whose visual impact is considerably lessened by the fact that they are surrounded by large established trees and there is a hill behind them which masks their height to a considerable extent. The open and highly visible site at Essex Wharf is not in any way comparable with these other sites. There are at present no residential buildings whatsoever alongside the River Lee Navigation anywhere in Waltham Forest (except for the Manager's small one-storey bungalow at the Springfield Marina). The proposed scheme still does not in any way fit in with and does not complement the surrounding open space. The nearest built structure, the Lea Valley Ice Centre, albeit an eyesore is only two storeys in height at its maximum. Across Lea Bridge Road, the locally listed "Red House" building in the Thames Water compound and the ‘Princess of Wales' and ‘Ship Aground' public houses by Lea Bridge are similarly only two storeys, as is the listed former school-house and chapel at School Nook; the ongoing development at the former OTV and Space Studios site behind these buildings is almost entirely screened from Millfields and Lea Bridge Road by the Princess of Wales public house, by riverside vegetation and by the mature (and TPOed) London Plane trees around the pubs and on the green at Lea Bridge Place. There is nothing in the riverside area approaching nine storeys, and by every criterion this is excessive.

In their response to the application for redevelopment of the former James Latham plc timber yard site, LB Waltham Forest are said to have asked in their objection to LB Hackney that the height of the buildings by the river be reduced to a maximum of three storeys, a request that was also made by the New Lammas Lands Defence Committee (we accepted four!). The fact that one 7-storey block at the Latham's development on the more urban west side of the River Lee Navigation was eventually permitted by the then Mayor of London and the ODPM should not affect this fundamental principle. (This unfortunate decision was made only after the scheme was objected to by Waltham Forest, was then refused by the London Borough of Hackney's Planning Committee, and a subsequent Appeal had been dismissed by the Planning Inspectorate.) Having made such an objection to a neighbouring borough, it would be inconsistent for LBWF Planners to recommend acceptance of the current proposals as submitted to Waltham Forest.

Fundamentally, NLLDC do not believe that a residential development at the Essex Wharf site represents its best potential use, given its potentially attractive riverside location, particularly in the context of the semi-rural character of the surrounding open space. In particular, we are very concerned that the river should not become hemmed in by yet more high-rise buildings, a point also made by the Inquiry Inspector this year. The landscape policies within the Lee Valley Regional Park Plan's ‘Strategic Policy Framework' make clear how important the Park considers it to be for adjoining landowners to contribute to the unique amenity and resource of the Regional Park - especially so when their land is within and surrounded by the Regional Park. Objective LS4.1 (Sustainability) of the Park Plan seeks to "recognise the Regional Park's open spaces and green landscapes as a finite resource to be protected from inappropriate development."

Policy LS1.2 of the Park Plan states that proposals for development or changes of land use within or on the boundary of the Regional Park should not act to the detriment of the landscape and its amenity value; should be sensitive to its landscape setting in terms of location, scale, design and materials; and should respect and contribute to positive landscape character, retaining existing features where appropriate. The Park Plan points out that "wetlands are linked to and influenced by the land surrounding them. Changes which … degrade adjacent habitat may adversely affect the biodiversity and amenity value of open water." NLLDC do not believe that the proposed development at Essex Wharf contributes to the amenity value or landscape character of the Regional Park. The Planning Inquiry Inspector earlier this year (paragraph 11) stated that "The design of any development on the appeal site needs to be sympathetic to this unusual context."

The LVRPA's Park Plan states that the character, visual amenity, ecological interest and informal recreational value of waterways within the Regional Park should be protected and promoted. Improvements to water quality and the waterside environment would strengthen the recreational potential of the River Lea, and the LVRPA has long hoped to redevelop Essex Wharf for water-related recreational activities. The Park Plan proposes an attractive and sensitively designed waterside leisure facility in this vicinity as a new visitor attraction for recreational use. The Planning Inquiry Inspector stated (paragraph 8) that whilst the site "is not an identified safeguarded wharf" he had in reaching his conclusion "taken into account the provisions of the London Plan dealing with the Blue Ribbon Network (BRN) and, in particular, Policy 4C.6. This policy requires that land alongside the BRN should be prioritised in favour of those uses which specifically require a waterside location."

The Planning Inquiry Inspector stressed (paragraph 12) in reference to the earlier - and lower! - Application design: "The proposal's general scale would reflect the more urban elements of development on the west side of the river and it would substantially complete the enclosure of Millfields recreation ground on all 4 sides. In my view, from the recreation ground and from Lea Bridge Road, the existing contrast between the urban area and the ‘marshland' landscape would be largely masked by the proposal and, because of its similarities in terms of scale and modern design, the proposal would be seen as an extension of the development to the west of the river rather than as an interface which reinforces the distinctive character of the 2 landscapes. From the ‘marshlands' area in the east, a development of this scale would be seen as a clear intrusion on to the eastern side of the river." We contend that an intrusion of modern-looking urban high-rise buildings such as this Planning Application proposes would effectively cut Leyton and Walthamstow Marshes off visually from the rest of Leyton Marshes south of Lea Bridge Road, as well as severing the historical link between Leyton Marshes and the ancient Mill Fields Lammas Lands, leading to a complete loss of contiguity on the Regional Park and of any sense of landscape legibility. We do not feel that,. In view of the scale of the high-rise, high-density buildings proposed in the current Planning Application, the suggested mitigation of what the Planning Inquiry Inspector called the "visually insignificant" entrance to the Regional Park here by provision of yet more cluttering signage is adequate to offset the fact that this Application, like the previous rejected Application, would "mask an important entrance to the Regional Park from parts of Lea Bridge Road, Millfields recreation ground and the river towpath" (paragraph 32).

