SOS’ OBSERVATIONS TO L&Q’S REVISED PLANS-WHY THEY MUST BE REFUSED PERMISSION

We set out below just some of the reasons why L&Q’s current plans for the Stow are contrary to public opinion, law and common sense and MUST BE REFUSED permission:

1.      CHANGE OF USE

The Planning Inspector confirmed that, despite L&Q wasting tens of thousands of public money on fancy reports, L&Q were unable to show that greyhound racing was not viable on the site. That’s because it is viable, it always was and it remains so today with a proven and completely viable operator in Bob Morton having made an above market value offer to L&Q for the site that remains on the table. As there remains a viable alternative that retains the site’s D2 Assembly and Leisure usage with the huge employment benefits to the borough then change of use must be refused.

2.      VIABILITY

L&Q’s plans are simply not viable. Should they erroneously be given planning permission, they will make a loss of part taxpayer money in excess of £25m. L&Q have never refuted this because they know that our figures are correct. We challenge L&Q to publish their viability analysis on the Stow so that the public can see for themselves how they are squandering your money. It is a disgrace that Waltham Forest Council is assisting them in covering up this huge loss.

Even L&Q’s own leisure plans are non viable. We note that L&Q are making a contribution to prop up their own on site ‘leisure centre’ because they know it cannot survive. But with this cash gift of taxpayer money it may just last long enough so that they can close it when the heat has died down.

3.      LEISURE

L&Q’s Pool and Track contribution of £1.75m is massively insufficient. L&Q bought the Stow for £18m so that is their valuation of the viable leisure facility. Using their own valuation, they should be making a contribution of the same sum, £18m, to replace this leisure facility elsewhere in the Borough, as is demanded by local planning policy in the approved UDP.

Their suggested ‘leisure uses’ are frankly a disgrace and an insult to the intelligence of locals and English Heritage. There is no local need for a leisure centre when the many local centres are nowhere near capacity-who would go to a housing estate to use a gym? No operator has agreed to run the facility which proves it is just not viable. There is also no need for a climbing wall. The ‘track’ around the estate will no doubt be used as a race track for local yobs. And as for a BMX/Skate Park next to a Listed Building-there just cannot be a more inappropriate usage-there is little doubt that this will lead to damage/graffiti of the Listed Building and create a crime den and bring gang culture and major crime to the area-turning it in to an old Broadwater Farm type Estate.

 

We challenge L&Q to state the number of locals who requested these facilities at their public consultations.

The simple fact is that L&Q are trying to fit a square peg in to a round hole. Their leisure proposals represent tokenism in the extreme-they are not needed or wanted by the community. How can their meagre plans in any way replace the world famous Stow, visited and enjoyed by hundreds of thousands of visitors each year?

4.      JOBS

Despite L&Q’s claims, there will be little or no proper local jobs created by L&Q’s plans. Bob Morton’s plans will bring many hundreds and quite possible thousands of direct and indirect London Living Wage jobs to the area. The creche has now been reduced in size and no commercial operator has been identified to run it, will this be the same story as the ‘leisure centre’?

5.      ENGLISH HERITAGE

Not only has L&Q totally ignored the demands of English Heritage, they have rubbed their noses in it. English Heritage stated that the eight storey tower block overlooking the Listed kennels was inappropriate and that the ‘track’s centre’ should remain ‘open’. Both demands have been ignored. And as stated above, L&Q has given the green light to the desecration of the front listed building as well. L&Q plans also include the demolition of Listed Buildings and curtilage listed buildings on the site.

6.      LACK OF PUBLIC CONSULTATION

There has been no proper public consultation and L&Q has not demonstrated that their plans mirror the wishes of the local people in any way shape or form.

7.      HOUSING MIX

The proposed housing mix provides for 60% 2 bed units. This is an over provision by 20% of these small units. It is against current Local Council and GLA policies. Whereas the 3 bed units (the much needed family units) are under provided by 24%. That’s 70 family units which this scheme fails to provide!

8.      DENSITY

The site density at 316 habitable rooms per Hectare is still massively over the London plan target for Ptal 2 – 3 rated areas in suburban settings. The range given by the London plan is 150 to 250 habitable rooms per hectare. Given that the stadium site is admitted by L&Q’s own application documents to be Ptal 2 rated, the target should be nearer the medium value of this range. This would mean around 200 habitable rooms per Hectare a reduction of one third on what L&Q presently propose.

9. AFFORDABLE HOUSING

The revised scheme details do not provide any information on what percentage of the new lower unit provision is to be affordable housing nor what proportion will be true social rent affordable rather than the shared ownership and actually quite expensive to rent so called ‘affordable rent’ units.

We note that there is a massive over provision of 2 bed units in the scheme when compared to planning policy. Are these to be ‘badged’ as affordable units under the ‘affordable rent’ banner where L&Q can charge up to 80% of market rent? We suspect so. These units are not truly affordable and neither are they family units. L&Q will want to get away with this if they can as it might help claw back some of the massive losses that they are facing on this site…hardly providing affordable homes for families though is it?

Given that the previous proposal was significantly short of the local authority’s target of 50% affordable where are L&Q now on this issue?

10. VALIDATION OF THE CURRENT PROPOSALS

We note the drawings have been updated and the Design and Access statement has been amended by an addendum. What about all the other supporting documents?

The scheme has changed and all the supporting reports must be properly re-addressed to describe the new proposals. Without this information it is impossible for interested parties to properly re-assess the latest revisions. We suggest also that neither can the professional officers at the Council.

Updated reports to the following should be issued before the latest amendments can be properly considered;

Energy Efficiency and Sustainability

Viability analysis (to be made public please)

Affordable Housing Statement

Section 106 heads of terms

Transport Impact Assessment

Draft Travel Plan

Daylight & Sunlight Assessment

Landscape, Bio-diversity and Open Space Strategy

Heritage Statement

Statement of Community Involvement including where the requests for these amendments came from.

Viability Assessment Methodology

Heritage Assessment

11. LOCAL INFRASTRUCTURE

Walthamstow MP Stella Creasy recently confirmed that Waltham Forest could be facing a deficit of 1200 school places by 2015. Housing estates such as this will only exacerbate this major problem as well as putting further strain on local transport, health facilities etc.

12. HOUSING NEED

Waltham Forest Council has confirmed that it can meet its housing targets without the Stow site. As detailed above, the affordable offer by L&Q is confused and, in any case, will be lower than that offered by Bob Morton.

13. L&Q MISLEADING PUBLIC

L&Q has misled the public throughout. The latest examples can be seen on their revised plans eg not highlighting the fact that the electricity sub station will now be adjacent to houses on Empress Avenue and overstating ‘tree cover’  to give false impressions of overlooking.

14. LOCAL OPPOSITION

The public is almost unanimously opposed to L&Q’s plans, as are the two local MP’s Rt Hon Iain Duncan Smith and Stella Creasy.

The above are just examples of why L&Q’s plans for Walthamstow Stadium must be refused. We call upon Waltham Forest Council to represent the demands of people that voted them in to office and to do the right thing.


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