Responses of other amenity groups

We submitted Stokey Local's formal response to the current application (2012/2228) on Friday 14 Sepetember. You can read our full response here.

We have also received copies of the formal objections of other local amenity groups with specialist expertise or interest in the development. and some of those are collected here. By all means refer to themm when making your own observations which should be made as soon as possible this week and no later than this coming Monday 24 September. Find out how, here.


Stoke Newington Conservation Areas Advisory Committee

This site lies in the centre of the Stoke Newington conservation area and is bounded by Conservation Area on all sides. The Conservation Area is of two characters, on one side a late Georgian/early Victorian townscape – on the other Abney Park Cemetery, an unique open space and public resource of great value to and much appreciated by local residents in the borough as a whole. Both, but especially the Cemetery are important resources for the Borough and their protection is of the first importance.

Our starting point is that planning decisions must be taken in accordance with and based upon the approved Core Strategy. With regard to the Conservation Areas the relevant Core Strategy policy is 25 which states

"All development should make a positive contribution to the character of Hackney's historic and built environment. This includes identifying, conserving and enhancing the historic significance of the borough's designated heritage assets, their setting and where appropriate the wider historic environment."

The Stoke Newington Conservation Area Appraisal (the CAA) describes the character of the conservation area and its important elements, and the matters to be taken into consideration when deciding whether a development enhances the area. Policy 25 and the Appraisal together constitute the heart of the Council's planning policy in this regard.

The planning committee must follow the CAA guidance and the SNCAAC must base its advice on the principles laid out in the Conservation Area appraisals. 

In our opinion this proposed development does not enhance the Conservation Area but is detrimental in several ways.

1. The effect on the character and environment of Abney Park Cemetery

The Cemetery is surrounded by a brick wall which allows views into the back gardens of adjoining property, most of which dates to the 19th century. Historically, this has created a very intimate, quiet setting around the perimeters of the cemetery, and the back gardens continue the rural quality of the cemetery beyond its immediate confines. Some new development has recently been constructed to the north of the cemetery, off Manor Road, filling-in a gap which was previously occupied by low key uses. This has brought new buildings, and the resultant activities associated with such uses, much closer to the walls of the cemetery. In future, new development should be kept as far as possible away from the walls of the Cemetery, to preserve the setting of the Cemetery, and its unique sense of privacy and peace. [CAA 6.3]

The Council is keen to preserve the rural qualities of Abney Park Cemetery and the domestic scale of the residential streets which lead off Stoke Newington Church Street. Similarly, in the busy principal streets, views must be preserved by not allowing new development which is too dominant or obtrusive. This can only be provided by adhering to the guidelines in the previous paragraphs of Chapter 7 and by following the general principles set out below:


Abney Park Cemetery:

  • New development should not encroach on the setting of Abney Park Cemetery by careful attention to scale, bulk and siting
  • New development around Abney Park Cemetery should not generate noise or other disturbance to the Cemetery
  • New development close to Abney Park Cemetery must preserve the existing domestic character of the surrounding buildings
  • New development around Abney Park Cemetery must be carefully sited so as not to interrupt existing views and skylines


  • New development should respect the scale and density 

[CAA 7.11]

The most negative features of the Conservation Area are:

  • New development impinging on the setting of the Cemetery  [CAA 8.2]
  • Backland development such as The Point (new housing on the former Council Depot in Defoe Road) does not relate to existing housing in terms of scale, massing and height
  • Cemetery threatened by inappropriate development of the land around its boundaries  [CAA 8.4]

We are disappointed that the application documents do not appear to contain any sections of the proposed building from the north which would enable an immediate idea of the bulk and height of the building compared to the existing structure.

However, from the dimensions given we are able to form a clear understanding of the mass of the building. It consists of a seven storey core centre surrounded by a larger five storey block (15.8m high), the whole surrounded by a “podium” 6.35m high, itself closely surrounded by a two story boundary wall (4.65m). The 4.65m high boundary wall will abutt the Cemetery directly and the “podium” will cover the bulk of the site apart from a small triangle at the North West where it drops to 4.65m high.

