The planning department have granted us an extension till then.

This was agreed at the meeting we had on Wednesday (5th October) with Sean Walsh (planning), Jimie Jamal (regeneration) and Cllr Clare Coghill.

Do not try to respond via the councils website as the link is not active anymore.

The document under consultation is called Blackhorse Lane AAP Preferred Options  and to find more details please click here

To respond just email Sean Walsh on planning.policy@walthamforest.gov.uk with your views.

At the meeting we talked about various things and communicated residents concerns and wishes.

Key points for the officers to take into account were these:

•    To incorporate environmental sustainability in the vision for the Area Action Pan.

•    To retain the Standard Music Venue as a performing music venue and community music venue and not just as a pub.

•    To re-design the network of streets in the neighbourhood centre (BHL1) to incorporate outdoor and indoor spaces other than shops and bars for people to interact and better promote community spirit and create a sense of place.

•    To attract and encourage quality of shops, cafes, restaurants and drinking establishment. To encourage and support local and independent business and shops instead of chains of businesses.

•    To strictly limit the height of buildings to 3 to 6 stories in all areas including BHL2 (North and South), BHL1 and BHL8.

•    To incorporate mixed size and tenure dwellings in BHL1, BHL2 (North) and BHL8 to prevent creating unsustainable transit communities.

BAG is meeting on Wednesday the 12th at 7pm at the Mill to write the response to the council. If you want to contribute please join us.

DOCUMENTS

Timetable for the coming stage of the Plan: http://www.walthamforest.gov.uk/lds-2011-2013-summary-timetable.pdf

Download the Blackhorse Lane Area Action Plan – Preferred Options Document below (it is also on display at The Mill):

• Blackhorse Lane Area Action Plan Preferred Options (4.4MB PDF file)
• Blackhorse Lane questionnaire/response form (1MB PDF file)

Supporting documents

• Blackhorse Lane – Sustainability Appraisal (494KB PDF file)
• Blackhorse Lane – Habitats Regulation Assessment (385KB PDF file)
• Blackhorse Lane – Equality Impact Assessment (132KB PDF file)
• Blackhorse Lane Urban Design Framework (including Planning Briefs for the Station Hub and Sutherland Road)
  • Part 1 – pages 1-12 (11.5MB PDF file)
  • Part 2 – pages 13-27 4.5MB PDF file)
  • Part 3 – pages 28-37 7.7MB PDF file)
  • Part 4 – pages 38-47 (6.2MB PDF file)
  • Part 5 – pages 48-52 (5.1MB PDF file)
  • Part 6 – pages 53-57 (13.7MB PDF file)
  • Part 7 – pages 58-62 (6.6MB PDF file)
  • Part 8 – pages 63-67 (11.1MB PDF file)
  • Part 9 – pages 68-77 (12.9MB PDF file)
  • Part 10 – pages 78-87 (11.2MB PDF file)
  • Part 11 – pages 88-102 (9.1MB PDF file)
  • Part 12 – pages 103-117 (10MB PDF file)
  • Part 13 – pages 118-119 (2.7MB PDF file)

BLACKHORSE LANE AREA ACTION PLAN MEETING – WEDNESDAY 5TH OCT

BAG has organised a meeting for residents to meet with Cllr Clare Coghill, Sean Walsh (Manager of the Blackhorse Lane Area Action Plan) and his colleague Jimy Jamal from Regeneration to discuss the plan and register residents views.

Meeting venue: The Mill (7-11 Coppermill Lane, E17)
Wednesday, 5th of Oct – from 6:30pm

There’s also a meeting about the proposed extension of CPZ parking in Edward Road: (Consultation Document .doc)

The Mill, 7-11 Coppermill Lane – Saturday, 8 October  - 1pm

The date for this meeting has been shifted and is NOT now on the 13th. Apologies for any confusion or inconvenience. 

Have your say on THE FUTURE OF OUR CHILDREN AND OUR LOCAL AREA

Public meeting about the relocation of Willowfield School

Wednesday 18th of March @ 7:30pm

At Willowfield School, (main hall, entrance through the car park) Clifton Avenue, E17 6HL

Your chance to question councillors and officials about the quality of their plans 

Key issues:

===============

IMPACT ON TRAFFIC AND ENVIRONMENT

IMPACT ON SURROUNDING HOMES

HOUSING ABOVE SCHOOL

ARE THEY PLANNING A HIGH-RISE SCHOOL?

================

Contact BAG :: mobile: 07847 059 164 / email: chair@blackhorseactiongroup.org.uk

================

The Council plans to relocate Willowfield School to the area at the northern side of the playing fields and south of Blackhorse Road tube station (the old goods yard area).

The Council is consulting parents, residents and others on the planning brief, which will then shape the plans for Willowfield School. The current brief proposes the following:

• A much larger 1000 pupil school with a small provision for post-16s.
• The council has identified a limited site of 1.83 hectares of which 0.17 hectares are green belt land. The site is next to a very high-risk flood area and also right next to the overland railway line, green belt land and residential streets.
• Possibly, flats above the school development.
• Provision of a prominent ‘landmark’ building  -which usually is taken to mean a high-rise building.  No upper limit on height in current plans, though probably ‘more than 3 storeys’ high.
• A one-way traffic system to be introduced to Cornwallis Road, Lloyd Road, Hawarden Road and part of Edward Road.
• Car parking restrictions in the area.
• No guarantees that the building will provide any free or affordable facilities for community use, despite vague promises.

