Lee Valley Ice Centre, Lee Bridge Road, London E10 7QL - Planning Statement

 
Lee Valley Ice Centre, Lee Bridge Road, London E10 7QL - Planning Statement
Lee Valley Ice Centre, Lee Bridge Road, London E10 7QL

Planning Statement
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
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
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       78
Lee 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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