Objection to Police Muster Site on Wanstead FlatsPaul Taylor |
This page is part of the campaign to
Save the Epping Forest Act.
I wish to object to the proposed use of the part known as the Fairground Site of Wanstead Flats by the Metropolitan Police Authority for a Muster Site during the Olympic Games in 2012, on the following grounds.
The proposed site is visible from my house, which overlooks Wanstead Flats. The activities in and around the muster station will have a serious impact on those living in Harrow Road.
It is a violation of natural justice that Redbridge be judging an application regarding a site that is a long way from any Redbridge constituents but right under the noses of those in Waltham Forest and Newham.
However, I have received no information about this planning application directly from the London Borough of Redbridge. Indeed, Anne Overbeke has now said that “given the vast number of households located within a radius of 800m of the application site, we will not be writing directly on this matter to households located outside of the London Borough of Redbridge boundaries”.
When I went out to search for notices, the only one that I found was near the playground in Dames Road and this is probably the only one that is in Waltham Forest. It was put there on 8 or 9 December but is dated 2 December. There is nothing in the Public Notices section of the free Waltham Forest News.
The Police claim in their Community Involvement statement to have been “committed to engaging and consulting thoroughly with local residents”. However, they had been developing these plans for at least nine months before they became known, which was when they were leaked to the press.
The locations of the other two briefing centres are still secret.
Only (some time) after the first public meeting in During Hall on 14 July this year did the Police and Corporation circulate their leaflet. Its tone was that the Save Wanstead Flats campaign had been lying about the Police proposals.
I only heard about the planning application by word of mouth. It involves about 500 pages of documentation, some of which is very technical. No reasonable allowance has been made for ordinary people (who also have their own occupations, families and lives) to digest these documents, seek relevant professional advice and formulate their objections to them.
I therefore call upon the Planning Committee to extend the period of consultation substantially and ensure that everyone that will be affected be given information about both these proposals and the popular campaign against them.
The objections that I am making in this letter are based on those documents that I myself have had time to read. I support the other objections concerning other parts of the planning application that are being made on behalf of the Save Wanstead Flats campaign.
The Epping Forest Act states in unambiguous terms the will of Parliament, Queen Victoria, the Corporation of London and the people of the day that this area of open land should remain unenclosed and undeveloped in perpetuity. Ordinary people fought then for their rights to use this land for grazing and recreation. They continue to this day to defend the lungs of London.
The 1865 and 1895 Ordinance Survey maps (included as appendices to the Archaeological Survey) demonstrate very clearly why this Act was needed. During this period the land between Leytonstone, Forest Gate and Wanstead went from being open fields to the street layout that we see today. Nowadays, the influx of people into London and the tendency to live in smaller households create relentless pressure to build houses on greenfield sites. The protection that the Epping Forest Act affords is therefore needed even more today than it was when it was passed.
After resisting the attempts at enclosure by landowners, Parliament and the Corporation continued to defend Epping Forest against the railways (High Beech, 1883) and motorways (M25, 1979 and M11, 1989). Even in the aftermath of World War II, when many east Londoners had been bombed out of their homes, they and the Corporation stood together to defeat plans to build houses on Wanstead Flats.
Today the people of this part of east London have again expressed their opposition to this threat to Epping Forest by attending public meetings and by signing a petition against these plans.
Unfortunately, on this occasion the Corporation has forsaken the local people. Section 7(2) of the Act says that “the Conservators shall not sell, demise, or otherwise alienate any part of the Forest, or concur in any sale, demise or other alienation therefor, or of any part thereof”. But they have concurred with the Metropolitan Police to alienate a part of the Forest. They have done this under a threat of compulsory purchase that is barely concealed in a Home Office consultation document about amending the Act.
Along with this planning application there was also a Home Office Consultation Document regarding a proposed change to the Epping Forest Act. However, this contained an elementary legal blunder. It said that the criminal offence of enclosing land on the Forest was contained in Section 34 of the Act, when anyone bothering to read this Section can see that it expired in 1882.
According to the Planning Policy Comments by Sian Evans and Ross Whear, “the proposed development does not fall within the schedule of appropriate development on the Green Belt, therefore it is deemed inappropriate”, based on the Planning Policy Guidance 2.
The Olympic Games will and already do occupy an enormous site in east London. Substantial effort went in to the Olympic Bid and the subsequent planning applications. It is inexcusable that policing issues of the kind for which this muster station is intended were not properly considered in the preparation of these substantial documents.
In their proposal for this site, the Metropolitan Police Authority refer to the example of the Notting Hill Carnival, but this analogy is completely inappropriate. The Carnival takes place on a site (the streets of west London) that is at other times used for ordinary residential and commercial purposes, whereas the Olympic Games already have exclusive use of their own site.
