Annexe A

 London 2012 Planning Application: Test Event 2011 questions

Documents reviewed: Planning Statement, Design and Access Statement, ES (Non-Technical Summary) and related drawings

1.  The amount of information provided for this important aspect of the London 2012 Equestrian and Modern Pentathlon events in Greenwich Park is inadequate. We have been critical elsewhere of the lack of definitive information relating to certain aspects of the London 2012 events proper,

and the position regarding the 2011 Test Event is even more serious.

2.   A reliance on brief textual descriptions in various parts of the submission is not acceptable and the sparseness of any drawn material is even more frustrating. 

3.   Although the Planning Statement (3.55) indicates that the Test Event is a project requirement and, as such, it will be assessed as part of the ES (alongside the set up, competition period and removal phase), our view is that the ES is far from clear on this point.

4.   One major concern is a statement in the ES that the area of lawn to be used for the [Test Event] arena will remain 'disturbed' from the set up of the Test Event until the end of the post Greenwich Park event amenity grassland reinstatement works. The documentation should describe more fully the anticipated appearance of the lawn during this period, currently projected to be from mid-June 2011 to Spring 2013, and to what extent the public will be denied access to this vital amenity space.

This would appear a long time to expect this popular part of the Park to remain an eyesore and closed. It will limit the recreational value of the Park as a whole, and put pressure on more vulnerable parts of the Park, eg the acid grassland, the impact of which does not seem to have been considered.

5.   It is acknowledged that spectator numbers around the Field of Play will be much reduced from those expected for the 2012 event proper (2,000 as opposed to 23,000), but we are concerned to note that, even at this late stage, a decision on the need for spectator stands has yet to be taken - Planning Statement (3.56).

6.   The phasing diagrams indicate that, in the Test Event set up period, two areas to either side of Jubilee Walk in Greenwich Park will be required, along with a section of Blackheath Circus Field at its eastern end so that, over the 4 - 5 weeks’ period of set up, all these areas will be inaccessible to the general public. However, it is not clear to what extent works required for the 2012 event will be tested out here (e.g. ground treatment, security fencing and, most critically, the base of the Field of Play).

7.   The same issues come into play, but to a much greater extent, when a much larger area of Greenwich Park is required for the Eventing and Modern Penthalon events.       

8.   The Design and Access Statement indicates (4.8 Events Facilities - Existing Buildings) that a small structure required for the Test Event on the terrace on the south side of the Queens House is to stay in place until the 2012 events proper. We have found no justification for this and we question whether any other elements of the 2011 Test Event are to be retained so that any impact can be assessed.    

9.   It is not clear whether the Test Event will be conducted on level ground, and, if so, how this will be achieved.

Annexe B

 London 2012 Planning Application: Greenwich Park: Questions

Documents reviewed:

Environmental Statement for the London 2012 Equestrian and Modern Pentathlon events

Sustainability Statement for the London 2012 Equestrian and Modern Pentathlon events

Design and Access Statement for the London 2012 Equestrian and Modern Pentathlon events

Appendix 2A: Arboricultural survey, constraints and protection measures

Appendix 9A: Archaeological desk-based assessment

BS5837: Trees in relation to construction

1. Threats to the existing acid grassland

The greatest cause for concern is the potential destruction of 2.3ha of U1 acid grassland and U1 intermediate habitats, which cover 39% of the planned cross country course. Given that U1 Festuca ovina – Agrostis capillaris – Rumex acetosella acid grassland is listed as a UKBAP priority habitat, a London BAP priority habitat and a Greenwich BAP priority habitat, this would appear extremely risky for several reasons:

• This is an uncommon habitat within London, comprising 1% of that found within the region, whose loss without mitigation would have a major negative impact and only a moderate positive impact with fully successful mitigation (as noted in the Environmental Statement).
  
  
• The restoration strategy for the acid grassland appears vague and open to numerous difficulties, in particular the persistence of higher nutrient levels and associated ‘improved’ grassland species such as Lolium perenne. Where have these methods been used before and to what success?

