Sham Consultation and unfair Planning Process |
This page is part of the campaign to
Save the Epping Forest Act.
It was hastily compiled from comments by
Paul Taylor,
Cilius Victor and
local solicitor.
Wanstead Flats is located close to and is substantially used by a population that is considerably less affluent than the London average, by any economic and social indices you could name. The area is one of the most diverse populations in the United Kingdom.
For a host of reasons it already shapes the nature of policing the area receives in general anyway. ‘Stop and search’ and ‘dispersal zones’ are widespread, under the pretext of ‘knife crime’, ‘anti terrorism’ and ‘anti social behavior’. The all-encompassing CCTV is unremitting.
Those who have knowledge of the Metropolitan Police from their experience as victims or witnesses of muggings, burglaries and car crime find themselves treated as if they were the criminals. They rarely see their misfortunes result in convictions.
Wanstead Flats provides some measure of relief from such treatment, easily accessible and affordable, free from mediated access. It is inconceivable that the nature of policing for the general community will not become more intensive producing numerous ‘encounters’ that one cannot refer to as cordial.
Campaigners have found, when distributing leaflets, that most people had heard nothing at all about these proposals from any source whatsoever. This was particular so for the residents of streets behind those on the front line. Even Dr John Samuel, whose surgery on Harrow Road is very close to the site, didn’t know about it.
None of the publicity has been provided in any other language besides English. This is despite the fact that many of the people who live in this area are transient or have a poor understanding of the language. The general level of education, even among the stable English-speaking population, is such that most people do not understand how to make a formal objection to a public body or have the confidence to write it. Most local people consider that they have expressed their democratic rights by signing a petition or by attending a community event. Those who have the professional skills to present their views through the official channels also have demanding jobs and families.
Besides this, the planning application was judged by a local authority that has no electoral mandate or moral authority to do so. This is because the site lies within 100m of the point the point where the London Boroughs of Redbridge, Newham and Waltham Forest meet. (On this map, these boundaries are purple and the orange arrow indicates the site.)
The Police base will disrupt the lives of thousands of Newham and Waltham Forest residents, but the nearest people in Redbridge are some distance away on the other side of the park.
The comparison with the 1946 campaign against building houses on the Flats is interesting. It was working class West Ham Council (now Newham) that wanted to build, whilst affluent Wanstead and Woodford (now Redbridge) were against. At that occasion, West Ham accused Wanstead and Woodford of (what is now called) nimbyism — putting their park above the need to house poor homeless people. This time, Newham has supported the local people by objecting to unwanted development that is being inflicted on them by Redbridge.
Newham’s last-minute objection aside, neither or MPs nor our local councillors or any party have made any effort to canvass the opinions of local people or assist in the campaign.
The Police claim in their Community Involvement statement to have been “committed to engaging and consulting thoroughly with local residents”.
They began developing their plans for this and two other briefing centres in the middle of 2009. Those for the one on Wanstead Flats became known because they were leaked to the press in June 2010. The location of the one on Black Heath (near Greenwich) was only revealed in February 2011 and the third (in West London) is still secret.
Only (some time) after the first public meeting in During Hall on 14 July this year did the Police and Corporation circulate a leaflet. Its tone was that the Save Wanstead Flats campaign had been lying about the Police proposals.
Their document about “Community Involvement” contains an awful lot of hot air about very little concrete activity. For example, it repeatedly lists the names of employees of Redbridge Council and other authorities as if this amounted to engagement with the public, when these people are merely doing their jobs and do not represent anybody.
The document refers to the public meeting that was held at Durning Hall on 6 October — as if this had been a planned part of their consultation exercise. However, this meeting was organised by the Save Wanstead Flats campaign. The Police representatives only turned up to it because Kevin Blowe threatened in his blog to put a cardboard policeman in their place at the meeting.
Many of the Police statements about Wanstead Flats are highly disingenuous towards local people. In particular, they say that it is “not close to residential areas” when in fact there are houses in Sidney Road that back on to it. When I pointed to my house on the aerial view at the exhibition, the police officer who was standing next to me visibly flinched: plainly he would not like to live so close.
At (7.39) is is claimed that “In relation to the recreational impact, one of the criteria used in the site selection procedure sought a site which minimised the impact on local activities and recreational use. The size of the MBDC when considered on other sites left no recreational space for public use. The advantage of Wanstead Flats is that due to its expanse the majority of the site will remain for recreational use. The site has required the temporary re-routing of the informal horse ride track but this is only a few metres to the south and a route would still exist between the proposed MBDC and tree belt located to the rear of properties on Sidney Road. All other recreational aspects will remain including the use of Jubilee Pond, adjacent children’s playground, Alexandra Lake, dog walking, cycling, sports pitches, the model flying club and all other uses outside the MBDC.”
This is disingenuous. People can walk onto the Flats from the south west and will tend to walk over the area in question. Its closure would divert them into the wet grassland of the SSSI to the north where walking is less easy and would be more detrimental to the land, or onto the playing fields to the west where there would be conflict with sporting activities. If the application were to be permitted the effect would be to seriously affect the recreational use of the Flats, which is their very purpose.
The exhibition claimed the site was “distant from residential areas”.
Try telling that brazen falsehood to householders in Dames Road, Sidney Road, and Knighton Road E7 living less than 100 yards away, and the thousands downwind from the site in Forest Gate and Aldersbrook.
The Police have wilfully neglected this aspect and talk generally about the satisfactory Olympic security arrangements.
The Met claim that distance from residential areas was a key criterion in their appraisal of potential sites, but it has never been clear how they weighted these criteria and the report is totally silent on this crucial factor in the application. Where is the evidence that the police seriously considered a site isolated from residential property, and if they did, why was it rejected in favour of the Flats?