URGENT COUNCIL CONSULTATION

The council would like residents feedback on plans to site Willowfield school at the top of the Douglas Eyre playing fields.
Visit the Building Schools for the Future consultation here to give them your views.
As usual with council consultations they’ve waited until less than a week before the closing date to send details to residents!

The consultation closes on the 12th of January.

Here’s what this months BSF bullitin says on the subject:

Following the request from the Governing Body further to pursue the possibility of a site at the current Douglas Eyre Playing Field, discussions have been held with the owners (London Playing Fields Foundation), the adjoining housing developers and the Greater London Authority over the constraints within which use of part of the field might be acceptable. A Project Manager has been identified, and the next steps are to commission planning advisers and various other consultancies to support the development of a revised proposal.

LATEST ON THE TOWER BLOCKS
Thank you very much for all your support with the housing campaign Blackhorse Action Group Residents Association (BAG) started this year. We received emails and comments from over 150 residents unhappy with developers plans to build 10 blocks of flats up-to 23 storeys high on the site right behind Blackhorse Road tube station overlooking the Douglas Eyre playing fields.

In the last few months BAG members have raised the residents concerns and have met many councillors and the regeneration officer for Blackhorse Lane. BAG have also maintained correspondence with English Partnerships who own most of the land the tower blocks would be built on.

BAG distributed leaflets at the tube station and through residents doors spelling out the sheer height and density of the plan. English Partnerships developers went on to change their plans twice only to receive negative feedback from the Commission for Architecture and Built Environment each time.

In late October, we tried to organise a meeting with English Partnerships. The response from them was: “All plans are slowing at the moment given the market and local context. We’ll come back to you when it’s a bit clearer what our aspirations for the site are” (English Partnerships)

A few weeks ago in a meeting with Cllr Terry Wheeler (Cabinet Member for Investment and Enterprise) BAG members discovered plans for the blocks of flats were “no longer an option”. Cllr Wheeler stated on the record the 23 storey towers had been scrapped. He went on to say that the most likely option for the site would be a new home for an expanded Willowfield School.

BAG is still waiting for official confirmation on this. At the time of the meeting the council was still in negotiations to acquire the site.

We’ll never know whether it was BAG’s campaigning and the massive response from residents outraged at this inappropriate development that stopped our skyline being overshadowed by vast tower blocks or if it was simply a consequence of the collapse in the housing market. Either way we’d like to thank residents for all their help, and feedback to both us AND the council.

Clearly this is not the end of the story, as the Arcade site at the top of the market enters its sixth year as a boarded up wasteland, its clear that even if the council acquires the site, they may not do the right thing by us as residents. We will renew our argument that any development on BHL2 should have mixed facilities for the local community. So far however we’ve got the strong impression the Council thinks this is very unlikely. So, one battle won but a big fight still looming.

TESCO EXPRESS
Opinion seems divided on plans for a Tesco Express store on the former site of the Essex Arms on Forest Road (2-3 minutes walk from Blackhorse Road tube).

The proposed store would have 9 car parking spaces, secure bays for 14 bikes and would be open between 7am and 11pm. Debate has raged over whether this will decimate local business’s and destroy diversity or whether it’s actually a good use of a derelict site.

LATEST NEWS: Tesco appear to have withdrawn their application for the site (link). Have they changed their mind about the store or are they reapplying? BAG will try and find out more.

EMD CINEMA UPDATE
Liberal Democrat Councillor, James O’Rourke contacted BAG to inform us the council are in talks with UKCG about a new planning application for the building. In 2003, in response to the demands of Walthamstow residents the government denied UCKG permission to convert the building into a church. In the 5 years that have followed nothing has changed at either the EMD or Arcade site. Will the church be given permission despite this clear ruling?

Cllr. O’Rourke, along with an English Heritage representative and the Council’s Conservation Officer visited the cinema recently and found it in a “sorry state”. Councillor O’Rourke commented that he was “encouraged plans are now being made to use the EMD”.

ST. JAMES STREET LIBRARY
A final open air library was held in December outside the former St James Street Library building. Despite being closed without warning or consultation the council has been steadfast in its refusal to reconsider.

Back in October a meeting of the Walthamstow West community council descended into chaos after councillors blocked plans for a feasibility study on reinstating the library, instead opting for a new plan for a scout hut.
Councillors refused to discuss the decision using a microphone so all could hear as requested, and in the end rejected the plan with Cllr James O’Rourke pointing out it was against council procedure. (Read the chair’s reflections on the meeting here.)

And so what was once a valued local library of vital use, in particular to the elderly and the young now has boarded up windows. Instead of educating the community the empty building now contributes to its decline with street drinkers and drug users replacing readers and families on the bench outside.

THE NORTH LONDON WASTE PLAN (NLWP)
Residents Against Pollution are tentatively reporting that plans for an Incinerator at Blackhorse Lane have been scrapped.

RAP’s website states “Though we only have verbal hints at this stage, it looks like Blackhorse Lane is now unlikely to be chosen as a new waste site. We are trying to get something in writing, and we won’t know for sure till the “preferred options” stage of the consultation process is reached in May, when it will be clear whether Blackhorse Lane is still an option.”

WALTHAMSTOW GOD STADIUM
Walthamstow Dog track sits empty as the housing collapse hits its developers (even though they claimed to be altruistically building “affordable homes”). While offers to buy or lease the track back for dog racing – even in the short term – have been blanked by developers, Kingsway International Christian Church were given permission to use the track for a huge New Year’s Eve service. 15,000 people were predicted to attend the event which was broadcast live to 217 countries on the God Channel.