• Only limited information is provided as to where the areas of acid grassland enhancement are to be located and how the projected 2.3 ha increase in this habitat will be measured.

• It is of huge concern that the ‘programme and methodology for reinstatement and enhancement’ of the acid grassland has not already been agreed and finalized with the Acid Grassland Habitat Action Plan Working Group and Natural England, given that work will start in Spring 2010.

• The location of the acid grassland on the slopes within the Park make it particularly vulnerable to leaching of fertilizers and pesticides and more evidence is required to demonstrate that the increase in buffer size from 0.5m to 1m will be adequate.

• The projected loss of habitat makes no allowance for the destruction of acid grassland through movement of vehicles and other plant during set up and removal of the course. These projections also fail to include habitat loss via other means, including the set up, presence and removal of event facilities and the movement of potentially thousands of spectators.
  
  
• Bearing in mind all of the above it should be remembered that the acid grasslands comprise the highest quality habitats for invertebrates throughout the Park, and the loss of 2.3ha (plus the intermediate and degraded acid grassland) for at least 5 years will therefore have a detrimental impact on those invertebrates and the dependent food chain.

2. Issues relating to the treatment and management of other grassland

The set up of the cross country course will create a 6km band (of 5-10m width), that will be prepared using a variety of treatments including decompaction of topsoil, improved turf density and root depth, increased soil moisture content and decreased stone content. The implementation of these methods leads to several concerns:

• There will be a very obvious distinction between the course (covering up to 5.8 ha, approx 10% of the publicly accessible area of the Park) and the surrounding grassland. It is not difficult to imagine the course outline being evident throughout the park for years to come, by virtue of the improved quality and growth of the turf along the length of the course. What steps will be taken to avoid this scenario?

• The fencing, which will limit access to the areas of the course subject to these treatments from early 2010 for the next 21/2 years, will be both visually intrusive and will impede much of the amenity and recreational pursuits within the park. It will certainly not have a negligible adverse magnitude of change or a neutral effect. Indeed, there is likely to be a significant loss of amenity and recreational value as the course divides and partitions all the open areas within the Park.

• The Environmental Statement makes very little note of the potential damage to some of the open areas of grassland that will be used as training and warm-up facilities. It would seem likely that these areas could be at least, if not more, damaged than the course and there should be appropriate mitigation measures described within the documentation.

• One of the biggest threats to the overall condition of the grassland within the Park is that from the trampling, soil compaction and other damage from such large spectator numbers. The implications of this damage have not been considered in nearly enough detail and there needs to be a full and detailed description of the restoration program for the wider grasslands within the Park.

• For this reason, (as well as transport issues) spectator numbers for the event should be reduced from the 75,000 proposed.

3. Potential damage to trees within the Park

The Environmental Statement claims that the cross country route has been designed to avoid loss or damage to trees. This is unsubstantiated as:

• There is not a full and detailed tree survey included within the planning application, making it impossible to verify the exact location of the route with regard to the tree classifications and root protection areas. The application requires a far greater level of detail with regard to the precise location of the trees that will be affected during the construction phase of the cross country course. Ideally, the documentations should include a copy of the Tree Constraints Plan (TCP) mentioned in Appendix 2A: Arboricultural survey, constraints and protection measures with exact position of the course overlaid.

• There is likely to be a great deal of damage to trees close to the arena area and in the vicinity of the temporary facilities, during the set up and removal phases. There should be far more clarity about the size and scale of the temporary facilities and a commitment to adhere fully to BS5837: Trees in relation to construction throughout the set up and removal periods.

4. Potential loss or damage to sites of archaeological importance

The proposed cross country course cuts through several areas designated of high archaeological importance and runs perilously close to the Roman Temple designated as very high importance. It would surely be wiser to avoid these areas entirely and thus protect them until they can be studied in greater detail. The Roman Temple is currently passed on two sides by the course and at the very least there should be more detail on how sensitive areas like this will be protected from both course set up and removal work, and interference from the vast number of spectators expected. Other areas of significance include:

• There is considerable risk of damage to the Le Notre parterres (AF41).

