Last chance to reply!

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Response to Blackhorse consultation

The Council’s consultation on “Annexe to Planning Obligations – SPD Blackhorse Lane Planning Obligations Strategy” or in English, the Blackhorse Road development consultation closes Friday (8 August).

You can read the document and electronically comment on the Blackhorse Lane Regeneration site.

Please send your individual responses via email to the Council (email).

BAG have sent local councillors our response to the consultation, see the document below, or Download the PDF.

At present the scheme appears to be experiencing delays, but we’re keeping an eye out for any news and will keep residents informed as soon as we hear anything!

Blackhorse Action Group’s response to the consultation
Annexe to Planning Obligations SPD – Blackhorse Lane Planning Obligations Strategy
By email – 6 August 2008

Dear Sirs

I am writing on behalf of the Blackhorse Action Group (BAG) in response to your invitation to comment on your proposals for funding the infrastructure required to support the new development in the Blackhorse Lane and Blackhorse Road area.

I would like to state from the outset that BAG has serious reservations about the proposed developments which straddle Forest Road and Ferry Lane and would appreciate the opportunity to discuss these with you in further detail.
We are particularly concerned that there is a lack of clarity about how the stated Objectives are going to be met and the extent to which the proposed tariff and other funding streams are going to contribute to an improved environment which is sustainable and which will result in the creation of a vibrant community of which we can all be proud.

Sitting as we do on the banks of the River Lee, we are ideally located to see how development around us is progressing. We have been struck by the visible poverty of Edmonton and its high rise housing developments, compared with the increasing prosperity of Hackney and its low level housing.
As you will appreciate, we are keen to see Waltham Forest take a leaf out of Hackney’s development book rather than that of Edmonton.

We question your apparent preference for high rise developments in this respect together with your plan to build a new school on a flood plain and next to green belt land.

The building of a new school in this area:

• carries with it risks in an area which is frequently flooded;
• will (together with the high rise blocks) spoil a much valued landscape;
and
• has limited use given that it is being built in an area where the majority of the new housing will be for single use and couples, rather than residents with school age children.
Objective 1
The plans that we have seen so far at the open evenings have focused on Housing in BHL2. We have not seen anything that relates to improved retail and leisure facilities. We are yet to be convinced that what is being proposed offers an ‘attractive gateway’.

PPG1 stresses the need for good design to promote sustainable development and the importance of design considerations. It states that the ‘appearance of proposed development and its relationship to its surroundings are material considerations in determining planning applications’ and urges the need for
new design to improve the quality of the existing environment.

PPG3 sets out the need to ensure that ‘new housing and residential environments are well designed and make a contribution to promoting urban renaissance and improving the quality of life’.

We have seen no evidence of anything that responds to the criteria set out in PPG1 and 3 to date.

We would welcome your rationale for the density which is being proposed which appears to be at a higher level than that recommended by English Partnerships in Urban Design Compendium (2007).

Objective 2 and Objective 6

We have not seen any plans that demonstrate how the new community proposed with the development at BHL2 (and indeed the existing community) are going to be able to take advantage of the Lee Valley Regional Park. We understand from the builders that there is a tunnel below Ferry Lane and the railway line which could provide access, but that this is blocked by a generator and that it also risks being flooded.

Objective 4

To the best of our knowledge, there is no planned business development within BHL2.

Objective 5

We have not seen any proposals for public services to improve the quality of life in the proposals contained in the development of BHL2.

At 1.6, you refer to extensive public and stakeholder consultation on the IPPF.
We would strongly dispute this, not least because the proposals that have been put forward in relation to BHL2 were at the outset very sketchy and remain so to this day. Indeed, the IPPF focused almost exclusively on development to the north side of Forest Road/Ferry Lane and to an extent on the Station Hub. It did not cover BHL2 in any depth.

The following which appeared in the IPPF:

On site BHL2 located behind Blackhorse Road Station and incorporating a semiderelict goods yards and industrial premises, the vision is for a residential development on the eastern portion of the site (BHL2a) and a relocated Willowfield secondary school in new purpose built premises on the western portion of the site (BHL2b) adjacent to (and offering improved access to) the Douglas Eyre Playing Fields.