Meanwhile the SaveOurStow campaign continues despite a letter from the new owners L&Q dismissing the views of all those that love the track along with all offers put forward to buy the stadium. No planning application for the site has yet been made. Rumours have emerged of an American consortium who already own dog tracks and have a successful record of developing multi-function commercial sites who intend to start talks with London and Quadrant to acquire the site in the very near future.
Perhaps the sights and sounds of race night may yet return? Although don’t hold your breath.

If you haven’t seen it already BAG found some old Walthamstow Dogs footage from 1937, 1968 and 1986 down the back of the sofa, so we put together a 30 minute video tribute to “The Stow” through the ages.

Watch “The Soul of Walthamstow: 75 years of ‘The Stow’” here.

KICK OUT KIER
Six months after getting the money saving contract to clean Walthamstow’s streets and complaints about the Kier group’s service continue. The Waltham Forest Guardian reports that the “Row continues over borough’s filthy streets” and our “dirty and “neglected” playgrounds”.

There’s even a flickr group for people to send pictures of any rubbish strewn streets.
Kier also hold the contract for a mixed use redevelopment of Walthamstow Tube Station.

OTHER NEWS
Radio 5 Live visited Walthamstow market – Listen to their broadcast here
Hate all the “To-Let” Signs left long after properties have been rented out – Get rid of them here.

BAG WEBSITE
Last but not least for all the latest news and to discuss local issues keep visiting the BAG Blog.

Once again thank you very much to all residents for their support.

Happy New Year!!!

BAG.

We learned various details about bats and heard their noises on a “Bat detector” which was tuned into the appropriate bat frequency. We couldn’t see any bats as it was dark but the walk over Walthamstow Marshes with an orange moon hanging low over the land was very enjoyable indeed.  We were back outside the pub again at around 10.15 pm.

People must have enjoyed it as Jeanette, our bat walk guide counted the donations of everyone. The grand total came to £37.70.  Thank you everyone for your generosity.

In the future we will strive to organise more public events for residents to participate.

Without any further ado here’s the rest of the news:

LATEST ON THE BLACKHORSE ROAD TOWER BLOCKS

On the back of the comments you made individually and the ones we have passed on, we have had an opportunity to meet members of the council about the proposed 23 storey tower blocks to the back of Blackhorse Road. This shows that we are being listened to!

On the 27th August we met Bob Belam (Lib Dem), (Portfolio Holder for Environment and Regeneration) and John Macklin (Lib Dem), (Portfolio Holder for Service Modernisation and Deputy Leader of the Council) who both seemed eager to hear our views and were sympathetic. On the 3rd September we also managed to meet Terry Wheeler (Lab), (Portfolio Holder for Enterprise and Investment). He stated that the original plan to build vast tower blocks has been shelved.

So if that’s true congratulations must go to everyone who gave their views to us and the council! It doesn’t end there though, a new architect is taking over and new proposals are being developed on which we have no details or assurances over quality, height or ways in which the whole project can benefit the community as a whole.

We have renewed our argument that any development on BHL2 should have mixed facilities for the local community, but we got the strong impression that the Council thinks that very unlikely. So, maybe one battle won but a huge fight still looming.

In addition, we will see new plans to be brought forward to meet the strategy to increase the amount of accommodation available in the Borough. We will keep fighting to be a part of the planning and thinking about them and will keep you posted.

Future meetings are in the pipeline with councillors as well as the developers including English Partnerships and Circle Anglia.

We will continue to put forward residents views at meetings with key players and will provide feedback – and ensure that you remain a part of the action.

NORTH LONDON WASTE PLAN

A new residents group has been set up to stop Waltham Forest becoming North London’s dumping ground. Six new ‘industrial’ sites are proposed, four of these are planned to be in the Lea Valley, and one is earmarked for Blackhorse Road.

There’s a demonstration against the plans on Tuesday the 30th September at 6pm on the Town Hall steps.

Visit Residents Against Pollution for more info and to download some of their very stylish posters.
*The Residents Against Pollution group is supported by the Socialist Party, although RAP have contacted BAG to point out that they are a residents group and not officially linked or funded by the Socialist Party (not that BAG has anything either pro or anti to say about the Socilaist Party!!)

TESCO EXPRESS

Opinion seems divided on plans for a Tesco Express store on the former site of the Essex Arms on Forest Road (2-3 minutes walk from Blackhorse Road tube).

The proposed store would have 9 car parking spaces, secure bays for 14 bikes and would be open between 7am and 11pm.

Debate has raged over whether this will decimate local business’s and destroy diversity or whether it’s actually a good use of a derelict site.

Visit here for more information and to give us your views.

LONG LIVE THE STANDARD

The Standard Music Venue has been given a temporary reprieve from the bulldozer. Developers have reportedly shelved the scheme, due to the slowdown in the housing market. There is however an agreement to buy in place that gives them the right to return to the deal whenever the housing market recovers.

Read more here.

SAVE OUR STOW

BAG found some old Walthamstow Dogs footage from 1937, 1968 and 1986 down the back of the sofa so we’ve put together a 30 minute video tribute to “The Stow” through the ages.

Watch “The Soul of Walthamstow: 75 years of ‘The Stow’” here.

The latest news is that representatives of Save Our Stow have met with housing developers L&Q.

L&Q issued the following press release:

L&Q acting on behalf of the above consortium met with the SOS consortium on the 17th September.