• The medieval earthworks (AF30, AF31, AF32, AF33 & AF38) to the south east of the Park look particularly vulnerable.

• The series of underground conduits and conduit access manhole to the south-east of the reservoir require further consideration (AF16 & AF42).

• Similarly, the course will also track over an unclassified linear feature (AF10), a medieval ridge and furrow (AF29 & 45), a medieval walk (AF61) and a 17th-centuary walk (AF71). Given the archaeological value of the site any planning consent should be require a firm commitment that all construction work be conducted under the auspices of an archaeologist to protect these features.

5. Interference with the resident bat population

It is evident from the documentation that the bat surveys are at a preliminary stage and there must be a cast iron commitment that the surveys will be ongoing until the 2012 games. The presence of all bat roosts and feeding areas must be disclosed and suitable action must be taken to mitigate against light and noise disturbances in those areas. 

6. Involvement of Natural England

Given the issues involved and that Natural England is a statutory consultee, we would have expected in the documentation a statement from them (analogous to that included from English Heritage) giving their comments on the ecological issues.

Annexe C

 London 2012 Planning Application: The Arena: questions 

Documents reviewed: Planning Statement, Design and Access Statement, ES (Non- Technical Summary) and related drawings

 1.   Given the fact that it will be necessary to level out the parterre to the south of the Queens House in order to provide a level Field of Play, we are concerned that the base treatment has yet to be decided. The three options referred to in the Planning Statement (3.5) each has its advantages and disadvantages but we question why testing of both a practical and financial solution is not currently under way. Option 3 seems prima facie unacceptable. Before any permission is granted, a definitive plan should be presented, in sufficient detail to evaluate the impact on the Park.

2.   In terms of the design of the Arena, we share the concerns of English Heritage and CABE at its height and scale relative to the complex of listed buildings in the Maritime Greenwich World Heritage Site to the north.

3.   The limitations imposed by the footprint of the existing parterre while at the same time needing to accommodate a 100m by 80m Field of Play, as well as providing seating for 23,000 spectators, is a challenge for any designer.

4.   The fact also that the decision has been taken to provide seating on only three sides of the arena to leave the north side open to views of the historic buildings beyond adds a further complexity.

5.   Given all these constraints and the fact that the structure is of a temporary nature, we consider that, while the view of the Queens House from the Wolfe Statue will be partially obscured during the Games period, this is inevitable. The emphasis therefore must be on achieving the best possible design for the temporary structure.

6.   There is a suggestion at 4.4 of the Design and Access Statement that the face of the structure may be clad in some manner but, as part of the on-going development work on the appearance of the arena, we would suggest that, perhaps other than at the base of the stands where a cladding for security purposes may be required, the structure be left open to view.  

7.   The outer face of both the eastern and western stands will, during the Games period, be partially obscured by tree foliage obviating the need for cladding and, while regretting that the southern stand will obscure the lower level of the Queens House when seen from the Wolfe Statue, if a full cladding solution were to be adopted this would have a more damaging impact.

8. In view of the fact that the detailed design of the arena has yet to be finalised, given the impact its appearance will make on Greenwich Park, the National Maritime Museum and the Old Royal Naval College, if planning permission is to be granted, it is essential that this element of the application is the subject of a planning condition. The condition should go out for public consultation and be brought back to the Planning Board for consideration.

