Lee Valley Ice Centre, Lee Bridge Road, London E10 7QL - Planning Statement
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Lee Valley Ice Centre, Lee Bridge Road, London E10 7QL Planning Statement
Lee Valley Ice Centre, Lee Bridge
Road, London, E10 7QL
Planning Statement
February 2020
WSP | Indigo
Aldermary House
10-15 Queen Street
London EC4N 1TX
T 020 3848 2500
E info@indigoplanning.com
W indigoplanning.com
Lee Valley Ice Centre, Lee Bridge
Road, London, E10 7QL
Planning Statement
Contents Page
1. Introduction 1
The Application 1
The Purpose and Scope of this Statement 2
Other Application Documents 2
2. The Context for the Proposals 4
Lee Valley Regional Park and the Park Authority 4
The Lee Valley Ice Centre 6
3. The Site and Proposals 8
Environmental Impact Assessment (EIA) 10
What we are proposing 10
Development Phasing 13
4. Pre-Application Consultation 14
Public Consultation 14
Pre-Application Advice 14
How engagement has improved the Scheme 15
5. Overview of the Planning Policy Context 16
National Planning Policy Framework (2019) 16
Statutory Development Plan 17
Other guidance documents 20
Emerging planning policy documents 21
Summary 22
6. The Park Development Framework 24
Vision, Strategic Aims and Principles (2010) 24
Strategic Policies (2019) 25
Area Proposals (2011) 26
7. Development on Metropolitan Open Land 27
Inappropriate Development 27
Very Special Circumstances 28
8. The Harrow School Decision 29
Background 29
Impact On Openness 29
Consideration of VSC 30
Conclusions on VSC 32
Summary 32
9. The Role of the Park Authority 33
Summary 33
10. The Need to Replace the Ice Centre 34
Operational Capacity 34
Repairs and Future Investment 35
Options for replacing the Ice Centre 36
Replacing the Ice Centre with a Twin Pad 37
Summary 43
Lee Valley Ice Centre, Lee Bridge
Road, London, E10 7QL
Planning Statement
11. Delivering Community Benefits 44
Community Value 44
Enhancing Social Interaction and Skills 45
Reaching Target Participation Groups 46
Making Sport More Accessible 47
Culture and Sports 47
Park Authority Community Programmes 49
Community Use Agreement 50
Socio Economic Benefits 50
Summary 51
12. Delivering Health Benefits 53
Physical activity improves health 53
Physical Activity and Sport Strategy for Waltham
Forest 2017-2021 54
Health and Wellbeing Benefits 55
Summary 55
13. Improving the Quality of MOL 56
Improving the Visual Appearance 56
Landscaping Improvements 58
Improving Biodiversity 59
Birds, Bats, Reptiles and Amphibians 61
Water Management and Biodiversity 61
Summary 62
14. Other Key Planning Considerations 63
Transport and Accessibility 63
Sustainability and Renewable Energy 65
Flooding 67
Drainage 67
Noise Impacts 68
Air Quality 68
External Lighting 69
Archaeology 69
Security 70
Ground Conditions 70
Demolition and Construction 70
Summary 70
15. Summary of Very Special Circumstances 72
Impact on the Openness of the MOL 73
Other Harm 73
Do the VSC Clearly Outweigh the Harm 74
16. Summary and Conclusions 75
The Existing Ice Centre 75
The Proposals 76
Key Policy Designations 76
The Acceptability of the Proposals 76
Very Special Circumstances (VSC) 77
Conclusion on VSC and Harm 78
Overall Conclusions and the Planning Balance 78Lee Valley Ice Centre, Lee Bridge Road, London, E10 7QL Planning Statement Appendices (Bound separately) Appendix 1 Selecting the Most Appropriate Site Report Appendix 2 Decision notice (LPA ref. 822222/458) Appendix 3 EIA Screening Opinion, dated 13 September 2019 Appendix 4 Harrow School Appeal Decision Ref. APP/M5450/W/18/3208434 Appendix 5 Current weekly programme Appendix 6 Executive Meeting Agenda 25 April 2019 Appendix 7 Map of ice provision in England and Wales Appendix 8 Indicative LVIC twin pad timetable Appendix 9 Letter of support from Real Initiative Letter of support from the Waltham Forest Islamic Association Letter of support from Sport England Letter of support from British Ice Skating (National Ice Skating Association UK) Letter of support from UK Sport Letter of support from the Lee Valley Junior Ice Hockey Club Letter of support from London Sport Appendix 10 Letter of support from Jessica Cooper Letter of support from Marika Humphreys-Baranova OLY & Vitaliy Baranov OLY Appendix 11 Lee Valley Regional Park Authority Case Studies
Page 1
1. Introduction
This Planning Statement has been prepared by WSP | Indigo on behalf of the Lee Valley
Regional Park Authority (“the Park Authority”) in support of a full planning application for the
proposed redevelopment of the Lee Valley Ice Centre (“LVIC”) to provide a state-of-the-art,
twin-Olympic pad ice sports facility.
The Park Authority owns a number of world-class sporting and recreation facilities. As part
of its remit, the Authority is creating a zone of sporting excellence throughout the Park. The
proposed redevelopment seeks to provide an ice venue of an exceptional design quality
which is able to meet existing and future demand for ice sports.
The key purpose of the proposed redevelopment is to deliver an Olympic quality twin-pad ice
facility that will serve as a specialist, regional ice facility for London and the South East.
The proposals for the ice centre have been developed with expert input from ice specialists,
IPW…and internationally renowned architects, FaulknerBrown, to ensure that the facility will
be exemplar in design and offer, ensuring that it is suitable for elite and community users.
The multi-purpose facility will serve as an anchor sporting facility at this gateway location into
the Lee Valley Regional Park (“the Regional Park”).
