Appendix 1: Hackney Wick and Fish Island SPD Consultation Summaries and Responses
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Appendix 1: Hackney Wick and Fish Island SPD Consultation Summaries and Responses No. Name & Organisation SPD Summary of consultation comment/issue Response to comment Changes proposed to SPD section page / issue 1. Ref: 001 Highways - No specific comments provided - - England 2. Ref: 002 Health and - No specific comments provided - - Safety Executive 4. Ref: 003 Natural - Natural England does not consider that this - - England Hackney Wick & Fish Island SPD poses further risk or opportunity in relation to our statutory purpose and so does not wish to specifically comment on this consultation. 3. Ref: 004 Thames Proposed Change to SPD Adding the specific wording Flooding and Drainage Water Thames Water recommends that developers requested would simply repeat section to be renamed engage with them at the earliest opportunity to parts of Local Plan Policy S.5 “Water, flooding and establish the following: Water supply and waste water drainage”. disposal. However, it would be The developments demand for water supply and appropriate to provide a short Add additional paragraph: network infrastructure both on and off site and reference to the need to take can it be met; these issues into account and “Policy S.5 Water supply and engage with Thames Water on waste water disposal requires The developments demand for a scheme by scheme basis major development proposals Sewage/Wastewater Treatment and network along with a cross reference to to demonstrate that there is infrastructure both on and off site and can it be Policy S.5. sufficient existing or planned met; and water supply and waste water disposal infrastructure or that The surface water drainage requirements and capacity improvements are flood risk of the development both on and off site part of the scheme. Early and can it be met engagement with Thames Water is recommended.” Thames Water consider that text along the lines of the following should be added to the SPD: “Water Supply, Wastewater & Sewerage Infrastructure 1 Developers will be required to demonstrate that there is adequate water supply, waste water capacity and surface water drainage both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing water and/or waste water infrastructure. Drainage on the site must maintain separation of foul and surface flows. Where there is an infrastructure capacity constraint the Council will require the developer to set out what appropriate improvements are required and how they will be delivered. 4. Ref: 005 Environment Public We support many of the design principles put Support for the design Add the following to the Agency Realm, forward in this section, particularly those that principle expressed is Locations and Designations Open make specific reference to improving and welcomed. list: “Water Framework Space enhancing the waterways for biodiversity and Directive - River Lee and Lee and drainage. Policy BN2 of the Local Plan includes Agree that reference to the Waterw “Support the aims of the Thames River Basin WFD be added to the text. Navigation are designated as ays Management Plan” and we think this section a WFD waterbody”. would benefit from setting out how the aims of the TRBMP can be achieved for this area. We While noting the desirability of would expect developments to consider the an 8 metre zone along the TRBMP aims and actions when designing banks of the River Lee/Lee developments next to the waterways and so the Navigation, the scale of the SPD should be enabling that to happen by illustration within the SPD providing more detail. would not make this possible The “Locations and Designations” list on page in an accurate and 21 doesn’t list the River Lea Navigation as representative sense. designated watercourse for the Water Framework Directive. The Water Framework Agree that a reference to the Add the following to the Directive should be considered a way in which opportunity to improve the “Strategic Green Linkages” waterways have been designated as the current connection between rivers and section (page 23 of the ecological condition of the waterways and their floodplains should be 2 actions identified to attain good ecological status added in the context of consultation draft SPD: (or potential) are set out in the TRBMP. Hackney Marshes and Wick “There is also an opportunity You could simply insert “Water Framework Field. to improve the connection Directive – River Lee and Lee Navigation are between rivers and their designated a WFD waterbody.” The “Open Space and Waterways” map on page floodplains at Hackney 22 should label the waterways e.g. Hertford Marshes and Wick Field.” Union Canal, Lee Navigation, River Lee, etc. It should also highlight the WFD designated River Lee/Lee Navigation in a specific colour or pattern so it is easily distinguished on the map. We would also welcome an 8 metre zone marked on either side of the River Lee/Lee Navigation to demarcate the area