Annexe D

 London 2012 Planning Application: Transport assessment response

Documents reviewed: Transport Assessment for the London 2012 Equestrian and Modern Penthathlon events Greenwich Park

• The most important omission of the Transport Assessment is any detailed assessment of how public transport will cope with the very heavy demands for spectator travel, especially on the Cross Country Event day. This is a particular concern given the very heavy reliance on PT for spectator travel (100%, 75,000 on Cross Country Day, 47,000 by rail (inc DLR)).  The estimates of demand are for each mode as a whole (Rail (inc DLR), Direct Coach, Local Bus, River, Walk and Cycle – Tables 8.1 and 8.2) with no breakdown of demand by route (eg Greenwich Line, North Kent Line, DLR) and direction (eg with or contra commuter peak hour flows on the mode/route).  There are no estimates of existing public transport capacities during peak Games arrival and departure periods (1½ hours before Games starts at 11am and similarly after Games finishes at 16.30pm) or estimates of increases in capacity the PT operators can offer during the Games period (eg additional outbound SET services to Maze Hill and Blackheath, additional DLR services).  There is no consideration of the extent to which spectators may add to existing commuter flows (eg spectators from Kent) or the impact on the main originating stations in London (eg Charing Cross, London Bridge and Victoria).  Finally there are no assurances from the main PT operators (SET, DLR, London Buses, river service providers) that they are aware of the demands expected and are comfortable with them.  In the absence of a proper and detailed assessment (with all assumptions clearly set out) demonstrating that 75,000 visitors can be transported safely and comfortably to and from Greenwich Park on the Cross Country Day visitor numbers on that day should be capped at a lower figure based upon existing public transport capacity allowing for existing commuters and other users.

• The document is silent on the effects of introducing an Olympic Lane into the Blackwall Tunnel. This is an extremely contentious issue and must be debated/consulted on before planning permission is granted. There must be a variety of ways of getting Games Family vehicles through the Tunnel with minimum impact on general users (eg convoying Games Family vehicles during short red signal phases to general traffic) and these should be tested and consulted upon as soon as possible. At minimum devising and submitting a satisfactory Blackwall Tunnel ORN management plan should be a condition of consent.

• Regarding direct coach services there is no modelling or other assessment of coach arrival, set down and departure for parking at the main set down/pick up point on Charlton Way (see Figure 3.1 for modelled junctions). How will the coach set down and pick up work and where are the calculations/modelling to demonstrate Charlton Way offers adequate capacity and can be operated without bringing the A2 to a standstill during AM and PM peaks?  Direct coaches are presumably included in the road traffic modelling (Chapter 10). How have spectator numbers by coach (1,150 Arena days/7,500 Cross Country day) been converted to coach numbers? ie what assumptions have been made about mix of full size coaches (50+ seats) and smaller coaches/mini buses as this will affect coach numbers?  Devising and submitting a satisfactory coach circulation plan showing set down and pick up arrangements should be a condition of consent.

• There is no estimate of numbers of spectators using taxis/private hire vehicles. Para 7.18 suggests all taxis and private hires will use existing Greenwich town centre taxi ranks. How many spectators are expected to arrive and depart by taxi/private hire and where will they set down and pick up? Devising and submitting a satisfactory taxi/private hire circulation plan showing set down and pick up arrangements should be a condition of consent.

• There are no estimates of Blue Badge requirements. Blue Badges are issued to 4.8% of the population (2.46 million in issue as at 31 March 2009 ) implying a need for 1,100 Blue Badge parking places on Arena Days and 3,600 Blue Badge parking places on the Cross Country day. There is likely to be a higher demand for Blue Badge parking during the Paralympic Games on a /’000 of spectators basis.  Will Blue Badge parking be required on the Heath?   If so over what period?

• On the Cross Country day there are projected to be 5,500 spectators using river transport. Do the river service operators have the capacity to transport 5,500 persons during the arrival and departure periods and does Greenwich Pier have the capacity to unload and load these numbers during the same periods?

• Cross Country day Park ‘n Ride: There is a need for a southern location for spectators from south of England (Kent to West Country). Spectators from these locations will not traverse the Dartford Crossing northbound in the AM peak (nor should they) and they need a convenient SE quadrant Park ’n Ride to prevent parking in residential areas in SE London.  Where will Park ‘n Ride coaches set down and pick up? If also Charlton Way this will add substantially to the already large numbers of direct coaches and compound the traffic conflicts likely on the A2 during the AM and PM peaks (see 3 above).

