Policy & Partnerships Directorate City Hall
The Queen’s Walk
London SE1 2AA
Switchboard: 020 7983 4000
Minicom: 020 7983 4458
Our ref: PDU/2101g/LF01
Head of Development Control
Your ref: 08/90143/REMODA
Olympic Delivery Authority
Date: 4 August 2008
Planning Decisions Team
1 Churchill Place
LONDON E14 5LN
Dear Ms Ramsey,
Town & Country Planning Act 1990 (as amended); Greater London
Authority Act 1999; Town & Country Planning (Mayor of London) Order
Olympic Stadium Site. Land bounded by River Lea, City Mills River and the
Greenway, contained within Planning Delivery Zone 3A, Submission of
second stage reserved matters for the Olympic Stadium (pursuant to
Planning Permission reference 07/90010/OUMODA)
I refer to your letter of 15 May 2008 consulting the Mayor of London on the above planning
application. I have assessed the details of the application and make the following comments.
Access and inclusive design
I welcome the process and mechanisms that the ODA has put in place to ensure that the
Stadium is being designed to be accessible. The aim that everyone both during the Games and
afterwards in Legacy will have a high quality and inclusive experience on equal terms meets
with the aspirations of the London Plan’s inclusive access policies.
The Access Statement is well written and makes the provisions made in the design at this stage
very clear, though a few additional drawings included in the access statement would have
helped understanding further, for example a plan that illustrated the numbers of each of the
bridges and a detailed drawing of the ramp to be used by the marathon route and of the ramps
to the wheelchair viewing areas.
There are, however, a few outstanding issues, which still need to be resolved. I understand
these are the subject of ongoing discussions between Julie Fleck (the GLA’s Principal Access
and Inclusion Officer within the London Plan Team), and the ODA (Promoter).
Direct telephone: 020 7983 4271 Fax: 020 7983 4706 Email: email@example.com
1. The main outstanding concern in this respect is the amount and location of seating for
disabled people. The ODA (Promoter) has agreed to submit for approval an Access Strategy for
Accessible Seating, which will be very helpful in establishing that sufficient space has been
allocated for general admissions wheelchair users in both games and legacy modes. However,
there is concern that elements of the design might be fixed in advance of agreement on the
seating strategy. For example the number of general admissions wheelchair seats appears to be
less than 1% of the total number of general admissions seats – 566 spaces at podium level. A
further 60 in the upper tier on the west stand and 54 in the mid tier are provided but will be
predominantly for Olympic family use not general admissions use.
2. It is also unclear at this stage how the 100 wheelchair spaces at field of play level will be
arranged in legacy mode – for example will these be accessible from the general admissions
areas or only from the athletes areas? This is particularly important for occasions when only
some of the 25,000 seats are occupied, to ensure that wheelchair users are not isolated in the
back row a distance from all the other spectators (e.g. if there are only 10,000 spectators in total
for an event). The number of amenity seats and their location and the opportunity to provide
wide seats in various locations across the stadium is also important.
3. Finally, the ramp to be used as the marathon route referred to in paragraph 4.15 is 130m
long with two 55m long 1:30 flights, broken by a 20m long, level intermediate landing. The
ODA’s Inclusive Design Standards recommend that ramps of 1 in 30 gradient have a level
landing every 20m. This may be suitable for the marathon, but there is concern about the use of
this ramp in legacy and whether the ODA’s standards for regular landings should be adhered
to. I understand that discussions have been held on this matter, but would ask that it be
clarified and if necessary amended before the applications is determined by your Development
Control Committee later this month.
I would therefore ask that you contact Julie Fleck directly to seek clarity on these matters, and
if necessary seek to agree an appropriate condition should these matters remain unresolved at
the time the application is considered by your Development Control Committee later this
4. A number of commitments have been made in the Access Statement regarding items
that are yet to be designed, and it is recommended that these be appropriately conditioned to
ensure that the commitments are achieved. Specifically.
a. Stadium western drop off (paragraphs 4.9 – 4.12). Details of the set down bays, flush and
dropped kerbs, pavements, pedestrian crossings, bus and coach bays, shared surfaces to
ensure they are accessible to wheelchair users and visually impaired people and others in
accordance with Inclusive Mobility and the ODA Inclusive Design Standards.
b. Paragraph 4.25. The design of the pod villages should take into account the need to
provide weather protection for spectators. This is a particular issue for wheelchair users
if they have to go outside to obtain refreshments etc.
c. Paragraph 5.8. The commitment to further studies to measure disability glare levels is
welcomed, but these details should then be submitted for approval. These studies should
also include the spectator entrances in the Wrap panels and the ‘black space’ (paragraph
5.18), to ensure that the additional design development of the ‘black space’ ensures that
the colour scheme and lighting programme take account of inclusive design issues.