The proposed building on the North Eastern corner is almost double the height of the current building, the new building will be 15.8m high set back  1 m –18m  from the Cemetery boundary. At this corner the existing building is approximately only 6m high, and the taller building (only 10m at the ridge) is set back 10 m from the boundary. Furthermore at the North Western corner the site is currently open space with open railings, in line with the conditions set out in the CAA.

The proposed development abutts the popular pathway between the two Cemetery entrances.  Currently walkers in the Cemetery are able in most places to see sky through the trees. This contributes to the particular secluded and “rural” atmosphere as stated in the appraisal. The development proposal of a 4.65 m wall on the boundary, closely backed by a seven storey building (22.3 m high) positioned so as to come within 2.5m – 3.5m of the Cemetery boundary line on the West boundary of the site will be massively intrusive.

We do not believe that the mock-up views of the building from the Cemetery in any way represent the effect that the development will have. In particular in winter with reduced foliage and light pollution.

The development should not immediately abutt the cemetery boundary. We believe that any building on this site should be set back at least 10 m and should be no more than four stories high – in other words, very much the size of the current collection of buildings.

There are in addition concerns that ecological damage to the Cemetery will occur. We have had sight of reports from the Abney Park Trust, Russell Miller Arboriculture and the Garden History Society. We support those submissions .

2.  Over-development, mass and height

The High Street entrance to Abney Park Cemetery, with its Egyptian buildings, is the most significant feature along this part of the High Street, and acts as a focal point in views along the street. [CAA 4.4]

New buildings should relate to their surroundings in terms of scale, height and massing. [CAA 7.1]

The height of new development in the Conservation Area should generally respect the height of buildings that forms its context.

  • A variety of heights may be acceptable in areas where there is no common building height, but the range of heights which might be acceptable will still be determined by the heights of neighbouring buildings.
  • The depth of any new development, and the impact of bulky new buildings on neighbouring properties, will also be very carefully considered by the Council.

[CAA 7.3]

New development should respect the scale, massing and height of the surrounding historic properties.

  • New development should follow the historic building line.
  • New development should follow the historic plot ratios in the area and should allow for the retention of some garden or amenity space to the rear of the building.
  • New buildings should reflect the existing details and materials of the historic buildings in the surrounding area.

[CAA 7.10]

New development should respect the scale and density of existing buildings

  • New development should not be over-dominant in views along the street
  • All new development should respect existing heights and should not interrupt existing skylines 

[CAA 7.11]

In addition to its direct affect on the Cemetery, more generally, we note that the proposed building is out of scale with the surrounding properties, the Victorian terrace on the High Street and the Cemetery gates. The effect can be clearly seen from the submitted views from Stamford Hill and Cazenove Road. But again, we do not believe that the submitted mock-ups sufficiently represent the visual effect that this very high building.

It is clear the new building will have a substantial detrimental affect on the visual environment both along the northern end of the High Street and from the Cemetery.

3. Shadow

We do not believe the account of shadowing set out in the application sufficiently represents the situation that will occur. We note that the shadowing effect of the boundary wall (4.65m) has not been included.

In particular we note that for half the year the shadow will extend right across the Cemetery gates and cover the area to the right of the gates (when entering the Cemetery) which is currently heavily used by adults and children for recreation, eating lunch, picnics etc.  and would be a substantial loss of public amenity.

4. Historical plot size

New buildings should preserve the plot widths and urban grain of the existing historic development.  [CAA 7.1]

This application represents a radical departure from the historical development of the site. As can be seen from the maps contained in the presentation, the major part of this site, especially the North Western corner abutting the Cemetery entrance , has been open space for the last 120 years.

Such a departure is contrary to the CAA guidelines

5.  Details of the proposed development along the High Street are inappropriate

The west side of Stoke Newington High Street contains an almost continuous terrace of good quality buildings which are listed, locally listed or have been identified as Buildings of Townscape Merit.

Apart from the listed and locally listed buildings, a large number of unlisted buildings in the Conservation Area have been identified as “Buildings of Townscape Merit”. These are usually well detailed examples of mainly late 19th century houses or commercial premises which retain their original detailing. As such, they make a positive contribution to the character and appearance of the Conservation Area, and any proposals to alter or demolish such buildings will be strongly resisted by the Council (see Policy EQ13 of the UDP of 1995). Together, these buildings provide the cohesive and interesting historic townscape which is necessary to justify designation as a Conservation Area.