The Police say that “the vast majority of officers across London will not be deployed within the Olympic Park itself” and that the use of a muster station “minimises the pressure on to local police facilities, allowing them to get on with day to day policing activity”. On the other hand, they also say that “centralising briefing facilities is not only tried and tested as being operationally the most effective but they are also cost effective” and “proximity to the areas to be policed [is needed] to avoid too much delay in deploying officers following their briefing”.
It is therefore completely ambiguous what the purpose of this briefing centre is, whether it is for the Olympic Games or for day-to-day policing activity.
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.
The site is also described as “2% of the total area of Wanstead Flats”. In fact, it is about half of the naturally defined portion of the Flats between Lake House Road and Centre Road, whilst the remainder of the ground there is rough or boggy. People will therefore effectively be prevented from using that portion at all. What you choose to define as the “total area”, or indeed call Wanstead Flats as distinct from other parts of Epping Forest, are rather academic questions.
The Police were repeatedly asked what other sites they considered alongside Wanstead Flats. In particular this question was put to Alaric Bonthron at the public meeting on 6 October, but he refused to answer it. Still no indication has been given of what their fallback option would be should they fail to get planning permission or the necessary change to the Epping Forest Act. Objectors have consequently not been given reasonable opportunity to examine alternative sites.
Now that we have seen the selection criteria and the sites that were considered, it is highly suspicious that Wanstead Flats was the only one that matched. Plainly, this site was chosen first and then the criteria to match it.
Any kind of search is severely restricted if the criteria are unnecessarily rigid. In particular, this site is intended for horses as well as human police officers. Do the horses need to be briefed? Are they going to take the same circuitous route via the Leytonstone bypass as the vehicles?
If the horses and the people were considered separately it would be possible to post the latter further away, such as on a site adjoining the M11 motorway.
It is said that “at the time of searching for a location, a number of sites were unable to confirm whether other Games related activity would be taking place on these”. This just shows that the Olympic Delivery Authority’s left hand doesn’t know what its right hand is doing.
One alternative site that is already available to the Metropolitan Police Authority is their disused station in Leytonstone High Road, which is currently occupied by squatters. The excuse for the unsuitability of this site is that they plan to sell it.
Altogether, no serious attempt has been made to consider other sites.
Finally, the proposal refers to two other muster stations, but the locations of these remain secret.
The Olympic Games have been an arena for international politics ever since they were re-established in 1896. The Games held in Germany in 1936 and 1972 particularly illustrate this. Everybody takes it as read that the London Games are likely to be a target for terrorism.
It is therefore natural to surmise that the real reason for locating police muster stations away from the Olympic Park is that the latter may need to be evacuated. However, the planning application is based entirely on the assumption of a normal policing situation. It makes no mention whatever of contingency plans for a major terrorist incident.
Are we to suppose that, just as the main Olympic documentation failed to consider policing, the Police have given absolutely no thought to the role of the Wanstead Flats site in the event of a major terrorist incident? Or will this, like the muster site, be sprung on us as a nasty surprise at a later date?
The proposed site on Wanstead Flats is an obvious terrorist target in itself and is a legitimate one in the language of previous campaigns. Either as an isolated incident or, more likely in view of events such as those of 11 September 2001 and 7 July 2005, simultaneously with one on the main site, someone could very easily throw a petrol bomb over the fence of this site. Since its internal plans are now in the public domain, it would be easy to choose the most effective place to do this.
How are the Police likely to behave on the day in the context of such woefully inadequate security provisions for their own base? Are they going to keep peacefully inside their own fenced area and to their stated route to the Olympic Park?
It seems much more likely that they will patrol some distance around their site. However, Londoners who have had personal experience of muggings and burglaries have very little confidence in the ability or the inclination of the Metropolitan Police to deal with ordinary crime.
At the public meeting on 9 October 2010, Alaric Bonthron was asked whether the Police would be searching local people. His initial response indicated that they would. He certainly made no effort to reassure people and evaded the question when it was raised again.
We saw on 22 July 2005 what the consequences are when the Metropolitan Police get the idea fixed in their heads that they are in the midst of a terrorist drama but an ordinary person is oblivious to his being cast in the starring role.
The concern that I have most often heard raised by my neighbours regarding these proposals is that the extra traffic will cause chaos. Woodgrange Road, the main shopping street through Forest Gate, is severely congested at the best of times.
The Transport Analysis document is one of the most technical in the planning application and I would very much like to have more time in which to obtain independent expert advice about it. However, it is already clear without such analysis that it is based on several assumptions for which no justification is given.