The Application
This application seeks the:
“Phased demolition of the existing building and erection of a new
community twin pad ice centre, including changing rooms, gym including
exercise studio, café and service areas. Amendments to the existing car
parking area to provide integrated swales, landscape and biodiversity
enhancements.”
The proposed development would comprise of a high quality sports facility which will further
enhance the Regional Park’s portfolio of iconic venues. The proposed replacement ice
centre would be located on the site of the existing ice centre. The key principles which have
shaped the proposed development are the need to deliver:
• More ‘ice time’ for all users including social skaters from the local community;
• A programme that will accommodate new and under-represented ice sports at the venue,
and introduce new participants to them;
• An Olympic quality venue with a regional catchment;
• A high quality, sensitive design which responds to its landscape context;
• Ecological enhancements to the surrounding landscape, including the River Lea and
oxbow lake;
• A sustainable venue with a minimum BREEAM rating of ‘Very Good’;
• New facilities for visitors such as a gym, an exercise studio and a café;
• An attractive sports facility that will encourage healthy lifestyles; and
• Continuity of ice provision during redevelopment, as far as possible.
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The Purpose and Scope of this Statement
The purpose of this Planning Statement is to explain and assess the proposed development
in the context of policies in the adopted development plan and other material considerations.
The Statement is structured as follows.
• Section 2 introduces the key context for the proposals, the background to the Lee Valley
Regional Park and the Park Authority, and the existing Lee Valley Ice Centre.
• Section 3 summarises the application site and the proposed development.
• Section 4 covers the pre-application consultation and engagement with key stakeholders.
• Sections 5, 6 and 7 set out the key policy context and material considerations for the
application. This provides the basis upon which the proposals are assessed in the
following sections.
• Section 8 summarises a piece of key case law that should be taken into account in the
determination of the application.
• Sections 9 – 13 contain the key supporting arguments that comprise the case for Very
Special Circumstances, which underpins the principle of development and the
acceptability of the proposed development.
• Other key planning considerations, not addressed in the previous chapters but still of
importance in assessing the application are included in Section 14.
• Section 15 provides a final summary of the case for Very Special Circumstances,
weighed against the harm to openness and any other harm.
• Finally, Section 16 provides an overall summary and conclusion of this Planning
Statement.
Other Application Documents
This Planning Statement forms part of the submission package for the application for
planning permission and should be read in conjunction with the following supporting
documents:
• Planning application forms and ownership certificates, prepared by WSP | Indigo;
• CIL-Additional Information Requirement Form, prepared by WSP | Indigo;
• Existing and proposed set of drawings, prepared by FaulknerBrowns;
• Design and Access Statement (including the Landscape Scheme prepared by LDA
Design, Crime Prevention/Safer Places Report prepared by Arup and Fire Statement
prepared by OFR Consultants) prepared by FaulknerBrowns;
• Landscape masterplan, prepared by LDA Design;
• Landscape Visual Impact Assessment, prepared by LDA Design;
• Ecological Appraisal, Biodiversity Impact Assessment, Updated Ecology Surveys and
Ecology BREEAM Assessment, prepared by LDA Design;
• Arboricultural Impact Assessment and Arboricultural Method Statement, prepared by
Patrick Stileman Ltd;
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• Tree Survey Report, prepared by Patrick Stileman Ltd;
• Transport Statement (including a Parking Management Plan and Servicing and Delivery
Plan), prepared by Cole Easdon Consultants;
• Travel Plan, prepared by Cole Easdon Consultants;
• Sustainability Statement (including a BREEAM assessment), prepared by Max Fordham;
• Energy Assessment, prepared by Max Fordham;
• Socio-Economic Statement, prepared by Volterra;
• Statement of Community Involvement, prepared by Grayling;
• Flood Risk Assessment, prepared by Expedition Engineering;
• Drainage Strategy (including a Foul Sewage and Utilities Assessment), prepared by
Expedition Engineering;
• Geo-Environmental Report/Ground Conditions Assessment and Ground Conditions
Interpretive Report, prepared by Concept;
• Noise and Vibration Assessment, prepared by Max Fordham;
• Ventilation and Extraction Statement, prepared by Max Fordham;
• External Lighting Assessment, prepared by Max Fordham;
• Air Quality Assessment, prepared by Air Quality Consultants;
• Archaeology Desktop Report, prepared by Orion Heritage; and
• Construction and Demolition Method Statement, prepared by Wrenbridge Sport Ltd.
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2. The Context for the Proposals
In order to understand the context for the proposals, it is necessary to understand the role
and function of the Regional Park, the Park Authority, and the history of the ice centre.
Lee Valley Regional Park and the Park Authority
The Lee Valley Regional Park stretches 26 miles, following the course of the River Lee from
the southern edge of Ware in Hertfordshire through north and east London to the River
Thames at Lime House Basin in Poplar and to the River Thames at Leemouth.
The Park Authority was set up on January 1, 1967, under the terms of the Lee Valley
Regional Park Act 1966. It is therefore a statutory public body and this is enacted in law.
The Park Authority is a unique and very special body with a duty to carry a very particular
and special role in a particular part of the country, the Regional Park.
The Lee Valley Regional Park Act 1966
Before considering the statutory duties of the Park Authority and the role of the Regional
Park, it is important to understand the historical context of the Lee Valley Regional Park Act
1966. Following the Second World War, the Lee Valley was largely neglected and derelict.
The Lee Valley was historically home to a range of industries, gravel pits, waterworks sites
among other uses. Over the years, many of these uses have disappeared and land was left
derelict. It wasn’t until 1961 when Alderman Lou Sherman, Mayor of Hackney, took up the
challenge to regenerate the Valley. With seventeen local authorities supporting his vision,
the Civic Trust was invited to undertake an appraisal of the Valley’s potential as a vast
leisure and recreational resource. The Civic Trust’s report was created in 1964 and
envisaged built developments across the area for public indoor and outdoor recreation and
leisure facilities. This report became a principle part of the evidential base and vision for the
Bill that was promoted by Parliament establishing the Lee Valley Regional Park Authority.