[CAA 8.4]

The amalgamation of five units into one shopfront as illustrated in the application is an example of alteration which according to the CAA will be “strongly resisted by the Council”. We believe any alterations to these shopfronts should be in line with the Conservation Area shopfront design guide. We particularly refer to page 5 where the extension of a single facia across multiple buildings is counter-indicated.

6. The Effect of a large scale single retailer on the Conservation Area


  • Small businesses with low profit margins do not generate funds for repairing the buildings [CAA 8.4]

We would argue that any retail development of this size, is inappropriate for the conservation area.  A conservation area is more than buildings. The Stoke Newington Area is anchored on two shopping streets and streets of a particular or two particular but similar characters.

The character of the Conservation Area depends on the number and type of shops which typically are single fronted, independently owned convenience and speciality shops. A large supermarket would undoubtedly upset the current centre of gravity with the risk of urban blight.

The CAA identifies the poor profitability of the current shops as a major factor in the decay of the local buildings so any threat to that profitability must be taken seriously.

A Conservation Area is also, if it is to work, an expression of a local community. The very strong opposition to the proposed supermarket is therefore worrying.

We were concerned that these commercial considerations might not be appropriate for a heritage body like ourselves but we believe this approach is supported by a recent planning appeal regarding the conservation area at Newington Green,  (combined judgements APP/V5570/A/05/1193422 & 1193806). In it the Inspector observes that, a

 “failure to observe the scale of shops… would create a discordant feature in the street scene…which would be harmful to the character of the CA, with its more intimate, even domestic scale of shops”.

The Inspector is stating that the scale of the retail outlets are a legitimate defining characteristic of the (Newington Green) CA.


We believe that this application, if successful would be seriously and substantially detrimental to the Conservation Area and should be refused.

Our particular objections are:

  1. The impact on the atmosphere of and views from the Cemetery. This is called seclusion and ‘rural quality’ in the 2004 CAA.  The scheme is built right up to the boundary of the Cemetery and is 7 storeys high. We feel that the visual impact, light pollution and shadow cast are all substantial detriments.
  2. The view from High Street of the Cemetery gates and the Victorian terrace will be dominated by a 7 story building, unsympathetic in style and of inappropriate mass and height.
  3. The Conservation area was set up in 1983 in part to preserve the character of the High Street characterised by local independent shops and cafes. A single large retailer (supermarket) is likely to affect this character and raises the danger of urban blight.
  4. The proposed amalgamation of the five units on the High Street is inappropriate in the context of the existing terrace.
  5. The development entails the loss of historical open space in the North Western corner which has been there for a very substantial period and contributed to the open feel of the Cemetery.

Submitted 17 September 2012

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Russell Miller Arboriculture

In summary the proposed development should be rejected on the following grounds:-
  • failure to conduct an Environmental Impact Assessment or any investigation into the consequences of the development for Abney Park Cemetery Nature Reserve;
  • failure to conduct adequate bat surveys. Bats are known to exist at Abney and the developer's ecological surveys reveal they may be present on the site itself. Despite recommendations to do so by their own ecologists the developers have failed to conduct a full nocturnal bat survey across all appropriate seasons;
  • failure to design in the retention of Abney's valuable veteran trees. The developer's tree survey fails to recognise the importance and value of Abney veteran black poplars. The developer originally sought to fell 12 trees inside Abney (including 8 old black poplars). Whilst the developer appears to no longer require the trees to be felled they nevertheless intend to build right up to them and thereby condemn them by default in breach of industry best practise guidelines.

The full objection is available on the Sustainable Hackney website.
Submitted 21 August 2012

Further objection

Further to those objections I have now had a little more time to consider the ecology of Wilmer Place and the very limited ecological surveys submitted with the planning application. I have not seen the Phase 1 habitat and ecology survey since this does not appear in the case file on the LBH website.

