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Applicant's Responses to Written Representations Riverside Energy Park Applicant's responses to Written Representations VOLUME NUMBER: PLANNING INSPECTORATE REFERENCE NUMBER: EN010093 DOCUMENT REFERENCE: 08 8.02.14 June 2019 Revision 0 (Deadline 3) APFP Regulation 5(2)(q) Planning Act 2008 | Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 Riverside Energy Park Applicant’s Response to Written Representations Contents 1 Introduction.................................................................................................................................... 1 2 Local Authority .............................................................................................................................. 2 2.1 Greater London Authority .............................................................................................. 2 2.2 Kent County Council .................................................................................................... 63 2.3 London Borough of Bexley .......................................................................................... 68 2.4 London Borough of Tower Hamlets ............................................................................ 97 3 Statutory Organisations ............................................................................................................... 99 3.1 East London Waste Authority ...................................................................................... 99 3.2 Environment Agency ................................................................................................. 105 3.3 Eversheds Sutherland LLP on behalf of Thames Water Utilities Limited ................. 108 3.4 Eversheds Sutherland on behalf of National Grid Electricity Transmission Plc ........ 128 3.5 Shakespeare on behalf of Western Riverside Waste Authority ................................ 130 3.6 Winckworth LLP on behalf of Port of London Authority ............................................ 142 3.7 Womble Bond Dickinson (UK) LLP on behalf of Network Rail .................................. 143 4 Non-statutory Organisations ..................................................................................................... 146 4.1 Friends of Crossness Nature Reserve ...................................................................... 146 4.2 Greenwich-Bexley Environment Alliance .................................................................. 161 5 Members of the public/business ............................................................................................... 169 5.1 Barbara Fairbairn ...................................................................................................... 169 5.2 Dave Putson Councillor Belvedere Ward (Labour) ................................................... 176 5.3 Knights on behalf of S Wernick and Sons Ltd and Wernick Event Hire Ltd .............. 205 5.4 Knights on behalf of SAS Depot Limited ................................................................... 206 5.5 Mrs Margaret J White ................................................................................................ 214 5.6 Jon Cruddas MP ........................................................................................................ 222 5.7 Rt Hon Teresa Pearce MP ........................................................................................ 234 Tables Table 2.1: Policy Compliance .................................................................................................................. 6 Table 2.2: Technical Elements of the Proposed Development ............................................................. 18 Table 2.3: Bicarbon figures for all 4 scenarios within the Carbon Assessment .................................... 22 Table 2.4: Benefits of Energy from Waste in accordance with NPS EN-3 ............................................ 25 Table 2.5: Local Authority Collected Waste incineration and recycling rates across four London boroughs, 2017/18 (an update of the table in UKWIN RR at paragraph 80) ...................... 46 Table 2.6: Summary of median gate fees for waste management options, WRAP reporting, 2011 to 2018 (£ per tonne) .................................................................................................. 47 Table 5.1: Responses to bullet points raised by Counsellor Putson ................................................... 179 Table 5.2: Updated Responses to concerns raised by Councillor Dave Putson in May 2018 ............ 183 Riverside Energy Park Applicant’s Response to Written Representations Table 5.3: Responses to findings of the London Assembly Environment Committee 'Waste: Energy from Waste' report (February 2018)...................................................................... 199 Table 5.4: Responses to further comments made by Councillor Dave Putson .................................. 202 Table 5.5: Applicant’s response to Paragraphs 14 to 22 of SASDE’s WR ......................................... 210 Figures Figure 2.1: Extract from Land Plans (Rev 1) ......................................................................................... 95 Figure 2.2: Extract from Access and Rights of Way Plans (Rev 1) ....................................................... 95 Appendices Appendix A Response to Appendix 1 (Analysis of Carbon Intensity Floor Calculations) to Greater London Authority Written Representation .................................................. 257 Appendix B Comparison of EfW capacity need identified in the GLA WR and the Applicant’s LWSA .................................................................................................... 266 Appendix C Riverside Resource Recovery Facility Heat Export Feasibility ............................... 293 Appendix D Applicant response to LBB’s tracked-change draft of the DCO .............................. 294 Riverside Energy Park Applicant’s Response to Written Representations 1 Introduction 1.1.1 This document, submitted for Deadline 3 of the Examination, contains the Applicant's responses to Written Representations (WR) submitted to the Secretary of State by Deadline 2 of 20 May 2019. 1.1.2 For defined terms, please refer to the Project Glossary (1.6, REP2-031). 1.1.3 A total of 18 WRs, one Written Statement and one email were received. This document has been structured to provide a response to the individual Interested Party/Respondent, which are grouped as follows: Individual responses to Local Authorities (Chapter 2); Individual responses to Statutory Organisations (Chapter 3); Individual responses to Non-statutory Organisations (Chapter 4); and Individual member of the public / business (Chapter 5). 1 Riverside Energy Park Applicant’s Response to Written Representations 2 Local Authority 2.1 Greater London Authority Introduction 2.1.1 The Greater London Authority (GLA) has raised seven areas of concern within their Written Representation (WR) (see REP2-071 to REP2-074). These relate to: Heat Offtake (WR1); Renewable Energy (WR2); Carbon (WR3); Excess Waste Capacity (WR4); Waste Transfer Impacts (WR5); Air Quality (WR6); and Construction Traffic (WR7). 2.1.2 Our response covers each of these issues in turn below and refer to specific paragraph numbers in the GLA’s Written Representation as required. 2.1.3 Appendix A of this response provides a response to Appendix 1 (Analysis of Carbon Intensity Floor Target) of the GLA’s WR (REP2-072). Heat Offtake (WR1) Projected Demand 2.1.4 In Paragraph 3 of the GLA’s WR, the GLA claim that the “Applicant’s study of heat demand (document 5.4 Combined Heat and Power Assessment) focuses on heat supply from the proposed ERF and ignores the fact that the existing adjacent RRRF is also equipped with heat offtake as a planning requirement in readiness to supply a future a heat network.” 2.1.5 In accordance with the relevant National Planning Statement (Section 4.6 of NPS EN-1 and Paragraphs 2.5.26 and 2.5.27 of NPS EN-3) and Environment Agency (EA) guidance ‘CHP Ready Guidance for Combustion and Energy from Waste Power Plants’, the primary objective of a CHP assessment is to assess heat export opportunities, in a technical and economic context, with respect to the proposed development. In the case where alternative heat sources exist within sufficient proximity of the proposed development (as is the case for REP), the Applicant is obliged to consider the additional benefits which may be realised if an additional heat supply connection is made. Section 6.9 of the Combined Heat and Power Assessment (5.4; APP-035) submitted in support of the DCO Application, presents the review of additional heat sources in the region and in particular, the benefits 2 Riverside Energy Park Applicant’s Response to Written Representations associated with heat supply from RRRF, which presents an opportunity to increase the capacity of a heat network developed in the region. The availability and thermal export capacity of RRRF is broadly equivalent to that of the proposed REP Energy Recovery Facility (ERF). As discussed in Paragraph 2.1.12 of this response, there is a significant volume of existing and proposed local heat demand which would require heat supply from both REP and RRRF to be satisfied and for the benefits of renewable/low carbon heat provision to be maximised. 2.1.6 As set out in Section 3.2 of the Combined Heat and Power Supplementary Report (5.4.1, REP2-012), based on the results of the National Heat Map (commissioned by DECC and subsequently adopted by BEIS), a total demand of
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