So, the Park Authority was set up to manage the future development of the Regional Park
and their jurisdiction is limited to land within the Park. The function and role of the Park
Authority and the Regional Park is explained in Section 12 of the Lee Valley Regional Park
Act 1966 (the ‘Act’) states the following:
“(1) It shall be the duty of the Authority to develop, improve, preserve and manage or
to procure or arrange for the development, improvement, preservation and
management of the park as a place for the occupation of leisure, recreation, sport,
games or amusements or any similar activity, for the provision of nature reserves and
for the provision and enjoyment of entertainments of any kind.
(2) For the purpose of fulfilling the duty imposed upon the Authority by subSection (1)
of this Section the Authority may construct, lay out, equip and maintain all such works
and buildings, enter into or carry out all such agreement or arrangements with any
body, company or person, provide or arrange for the provision of all such facilities,
equipment and services and provide or do all such other acts or things as they may
think necessary or expedient for that purpose.” (Our emphasis).
Section 13(1) of the Act is written without prejudice to the generality of Section 12. It sets out
ancillary powers and it helpfully lists the types of development and activity, which are lawful
for the Park Authority to do in the exercise of its functions. The activities are wide ranging.
Section 13(1) states:
“…it shall be lawful for the Authority in the exercise of their functions under this Act
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either themselves to do or to make arrangements for the doing by any company, body
or person of all or any of the following things:
(a) the development, laying out, enclosing or appropriation of any part of the park for
any of the purposes of this Act;
(b) the provision, erection and maintenance of all such accommodation, houses,
buildings, structures, erections, vehicles, plant, machinery, apparatus or equipment as
the Authority may think necessary or expedient for the purposes of this Act or the
enjoyment of the park or any facilities provided for those purposes;
(c) the winning, working, removal and carrying away of sand, gravel and other
material;
(d) the provision of dwellings and other accommodation for persons
i. employed by the Authority; or
ii. by any company, body or person for or in connection with the carrying on of
any activity or the provision of any entertainment in the park in pursuance of
this Act;
(e) the holding of exhibitions, shows, rallies, regattas and athletic and other
competitions or contests, and the provision of amusement fairs, music, concerts,
dances and dramatic, cinematograph and other entertainments;
(f) the provision of camping grounds and parking, mooring and landing places and
means of access thereto and egress therefrom;
(g) the improvement of waterways for the purpose of open air recreation;
(h) the provision of hotels, motels, hostels, caravans, holiday camps and other
dwellings;
(i) the provision of accommodation for, and the provision of meals and refreshments
(including intoxicating liquor);
(j) the construction, improvement and maintenance (whether inside or outside the
park) of roads, cycle tracks, bridleways and footpaths;
(k) the construction, maintenance and operation within the park of railways (including
elevated cable railways and mono-railways),tramways and other means of locomotion
and the provision and operation of vehicles (including trolley vehicles), vessels, plant,
machinery, apparatus and equipment;
(l) the provision and operation of road transport vehicles for the conveyance of
passengers within the park;
(m) the levying of tolls for the use of any private road in the park;
(n) the levying of charges for admission to, or the use of, any part of the park…” (Our
emphasis).
The list of activities and provisions that can be accommodated in the Regional Park relate to
land within the Regional Park boundary.
The Regional Park
In accordance with the Act, the Park Authority began by acquiring land in the late 1960s,
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establishing parklands and creating major and leisure venues within the Regional Park
boundary. In 2012, the Park Authority adopted a vision that the Regional Park would be a
‘World Class Visitor Destination’. Consistent with this, the Park Authority currently owns a
number of world class sporting venues, outstanding parklands, internationally valuable
wildlife sites and a host of recreation facilities and visitor attractions. This includes three
London 2012 Olympic and Paralympic Games venues.
Currently, the Regional Park consists of 4,000 hectares of open space interspersed with
various leisure facilities. The Authority’s venues and open spaces attract more than seven
million visits a year, including more than 279,000 visits a year to Lee Valley ice centre,
150,000 to Lee Valley Riding Centre and one million to the area’s green spaces, including
Walthamstow Marshes and Middlesex Filter beds. There are also pockets of residential,
industrial and horticultural uses.
The Park Authority continues to protect and enhance the environment and biodiversity of the
Regional Park, to create public open space for leisure and recreation and to deliver sports
facilities of regional significance.
A total of 95% of the Regional Park is designated as Green Belt and Metropolitan Open
Land1, with the remaining 5% already developed or allocated for development (these sites
are described in detail in the report looking at alternative sites, see paragraph 3.4 and
Appendix 1). Taking this context into account, there is an implicit acknowledgement that
some of the activities covered by the Park Act, which would otherwise be deemed
‘inappropriate’ in the Green Belt or MOL, are appropriate if being undertaken by the Park
Authority. The Park Authority has a legal duty to provide facilities for the purpose of enjoying
the Regional Park, which contains land that is otherwise safeguarded as Green Belt or MOL.
In short, the remit of the Park Authority includes providing directly or indirectly, built facilities
for leisure, recreation and sport; and the holding of sports competitions. Building a
replacement ice centre is fully consistent with the statutory remit of the Park Authority, its
location within MOL does not change this.