The traffic plans assume that the Police “traffic will primarily use the A12, where the Olympic Route Network will be in operation, to get to and from the site and to and from the Stratford area. The traffic will use the Green Man Roundabout, Bush Hall Road and then Centre Road to access the briefing centre.”
There is no “Bush Hall Road”, so plainly the author of this document is not familiar with the local roads. Between Centre Road and Blake Hall Road there are two roundabouts that are in normal circumstances generally congested. Then there is a turning to Bush Road and finally there is the Green Man Roundabout, where the traffic will be horrendous.
The direct routes from this site to Stratford are via Cann Hall Road or Woodgrange Road. It is simply not plausible that the operational manager of the site will stick to the circuitous route stated when these roads are far more obvious. No doubt Police vehicles will amplify the disruption by using their blue lights at the least excuse.
What assurance do we have that Police vehicles they will stick to the route stated? The document includes a question to this effect by Peter Foley, but not any reply to his letter.
The second major assumption behind the traffic assessment is the “Olympic Downturn Factor”. This document cites page 209 of the Transport Analysis that was part of the planning application for the Olympic Games as a whole, but this page discusses railways, not roads. The supposed Downturn Factor is indeed mentioned, on pages 210-1, 222 and 236 (sections 6.9.5-8, 6.11.1-2 and 6.13.6).
Such a reduction in traffic is highly implausible given the enormous numbers of additional people that the Games will attract. In fact, it is only ever mentioned in the Olympic document as an assumption: no evidence is presented for it there. I have written to the Olympic Delivery Authority to ask what evidence there is for this claim and am awaiting the reply. (Here is an example illustrating the inadequacy of the time allowed for ordinary people to object.)
It seems much more likely that the “Olympic Downturn Effect” will not be a naturally occurring one, but the result of draconian restrictions on road and probably all forms of transport during the Games.
Besides this, the Transport Assessment makes no mention whatever of the proposed use of 85 horses stabled on Wanstead Flats. The site was chosen to be within walking distance for the horses. Are they going to go out of their way via a road that has the status of a motorway, or are they going to take the direct route? Horses go very slowly in comparison to cars. They are going to cause huge tail-backs.
We also learn from the Traffic Assessment (and, surprisingly, from no other source) that the Corporation of London is in fact planning to do something for the people of this area during the Olympic Games, namely to stage popular sporting events on Wanstead Flats. Whilst I applaud this, I also observe that these events will add further to the traffic and parking.
On most Saturday and Sunday mornings there are football matches on the Flats opposite my house in Harrow Road. As a result, Harrow Road is already completely full of parked vehicles on these mornings.
It is inevitable that these events will conflict with the Police operations. Then, as the Transport Assessment says, “the Police will be able to apply temporary parking restrictions to ensure the traffic flow along Centre Road is not unduly affected”, which they will of course do in their own favour and to the inconvenience of both local residents and participants in the sporting events. Indeed, the Assessment goes on to say that “[Transport for London] has confirmed that measures will be introduced at the Green Man Roundabout as part of the management of Olympic traffic and that these are designed to cater for the [Police] traffic appropriately”, so the latter will be able to do as it pleases whilst residents have to wait in jams.
I have already remarked that these proposals were being kept secret, so the purported “community involvement” only happened because the Police and Corporation were bounced into it by a leak.
The document on this subject 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.
Two aspects of community relations are very conspicuous by their absence. One is that absolutely no attempt has been made to communicate the proposals in any language besides English.
Another is that there is a long and bitter history of friction between the Metropolitan Police and both the local Muslim population. No attempt has been made to address this.
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 the 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.
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.
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. The sole purpose of her 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.
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.
Despite being free (0800) the dedicated answer phone line attracted a grand total of five calls. Also, admin@wanstead-mbdc.co.uk attracted a mere six emails.
Finally, 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.
These proposals are against the law, the wishes of local people and the vital need to retain open space around London.
The site is only needed because inadequate provision was made in the main plans for the Olympic Games. A decision was made about the location first and the criteria invented afterwards to justify it.
The site is a major security hazard, both to itself and to local people. It will seriously disrupt the lives of ordinary people going about their business on foot and by car.
An obvious reason for the choice of location is that it is at the corner of one borough, whilst the people that it will affect are in two other boroughs, so that none of the three local authorities will care about what happens.
These plans were deliberately being kept secret and the Borough of Redbridge has refused to inform the people of the neighbouring boroughs about it. The consultation exercises have been farcical and grossly insincere.
I therefore call on the Planning Committee to reject this application.
I am writing to object to the proposed Legislative Reform Order to amend the Epping Forest Act 1878 that would allow the Metropolitan Police to build a Muster Station on Wanstead Flats for the Olympic Games in 2012.