• The document gives no details of likely parking restrictions on roads in the immediate vicinity of Greenwich Park (Park Vista, Maze Hill and Crooms Hill).  This may be a detail to LOCOG but is of great importance to local residents in these roads who expected to see this matter addressed within the planning application. 

• The transport assessment assumes 100% of spectator travel by public transport.  What if despite the organisers’ best endeavours, say, 10 or indeed 20% of spectators come by private car?  Has any of the modelling considered this situation and if so what are the projected results?  What contingency plans, if any, have or are being developed to respond to this contingency?

See http://www.dft.gov.uk/adobepdf/162469/221412/221535/224237/517849/supplement09.pdf

Annexe E

London 2012 Planning Application: Circus Field questions

Documents reviewed: Planning Statement, Design and Access Statement and Environmental Statement

1.  The Heath: a late inclusion in LOCOG’s thinking and this is reflected in the planning submission which is very light on detail.

2.  The Blackheath Society has already raised concern over the legality of the use of Metropolitan Open Land for the Olympics (ref our letter of Dec 4 to Ms M Ney, to which we have as yet have had no full reply), and it is now a matter for the appropriate legal departments to resolve.  The issue is important, not just as an important legal issue but for setting a precedent for holding major public events on this temptingly open space in London. The Heath (and Park) should not, in future, become the default option for large-scale outdoor events which cause considerable local upheaval.

 3  Circus Field: eight months of disruptive use would transform the area.  LBG’s UDP seeks to 'safeguard, improve and enhance open spaces’ (Planning Statement Document p74) so, if permission to use the Field is granted, it should be conditional on the area not only being ‘reinstated’ but improved to a better standard as recommended by LBG officers, with advice from other experts. Hardwearing grass, better irrigation, improved provision around the vehicle entrances and reinstatement of the bunds with their meadow grass should be specified. The conditions should include compensation to LBG for loss of earnings (from lettings) until 2015 to allow for the replacement grasses to embed properly – as for the Park.

Duke Humphrey spur: this too would be transformed by eight months of heavy traffic.  The Donkey Walk has been carefully excluded from the planning boundary, but would inevitably be much
affected and should be included in the reinstatement provision.  Any permission should be conditional on the spur being re-landscaped in line with Wilkie’s recommendations (2003): after all this is the south entrance to the World Heritage Site.

4.   The Blackheath Gates: there is no mention of these in the application, although discussions have taken place with LOCOG/LBG/RPA.  If permissions is granted, it is in everyone’s interests to reconfigure the Gates before 2011, to an appropriate design and specification, to avoid the otherwise inevitable damage which heavy use of that entrance would incur.

5.   Legacy: legacy is scarcely mentioned in the application and none relating to the Circus Field area.  LOCOG should be pressured to go beyond mere ‘reinstatement’ to long term improvements and detail their commitment. It was the proud boast of the Olympic bid that legacy would result and the above suggestions would be of real and lasting local benefit, at a modest cost.

6.   Traffic management (in relation to Circus Field) More detailed consideration needs to be given to

• large lorries turning in/out of Circus Field - as shown on the plan the turns would be very sharp and therefore slow and disruptive.
• deliveries during the construction period: LBG should insist that these be restricted to certain hours and inform the ODA that peak hours in SE London extend beyond the 2 hours quoted.
• where coaches and blue badge holders would set down/park.
• the relationship between the proposed  A2 pedestrian crossing and the vehicular access by Duke Humphrey spur.

7. Site construction/management: using Blackheath Circus Field rather than the Park would have many advantages, but there would be the potential for the area to be an eyesore and to become, in the course of eight months, muddy, smelly and with a hint of a detention camp. Hopefully LBG wwould insist on ‘good practice’ (as per the Environmental Statement) and ensure that the hoarding is attractive; the lighting inward facing; the waste management efficiently effective, lorry tyres hosed clean etc.