The Park Authority does have a town planning function, but it is not the local planning
authority for the purposes of development control. Section 14 of the Act is a mandatory
requirement for the Park Authority to prepare a plan defining the future use and development
of the Park. We comment on the Park Authority’s role in preparing a plan, the status of the
plan and its relationship with the London Borough of Waltham Forest’s (LBWF) planning
policies further in Section 5.
In summary, the role and function of the Park Authority is clearly unique and covers the
provision of high quality sports and recreation facilities in the Regional Park, the Park being
a significant and strategic leisure and open space resource for communities in London and
beyond. The development of a new, replacement ice centre within the Regional Park which
is being promoted by, funded by and run by the Park Authority is a key material
consideration in the determination of this application that must be taken into account.
The Lee Valley Ice Centre
The LVIC was granted permission by the Council in 1982 and the facility has served the
local community and ice-sport athletes as a single-pad ice rink for over 34 years. It is a
hugely popular facility, attracting just under 279,000 visits in 2018 of which around a third are
from the local community in the London Borough of Waltham Forest and London Borough of
Hackney. The centre supports public skating sessions and a community of ice hockey
teams and competitive figure skaters, as well as a programme of learn to skate and training
1A study undertaken by WSP | Indigo of land within the boundary of Lee Valley Regional Park found that 95% of the Park is
designated as Green Belt and MOL.
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activities.
The ice centre is at the end of its useful life with the existing structure and design being
unchanged since its conception. The site is currently operating at 100% capacity. Given its
age, it now suffers complicated and expensive operational issues, that have caused a
number of unplanned closures in recent years. The costs of keeping the ice centre running
in its current facility are substantial and additional works and disruption in the future are
inevitable. Despite the works already undertaken, the ice centre will require significant future
investment in order to maintain the facility and its existing equipment. In Section 10, we
further explain why it is unsustainable to continue to use the facility as is and it needs to be
replaced. However the key issue is that the Park Authority will be forced to close the facility
if intervention is not made, due to the financial and operational weight of maintenance and
refurbishment works.
The lack of capacity and the state of the existing building and facilities present a clear need
to replace the existing ice centre with a new facility in order to continue to provide ice time
for the local and regional community and provide a long term solution to the current issues,
described above. The Park Authority has a responsibility to provide sporting and
recreational facilities within the Regional Park (as outlined above) and, therefore, is
committed to the continued provision of the community facility. The need to replace the
facility also marks an opportunity to enhance the ice centre’s offer to respond to the
changing context within the London Borough of Waltham Forest, London and the ice
sporting world.
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3. The Site and Proposals
The site comprises of the existing Lee Valley Ice Centre, annexe buildings containing plant,
car parking areas, trees and grassland. The existing ice centre building has a simple barrel-
vaulted design in steel profile cladding, approximately 12.17 metres in height and orientated
parallel to Lea Bridge Road. The existing building (shown in Figure 1) has a dated
appearance and does not make a positive contribution to the natural sitting of the Park and
Lea Bridge Road. To the north (rear) and west of the building, single story flat roofed
annexes comprise plant and service areas.
To the west of the building is a car park formed of hardstanding which provides for 177
spaces. The area immediately to the front of the ice centre is currently used as an overflow
car park and provides an additional 130 parking spaces. In total, the ice centre is served by
307 car parking spaces. The remainder of the site is grassland with some trees of varying
quality.
Figure 1 Image of the current Ice centre building as viewed from Lea Bridge Road
The site is accessed via a two-lane entrance off Lea Bridge Road that provides a route to the
car parking area and links with Sandy Lane, the access road to the Springfield Marina.
Sandy Lane runs northwards through the site to the Marshes and Marina in the north.
The existing site was chosen as the best option for the proposed replacement ice centre,
following a robust process of site selection 2. The details of the site selection process and
outcome are set out in Appendix 1.
Site context
To the north of the site lies Leyton Marsh and Walthamstow Marshes and to the south, a
2 This included the application of the sequential test as an ice centre is a Main Town Centre Use.
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disused Thames Water depot. A formed oxbow lake of the River Lea borders the site to the
north west. Adjacent to the site to the west is Essex Wharf, a housing development rising to
seven storeys consisting of four separate blocks. To the east, separated by a footpath from
the ice centre, lies the Lee Valley Riding Centre.
The site lies between the urban area in the London Borough of Hackney (LBH) to the west
and the urban area of London Borough of Waltham Forest (LBWF) to the east, but is located
within the boundary of LBWF. The areas of Clapton and Leyton, respectively, are the closest
to the site. Business and industrial land uses are present at the edge of the Lee Valley
Regional Park, but the wider area is predominantly residential, interspersed with areas of
open space. The closest train station is Lea Bridge Road in the east, 0.5km away. Clapton
train station to the west, just under 1km away.
Figure 2 Site Plan
Key policy designations
The entire site is designated as Metropolitan Open Land (MOL), including the ice centre.
The site is within Flood Zone 2. The entire of the London Borough of Waltham Forest is an
Air Quality Management Area, so the site is within this.
The site is located the Upper Lee Valley Opportunity Area as defined in the Mayor’s Upper
Lee Valley Opportunity Area Planning Framework (2013). It is also within the Lower Lea
Valley Opportunity Area which was replaced by the Olympic Legacy SPD in 2012. The site
is also located in the Lee Valley Regeneration Area as defined on Waltham Forest’s
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proposals map.
A small part of the site is within a Site of Metropolitan Importance for Nature Conservation
(SMINC) to the north. The external annexes to the north and west of the current ice centre
are partially within this designation.
The site is not within a Conservation Area and there are no listed building on the site. The
closest listed building is down Waterworks Lane to the west. The site has a PTAL rating of
3.
Planning History
Planning permission was granted on 18 October 1982 (LPA ref. 822222/458) for the
“erection of a covered ice rink and associated parking”. The decision notice and approved
plans can be found in Appendix 2.