Finally, When we objected to the original application (2007/2341) we had several ecological and wildlife habitat concerns, particularly the lack of regard to the special character of the MOL immediately to the north and across the River Lea, and the absence of any explicit mention of the two nearby bird sanctuaries at the former Filter Beds. The limited ecological survey then carried out inexplicably failed to find any sign of the very common Daubenton's bats, and field transects were carried out over a very short period of time, therefore possibly missing several migratory species. A new survey has been carried out, which adds little to the previous one; however we learned last week that a snake, possibly a viper, was very recently seen in the vicinity (our informant's father once worked with snakes at London Zoo, so this is of some interest).

We remain of the opinion that given the high ecological importance of the adjacent marsh habitat, a full and comprehensive Environmental Statement should be carried out under the European Union's Environmental Impact Assessment (EIA) Directive (85/33/EC as amended by 97/11/EC), to assess the impact of the proposed development on the nearby SPAs, SSSIs and PSNCIs, and providing a detailed assessment of the possible effects of the proposed development upon the river and riparian environment and the open spaces and marshland beyond, not just the Essex and Eastwood Wharf site itself. In 2001 a planning application was first made to LB Hackney for redevelopment as housing of the former James Latham plc timber yard site, on the Clapton side of the river to the north (Applications 2001/1886 and 2001/1894). Responding to LB Hackney's consultation, Waltham Forest's Planning Officers requested a full Environmental Impact Assessment of the development's effects on Walthamstow Marshes and also asked for consideration to be given to any likely effects on the Walthamstow Reservoirs Special Protection Area. Having asked for this to be done in such a similar context, we suggest it is inconsistent of Waltham Forest not to have made the same requirement in the case of the present application for Essex and Eastwood Wharf.

LB Hackney have also identified the river as "an important legacy which the Council wishes to protect and enhance" (LBH Supplementary Planning Guidance, note 12 on Conservation). In June 2002, at the time of the Latham's site application to LB Hackney, the GLA Planning Decisions Unit wrote to LB Hackney's Planning Department with concerns that because of the "ecological sensitivity of the site due to its proximity to the River Lea and the Principal Site of Nature Conservation Importance that becomes an SSSI towards the Warwick Marshes [sic], the assessment should analyse the potential effects of the development on the whole of the Walthamstow Marshes rather than perhaps confining [sic] to the river bank." We believe these criteria should also apply to the Essex and Eastwood Wharf site.

NLLDC do not object in principle to the use of the site - or part of the site - for a low-rise site-specific development, such as water-based recreational facilities as envisaged by the Park Authority or even an exceptionally sensitively-designed residential area. A traditional low-rise housing similar to the nearby Riverside Close estate and substantial sight-lines between built structures through which Millfields and Leyton Marshes would be clearly visible and which incorporated features which recognised the waterside location would be quite acceptable. But we would insist that no buildings be more than 2-3 storeys high, in line with other nearby built development.

In conclusion, the height and visual impact of the proposed buildings immediately beside the River Lea Navigation is completely unacceptable, and indeed even less acceptable than the previous Application which was turned down by London Borough of Waltham Forest, objected to by the London Borough of Hackney and the Lee Valley Regional Park Authority and its rejection upheld by the Planning Inspectorate. It is not appropriate to build a high-rise housing estate on a highly visible riverside location within the Lee Valley Regional Park which is surrounded by water, recreational space and environmentally-sensitive Metropolitan Open Land. The Application does little to address the concerns of the Planning Inquiry Inspector, it is contrary to the Blue Ribbon Network recommendations in the London Plan, takes little or no cognisance of the importance of the surrounding open spaces or the Lee Valley Regional Park within which it is situated, and is in any case clearly contrary to Waltham Forest's adopted Unitary Development Plan.

Please acknowledge receipt of this letter of objection. We should be grateful if you could please keep us informed as to the progress of the new Planning Application.


Download the NLLDC Planning objection about Essex Wharf from January 2008 .


Download the NLLDC letter to the Planning inspectorate about Essex Wharf from 2008.


Download the NLLDC Planning objection about Essex Wharf from december 2009.




Education is also a problem. There is already a shortage of primary school places in Waltham Forest and the capital is not available to build new classrooms. Building enormous numbers of new dwellings will make matters worse.