This was not, as has been reported, a meeting to negotiate the sale of the land. No deal has been agreed between us and the SOS consortium. Instead this meeting was an opportunity for the SOS consortium to actually introduce themselves, for them to present a more detailed business proposal and to provide evidence that funds are available for any proposed purchase. The proposal received on the 23rd July was far too brief to be considered.

Following this meeting we are now able to look at their proposal and give it our full consideration. Once a decision has been made we will contact the SOS consortium directly. As this is a private business matter until a decision has been reached we have no further comment with regards to the proposal.

VICTORIA STILL EARLY TO BED

BBC London has revealed that early closures on the Victoria Line are likely to continue throughout 2009 after a brief pause for Christmas and New year.

Watch the BBC London report including a look at the new trains.

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

————————————————
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.

Six fire engines and around 30 firefighters dealt with a blaze on the proposed site of the 23 storey tower block development at the top of Douglas Eyre playing field on Wednesday (30th July 08).

Around fifty tonnes of tyres and rubbish were damaged at the site next to the Blackhorse Road Overground station. The fire brigade were called at about 2.30 in the afternoon and had the fire under control by just gone 6.30PM. Fire fighters remained to damp down the fire well into the next day and thick smoke was still drifting across Forest Road at 1.30am Thursday morning.

The sight of dozens of fire crew hanging around the area all day did appear to raise the spirits of some locals I noticed, although investigations as to the cause of the fire are underway.  Fire hoses stretched from the playing field up Hawarden Road, all the way to Blackhorse Road and across to the Standard side of Forest Road (with cars having to drive over them using makeshift ramps once the road had reopened).

Local residents Richard & Gill took some fantastic pictures (above) which you can see on their Flickr site here.

There’s another great wide shot of all the smoke on the horizon here.

Did anyone else get any shots we could put up on the website, email here.

With leaflets winging their way around the area, the first part of BAG’s campaign against the 23 storey (230ft high) tower block at Blackhorse Road is also well under way and we have to say a big thank you to all the appalled and mostly unaware residents who have submitted comments. PLEASE KEEP THEM COMING (see a selection below the form)!

TO STOP A 23 STOREY TOWER BLOCK BEING BUILT AT BLACKHORSE ROAD WE NEED LOCAL PEOPLE TO SUBMIT THEIR VIEWS, ALONG WITH THEIR NAME AND EITHER AN EMAIL OR HOUSE ADDRESS. WE CAN THEN PROVE TO COUNCIL PLANNERS THAT THE LOCAL COMMUNITY WANTS MORE THAN JUST HUGE TOWER BLOCKS.
WE WILL NOT CLOG UP YOUR EMAIL OR DOOR MAT WITH JUNK! ALTERNATIVELY BECOME A MEMBER OF BAG HERE.

Here’s a taster of the comments you’ve been sending us (we’ve shortened some to fit. Please let us know if we’ve altered the meaning in any way!):

“I know housing is short,but this is the most stupid thing I have heard for a while…its hideous.”

“I’m especially concerned that there seems to be nothing socially useful to the wider community being planned. we need facilities for the young people, shops, green spaces. somewhere to eat would be nice!”

“It seems to answer a brief that called for the design of a sink estate. It needs to be stopped in its present form and redesigned to reflect the nature of the surrounding houses and neighbourhood.”

“Will be out of keeping with the areas renowned Warner style of two-storey terraced dwellings“

“I will do all that I can to help stop these ludicrous plans.”

“Offers nothing to the existing community. It will put further strain on transport to have thousands more people living in the tower blocks”.

“We simply don’t want to see these monstrosities… huge ugly buildings that will look out of place in this community. We are worried about the additional traffic, both foot and mechanised that will be part of this”

“This is not an acceptable development for the area. Tower blocks are an awful addition… but also have been the cause of much social living discontent, that is why most of them have been knocked down. No logic to this.“

“If this is really what is planned… then this is appalling, and will cause serious problems for the area. How can the plans have gotten this far without addressing the issues of capacity, services etc?”

“I agree with developing the area but only with low rise accommodation (4 stories max)“

“Too many blocks built in a small area and will add to overcrowded transport.”

Please keep them coming! Here’s the Fight the Height Demo on BBC News, for more pics visit our flickr site.

OTHER POSTS ON THIS SUBJECT (CLICK BELOW)
%RELATEDPOSTS%

Do you want the future of Blackhorse Rd to be tonnes of high-rise concrete and more congestion?

The 23-STOREY, 230 FEET HIGH BLOCK is part of a planned ‘super-density’ housing development near the station, with OVER 400 FLATS for up to 1,000 people in 10 TOWER BLOCKS, squeezed into only 1.7 hectares (thats less than two football pitches).

The huge buildings are far higher than any other in the area (mostly two storey Victorian terraces) and will create a precedent for more tower blocks in Walthamstow. It will also add hundreds more people to the rush hour crushes in cars, buses, tubes and trains. There’s also a much larger development planned for the area north of Forest Road, adding even more people and cars to the Blackhorse Rd bottleneck.

TO STOP A 23 STOREY TOWER BLOCK BEING BUILT AT BLACKHORSE ROAD WE NEED LOCAL PEOPLE TO SUBMIT THEIR VIEWS, ALONG WITH THEIR NAME AND EITHER AN EMAIL OR HOUSE ADDRESS. WE CAN THEN PROVE TO COUNCIL PLANNERS THAT THE LOCAL COMMUNITY WANTS MORE THAN JUST HUGE TOWER BLOCKS.
WE WILL NOT CLOG UP YOUR EMAIL OR DOOR MAT WITH JUNK!  ALTERNATIVELY BECOME A MEMBER OF BAG HERE.