  • The planning application should be rejected because the proposed development pays no regard to the valuable ecology of the site, specifically the woodland edge to the Abney Park Nature Reserve/Site of Metropolitan Importance for Nature Conservation. If permitted the development will completely destroy this woodland edge and its associated flora and fauna. This includes protected species.
  • The development breaches LDF Core Strategy planning policy, the Hackney and London Biodiversity Action Plans and Hackney's statutory duty to protect biodiversity.

The detailed supplementary objections are available here 
Submitted 10 September 2012


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London Parks & Gardens Trust / Garden History Society

I write as Chairman of the Planning & Conservation Working Group of the London Parks & Gardens Trust.  I am also writing on behalf of the Garden History Society which, in view of the seriousness of the threat posed by the proposed development to one of the most significant of London's historic cemeteries, may also wish to contribute additional comments.

Abney Park Cemetery is included at grade II in the English Heritage Register of Parks & Gardens of Special Historic Interest and is described as London's most important non-conformist cemetery.  It is important on many levels – historical, aesthetic, architectural, horticultural, sociological and ecological – none of which is respected in the current planning application, which seeks to exploit the public amenity for private gain.

The density of development proposed is excessive, leading to over-high buildings constructed up to the edge of the cemetery, and would result in the overshadowing of the cemetery, the listed monuments, the trees and the cemetery gates, lodges and offices, and of the other listed and unlisted buildings in the conservation area.

All sense of privacy and sanctuary within the woodland would be lost, and the trees themselves would be threatened by overshadowing and pressure to lop and thin to allow views from the new flats.

The scheme is crass and insensitive to the special character of the cemetery and the conservation area and should be refused.  It requires a radical rethink to ensure that any development is of an appropriate scale and is kept well back from the boundary of the cemetery.

A roughly comparable scheme to build on the edge of the registered Bunhill Fields Cemetery (LB Islington) was recently refused following a Public Inquiry, and you may be interested to read the decision on the planning portal.

Chris Sumner
London Parks & Gardens Trust, Duck Island Cottage, St James's Park, London, SW1A 2BJ

Submitted 20 August 2012


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Professor Matthew Gandy, UCL Dept. Geography

I am writing to oppose the proposed development at Wilmer Place. This will have a deleterious impact on Abney Park, which is one of the most important sites for bio-diversity and landscape history in London. I am writing in my capacity as a local resident, a member of Hackney Biodiversity Partnership, and also an academic specializing in urban environmental issues.