The Home Office a consultation document on 16 September 2010, but this grossly mispresented the Act and what had to be done to change it. Most of the legal discussion concerned a section of the Act that became obsolete in 1882.
Maybe somebody made the schoolboy error of failing to read what the Act actually said, but if so this was a blunder of a magnitude that should have lost them their job.
The other explanation is that this was a deliberate attempt to mis-lead local people and the organisations that care for Epping Forest in order to avoid a powerful campaign.
The 2006 Act claims that its purpose is to simplify complicated legislation. It is a pot calling the kettle black, because it is written in the most appallingly contrived language. Whilst there are some archaic words in the 1878 Act, there are no “technical” clauses in it.
Section 7 of the Epping Forest Act is essentially all there is to it. The only way of legalising the Police proposals is to change this Section. Indeed, it has emerged that the Corporation had given them correct legal advice in March 2010, long before the consultation document was published in September.
Section 13(2) of the 2006 Act requires the Minister to go back to square one with his consultation process.
The proposal was first advertised on the Redbridge planning website on 16 November and eventually rubber-stamped by their Regulatory Committee on Thursday 24 February.
Whilst those dates were three months apart, it was not possible for local people to arrange for professional scrutiny of the documents because
The website is also extremely awkward to use: after following this link, you have to click on “View documents”, then select the document and finally click “View”. There seems to be no way to make Web links direct to individual documents. There are 150 documents in six pages of listings. Some of the planning documents are on the first page, some on the last.
Nevertheless, in between these are more than 80 formal objections from local people and a petition with over 1800 signatures.
Amongst the representations that were made to Redbridge Council during the planning process, four were classed as “support”.
In fact, only one of these is unambiguously in favour. The others acquiesce to the proposals on condition that the site be restored to its original condition, strictly at the end of the period.
These contributions are in fact comparable in length to the numerous single paragraph objections that were made. None of them considers the issues in anything like the depth that the major opponents did.
In the Police Community Involvement document, Mrs Flash Bristow styles herself Chair of the Ferndale Residents Association (FARA) and purports to represent the residents of five roads that are not even adjacent to the site.
However, there is no evidence in her letter that she either canvassed the views of her neighbours or investigated the issues behind the proposals before writing. In fact, three residents of Ferndale Road lodged objections with Redbridge Council.
The sole purpose of Mrs Bristow’s letter was evidently to appropriate the £170,000 for the benefit of the part of the park that is nearest to her house. However, this part is in a perfectly respectable condition for parkland and in a far superior state to the site itself.
Shannell Johnson of Aldersbrook Voice, on the other hand, has indicated that group’s opposition to the proposals. The Aldersbrook area will be directly affected by the traffic, if it takes the stated route.
In fact, Mrs Bristow made another representation later that opposed the plans.
The letter from Gill James of the Redbridge London Cycling Campaign is extremely terse, indicating that she has not consulted her members at all either. Moreover, the appendix to the Transport Assessment records four accidents near the site in which cyclists were injured, one seriously, so it would also appear that Ms James has not actually investigated the issues involved.
Canvassing experience is that a tiny monority (maybe 5%) of local people are in favour of the proposals, believing (misguidedly, we feel) that having more police around will improve the local crime situation. However, many of those who said that they were in favour probably did not understand the question through lack of fluency in English.
As part of their purported consultation process, the Police set up a phone line, web site and exhibition.
However, even though it was free (0800), the dedicated phone line attracted a grand total of five calls, whilst the address admin@wanstead-mbdc.co.uk attracted a mere six emails.
Five rather unimpressive exhibitions were held, which we are told were attended by 257 people. This is about the same number who attended the first public meeting at Durning Hall, on 14 July 2010. The people who visited the exhibitions were given no warning that in so doing they were consenting to the proposals.
It is first claimed that 53 people “clearly” stated their support for the proposals, but then revealed that all but 28 made significant reservations to their support. We do not, of course, know whether these people are local residents, off-duty police officers or people who are live near other potential sites and are relieved that theirs was not chosen.
These were another 45 cards that stated opposition, which is quite a lot considering that this was a partisan channel. I saw the exhibition but didn’t fill in a card because I knew very well that any such responses would be abused in the way that they are being in this report.
There are lies, damned lies and website statistics.
Every time a file is accessed on a web site, the server records a line in its log, but if a page has formatting or contains any kind of graphics (including trivia like coloured bullets), every one of these items causes a line to be added to the log. So there may easily be 20 “hits” per page.
Besides this, by far the majority of the traffic measured in this way actually comes from robots such as Google, Yahoo and numerous other things on the Internet that collect data completely indiscriminately.
The author of the statement that “www.wanstead-mbdc.co.uk went live on 11 August and has had just under 58,000 visits, averaging 456 hits per day” is taking no care to distinguish “hits” (the number of lines in a log file) from “distinct visitors”, let alone to exclude known robots from the count.
For comparison, my own website contains just my own academic research papers. During October 2010 it had about 50000 “hits” (lines in the log file) from about 5200 distinct sites. However, looking at the names of the top 30 of these, which accounted for 20000 hits, they are either obviously robots or anonymous. The latter are probably collecting email addresses in order to send out spam for criminal ends. This does not mean to say that no-one reads my site, just that the figures from the log are highly misleading.
Moreover, associating IP addresses with geographical locations is very difficult. Doing so with the precision required to say that the visitors are local residents is impossible. That is, without obtaining information from numerous Internet Service Providers that would each require a Court order.
A mere 30 responses were received through the website and there is not even any claim that these comments were supportive. So altogether the website was completely ineffective.
This document was translated from LATEX by HEVEA.