BAG WANTS THE DEVELOPMENT TO BE….
…on a smaller scale; less dense; better designed; sustainable; sympathetic to the area; with community spaces, facilities and services; meeting the needs of residents.

WHERE WILL IT BE?

WHY IS IT PLANNED?
The council wants to build 2,000 flats in the Blackhorse Lane area. Over 400 of these are earmarked for the site next to the tube station. Many more flats are planned on the north side of Forest Road.

WHEN IS THE BUILDING DUE?
After an inadequate public ‘consultation’, planning permission may be applied for in summer 08 and building could start as early as autumn 08.

THE OWNER & DEVELOPER
Government agency English Partnerships owns the land. The developer is the Key London Alliance, which is private house-builders Barratt Homes and Inspace, and housing associations Circle Anglia and Notting Hill Housing Group.

JOIN THE CAMPAIGN TO SAY NO TO THE ‘CONCRETE AND CONGESTION’ PLAN AT BLACKHORSE RD

1. TOO HIGH
Developers haven’t learnt from the anti-social, alienating high-rises of the 1960s and 70s. If this 23-storey block gets consent, it creates a precedent for more in the area.
The tower block contradicts what the council has said about taller buildings being: “out of keeping with the character of the area” and “particularly inappropriate”* when they’re close to greenbelt land like the Lea Valley Special Protection Area right next to it!

2. TOO DENSE
Over 2,000 new flats are planned for the Blackhorse Lane area. Over 400 of these are proposed for a small area of 1.7 hectares next to the tube station.  This is much denser than other local housing, and has no significant open spaces.

The proposal is…
3. TOO RESTRICTED
The proposal only includes housing. There are no shops, businesses, communal facilities or usable open spaces for people. This is a recipe for social alienation and anti-social behaviour.
The development will add more traffic to the jams at the Blackhorse Road cross-roads, and swell the crowds on our pressured tube, buses and trains.

4. ADDS TO OVERCROWDED TRANSPORT

The development will add more traffic to the jams at the Blackhorse Road cross-roads, and swell the crowds on our pressured tube, buses and trains.

5. POORLY DESIGNED
The height and bulk of the buildings will tower over the area and local housing. At ground level it will be walled in and used mainly by vehicles rather than as landscaped open space. There are no shop fronts, communal and work spaces, services or other facilities to bring the place alive for local people.

6. SPOILING THE AREA
This is a super-dense bunker. It will dominate the existing two-storey homes nearby and damage the character of the nearby streets.

7. UNSUSTAINABLE
The design is to a minimal level of sustainability for energy efficiency, water/ waste management and countering climate change. This level of sustainability is well below what owner English Partnerships champions on other sites.

*Waltham Forest council’s Unitary Development Plan, March 2006

The Blackhorse Action Group (BAG) is the residents association for the Blackhorse Rd area. We are not a party political group.

OTHER POSTS ON THIS SUBJECT (CLICK BELOW)
%RELATEDPOSTS%

We look forward to hearing their reply to residents concerns. 

Download: Word doc: BAG’s response to developers proposal for BHL2

Feedback from the Blackhorse Action Group

Following your recent second public open evening, I am writing to you on behalf of the Blackhorse Action Group, the Residents’ Association for the area bounded by and including Blackhorse Road, Hawarden Road, Lloyd Road, Cornwallis Road, Courtenay Road, Edward Road, Coppermill Lane, Elmfield Road, Salop Road, Stephenson Road and Leucha Road.

As well as providing feedback on the design, housing mix and traffic plans (as you have requested), we believe that there are two other important issues that need to be addressed: local amenities and community safety and crime prevention. We have covered these as well, insofar as they relate to the proposed development.

We have some major concerns about the proposed development because of the following issues. We do not think that the proposals respond adequately to the vision set in:

• • the Government’s Planning Policy Statements and Guidance;
  • the London Plan; and
  • the London Borough of Waltham Forest’s Interim Planning Policy Framework and UDP.

and because of this do not offer a robust strategy for sustainable development. In addition, we are concerned that little regard seems to have been paid during the open evenings to the views of local residents or to their suggestions and the proposals have been put forward as more or less a done deal.

We sincerely hope that this is not the case and herewith offer our own considerations. We would appreciate it if you could please respond to the questions we have raised.

We look forward to hearing from you.

Chair
Blackhorse Action Group

Read on for full document…

DESIGN

We are starting from the basic tenet of PPG1 which 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’.

Tower blocks

We are concerned that your plan to build a series of high rise buildings does not offer the level of creativity and sensitivity that is so much evident in the vision put forward in the London Plan and Planning Guidance both at a pan London and local level and does not fully take into account its likely impact on the existing residential area. We would also like to make the point that experience of building high rise developments in previous decades has demonstrated how they can, if the design is not exemplary, and if there is not an adequate infrastructure to support the residents, the centre of anti-social behaviour and become ghettos – no go areas for anyone who does not live in them.

Waltham Forest’s UDP (Chapter notes that environmental conditions in West Walthamstow are ‘less satisfactory’ than some other parts of the Borough and attributes this in part to ‘larger slab and tower block estates’. It recognises in this respect that ‘the environmental problems in this part of the Borough are largely due to traffic, noise, pollution, ‘bad neighbour’ uses and lack of building repair and maintenance.