I want to raise five points in particular:
1. A unique site
At its completion in 1840 Abney Park combined a garden-cemetery with an elaborate arboretum and rosarium, that were unique in Europe at the time, and featured some 2,500 species of trees and shrubs from around the world. The design drew on prominent European cemeteries such as Père-Lachaise in Paris as well as the natural woodland setting of Mount Auburn Cemetery near Boston. The proposed development does not acknowledge the national and international significance of Abney Park in cultural, historical and bio-diversity terms.
2. Landscape history
The park provides a direct continuity with the rural landscapes that were fast disappearing at the edge of nineteenth-century London since the site incorporated an area once called “the Wilderness” along with seventeenth-century landscaped grounds.1 These features of Abney Park form part of what the urban ecologist Ingo Kowarik terms “old urban nature” comprising elements of the original landscape which have never been built on, and which have subsequently become a pivotal aspect to the ecological significance of the site.2
3. Hackney’s first nature reserve
In the early 1990s the ecological significance of Abney Park was officially acknowledged for the first time and the site was designated as the first statutory Local Nature Reserve in the London Borough of Hackney, and it has subsequently been recognized as one of the most important sites for biodiversity in London. It is now recognized as a Site of Metropolitan Importance for Nature Conservation (SINC) with over 170 species of trees and shrubs, including some rare trees dating from the original Loddiges planting scheme of 1840. The reserve is nationally important for fungi (over 300 species have been recorded), rare beetles thrive on rotting wood (including nationally scarce species), and a remnant fauna of moths and butterflies persists (aver a third of the UK butterfly species have been recorded along with over 200 species of moths).3 The proposed development will present a threat to Abney Park from damage to tree roots, noise and persistent light pollution (which adversely affects bats, birds and night-flying insects).4
4. Environmental Impact Assessment
No Environmental Impact Assessment has been carried out as required under EIA Regulations (SI 293 1999). An adequate bio-diversity impact survey would take one year to complete since many key species are only observable at certain points over a twelve-month period. In order to assess the invertebrate fauna it would be necessary to employ a team of professional scientists to carry out the work and provide a full report. Additionally, a professional bay survey would take several months to complete, and would have to take into account the full range of habitats around the site.
5. Hackney’s Biodiversity Action Plan
The proposed development would contradict Hackney’s own Biodiversity Action Plan (BAP), published this year, which took over a year to complete, and involved a wide range of stakeholders across the borough. The Hackney BAP, written by the Hackney Biodiversity Partnership in collaboration with Hackney’s outstanding Biodiversity Officer, Kate Mitchell, is an example of best practice for London Boroughs. It would be a shame if Hackney’s public commitment towards bio-diversity and environmental education were to be irrevocably damaged by the proposed development.
  1. See E. Walford, Old and new London: a narrative of its history, its people, and its places (Cassell, Petter and Galpin, London, Paris and New York, 1877).
  2. I. Kowarik and S. Körner (eds.) Wild urban woodlands: new perspectives on urban forestry (Springer, New York, 2005).
  3. Critical species of Lepidoptera recorded on the site include Acasis viretata, Combibaena bajuaria, Lobophora halterata and many others. Further information can be obtained from Greenspace Information for Greater London (GIGL) and from Hackney Biodiversity Partnership.
  4. On the effects of light pollution see T. Longcore and C. Rich, “Ecological light pollution” Frontiers in Ecology and the Environment 2(4) (2004) pp. 191–198.

Submitted 6 September 2012


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Joseph Bloor, Abney Park wolunteer, green wood worker, professional visualizer




1. Damage to Ecology/Environment and Wildlife of Abney Park Cemetery. Nature Reserve.

Further to Objections raised by Russell Miller, Gina Rackley and others on ecological grounds.


These include direct damage (through excavation) to veteran poplar trees which ignore of the British Standard Root Protection Areas. A lack of a full ecological survey, bat survey, and tree survey. Detrimental effect on both Flora and Fauna Species including a Breeding Pair of Tawny Owls, Sparrow Hawks, Woodpeckers, White Letter Hair Streak (Butterflies/Moths) and a number of Species of Protected Bats.


The Proposed Development at Wilmer Place is of a Significantly Larger Scale than any other development that borders Abney Park Cemetery. Abney is a unique WOODLAND habitat within Hackney and within Central London. The proposed development lies to the South and East of Abney and as such will block a significant amount of direct sunlight from reaching both canopy and ground level of the Woodland. Given the Overall Mass of the Scheme which includes a 5-6 metre ground floor (at approximately 1.5 metres above Abney ground level) PLUS 5 floors of Residential Accomodation (3m floor heights). A total height of over 20m This is only set back a nominal 1 to 1.5 m from the Boundary with Abney. This will cause a radical and NEGATIVE change which will result in the Death of a large number of Veteran Trees, Shrubs and will change the habitat of a Large area making it uninhabitable by a wide variety of existing species. The proposed development will Significantly Overshadow a large area of the Cemetery throughout the year. I have completed some sun shading illustrations (attached) showing the whole of the Cemetery. These have been completed for the 21st day of each and every month and show the cumulative effect of Overshadowing throughout the course of a whole year. These diagrams demonstrate a truer extent of the overshadowing than the information contained within the planning application (sunlight and rights of light) which only assesses the impact on the 21st of March, for a limited period of daylight and for a limited (small area) and show that the consultants reports are wholly insufficient to assess the impact of the development on the Nature Reserve.


Additional negative impact will be caused during the demolition of existing buildings, construction of and lifetime of the proposed building, caused by Mechanical Noise, Vibrations, Dust, Changes to Temperature and air quality from the location of Building Plant Rooms and other disruption (light and noise) from inhabitation.