in which a natural green corridor should be protected (more comments on this below). The “Strategic green corridor linkages” makes note of some local green assets. The waterbody wide actions include aspirations to improve floodplain connectivity with Hackney Marshes and Wick Field (see enclose the Waterbody Summary Report for River Lee). To reflect this we suggest a sentence is added that states “There is also an opportunity to improve the connection between rivers and their floodplains at Hackney Marshes and Wick Field.” This links with the infrastructure project identified for the Hackney Marshes to alleviate flood risk in Hackney Wick which may also improve drainage and enhance biodiversity. As a general point it would also be good to tie the strategic aims with the Lee Valley Regional Park Authority Biodiversity Action Plan. The “Enhancing Green Corridors” initial scene Agree that additional text to Add the following text to first setting paragraph could be improved by “Enhancing Green Corridors” paragraph of “Enhancing inserting the following in italics and underlined section to address water Green Corridors” section after the first sentence: quality issues would be (page 23 of consultation draft The River Lee/Lee Navigation is currently failing appropriate SPD) to meet Water Framework Directive standards 3 (classification in 2015 is “bad”) due to a “The waterways, parkland combination of pollution from sewerage and other green edges discharges, urban runoff and hard engineered within and around Hackney walls and structures. Maintenance of the high Wick and Fish Island quality habitat areas along with opportunities to expand and improve the River Lee and these present the opportunity to corridors are present through: enhance the local This enables the audience to understand that wildlife and habitat linkages the WFD context for the River Lee is an that these create. The River important aspect of enhancing green corridors Lee/Lee Navigation is and this leads onto the design principles below. currently failing to meet We support the measures you have already Additional text to list on page Water Framework Directive listed and we suggest this includes the following 23 of the consultation draft standards due to a additional design measures in italics and SPD is agreed. However, a underlined: setback along the western combination of pollution from Linking and enhancing existing green assets edge of the Lee Navigation in sewerage discharges, urban with the creation of new green spaces and particular of eight metres has run-off and hard engineered corridors the potential for compromising walls and structures. Appropriate waterway edge treatment the existing and future urban Maintenance of the high including native planting and reedbeds context. Further qualifying text quality habitat areas along is therefore inserted. Re-naturalise waterways where appropriate with opportunities to expand by removal of hard banking and obsolete and improve these corridors structures are present through:” Setting new development back from the waterway edge/tow path aiming for a minimum of eight metres Amend text in “Enhancing Concentrating green roofs and sustainable Green Corridors” section: drainage systems within new development Linking and enhancing along these corridors existing green assets with Managing and preventing the spread of the creation of new green invasive species spaces and corridors Designing lighting to minimize the impact on Appropriate waterway sensitive habitat edge treatment including native planting and The additions are quite specific but we feel this reedbeds where is appropriate for the SPD. The eight metre appropriate minimum setback is a standard requirement we Re-naturalise waterways have to ensure access can be maintained for where appropriate by 4 maintenance and inspection of flood defence removal of hard banking assets or emergency removal of blockages. It and obsolete structures also provides a green corridor to allow Setting new development movement of wildlife and create habitat. Whilst back from the waterway we appreciate eight metres cannot always be edge/tow path aiming for achieved we expect this to be a minimum to aim a minimum of eight for and compensated for where it cannot be metres where the context achieved. Even where previous developments is appropriate on site or in the vicinity have not achieved this Concentrating green setback, developments should aim to improve roofs and sustainable the buffer width to give greater space for drainage systems within drainage, potential flooding, access and new development along enhanced habitat. It contributes to enhancing these corridors strategic green corridors and lessens Managing and preventing vulnerability to future climate change impacts the spread of invasive such as increased flood risk from heavy rainfall. species We appreciate that it will not always be Designing lighting to appropriate to remove hard banking along the minimize the impact on River Lee particularly the navigable section.