In contrast to ‘larger slab and tower block estates’, it proposes that the ‘design and layout of all new developments should be of a high standard and be seen as providing a worthwhile contribution to the Borough’s environment. Proposals should pay careful attention to the size, appearance, materials and fine detailing of new buildings and in addition demonstrate an equal consideration to the design and layout of surrounding public and private space’.

As the UDP notes, RPG3 urges London Planning Authorities to give careful consideration to the height, density, scale, massing, bulk landscaping, design and architectural quality of proposed buildings. Paragraphs 8.29 – 8.30 of the UDP (First review 2006) notes that:

‘Waltham Forest is characterised by low rise developments such as two storey terraced houses and shops with two floors above. Most of the taller buildings are blocks of flats and maisonettes built in the 1960s and ‘70s and which are now generally regarded as being out of keeping with the character of the area…..in general the erection of further tall buildings is not appropriate in Waltham Forest.’

The London Borough of Waltham Forest has stated in the UDP that it will not normally allow the erection of buildings or other structures which significantly exceed the height of their surroundings. An exception might be where ‘the development is of high architectural quality and does not have serious disadvantages to its immediate surroundings’. Paragraph 8.31 notes that it is particularly inappropriate to erect tall buildings in or next to Green Belt land or Metropolitan Open Land as this would spoil the open character of these areas. We would add to this that it is inappropriate to erect tall buildings adjacent to the Lee Valley Special Protection Area.

High density at a reduced height

It is our understanding that this site is a Major Opportunity Site as identified by the London Borough of Waltham Forest, but is not in the Opportunity Area (as set out by the Mayor in The Opportunity Area Planning Framework, Strategic Planning Guidance, January 2007). Even if it were, the Mayor has made it clear that high density housing does not necessarily mean high rise blocks. (London Plan Supplementary Planning Guidance 2005. Indeed in paragraph 5.4 the guidance notes:

‘Different forms of development can have similar densities. High density does not always mean higher rise development, and there are many studies that explore how high density schemes can provide good quality attractive housing and ensure the most efficient use of land’.

There is an inference in this paragraph that higher rise developments do not mean good quality attractive housing and this is a sentiment we share.

We are keen for your views on how you consider that the proposed development, including now a 23 storey building (higher than at the previous presentation) addresses these issues and how you have responded to the London Borough of Waltham Forest’s policies on high buildings, conservation areas and areas of special character.

High standard of design and architectural quality

In the proposals you have put forward (both on the Green Issues website and in the public displays) you make reference to ‘a high standard of design and architectural quality’. It would be helpful if you could advise in what ways this design and architectural quality is of a high standard.

We would also appreciate it if you could give us details of how you will achieve such high quality standard (including methods and materials. Indeed, in this landmark development we are keen to see that the quality is of the highest standard. In relation to the use of sustainable building practice in the development we are disappointed that developers are only working to achieve Code for Sustainable homes level 3 (on the basis that this is the minimum requirement to attract funding for social housing from the Housing Corporation). For the development to be exemplary, as the LWI suggests it is, we would like to see the development achieving level 5. This has already being achieved in other London Wide Initiative schemes in London.

Physical environment

You state that the development: ‘will make a significant contribution to improving the physical quality of the area, whilst respecting the nature conservation value of its location’  and ‘The form, scale and layout of the development respect the character and amenity interests of the adjoining residential streets whilst making full use of the site’.

Whilst some of the land is not being used, and indeed has been left to deteriorate (pending planning applications as regards the site adjacent to Blackhorse Road tube station), there is an argument that any development will improve the physical quality of the area. However, we strongly dispute the assertion that what is being proposed respects the nature conservation value of its location.

As you know, the adjacent land is a mix of playing fields, green belt land, marshes and a Site of Special Scientific Interest (SSSI) with a wide variety of breeding species and protected by European Law. We believe that it is fundamental to incorporate this landscape (together with the existing architecture) into any future design plans. We fail to see how buildings that rise to 23 storeys achieve this in a sympathetic way.

Lack of private and defensible space

The ‘Strategic Guidance for London Planning Authorities’ issued by the Government Office for London in 1996 stressed the need to consider the desirability of private and defensible space. We question the most recent design with what appears to be a brick wall surround, a carpark behind and a concrete podium above. A more attractive frontage of shops and other working and recreational spaces (including shops, cafes and other services) on the ground floor instead of garages would create a safer and more animated environment on the streets. In terms of a layout we believe a better design would be a perimeter block providing a street which would facilitate surveillance with private and defensible space in front of the dwellings.

Economic regeneration

You note that these buildings will: ‘…contribute positively to the area by becoming landmark buildings and by promoting regeneration through improved economic confidence in the area’.

We remain to be convinced of this, and would appreciate further information on how this might be the case. At a time when there is some uncertainty in the housing market, and when little flesh has been added to the bones of the other development plans in the Blackhorse Lane area, we have strong concerns that these buildings will not on their own provide the catalyst for regeneration that Walthamstow so dearly needs.

The London Plan (3.31) notes that large scale residential developments present the potential to provide not only additional housing and related uses, but to create a new sense of place with its own character and identity where people will want to live and work. Overall we very much doubt that the designed concept aims to meet the Mayor of London’s requirement for maximising residential development in sustainable locations.