A Significantly Larger Setback from the boundary (10 metre, root protection area) and garden buffer zone which should not be built on. Plus Significantly reduced Mass of Building may reduce the wholly innapropriate and HARMFUL impact of the scheme.


It should be the role of the developer, the architect and their consultants to prove that NO significant damage will be caused, and this is simply NOT the case.


When was the last time you heard a woodpecker, or saw an owl. These things will be lost unless you decide to protect them and their habitat.


2. Damage (Through negative visual impact) on the Architectural Heritage of Abney Park Cemetery, the Grade ii listed Gates, The Main entrance and other listed monuments and buildings on the site.

Further to Objections by Bernard Boudillion and others on Architectural, Town Planning and Heritage Grounds.


The proposed development is of such a large scale that it dwarfs the Lodge buildings either side of the Main Entrance, and The Grade ii listed gates. It will Overshadow and Overlook large areas of the Cemetery including, the Main Entrance, Lodges, The Funeral Chapel, The Childrens Garden, Green Wood Workshop, Stone Carvers Workshop, as well as many thousands of burial plots. It is a rude and obnoxious building that shows a complete lack of respect for its environment and its nearest neighbours. It takes no account of its location within a Conservation Area, Its Materials are not Local (Imported Terracotta from Italy). Its form and scale might fit somewhere more densely urban but It will detract from the appreciation of historic monuments, cultural heritage and buildings that exist on site.


The proposed development will cast a shadow over the War Memorial on Armistice Day (11th of November). This shows a lack of respect for those who gave their lives to ensure our freedom during two world wars and it will be intrusive to the many visitors who have come either to simply enjoy the peace and tranquility of a natural landscape as an escape from busy London life or to tend the graves of their friends and family.


Few of the other developments that now surround Abney Park actually overlook of the Cemetary. Many terraced houses have their gardens which back on to the boundary wall, and these benefit from views of a tree canopy but do not look down on the landscape. The proposed development seeks to benefit from its proximity to the green space, but shows no consideration for its current use as a cemetery and will in time damage the very nature and character of the place.


The Computer Generated Images within the Planning Application are not numerous enough or extensive enough and do not fully examine the visual impact of the scheme and specifically do not address its impact in either Spring, Autumn and Winter where leaf cover of trees is less significant. A limited number of views and Only 1 (maybe 2) image(s) have been produced with Winter Foliage. A full Visual Impact Assessment should be required which includes a greater number of views from within the Cemetery. (See Attached Map). From Professional experience working in Urban Areas, I would expect that a building of this scale which is classed as a MAJOR DEVELOPMENT, would require at least 20 – 30 views of the scheme in order to assess its visual impact fully. These views should be Verified Views (Which despite claims the ones in the application are NOT) and they should be produced using both Summer AND Winter Photography to clearly show the difference in Foliage of what is primarily a natural environment. The NEGATIVE visual Impact will be greatest in Winter when many of the trees have shed their leaves


3. Damage to the Unique Character and Nature of the WOODLAND landscape.

Abney Park Cemetery may be classified as many things. A Cemetery for one, A Park and Garden, A Nature Reserve, Within a Conservation Area. But Ultimately it is a Woodland Landscape. This is an extremely rare habitat especially within London and though it has developed through many chance occurrences over the 170 years since it was originally planned (1840). This aspect of the site should be protected and treasured. The proximity of a Large Mass of Building will drastically affect the experience of visitors and the survival of Wildlife. Woodland Rides (paths) which currently enjoy dappled sunlight will be cast into long and dark shadows throughout the year. Some areas will not receive any Sunlight before 12noon or 1pm (And these will die). The Lawn and Garden areas at the Main Entrance will be overshadowed for most of the late morning, mid day and early afternoon throughout the year. Damaging the hard work put in by many volunteers over the years. I have worked with many people who are always surprised and delighted to find a real Woodland in the heart of Hackney, I have seen visiting Children from Dalston who have never been to a woodland before jump with joy that this place exists so close to their grey and concrete homes. Abney Park Cemetery may have been neglected in the past, but it is a hidden jewel within a deprived borough and it can and does shine a light into even the darkest corners of urban life.