The height of the blocks was skimmed over in the original documentation and has increased at each public open evening, we have not been given a clear indication from the developers of:

• the number of occupants;
• the type of dwellings proposed; or
• the timescale.

You will appreciate that this makes it difficult for us to gauge whether or not you are pitching the tariff at the right level. It also makes it difficult for us to comment if:

• the goal posts keep moving; and
• our concerns to date do not appear to have been addressed.
BAG believes that local residents understand the local area, valuing its intrinsic character and recognising its deficiencies. The local community’s interests are not being addressed by the scheme resulting in both existing and incoming residents being severely disadvantaged. The character of the area and its community identity will suffer unless local concerns are given proper attention. Our detailed comments follow.

We look forward to hearing from you and would be grateful if you could address your response to chair@blackhorseactiongroup.org.uk

Yours faithfully
Blackhorse Action Group

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BLACHORSE ACTION GROUP

DETAILED COMMENTS

1.6 and 1.8
We concur that there is a need for any new development to be sustainable
and successful and must not adversely impact on the quality of life or the level
of services provided to existing residents and businesses. We also believe
that any new development should enhance and add to what already exists.
BAG is concerned that the first phase of development likely to be submitted
for planning permission and then implemented in the Blackhorse Road area is
for large-scale, high density and exclusively residential proposals. Occupation
of this development by up to 1000 new residents will place an unsustainable
and damaging impact upon existing infrastructure provision in the area.
It is noteworthy that most of the infrastructure to support the entire new
development is located in BHL1 and that BHL2 is cut off from this by a major
road and railway line.
There is no certainty regarding either the detailed content or proposed
timescales for other phases which are intended to provide for community
facilities alongside other infrastructure provision. Moreover, the delivery of
these other phases is more seriously in doubt in the light of the current
economic climate. This could mean that the development at BHL2 may be in
place months or years before the infrastructure to support it is built in BHL1 or
developed from what is already here. For example, there is a need to ensure
that measures are in place to support the additional traffic and pressures on
existing transport facilities (the tube as well as buses) at the outset.
BAG urges the Council to review its brief for this first phase of intensive
residential development to ensure that it makes a direct contribution to both
the existing and new community by, for example, incorporating a mix of uses
and community facilities at ground level to meet the needs of both existing
and new residents and to comply with the intentions of the final sentence in
1.8. BAG asks the Council to confirm that the infrastructure to support the
accommodation at BHL2 will be ready at the same time as BHL2.
1.10

BAG would wish to see further details on proposals for the assessment of
local area infrastructure needs and the likely contribution to these from public
funds. In particular the following questions are raised:
• To what extent does the audit of existing facilities highlight their
paucity for the existing community?
• What is the brief for this assessment?
• What headings / topics will it include?
• What methodologies are proposed for the assessment?
• Who will carry it out?
• What inputs will there be from the local community?
• What is the timescale for a) commencement and b) completion of the
assessment?
• What procedures will be carried out from its initial findings to its formal
adoption?
BAG would be keen to learn what the priorities are for the use of the tariffs
collected under the BHL2 development. BAG would also welcome
confirmation from the Council that infrastructure to support the development at
BHL2 does not risk being held up until work in BHL1 is underway/ has been
completed.

We would also like to hear what priority the Council has afforded to the new
Waterside Development.

1.14

BAG would like confirmation that the proposed tariff (with details on what it will
be used for and projected costs) applicable to the local area be produced as a
Supplementary Planning Document in its own right with full consultation and
formal adoption procedures, in line with Government guidance from CLG
(paras 30-32 in document dated January 2008) on the Community
Infrastructure Levy.