The Epping Forest Act states in unambiguous terms the will of Parliament, Queen Victoria, the Corporation of London and the people of the day that this area of open land should remain unenclosed and undeveloped in perpetuity. Ordinary people fought then for their rights to use this land for grazing and recreation. They continue to this day to defend the lungs of London.
The 1865 and 1895 Ordinance Survey maps (included as appendices to the archaeological survey in the planning application for this muster site) demonstrate very clearly why this Act was needed. During this period the land between Leytonstone, Forest Gate and Wanstead went from being open fields to the street layout that we see today. Nowadays, the influx of people into London and the tendency to live in smaller households create relentless pressure to build houses on greenfield sites. The protection that the Epping Forest Act affords is therefore needed even more today than it was when it was passed.
After resisting the attempts at enclosure by landowners, Parliament and the Corporation continued to defend Epping Forest against the railways (High Beech, 1883) and motorways (M25, 1979 and M11, 1989). Even in the aftermath of World War II, when many east Londoners had been bombed out of their homes, they and the Corporation stood together to defeat plans to build houses on Wanstead Flats.
Today the people of this part of east London have again expressed their opposition to this threat to Epping Forest by attending public meetings at the proposed site and at a local community centre (Durning Hall in Forest Gate) and by signing a petition against these plans.
Unfortunately, whilst all recent legislation is readily available online, this is not the case for either the Epping Forest Act 1878 or any of the Corporation of London Acts that have amended it. The Home Office has seen fit neither to rectify this situation nor to include the relevant sections in its consultation document. There might have been an excuse for this on the grounds of the labour involved in transcribing the Act, if it had been particularly lengthy, but in fact it is shorter than many of the individual papers that have been prepared the planning application and are already in the public domain. I have therefore copied the relevant sections of the Act in the form in which it was originally passed as an appendix to this letter of objection.
The Home Office consultation document also fails to specify what “burden” it alleges that the Act creates, or to spell out what amendments it proposes to make to remove this burden.
Somewhat vaguely, it suggests on page 9 that Section 34 of the Act is at fault, this being the section that made it a criminal offence to “inclose land”. However, this word is to be understood there in its 18th and 19th century sense, namely an action taken by a landowner on his own land to prevent the public from exercising their ancient rights as commoners of grazing animals, collecting firewood and recreation. Moreover, Section 34 ceased to apply as soon as the process of acquisition of land by the Corporation was completed in 1882.
The Home Office proposal is therefore completely erroneous.
Indeed, the Superintendent of Epping Forest, Paul Thomson, has acknowledged this error in a letter to me. The offence of enclosure, presumably understood in a modern sense, is now the subject of Section 3(1) of the Epping Forest Byelaws. The Corporation of London has the power under the 1878 Act and others to make and amend its own byelaws. Primary legislation is neither involved nor needed for the purpose.
Maybe the burden that the Home Office has in mind is really the obligation that Section 7 of the 1878 Act places on the Conservators. It requires that “they shall by all lawful means prevent, resist, and abate all future inclosures, encroachments, and buildings”. It also forbids them to “sell, demise, or otherwise alienate any part of the Forest, or concur in any sale, demise or other alienation therefor, or of any part thereof”.
Over the past year or two, the Conservators have indeed been concurring with the alienation of part of Epping Forest. They have been compelled to do this by the threat of compulsory purchase, as the Home Office consultation document barely conceals.
The means by which the Home Office intends to make this amendment are even more outrageous than the amendment itself. The Legislative and Regulatory Reform Act 2006 was quite appropriately described in the national press at the time as “the abolition of Parliament” and “the Bill to end all Bills” because it gives any Minister the right to rewrite any Act of Parliament as he or she chooses.
This 2006 Act, which seems to have no legitimate function, is a clear candidate for the new Coalition Government’s proposed Great Repeal and should already have gone the same way as the Identity Card Act. A new Government that has rightly made a major issue of its predecessor’s disregard for civil liberties has no business to be making use of legislation like this, whatever the purpose.
This Act gives Ministers “power to remove burdens” and it has been used legitimately in this way. One recent Order simplifies the transfer of a pub licence when its holder dies. Another allows civil partnership ceremonies in British embassies abroad to be conducted by more junior staff. Hardly anybody would argue with these particular measures.
If the present proposal aims to change Section 7 then it is an utterly different thing from these examples. The essence of the Act is contained in Section 7. A Legislative Reform Order amending the Epping Forest Act would tear the Act up altogether. If this Section is removed then nothing is left of the Act, or of the protection of open space around London.
This document was translated from LATEX by HEVEA.