4. Damage to the Experience of Every Visitor to the Cemetery.

There are numerous individuals who visit Abney Park Cemetery throughout the year. From the Daily Dog Walkers and joggers, Cyclists who use it as a shortcut to avoid a long route through traffic laden one way systems. Families with Children, Students, Retirees. (The whole spectrum of Hackney Residents) The Staff and Volunteers who work there in many different ways. Local artists, musicians who have been encouraged to use the place as inspiration for work and for performances and events. To others who may only be visiting once but have travelled a long way from countries all over the World. Some come to find the graves of long lost relatives, others to study the rare ecosystem and biodiversity that has developed. Still more just to walk through between the trees and stop for a moment in the glades and to rediscover a childlike wonder of the Natural World, all too often forgotten.


I ask you to imagine visiting the grave of your loved one (an ancestor, your mother, father, brother, sister or child) which was previously located in a secluded spot where you felt able to have a private moment of reflection on your loss, only to look up and see a resident of the proposed building walking around in their towel, doing their ironing, overlooking (towering over) you from their 3rd, 4th or 5th floor balcony. To say this is a rude intrusion is to actually too mild a word. That possibility is frankly disgusting and deplorable.


I am not saying that as a member of the planning committee you should be outlawing wearing a towel. But the size and position of this building means that this would be a real possibility if you were to approve the application.


5. Damage Caused to Minority Groups who are not able to represent themselves.

The proposed scheme will overshadow and overlook the Childrens Garden which is adjacent to the environmental classroom. This space is well used throughout by a number of local Nursery Schools, Primary Schools and families as well as for educational activities for school Children run by the Abney Park Trust. It has recently had a significant amount of time and effort put into developing it as a place for Children to both Play and Learn. Through Corporate Volunteers provided through ELBA (East London Business Association). In Winter what is now a sheltered but sunny spot will become dark and uninviting. I doubt whether the Architects or the Developers actually realise that the Childrens Garden at Abney exists and this oversight and ignorance should be enough to prove that they should return to the drawing board and consider the fulllest and widest impact of their scheme before putting forward a new proposal. The developers inclusion of a Private “Woodland” themed play area for Residents Children at the Podium level (6m first floor) is just a contrite and facile attempt to recreate a pseudo interpretation of what actually already exists and is open to the public at Abney.


The proposed development will also Overshadow the Green Wood Workshop, and during demolition and construction would cause disturbance and noise that would mean the activities could not be continued. These activities support a broad range of people drawn from all backgrounds from the local community and people who travel across London to particpate. These range from home schooled children undertaking craft based workshops as part of their education to retirees who value the social and community aspects as much as the skills they share. And again I am sure that neither the Developer nor their Architects are aware of the negative impact their building would have on these groups and others that use the cemetery.


6. Damage to Local Businesses including small independent retailers, by the Large Sainsbury Supermarket Component.

Further to Objections by Stokey Local and other Local business Organisations. There is Significant Local opposition to another Large Supermarket being built in Stoke Newington. The unique character of Stoke Newington Church Street, and the thriving nature of the traditional High Street is all to rare nowadays. This should be protected from the influx of additional retailers which will damage local businesses that have been serving the community for many years.


7. Misleading, Incomplete, Missing, and Misinformation Contained in the Planning Application.

There are a number of questions within the planning application forms which have been answered untruthfully. As well as numerous omissions and professional Disclaimers within consultant reports. A full ecological survey of Abney Park Cemetery should be carried out. Including, Tree Surveys, Bat Surveys, Butterfly and Moth Surveys and Other Wildlife Surveys. The Ecological Report in the application does not even acknowledge that the proposed site is adjacent to a WOODLAND, only seeking to assess the site based on “Built Environment” and “Park and Garden” Criteria. The Rights of Light (Sunlight and Sun Shading) component, does not examine the Overshadowing of the Nature Reserve. The few Computer Generated Images produced are of questionable efficacy, honesty and accuracy, they seek to hide the true impact of the scheme and do not fully (or even adequately) examine the visual impact, especially during winter. Disclaimers within the Sustainability Report from Arup State that this is not their professional opinion, but has been paid/served by their client.