A ‘sustainable location’ is not simply an area close to a tube station, served by few buses. A sustainable location with a ‘sense of place’ will enable residents to live, work and socialise, there. In order for this to happen, there needs to be a social, economic and service infrastructure in place. Jobs, services, amenities, leisure, culture, work and community spaces are essential to a ‘superdensity’ development such as the one proposed. Your current proposal means that potential residents will have to travel and commute either using private means or public transport to work, shop and go out. A sense of community and neighbourhood will never be achieved in his way. The Mayor, in his Housing Strategy draft announced recently stated:  “We will create communities that are strong, inclusive, safe and sustainable and supported by excellent social, physical and economic infrastructure. We will help to empower residents”

HOUSING MIX

The UDP notes that the current estimated population of 221,000 living in 93,000 households is likely to remain stable and fall slightly over time. However, projections to 2016 suggest that one person households will dominate and this will result in a 22,900 increase in the number of households, giving a predicted total of 115,900.

We understand that the aim is to create 2000 new homes in the area over the next 10 years. The current plans propose:

• 418 units
• 672 HrH
• 46% private
• 18% LWI
• 30% Affordable rented
• 6% Shared Ownership
• 100% lifetime homes.

Proportion of new units in this development

There are a number of issues surrounding the housing mix that cause us concern. We were under the impression that this site was part of a larger development of the Blackhorse Lane area and that as such it would be accommodating some of the 2000 new homes. Given the area concerned, we had not expected that it would be accommodating  over 25% of the new homes. We believe that there is a need to reconsider the extent to which this site CAN accommodate this many homes and be sustainable especially without provision of services, amenities, work and community space.

We would strongly argue for the number to be reduced. In addition, we have serious concerns about the claim made in the IPPF that:

‘the Station Area might qualify for density of up to 450 habitable rooms per hectare and also with reference to  the London Plan that higher densities might be appropriate in urban areas with good access to public transport if low levels of car parking are provided. It also adds that for sites within 10 minutes walk of a Town Centre and with good access to public transport could be suitable for higher densities, of up to 700 habitable rooms per hectare’.

Whilst the proposed development does have access to the tube station and to some local buses, there is a question around the capacity for public transport to accommodate a large increase in the number of residents. We will cover this in the next section.

LWI units

We had understood from earlier discussions that the percentage of housing allotted to the LWI was higher than 18%. We would be pleased to receive any information you have about the projected demands for housing in this area in the coming years as well as any work you have done to identify how you might increase the number of units owned by cooperatives and other types of housing association. In addition, it would be helpful if you could advise which organisations will own the properties that are offered for affordable rent and shared ownership. The previous plans identified more social and less private housing than the current plans. Could you please explain why this has happened?

Number of family homes

The percentage of family homes is only 13% in your plans. Could you please explain the criteria used to decide that that is the proportion of family homes most appropriate for this area? Could you also please provide an explanation of how you arrived at this proportion.?  Additionally it would be helpful if you could confirm that  family homes for this development are at a minimum  3 bed-bedroom flats.

People living alone

The London Plan notes at 3.29 that lifestyles are changing with people working from home and people living alone who no longer require one bedroom flats and bedsits because they need a spare room for visitors, carers and families. It would be helpful if you could please supply the room sizes for  all types of dwellings.

TRAFFIC PLAN AND TRANSPORT ISSUES

Roads

One of the key issues for the surrounding neighbourhood is the impact that this proposed development will have on road, rail and tube facilities in the area.

As far as the roads in the area are concerned, we understand that the plan is to make Hawarden Road one way (with cars not being able to enter the Road from Blackhorse Road). This will mean that cars accessing the BAG area will be forced to use Lloyd Road or one of the other Roads which will increase the level of traffic. Blackhorse Road and Ferry Lane already suffer from severe traffic congestion particularly during the rush hour, but there is a constant flow of traffic throughout the day. We are concerned that this can only increase with the current proposed development and a further 1572 homes planned for the area.

In addition, the plan is to allow 30% parking provision in the proposed development. We are keen to hear how this limit is going to be policed, particularly if a number of the units are going to be privately owned and owners may argue that they need their cars. We are concerned that car owners from the proposed development, unable to find a parking space in the development, will park their cars in the BAG area (on the basis that not all roads in the BAG area are part of the Controlled Parking Zone). This will cause problems for current residents if they are unable to find a space to park their car.

Whilst we welcome the proposal for an on-site car club with membership for all local residents, we would question how this is going to work. It is difficult to be precise, given that we have not been given an indication of what the likely occupancy rate is going to be of the proposed development, but in the event of there being at least 1000 residents and 124 parking spaces, there would appear to be a likely high demand for the car pool. It would be helpful if you could indicate how many people you envisage living in the development and how many cars there will be in the car club.

Two other initiatives you plan to introduce are: ‘Good quality, secure cycle parking for all Scheme residents and visitors’ and ‘Safe, convenient walk links and pedestrian priority in the Scheme’s Home Zone’.

We are keen to see these programmes supported in any development, but have concerns about the security and safety of the area in general (and specifically in relation to theft and personal security) because of the way in which the development has been designed. I will return to this in the Crime section below.

We are also having difficulty in envisaging how these programmes will be inclusive and involve the existing community. We question the extent to which the development will be open to non-residents. The current drawings suggest a quasi-gated community with little access to people outside.

Rail and tube provision

You have noted:

‘With good rail and tube connections to London it is the view of Waltham Forest Council that the Blackhorse Lane is an area with significant untapped potential, adjacent to the wonderful natural resources of the Lee Valley Regional Park’.

