Problems with 2013/0410   
Lea Marshes
Horses
See: Planning history
  Thanks to considerable public pressure LVRPA/LBWF backed down and submitted a separate planning application for the golf course three days after this correspondence. But as with all LVRPA planning applications the process is shrouded in mystery. Apparently there are going to be permanent buildings instead of the temporary toilet blocks we had during the Olympics. But where are they going to be and what are they going to be like? And there is going to be pony trekking. What does this mean and why does it require planning permission? If it's just ponies crossing the land then does LVRPA need to get planning permission for pony trekking on the rest of lea marshes? Or does it means yet more building on Metropolitan Open Land ?
  Earlier today in Lea Bridge Road Hackney (Haggerston Ward) Councillor Barry Buitekant saw 2 planning notices for 2013/0410 dated 19 April in respect for the erection of a new stable block to provide 13 stables at the nearby LVRPA riding centre. When he looked at the detail of the application he discovered that it was also for a new camp site and pony trekking facilities at the Waterworks Centre. But no member of the public looking at the planning notice could reasonably tell that the notice included proposals for the Waterworks Centre. I hope you will agree with me that the planning notices are misleading and therefore should be withdrawn. And that new notices clearly stating that the application covers 2 separate sites should be put up.

Cllr Buitekant was also amazed to discover that there are no signs around the actual boundary of the riding centre, just in Lea Bridge Road, so few people who actually use the marshes are likely to see them.

The LBWF web site is just as bad. On the title page for application 2013/0410 it simply says:

"Proposal: Erection of new stable block to provide 13 stables."

You have to look at the documents to get any idea that far more than the stables is involved. No mention of this fact is made on the title page.

Today I made the following complaint about the presentation of the application to the LBWF web master:

"It does not provide an email link to the officer who has a very common name. It says there is no map and then provides one in the bowels of the added documentation. It is titled as an application about the riding centre but in the bowels of the documentation we find LVRPA talking about the totally unrelated golf centre. Quite, quite extraordinary."

What is even more remarkable is that not long ago I made a complaint to the ombudsman about LBWF's handling of an LVRPA application . That time the ombudsman could not find any fault in my case (I was 100% right) but rejected my complaint on the grounds that since I was the only complainer it couldn't be very important. I suspect that should a further complaint be made to the ombudsman about the extraordinary relationship between LBWF planning department and LVRPA that the ombudsman will not be able to rely on the same grounds for rejection of any complaint.

Jonathan Brind
(23/April/2013)
A second complaint about the process was also made by Hackney Councillor Ian Rathbone (forwarding an email that had been sent to him):

Flawed validation and publicity - LVRPA stables expansion and Waterworks development 2013/0410

Dear Mr Harrison

The publicity for 2013/0410 does not appear to be in accordance with the requirements of the Town and Country Planning (General Development Procedure) (England) Order 2010, and the application should not have been registered. There are major inconsistencies between the application form and other documents submitted, and the Design and Access Statement (DAS) and plans include multiple developments not described in the application form.

According to the DAS the application appears to be requesting approval for three separate and unrelated proposals - construction of 13 additional stables at the Lee Valley Riding Centre to the north of Lea Bridge Road; change of use of golf course to a paddock for the keeping of ponies with an associated field shelter at the Waterworks Nature Reserve and Golf Centre, Lammas Road E10, located some 500m away to the south of Lea Bridge Road ; and change of use of golf course to campsite with associated ablution blocks, also at the Waterworks Centre. However the application form and the publicity derived from it - site notices, the LBWF Planning Explorer website, and the Weekly List, omit any reference to the latter two proposals. The address is given as "Lee Valley Riding Centre & Grazing Land, 71 Lea Bridge Road, Leyton E10" and the application description as "Erection of new stable block to provide 13 stables" . All information on the application form relates solely to the stable blocks element of the application.

The site notices are currently fixed to lamp poles either side of the Riding Centre entrance on the north side of Lea Bridge Road. These seem to be the only notices. No notices have been placed on the south side of Lea Bridge Road near the sites of the other two proposals where affected parties could reasonably be expected to encounter them. In any case, given the partial and inaccurate description of the application in all publicity, the public will remain unaware of the proposals affecting the Waterworks Golf Course and so the application has not been publicised in accordance with article 13 of the 2010 Order.

Regardless of the inadequacy of the summary description of the proposals and their locations, and the misleading contents of the application form, it is unacceptable to combine multiple unrelated proposals in separate locations - which clearly do not form part of a single development - in one application as has been done in this case. It creates confusion, makes documents difficult to understand, and may compromise the proper consideration and determination of the individual proposals.

As an example of the problems arising, the application form declares the site area as 237.5 sqm while the DAS on P3 describes '8 ha of land to use as camping and pony trekking'. This is significant as with an area over 1ha it is a major development requiring publicising in a newspaper, and a campsite over 1ha would appear to be a Schedule 2 development requiring an EIA screening opinion.

For the above reasons, and since the proposal description and other information in the application form is clearly inconsistent with other supporting documents to a degree that could be construed as deliberate obfuscation by the applicants, I believe there should be submission of new applications which correctly describe the individual proposals so that there can be lawful publicity and consultation. Failing that, only the stables proposal should be determined.

Given that LBWF should be fully aware of the controversial nature of developments affecting LVRPA land, it is very surprising that this situation has arisen and the application was not given more careful scrutiny prior to validation.

Please could you let me know how you intend to resolve this?