Since this application the site’s planning history has focused on minor works and/or
temporary uses associated with the operation of the ice centre, shown in Table 1.
Table 1 History of planning applications on the site
Reference Description of proposals Approved
140833 Installation of a 3m steel acoustic fence September 2014
and 2m timber fence around chilled units
and waste compound.
130323 An application for consent to display July 2013
advertisement- non illuminated Lea
Valley Regional Park and ice centre way
finding signage.
081944 Formation of 250m long cycle/pedestrian February 2009
path with seating area as shown on
drawing 1444/0/12 and un-numbered
drawing showing scheme details and
cross Section received on 3 December
2008 and location plan received on 21
January 2009.
930569 Erection of seven, 8 metre high security January 1993
lighting columns to over flow car park.
Environmental Impact Assessment (EIA)
Prior to the submission of this application, the Council considered the requirements for an
EIA on the site. It has been determined that the proposed development does not require an
EIA under the Town and Country Planning (Environmental Impact Assessment) (England
and Wales) Regulations 1999. This was confirmed by the Council in their letter dated 13
September 2019 as attached at Appendix 3.
What we are proposing
The description of development is as follows:
“Phased demolition of the existing building and erection of a new
community twin pad ice centre, including changing rooms, gym including
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exercise studio, café and service areas. Amendments to the existing car
parking area to provide integrated swales, landscape and biodiversity
enhancements.”
Replacement Building
The existing ice centre has a footprint of 3,596sqm (excluding annex buildings) and is a
simple barrel-vaulted form in steel profile cladding, approximately 12.17 metres in height and
running parallel to Lea Bridge Road.
The proposed development seeks a phased demolition of the existing building and phased
construction of the replacement ice centre to allow the continued use of the existing ice pad
for as long as possible so that the period when there is no access to ice is kept to a
minimum. The proposed building has a footprint of 7,029sqm, a height of 10.5 metres and
will provide state-of-the-art facilities including two new Olympic-size 60 metres x 30 metres
ice pads. The proposed development will also provide spectator seating for 500 and
standing areas for 300 spectators. Ancillary facilities will be provided in the space between
the two ice pads, including:
• Public skate change and skate hire area with vending and locker facilities;
• Changing rooms for Home and Away teams;
• Referee/judges/officials changing rooms;
• Accessible changing facilities;
• Team equipment and general ice equipment storage;
• Office and operations room; and
• Staff welfare facilities.
The building orientation will shift, so that the building is perpendicular to Lea Bridge Road,
with the narrowest elevations addressing the road and the marshes and the main entrance
facing the car park.
The proposed ice centre will include a new gym at the first floor, with capacity for 100
stations, dedicated changing facilities and an exercise studio. On the ground floor, a new
café space that includes both a skater’s café and a public café is proposed. The café will
provide access for non-skaters and users of the wider park. A bar and concessions area is
also proposed located at Pad B.
The GEA, of the proposed ice centre is 8,718sqm. This represents an increase of 4,515sqm
of floorspace compared to an existing GEA of 4,203sqm, which includes the first floor
accommodation. This will double the ice time available for the community and social skating
currently and allow additional ice sport teams and athletes to take part in sports which are
not currently on offer at the existing ice centre because it is at 100% capacity.
Refurbishment of the Car Park
The total car parking spaces will be reduced from 307 to 155. The car parking will be limited
to the area to the south west, where the main existing car park is sited. However, the area
will be broken-up with areas of planting and water features, proposed as part of the
integrated landscape strategy that will ‘green’ the car park. Provision will be made to provide
16 electric charging points with a further 16 spaces provided with passive provision.
Currently there are none provided.
The provision of 155 car parking spaces ensures that the minimum car parking requirement
is met on-site and there will be no impact on neighbouring roads and potential of on-street
parking in the surrounding area as a result of the increased capacity of the venue.
The overflow car parking area will be returned to nature as an area of soft landscaping and
open space. The total footprint of the proposed development, including the building footprint,
the car park and hardstanding is 14,992sqm compared to an existing 12,334sqm. The
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increase in the building footprint is mitigated by the 776sqm reduction in the extent on hard
landscaping in the proposed development.
Figure 3 Proposed ice centre building
Landscape Improvements
The rotation of the ice centre layout allows street facing hard landscaping to create links with
the rest of the MOL to the north of the site, by virtue of the soft landscaping proposals. The
soft landscaping proposals are based on the principles of maximising biodiversity through
the introduction of a native meadow, wetland habitat and native tree and shrub planting.
This also helps to mitigate against any loss of trees and habitat as a result of the increase in
the larger building footprint. Of the existing woodland and vegetation, the proposals retain
97% of this in the proposed scheme and as well as this, an additional 143 trees will be
planted. There will be 20 trees removed as part of the application. These are all assessed
to be of low quality.
We address the landscaping, ecological and habitat improvements further in Section 13, but
it is sufficient to state that there will be significant tree planting, landscaping, ecological,
biodiversity and habitat as a result of the proposals.
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Figure 4 Visualisation of landscape improvements
Development Phasing
This application for full planning permission is submitted covering three phases of demolition
and construction. The phasing is to ensure that there is continuity of access to the ice for as
long as possible. The existing ice pad will be revised in the new building and the phasing
will allow a new pad to be constructed whilst the existing pad is still being used. There will
need to be some temporary facilities (such as temporary changing rooms) to be provided
during the construction period to keep the pads useable for as long as possible. This will
ensure there is limited negative impact on ice-users who rely on the ice centre for exercise.
Construction Phase One
Phase One will involve the construction of the Pad A ice hall, ice plant room, new substation,
the core accommodation block over two storeys and a range of mechanical and electrical
systems. During this period the existing ice centre will continue to be available.