1.15

We support the aim of having a clear income stream, but are concerned that
there is no clarity on the proposed length of time for which the tariff will be
collected. We are particularly concerned that pooling the contributions for
flexible spending in light of changing timescales could, if not managed
effectively, mean that funding will be delayed alongside delays imposed by
developers. We would like to see a proposal that recognises that the tariff will
be needed for twenty years with a clear plan of how the Council (and other
public service providers) will continue to ensure that public facilities are
supported after that.
Will the payment of a tariff mean that developers will not have to provide ANY
infrastructure provision, including community facilities, themselves? If this is
not the case, it would be helpful to know what infrastructure provision will be
provided directly.
Some facilities which would provide value and services to the community and
help to ensure a more sustainable development could be commercial or
privately funded (e.g. shops, cafes, nurseries and creches, local small
business or workshop opportunities, meeting places and cultural spaces),
possibly with publicly-funded subsidies for local users or subsidised rents for
marginal start-up businesses. They would also be a welcome addition to the
current proposals for BHL2 where there is, disappointingly, no mention of
mixed use buildings at ground level which would also improve safety and
security and enable sustainable community for new and existing residents.
This is particularly poignant in an area of Walthamstow where recent housing
developments which are NOT mixed use are now guarded against criminal
activity by a permanent security presence (Stephenson Road, near The Firs
Medical Centre).
Would the payment of the tariff preclude such provision as all the
infrastructure would effectively be Council-owned, supplied and managed?
BAG consider that this would be a disappointing outcome and does not
illustrate an effective move to encourage good quality private investment
which would contribute to an overall improvement of the area.
Does the tariff approach also mean that opportunities to integrate
infrastructure (and especially community facilities) into the fabric and
construction of a development may be missed, and that monies received will
then be expended elsewhere in the area? This could result in new
infrastructure being delayed or being in locations that are physically
disconnected from the main accommodation and could also mean that it is
more costly as the economies of scale and integration available during
planning and construction will be unavailable.
2.1
As noted above, BAG would question whether the tariff is adequate given the
lack of information we have been given about the current gaps in service
provision in the area and the number of residents and demography of the
residents proposed under the new development. We are also concerned that
the proposed tariff does not take into account the need for uprating year on
year to ensure that there is a continued income stream to maintain the
infrastructure.
2.3
BAG had originally assumed that the mix of accommodation would favour
single people and couples, but had been led to believe by Green Issues that
there would be a fair number of family sized units within BHL2. We had been
unable to ascertain from the developers how many people they were
intending to build for at any of the open evenings. The nearest we got (and
hence our questioning that there has been an extensive consultation) was
information between the first set of open evenings and the second set was
that they needed to provide for more people. You note here that you are
planning 2046 new homes for 3824 additional residents. A crude calculation
tends to support the view that there is not going to be a large amount of family
units. BAG has reservations about the move towards less family
accommodation. Our experience of high density accommodation in previous
decades has suggested that this building policy which is not mixed use,
becomes a magnet for antisocial and criminal behaviour.

BHL2 is at risk of this to a greater extent because it is isolated from the
infrastructure that is proposed to support it and will be some distance from
any services.
2.7
BAG’s understanding of the BHL2 proposals is that there is no provision for
public space, save for concrete squares between the tower blocks. BAG
consider that this is likely to attract antisocial behaviour.
2.9
BHL1
BAG are concerned that there is no discernible way of linking the north side of
Ferry Lane/Forest Road with the south side, so that the pedestrian and cycle
paths link Hawarden Road to the Waterfront Park. BAG are keen to ensure
that any links will be safe for both adults and children. BAG are keen to hear
what the timeframe is for this development.
BAG are concerned that the proposal for a neighbourhood centre is that this
will remain in private ownership. Whilst we are keen to see investment from a
range of sources, we believe that in an area that is already poorly served by
community facilities there is a need for the Council to play a part. Not only
would the current community benefit from a community facility, but it would
also benefit from the provision of leisure facilities which tend to be located in
the north and east of the Borough.
BHL2
As above, BAG are concerned about the logistics of linking BHL1 to BHL2,
taking into account the road and the railway line (and the flood plain.)
2.11
BAG welcomes the Council’s commitment to seek other types of obligation in
so far as they impact upon the environment. In this respect we are particularly
keen to ensure that any new development respects the need to be
environmentally friendly and sustainable, using the most advanced forms of
expertise available.
3.2
As noted above, BAG are concerned that the tariff is payable at
commencement of development. This could be 3 years after consent which
may in itself be many years ahead. This could mean that the infrastructure to
support BHL2 cannot be put in place if, say, the development at BHL1 or one
of the other sites is delayed. Equally, developers are likely to want to
postpone their payments until the latest possible date so that they can
continue to use the funding to increase their own profits.