The majority of people who use Blackhorse Road station do so for the Victoria Line and not for the overground service. In addition, the overground system does not run into central London. Indeed, many people who do not live in the area change from the overground to the underground at Blackhorse Road. This means that underground is already stretched and with this proposed development (and future plans for more homes) can only become more stretched. As anyone who lives in the area will know, the Victoria Line often suffers from delays and parts of the line being closed (including the section from Seven Sisters to Walthamstow). In addition, last year and this, the line is closing at 10pm each evening for repairs. Any limitations in the service have an enormous impact on the current residents – and this can only get worse when the number of residents in the area increases.

This pressure could lead to a move by an increasing number of residents to either opt for car use or to opt to take a bus. Bus services in the area are already stretched and often held up because of traffic congestion – we would appreciate feedback on how you envisage this working. 

Furthermore, proposals need to take into account further developments in Walthamstow, Tottenham Hale and Seven Sisters. All of these sites are on the Victoria Line which is the only Underground Line. Any discussions about the ability of the Victoria Line to absorb the capacity from this proposed development need to take into account the future demands on the service which will be an inevitable consequence of this proposal and future development.

LOCAL AMENITIES

The UDP notes in Chapter 5, a more equitable, and locally based, provision of services (including education and health) and recreation and leisure facilities should be achieved. Paragraph 5.28 states:

‘There may be opportunities in the development of the Major Opportunity Sites and other major schemes to include community facilities that would otherwise become over-extended or are absent in the surrounding area’.

Impact of proposed development on existing services

We are concerned that the current proposals do not fully address the impact  this development will have on local services (and no attempt has been made within the context of this proposed development to explain how it sits alongside other projects for the other side of Forest Road/Ferry Lane).

We would be grateful if you could provide further information of the projected needs of the proposed residents (including their demography) together with information about what services will be available within easy reach of the development. We would like clarification in relation to:

• Education
• Health
• Leisure
• Community centres
• Religious buildings
• Services for children and young people
• Services for young families
• Services for older people
• Services for people with disabilities

PPG 17 sets out requirements for local sports and recreation facilities and PPS 3 identifies what play looks like within new housing developments.

The Mayor of London’s Supplementary Planning Guidance (November 2005) notes at 5.10 that where a development includes family housing, accessible play spaces designed to meet the needs of younger and older children should be provided, taking account of the projected child population.

We understand from your proposals that you will contribute to improving play facilities and areas that already exist in the locality of the site and are identified for improvement by the LBWF offering improved access to those within walking distance e.g. at Stoneydown Park and Garden or Coppermill Park. We have concerns about the reality of these venues, particularly for young children. A walk from the farthest tower block to these locations may be ill-advised for children who are not accompanied by adults. Without these, however, it is difficult to see where children will play.

COMMUNITY SAFETY AND CRIME PREVENTION

DOE Circular 5/94 ‘Planning out Crime’ states that crime prevention is also capable of being a material consideration when considering planning applications. The need to take into account crime prevention is also part of PPG 3. PPG3 stresses the need to ensure that new housing developments respect and enhance the local character and designs and layouts are safe and take account of public health, crime prevention and community safety considerations.

We are concerned that the current design does not allow people to easily access the development. In addition, the lack of ‘sense of space’ and defensible space will result in residents not feeling a sense of ownership of common areas which will lead to them being neglected and potentially becoming a focal point for anti-social behaviour. There is a risk under the current proposals that there will be a lot of residents who lack the opportunity to access amenities including shops and leisure facilities and could instead become nuisance residents.

Added to this, we are concerned that if many residents are going to be at work there will be potential for criminal activity to take place unnoticed because of the layout of the blocks. 

We understand that there has been recent criminal activity in Stephenson Road where there is a new development. That development is now protected by a security company 24 hours a day. We would be disappointed if this were to be one of the outcomes of the proposed development.

It would be helpful to hear what consideration has been made of crime prevention in this development and whether you have developed a Crime Prevention Through Environmental Design strategy. In particular, it would be helpful to know whether (as is recommended in the UDP) you have contacted the Metropolitan Police Service Crime Prevention Design Advisers and what they have contributed.

�

“When a resident next to the site went to a surveyor she discovered the preferred design that St Modwen has suggested for the site would overshadow her garden, meaning her home will be worth £10,000 less than if situated elsewhere.”

Caramel Quin of Fighttheheight.co.uk had been told that earlier plans for a seven storey development would have boosted prices: “property experts told us the area would be improved and prices would go up“.

Developers will of course make plenty of money from the new tower blocks planned at the Arcade, and the 23 storey Blackhorse Road development.

When residents who currently look out on playing fields and reservoirs find that view replaced by 23 storeys of flats, will they also find the price they can get for their home has fallen too?

Send the developers PR team your views on the proposed Blackhorse Land development here.

As previously reported Prince Charles’ Foundation for the built environment has stated (here) that high rise’s are both unnecessary and inappropriate for Walthamstow.

“Waltham Forest called in the foundation to masterplan the Town Centre of Walthamstow. (Foundation executive) Dittmar says the foundation was interested to explore how Walthamstow, in an outer London borough, could meet mayor Ken Livingstone’s target for affordable housing and how greater residential density was compatible with Walthamstow’s Victorian terraced houses.

Dittmar asks: ‘How can you increase density without sticking people into tower blocks? If you ask Londoners about tower blocks, you find that they are only liked by investors in property.’

The foundation looked at other boroughs and concluded that the four-storey houses of St John’s Wood or Swiss Cottage and the mansion blocks of Kensington and Chelsea provided density without towers”.