Construction Phase Two
This phase demolishes the existing steel-barrel ice centre and the provision of the necessary
temporary accommodation to provide changing facilities, WCs and the café.
Construction Phase Three
Phase Three is the final phase required to complete the new build elements of the proposed
twin pad ice centre. This will deliver the new Pad B ice hall and the spectator seating.
The above construction phases are out in greater detail in Section 5.6 of the submitted
Design and Access Statement and in the Demolition and Construction Method Statement.
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4. Pre-Application Consultation
The evolution of the proposals has been driven by the need to comply with the Park
Authority’s remit to develop and improve sports facilities in the Regional Park and the need
to replace the existing ice centre because it is at the end of its natural life. It is also informed
by the Park Authority’s desire to increase the amount of ice time to encourage more
participants in ice related sports, and to provide a World Class visitor destination. The
process has been informed by engagement with a wide range of stakeholders, including
existing ice centre users, sports clubs/bodies, local residents, community groups, local
councillors, council officers, Greater London Authority (GLA) officers and statutory bodies.
Full details of the consultation process, engagement and how the proposal has evolved as a
result of this process is included in the Statement of Community Involvement, prepared by
Grayling.
The consultation process aimed to increase awareness of the proposed development in the
first instance and to ensure that the most appropriate scheme is put forward based on
discussions with key stakeholders.
Public Consultation
The Park Authority appointed Grayling to implement a consultation and community
engagement programme for its proposals for a new twin pad ice centre to replace the current
Lee Valley ice centre. The Park Authority and Grayling have carried out extensive pre-
application consultation with stakeholders including the neighbouring London borough,
Hackney, Save Lea Marshes (a local interest group), ice user groups, sporting bodies, local
schools and local community groups.
To ensure the local community were aware of, and involved in, the design of the new
development, three phases of engagement were delivered:
• Phase 1: In 2016, the Park Authority held five information sessions with local councillors,
members of the community and regular ice users to find out their initial views of a
proposed new ice centre.
• Phase 2: In 2017, following progress in design development by the project team, a
programme of engagement activity was delivered to share emerging designs and seek
feedback on what the community felt important to provide in the new ice centre. This
included an online engagement platform, workshops with users of the existing ice centre,
a family open day for the local community and written and digital communication.
• Phase 3: The Park Authority commenced pre-submission engagement and consultation
activity in 2019. Updated proposals were shared, and further feedback was sought from
the local community. This consultation phase began in June 2019 and ran until
September 2019. This included online engagement through the dedicated platform,
engagement with key political and community stakeholders and neighbours, workshops
with users and five dedicated public community events.
The feedback from the public at each stage was largely positive and supported the need to
redevelop the ice centre. Key priorities were landscape and the ice centre’s environment,
the need to provide for further ice time, the design of the proposed building, and parking.
Pre-Application Advice
The development proposals have been the subject of extensive pre-application discussions
and consultation with Officers at the London Borough of Waltham Forest and the Greater
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London Authority, as well as a number of stakeholders. A list of pre-application meetings is
given in the Statement of Community Involvement.
The Park Authority has liaised with the Council and the GLA regarding the potential issues
raised by the proposals, and what is required to understand the nature and scope of any
potential impacts. These discussions have fed into the range of expert reports, submitted
alongside this Planning Statement.
The scheme was also presented to the Waltham Forest Design Advice Panel (DAP) on 19
June 2019. The feedback provided by the DAP helped to advance the final design.
How engagement has improved the Scheme
Key elements of the proposed development that have been influenced by the consultation
with the above parties are as follows:
• Improvements to the landscape strategy and biodiversity enhancements including a
greater degree of planting between the building and car park, planting within the car park
and planting to screen the building from views from the Marshes to the north.
• Limiting the number of spectator seating in order to reduce the footprint and massing of
the proposed ice centre.
• Increasing the changing room space for ice centre users as a result of community
comments.
• Orientating the building so that it runs perpendicular rather than parallel to Lea Bridge
Road.
• Reducing in the height of the building to minimise the visual impact and to integrate it into
the landscape context.
• Changes to the design to introduce gabions at the lower level, breaking up the mass of
the building, introducing more glazing and introducing new materials to more suitably
reflect the building’s context. The latest design creates a high quality and appropriate
gateway to the Regional Park.
• Revision of the band design to provide a more varied geometrical effect.
• Enhancing the café design and layout to ensure that it engages both visitors to the ice
centre and the wider Park.
• Incorporation of further sustainability measures.
• Reducing the level of car parking on the site to reflect the site’s accessibility using
sustainable transport modes and discourage users from travelling to the ice centre using
private vehicles.
• Preparing a Community Use Agreement to secure the existing provision of sports and
recreation activity to the community.
• Proposing a development phasing that ensures the maximum continuity of ice pad
provision for the community.
• Including other community sports facilities to make the best use of the building and widen
the available facilities for the public.
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5. Overview of the Planning Policy Context
In this Section, the development plan and other material policy considerations that are most
relevant to the proposed development are identified. In the following Section, we address
the Regional Park Development Framework and its relationship with the development plan.
The key policy issue is the principle of developing on MOL given the sites location within the
designation and we address the policy requirements for this in Section 7. Other planning
considerations and the specific policy requirements for these are addressed in Section 14.
Section 38(6) of the Planning and Compulsory Purchase Act 2004 states that, provided the
policies in the development plan are relevant, decisions on planning applications should be
taken in accordance with the development plan, unless there are material considerations
that indicate otherwise.
National Planning Policy Framework (2019)
The revised National Planning Policy Framework (NPPF) was published on 19 February
2019 and sets out the Government’s planning policies for England and how these are
expected to be applied.