3.3 – 3.5
BAG are keen to learn what might result in a reduction of the tariff within this
area as this may impact adversely on the proposed infrastructure (as per 1.10
above). BAG could envisage, for example, the case being made by
developers for a reduction in the tariff because of the additional cost of
making BHL2 workable. This may relate to additional measures to mitigate
against the existing flood plain or the lack of access between BHL1 and
BHL2. This would not mean that the need for a robust infrastructure would
diminish but could mean that there would be less funding to provide it. BAG
seek the Council’s clarification on this.
3.6 – 3.8
As noted already, BAG are concerned that proposals to develop the
necessary infrastructure could be delayed if parts of the overall development
are not carried out within the planned timetable. BAG are keen to ensure that
the process of managing these funds includes provision to seek views from
the community on the spend and is also transparent and accessible to the
community.
3.9 – 3.11
As noted above, BAG seeks the Council’s clarification on the capital sum and
commuted sum payments. We seek your confirmation that you have
assessed this for twenty years to support maintenance of the infrastructure.
Appendix B: Tariff calculation
BAG are concerned that so little of the tariff is being given to the provision of
community and cultural facilities. In an area which is already low on this
provision BAG would like to see the Council putting in place facilities that will
attract young professionals and families into the area and create an enhanced
sense of community. BAG notes that this part of Walthamstow has a sense of
heritage and pride in a community which was originally developed by the
Warner family on a philanthropic basis and asks the Council to use the
opportunity of this new development to build on that heritage and to support
that community. BAG is also concerned that there is no intention to increase
the provision of leisure facilities which would be easily accessible to the
community.
BAG are equally concerned about the need to ensure that there are adequate
library services and note their disquiet regarding the recent closure of the
library in Coppermill Lane.

Appendix C: Infrastructure Requirement
Education
BAG have serious reservations about the Council’s plans to expand
Coppermill Primary School. Given the large area that the BHL development
covers, it is evident that parents are likely to use cars to get their children to
school. We have seen no plans that demonstrate what the increased use of
cars around the school will look like and what measures are being considered
to ensure that the area can cope with the added volume.
BAG are equally concerned about the proposed relocation of Willowfield
School in an area of flood risk and on green belt. We oppose this. We do not
consider that this is an appropriate location for a new school and would
welcome the Council’s explanation of why it is pushing ahead with this
proposal and has seemingly not seriously considered alternatives in the area.
Not only do we have severe reservations in light of recent and frequent
flooding of the playing fields, but we also question the use of Council (and
Council Tax payers) money and other funding in the absence of central
Government funding because of the green belt and flood risk issues. BAG are
concerned that these additional and inevitable costs will at least partially if not
completely fall to be funded from the tariff and this will mean that there is less
available funding for other infrastructure.
BAG would be keen to hear what the Council proposes if the relocation of
Willowfield School fails because of the issues identified or for other reasons.
BAG asks the Council what alternative options there are and what the costs
would be – including land acquisition costs – and how this will be funded.
BAG is also keen to hear from the Council on how much funding it has
invested to date in its plans to relocate Willowfield School. BAG suggests that
the Council locate the school in an area that does not carry these risks and
means that the school will not potentially drain resources from other sources
including the proposed tariff.
BAG are disappointed that there are no proposals for open space
improvements at Stoneydown which is the closest existing open space to BHL
2 and nearby residents and no allowance for land, construction, equipment or
maintenance of any new public realm facilities (e.g. play areas, landscape
areas, etc.) on BHL 2 site. Are these all to be privately owned and
maintained?
We are equally concerned that there is no provision for:
• community use of / public access to Douglas Eyre Playing Fields;
• streetscape improvements in surrounding area south of Forest Road
or improved access to town centre; and
• new / improvements to children’s play or youth facilities.