I was actually shocked when I found out that the Architects were AHMM. I would have hoped that they would produce a building more sensitive to its surrounds, more fitting for the local community and with more care for their professional standards.


During the meeting I attended with the Developer I was asked if there was any sort (or scale) of development I would support. And I would say. If they proposed a modest mixed used development with 3 storey buildings adjacent to the high street, and two storey houses with back gardens that bordered the Cemetery. With some Live Work Units, Studios or Workshops to develop small local business then yes I would be likely to support it. But as it stands the Bohemothic Carbuncle they propose which will ruin a place that I love deserves no support whatsoever.


A Final Thought.

Abney Park Cemetery is a truly wonderful and special place and it is really this unique Charm and Magic which is at Stake here. You cannot quantify this. Or even start to qualify this unless you actually visit. So I ask that you, and that means ALL of you. Before you make a decision. Please, get up out of your chairs, leave your committee meeting room and take a walk, a cycle, get a bus or a taxi and come to visit Abney Park Cemetery and witness some of the things that will be lost if this planning application is granted. There are numerous local experts with vastly greater understanding of the place than any of the developers consultants who would be more than happy to show you the hidden treasures. Both natural and Cultural. I have tears in my eyes as I am writing this at the thought that the Greed of a Developer and the Financial Profits of Property Speculation will be favoured over Cultural Heritage, Beauty and a Natural Wonder that will be Sacrificed. You will never be able to return or replace what will be lost so please look deep into your hearts and know that the right thing to do is to REFUSE this application.


I realise that this objection may find its way to the bottom of the pile of paperwork associated with this case. But I hope that someone with more influence than me, reads it and is able to make a difference.


Submitted 19 September 2012


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Hackney Parks Forum


On behalf of Hackney Parks Forum I write to object to Planning Application 2012/2228.
Hackney Parks Forum is an umbrella group of all park user groups in Hackney. Planning
Application 2012/2228 is for a supermarket and 68 residential units. The proposed building is
six storey’s high. It abuts Abney Park Cemetery Nature Reserve.
We object to the proposed development because:
  • the building is too close to the nature reserve
  • the building is too tall and will shade the nature reserve
  • the building will damage trees inside the nature reserve
  • the open woodland edge to the reserve will be lost
  • insufficient surveys have been done to examine the impact on the reserve
  • no Environmental Impact Assessment has been conducted
  • the developer's tree survey does not attach sufficient value to the trees in the reserve
  • the development will have a negative impact on people’s ability to enjoy the nature reserve.
Abney Park Cemetery is a designated Local Nature Reserve and Site of Metropolitan
Importance for Nature Conservation. It is home to many protected and iconic species
including tawny owls, sparrow hawks, pippistrelle bats and rare insects and fungi.
The importance of the nature reserve does not appear to have been sufficiently considered
since the development is very close to the west and north boundaries. In these locations
the proposed building would remove the woodland edge, currently a habitat for sun-loving
The impact of such a large development should have been assessed by surveying the
adjoining nature reserve. Such a survey has not been carried out. The surveys that have
been done of Wilmer Place itself appear to be inadequate. It is unacceptable that there is no
Environmental Impact Assessment. Has the council exercised its statutory duties to protect
trees, wildlife and green spaces?
The developer's tree survey makes no mention of the site being adjacent to an important
nature reserve or the contribution the trees make to nature conservation. No account
appears to have been taken of the British Standard for development site tree surveys, BS
5837, which has a specific category (3) for trees with conservation value. To categorise trees
over 100 years old as having little or no value in a nature reserve is contrary to the opinion of
the developer's ecologist. The trees are habitat for roosting bats and numerous rare insects
and fungi.
The main entrance to Abney Park Cemetery is currently open and spacious with impressive
Egyptian gates. The gates and the ancillary buildings at the entrance would be dominated by
the proposed new building. The development will intrusively overlook a large section of the
nature reserve. Being located to the south and east it will cast a wide shadow. This will have
a negative impact not only on the reserve itself but on the public’s enjoyment of this valuable
open space.
For the above reasons we consider the Planning Application should be refused.
Yours sincerely
Ian Rathbone
Vice Chair

Submitted 20 September 2012


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