Paragraph 11 of the NPPF states that plans and decisions should apply a presumption in
favour of sustainable development. For decision taking, this means approving development
proposals that accord within an up-date development plan without delay.
As noted, the ice centre site is entirely within Metropolitan Open Land (MOL). London Plan
Policy 7.17 (Part B) attributes MOL as being equal in importance to Green Belt land in terms
of the level of protection afforded to it. As such, references to the Green Belt in national
policy can be read as applying to MOL. Chapter 13 of the NPPF covers the protection of
Green Belt land.
The existing and proposed replacement ice centre is inappropriate development on MOL.
Paragraphs 143 and 144 of the NPPF explain the tests for promoting inappropriate
development in the Green Belt, requiring applications to demonstrate ‘Very Special
Circumstances’ if applying for permission for inappropriate development. Since the
replacement ice centre constitutes inappropriate development, the Very Special
Circumstances (VSC) must be demonstrated to make the development acceptable.
There are other Sections of the NPPF that are also relevant to this proposal for a new ice
centre. Chapter 8 covers the promotion of healthy and safe communities. Paragraph 91(c)
requires planning decisions to enable and support healthy lifestyles, including the provision
of accessible green infrastructure and sports facilities. Relevant planning applications must
therefore give thought to how they will impact the health and wellbeing of communities and
provide accessible sports facilities.
Paragraph 92 guards against the loss of valued facilities and sets out that planning decisions
should plan positively for the provision of sports venues. Paragraph 97 protects sports
buildings unless the loss resulting from the proposed development would be replaced with
equivalent or better provision in terms of quantity and quality. Given that the existing Lee
Valley Ice Centre is an existing sports venue, these provisions would apply.
Paragraph 170 concerns the conservation and enhancement of the natural environment and
requires development proposals to minimise impacts on and provide net gains for
biodiversity by establishing coherent ecological networks that are more resilient to current
and future presences.
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Statutory Development Plan
The statutory development plan for the site includes the adopted London Plan and the local
Development Plan documents for London Borough of Waltham Forest, including the Core
Strategy (2012) and the Development Management Policies Document (2013).
The London Plan (2016)
The London Plan (2016) is the strategic plan for Greater London, prepared by the Greater
London Authority (GLA).
Policy 2.18 of the adopted London Plan notes that the Mayor will work with all relevant
strategic partners to protect, promote, expand and manage the extent, quality of and access
to London's network of green infrastructure. Describing this as a 'multifunctional network', the
network is noted to secure benefits including, but not limited to, biodiversity, culture, sport,
recreation and social benefits that promote individual and community health and wellbeing.
The delivery of green infrastructure will be pursued in partnership with relevant bodies,
including the Lee Valley Regional Park Authority.
Furthermore, the Lee Valley Regional Park is identified, at Map 4.2 of the London Plan, as a
'Strategic Cultural Area', which are areas of "major clusters of visitor attractions" containing
"rich heritage and unique offers". Policy 4.6 states that the Mayor will, and other boroughs
and stakeholders should, support the continued success of London's diverse range of arts,
cultural, sporting and entertainment enterprises, noting at Paragraph 4.30 that "providing a
world-class experience is vital to encouraging repeat visitors".
The Plan also includes an aim to increase participation in, and tackle inequality of access to
sport and physical activity in London. The policies of particular relevance are listed below.
• Policy 1.1 Delivering the strategic vision and objective for London.
• Policy 2.1 London in its global, European and United Kingdom context.
• Policy 2.4 The 2012 Games and their Legacy.
• Policy 2.7(h) Outer London: Economy.
• Policy 2.18 Green Infrastructure: The multi-functional network of green and open spaces.
• Policy 3.1(b) Ensuring equal life chances for all.
• Policy 3.2 Improving health and addressing health inequalities.
• Policy 3.19 Sports facilities.
• Policy 4.5 London’s visitor infrastructure.
• Policy 4.6 Support for and enhancement of arts, culture, sport and entertainment.
• Policy 5.1 Climate change mitigation.
• Policy 5.2 Minimising carbon dioxide emissions.
• Policy 5.3 Sustainable design and construction.
• Policy 5.14 Water quality and wastewater infrastructure.
• Policy 6.1 Strategic approach.
• Policy 6.13 Parking.
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• Policy 7.4 Local character.
• Policy 7.6 Architecture.
• Policy 7.16 Metropolitan Open Land.
• Policy 7.19 Biodiversity and access to nature.
Waltham Forest’s Core Strategy (2013)
The Core Strategy was formally adopted on 1 March 2012. This document provides the
strategy for delivering the vision and strategy for the Borough. The policies set out in the
Core Strategy will direct and manage development and regeneration activity up to 2026.
Paragraph 8.25 of the Core Strategy (2013) states:
"The Council will support and work in unison with the Lee Valley Regional
Park in order to deliver the Park Plan 2000 and the Park Development
Framework. The Council supports the overall aims of the Park
Development Framework which seek to protect and enhance the
biodiversity, sporting and recreation resources of the Lee Valley Regional
Park.”
The Core Strategy specifically states that the Council will support the Regional Park to
deliver the Framework.
The policies and supporting text of particular relevance are listed below.
• Policy CS4 Minimising and adapting to climate change.
• Policy CS5 Enhancing green infrastructure and biodiversity.
• Paragraph 8.25 states the Council will support and work with LVRP in order to deliver the
Park Plan (2000) and Park Development Framework (2010).
• Policy CS11 Tourism development and visitor attractions.
• Policy CS13 Promoting health and wellbeing.
• Policy CS15 Well-designed buildings, places and spaces.