Employment
BAG would be keen to hear what proposals the Council has to attract higher
quality employment and the extent to which the Council forecasts that this will
be available to the existing and new residents in the area. BAG are keen to
ensure that the tariff supports both new residents and existing residents in
ensuring that they can access the new jobs expected to be created.
Transport and Highways
We have alluded to this in previous comments, but we remain concerned that
the improvements proposed are dependent on money being made available in
the short term (commensurate with the development of BHL2). If this is not
the case, then there will be pressure on existing services which, as the
Council notes, are already stretched. The Council notes that the estimated
increase in road use will be 20%. BAG would like to draw the Council’s
attention to the traffic build up (and associated air pollution) during peak times
on Forest Road, Blackhorse Lane and Ferry Lane.
Parking management scheme
Much of the BAG area is already covered by CPZs. We seek the Council’s
reassurance that developments at BHL2 will not result in the use of existing
CPZs by those living in the new development. BAG note that the current
CPZs are already fully used and there are often not spaces for existing
residents.
Cycle park at Blackhorse Road Station
BAG welcomes a cycle park but would appreciate confirmation from the
Council that there is adequate provision for its upkeep in years to come.
Lee Valley cycle route/path
As noted in our comments on Objectives 2 and 6 above, BAG seeks
clarification on whether the cost of the Lee Valley cycle route includes the cost
of constructing a new and accessible underpass / bridge for railway and
Forest Road to link Coppermill / Douglas Eyre playing fields with area north of
Forest Road? This link alone could be very expensive and subject to flood
risk. The land take is indicated in Table 2.1, associated with BHL 2, but would
not necessarily include the acquisition of land below / above railway and road
to north of site (and not owned by developers) and associated cost of
construction.

Blackhorse Lane/Billet Road streetscaping/road safety
BAG have reservations that the funding the Council suggests will cover this is
not going to be sufficient to ensure that all parts of the new development
(including BHL2) are either:
• pedestrian-friendly;
• safer; or
• more attractive.
We consider that the issues of safety and appearance are fundamental to the
whole of this development and the Council needs to make adequate provision
for all ages – young and old, as well as those of working age who live or will
live in this area.
Bus priority measures and increased frequency
BAG welcomes measures to improve the 158 service, but would ask the
Council to also consider what measures are going to be introduced to improve
Tube provision from Blackhorse Road. The station is already suffering with
the volume of passengers and the sporadic nature of service on the Victoria
Line. Additional residents are going to increase the existing pressure on the
service. We would welcome information about how the Council is taking this
forward with TfL.
Public open space
BAG are disappointed by the lack of thought that has been given to date to
public open space in relation to BHL2. We would welcome the Council’s
opinion on how this can be enhanced and how developers can be encouraged
to work with and complement existing open spaces so that they are open to
all.
Equally important for all those residents on the south side of the development
is easy and safe access to open space on the north side. BAG are not
convinced that this has been afforded the consideration it needs in the current
proposals.
Community facilities
As noted above, BAG question the lack of priority the Council is giving to
supplying community/ cultural and library facilities. Like the LDA in its
response to the IPPF, we are concerned that there are not enough facilities
and that those listed at 5.10 of the IPPF are a long way away from BHL2.

BAG agrees with the Council that there is currently a shortage of youth
facilities and activities and poor coordination of existing facilities. BAG is also
concerned that there is a shortage of facilities for working residents and those
who have retired. BAG are keen to ensure that measures are put in place to
encourage residents to get together as a community and urge the Council to
reflect on this further. BAG is keen to see in this regard that the Council
makes provision for The Standard music venue in its future development of
the area.
In addition, BAG are keen to learn how the Council proposes to engage with
existing community groups to identify what residents want and need and how
the Council proposes to promote community development initiatives by
funding local community groups.
BAG would be keen to learn more about what is being proposed to date. All
we know is that there is provision for a new 500 sq. m building (but no
provision for location or land acquisition). We are not clear whether the sum
that has been allowed (£1.265m) is sufficient for all necessary fixtures, fittings,
equipment and staffing or whether it is simply the cost of the building structure
and fabric. If the latter, BAG would welcome further information from the
Council on how the other funding requirements will be met.
As we have noted above, BAG are concerned in this respect and more
generally that there are potentially insufficient sums allowed for ongoing
management / maintenance of community facilities, open space, play space
and so on. These costs can be considerable and BAG would like to see the
Council seeking a commuted sum from developers to cover costs for, say, 20
years, after which the costs will revert to the Council.