e. Paragraph 5.29 – 30 – details of the entrance doors should be submitted when the
detailed design has been completed.
f. Paragraph 5.51. The Access Strategy for accessible seating should be submitted for
approval following discussion with the ODA Access and Inclusion Forum and the ODA
Built Environment Access Panel. This is a particularly important issue that needs to be
satisfactorily resolved for both games and Legacy modes.
i. Can it be confirmed that all the lifts including the two lifts on the east side of the
stadium will be retained in Legacy?
j. Paragraph 5.84. The design of access to the photographers moat needs to be conditioned
to be satisfied that disabled photographers and those who are wheelchair users can
either access the moat and/or have suitable facilities adjacent to and co-located with
their non-disabled colleagues.
k. Paragraph 5.102. The arrangements and facilities for disabled spectators in Legacy
mode is still unclear for example will the field of play accessible toilets be useable by
general admissions wheelchair using spectators in legacy or just athletes?
The demand for water around the time of the Games will be very high according to the figures
in para. 3.3 of the Water Use Statement, and it is therefore important that all practical measures
are incorporated into the proposals to ensure the efficient use of water.
The Water Use Statement also refers to policy 4A.11 in relation to the London Plan policy for
Water Supplies, whereas Policy 4A.11 in fact relates to Living Roofs and Walls. The
submission should therefore be assessed against London Plan policy 4A.16 (Water Supplies and
Resources) which requires, inter alia, demand management measures and supply side measures
in the form of recycled water. It is therefore felt that the possibly of incorporating Rain Water
Harvesting (RWH) measures, particularly for the transformed Stadium, be better articulated
and provided for.
There is also concern about references and potential ambitions to extract water from nearby
rivers during the construction phase. As well as first exploring the possibility of rain water
harvesting, any such extraction could adversely affect the ecology of these water bodies, and if
more than 20 cubic metres of water per day is extracted from a water body, specific approval
from the Environment Agency (or British Waterways in the case of a canal), would be needed
which may not necessarily be forthcoming.
The Technical report on noise mitigation is not entirely clear as to the BS4142 assessment for
the chiller units during the Games. Paragraphs 3.9 and 3.10 make comparisons of the chiller
noise levels at nearby residential locations with existing background levels, and state that the
'noise impact' will range from 4dB to 11 dB below these background levels. It is not clear,
however, whether this includes the +5dB 'penalty', as per BS4142, referred to in paragraph 3.11.
This should be clarified if not yet done.
The assessment also indicates that use of the chillers in the Legacy mode should be subject to
further assessment. As the report recognises, this will be essential if future development will
bring residential development closer to the stadium, as additional noise mitigation may be
required, which might be best considered and allowed for at this stage.
Finally, there remains a strategic noise concern over the potential use of the stadium in the
Legacy mode for concerts, as the indicated open design will provide no significant noise
containment, which may render the venue unsuitable for concerts involving amplified music. It
is therefore suggested that this matter be addressed in longer term Legacy planning as soon as
Detailed comments from Transport for London were provided on 6 June 2008 which confirmed
that TfL were satisfied that the proposals would be unlikely to impose any significant negative
impacts on the surrounding highway network. TfL did though make the following comments,
which I would ask are taken account of by your Committee.
The details of the Sustainable Construction methods document indicate that many of the key
goals for the Olympic Park have been adhered to. TfL would however recommend the
publication of a Construction Logistics Plan (CLP), to provide a benchmark against which the
ODA can assess the performance of their sustainability targets. It is expected that this would
largely involve just taking current aspirations on subjects such as prefabrication of buildings,
sourcing and procurement and modal shift and putting them into an operational plan.
One way of ensuring the most sustainable and safe road construction transportation would be
to contract FORS (Freight Operator Recognition Scheme) registered operators as they should
be able to demonstrate best practice for freight in London in terms of driver training, safety and
fuel efficiency, along with other management factors such as fleet procurement.
Details of pedestrian paths between the western drop-off area and stadium are required, to
demonstrate that there is safe and adequate provision. Confirmation regarding the provision of
disabled parking should also be provided
I trust these matters are self explanatory, but please do not hesitate to contact the case officer,
Lyndon Fothergill (firstname.lastname@example.org), should you require any further
Head of Planning Decisions
cc John Biggs, London Assembly Constituency Member
Nicky Gavron, Chair of London Assembly Planning and Spatial Development
John Pierce and Ian McNally, GOL
Colin Lovell, TfL
Helen Wood and Dean Williams, LDA
Donald Considine, ODA (Promoter)