The Development Management Policies Document (2013)
The Development Management Policies Development Plan Document (the DMP) was
adopted on 24 October 2013 and sets out the vision and strategy for the borough. The
foreword states that the document provides a robust, yet flexible set of guidelines that help
to focus the Council's priorities and support the delivery of important infrastructure and
services.
Paragraph 13.11 of the DMP recognises the statutory duty of the Park Act, specifically
stating:
"The Lee Valley Regional Park Authority is a statutory authority created
by the Lee Valley Regional Park Act 1966 (The Park Act). It has a
statutory responsibility to either provide directly or work with partners to
provide facilities for sport, recreation, leisure, entertainment and nature
conservation throughout the Park… Both the Park Plan 2000 and the
Park Development Framework are relevant in terms of Section 14 (2) of
the Park Act and are formal statements of the Authority's position in
respect of development within the Regional Park."
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Policy DM12(H) states that the Council supports Lee Valley Regional Park's Development
Framework and, with specific regard to the contents of the Framework, Policy DM12(M)
states that:
“The contents of the Lee Valley Park Development Framework will be a
material consideration in the determination of planning applications."
(Our emphasis)
Paragraph 18.18 of the document states that: "the Council supports LVRPA… in improving
the range and quality of leisure provision in the borough."
The policies of particular relevance are listed below.
• Policy DM1 relating to sustainable development and mixed-use development.
• Policy DM12 relating to open space, sport and recreation, which specifically references
the Regional Park.
• Policy DM17 resists the loss of social infrastructure and meeting increased demand for
social infrastructure.
• Policy DM26 relates to leisure developments.
• Policy DM29 relates to design principles, standards and local distinctiveness.
• Policy DM34 relates to water supply and waste water infrastructure.
• Policy DM35 relates to Sites of Importance to Nature Conservation.
• Schedule 27 Table 27.3 relates to broadening visitor facilities at the ice centre.
Park Development Framework
Section 14 of the Lee Valley Regional Park Act contains a mandatory requirement for the
Park Authority to prepare a plan defining its proposals for the future use and development of
the Regional Park. The proposals set out within such plan are considered to have such
weight that they should be included in local development plans. The Park Development
Framework is therefore a key policy document in the assessment of any proposals within the
Lee Valley Regional Park.
The Act states:
“(1) As soon as may be after the appointed day, and in any case not later than two
years after the appointed day or within such further period as the Minister may allow,
the Authority shall, after consultation with the local planning authorities and the
appropriate statutory bodies, prepare a plan showing proposals for the future use and
development of the park, and shall from time to time review such proposals and shall
consult with the appropriate statutory bodies and with the local planning authorities in
relation to whose areas any amendment to such plan is proposed.
(2) (a) The local planning authorities shall from time to time include in their
development plans or in any proposals for any alterations or additions to their
development plans such part of the plan referred to in sub-Section (1) of this Section
or of any amendment to that plan as relates to their area.”
The plan prepared by Park Authority for the Park consists of a suite of documents which are
referred to as the Park Development Framework (the Framework).
Status
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The Park Development Framework has been enshrined in the local development plan,
covered above. As noted, the Core Strategy states support for the overall aims of the Park
Development Framework and commits the Council to working collaboratively with the Park
Authority to achieve its vision. Further to this, the Development Management Policies
document confirms that the Council must give weight to the Park Authority’s Framework in
their decision making as it is a significant material consideration in planning decisions (Policy
DM12). Indeed, the DMP goes as far as to state that the Council supports the Park Authority
in improving leisure provision, a key aim of the Park Development Framework. The
Council’s planning policies still make reference to the Lee Valley Park Plan 2000. However,
the Park Plan 2000 has been replaced as set out above over a number of years and has
now more recently been superseded entirely by the Park Development Framework which in
itself has effectively become the new Park Plan 2019. The Park Development Framework
therefore must be taken into account when assessing the whether the proposed
development is acceptable in planning terms. A summary of the Park Development
Framework is provided in Section 6.
The July 2012 Court Order
The status of the ‘Park Plan’ was confirmed following a judicial review taken by the Park
Authority against the Council in connection with Essex Wharf, the development to the west
of the existing ice centre. Following the judicial review, a compromise was reached and
enshrined in a Court Order, dated 10 July 2012 (ref: CO/6706/2011). This Court Order
obligates the Council to include the Park Plan within its own development plan and where
the Park Plan had not been included to treat it as if it were included within its development
plan in any planning determinations. This Court Order will apply to the determination of this
application.
Clearly, this is a very special arrangement and it ensures that the Council must give due
weight to the Park Plan in drafting its replacement development plan, and in taking all
planning decisions, including in determining the application for the replacement ice centre.
Other guidance documents
There are also a number of policy and guidance documents which are material
considerations in planning decisions, including formal Supplementary Planning Guidance
(SPG) These are set out below.
Olympic Legacy SPD (2012)
The site is within the Olympic Legacy SPD area, which superseded the Lower Lee Valley
Opportunity Area. The document was adopted by the Mayor in 2012 and sets out a
framework for the regeneration of the area used for the Olympic Games. This SPD focuses
on the long term regeneration of the areas affected by the Olympic Games.
Upper Lee Valley Opportunity Area Planning Framework (OAPF) (2013)
The OAPF sets out an overarching planning framework for the Upper Lea Valley Opportunity
Area. The document seeks to centre growth around blue and green strategies to offer better
sport and recreation facilities to link the visitor economy to the “reinvigoration” of the Lee
Valley Regional Park.
Section 4.3 of the SPD seeks to open up the Lee Valley Regional Park as access into the
Park and views of the Park are said to often be restricted. This Section also states that
some of the sites are ideal locations for sport and leisure and should be developed to
establish a vibrant community of the banks of the River Lee.
Economic Growth Strategy (2016)
This document was produced by LBWF in 2016 and sets out the economic growth strategy
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