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Application by North London Waste Authority for an Order Granting Development Consent for the North London Heat and Power Project

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Application by North London Waste Authority for an Order Granting Development Consent for the North London Heat and Power Project Application by North London Waste Authority for an Order Granting Development Consent for the North London Heat and Power Project Written Representation Lee Valley Regional Park Authority Registration No. 10031942 23 March 2016 Attached Separately Appendix A Statutory Context of the Lee Valley Regional Park and Authority Appendix B Plan showing location of EcoPark and Regional Park Appendix C Letter 2 Oct 2015 response to Phase 2 Consultation Appendix D Extract from Park Development Framework Area 4 Proposals 1 Summary of Representation The Lee Valley Regional Park Authority (LVRPA) and the North London Waste Authority (NLWA) have been in regular contact throughout the application process for the North London Heat and Power project. Both parties are working towards a Statement of Common Ground to be submitted by 6 April. Certain matters fall outside the SoCG and these form the basis of the LVRPA’s written representation namely: 1. An amendment to the DCO Schedule 2 ‘Requirements’ under sections (3) to (5), (10) to (12) and (15) to ensure that there is specific reference to consultation with the Lee Valley Regional Park Authority as part of the LPA approval process for the requirements on detailed matters where it is stated that the LPA as approving the requirements with the addition of words as follows…’ in consultation with the Lee Valley Regional Park Authority.’ 2. Temporary Laydown Area – related to point 1 above. As much information as possible should be provided at the outset of the process for the final landscape treatment and reinstatement of the Temporary Laydown area. 3. Use of the site of the existing Energy to Waste Plant once demolished. 4. Combined EcoPark and Regional Park Gateway – the LVRPA should be involved in the approval of the final treatment of this public entrance to both the EcoPark and the Regional Park. 5. Overall Design. 6. Road and Traffic Layout. Context The LVRPA is a statutory authority created by the Lee Valley Regional Park Act 1966 (the Park Act) with responsibility for the 4,000 hectare Lee Valley Regional Park. Section 14 of the Park Act (subsections 4-7) requires the riparian local planning authorities to consult with the LVRPA on planning applications which may affect the Park (please refer to Appendix A for further detail). The Edmonton EcoPark lies outside but adjacent to the Regional Park on its western side, please refer to Plan B. The LVRPA owns land, the Lee Park Way which is required for access purposes in relation to the Heat and Power Project. The proposed Temporary Laydown area is also located on land within the Regional Park, although not in the LVRPA’s ownership. The River Lee Navigation and its associated towpath together with the Lee Park Way form the boundary between the EcoPark and the Regional Park. The Navigation corridor is designated as a Site of Metropolitan Importance for Nature Conservation and Lee Park Way forms part of the National Cycle Route 1. This is a popular cycle route for visitors to the Park and together with the towpath provides access into a Park wide network of walking and cycle paths, open spaces and leisure venues. 2 To the east of the Navigation corridor lies an area of Green Belt within the Park south of William Girling Reservoir. Owned by Thames Water the northern half of the site is used by Camden Plant Ltd as a soil treatment facility whilst the southern half of the site remains as open grass and scrub land. The London Borough of Enfield has included this site within the Meridian Water Masterplan as recreational land contributing to flood alleviation. The southern part of this site is proposed as the Temporary Laydown Area. In responding to the consultations on the North London Heat & Power project the Authority has in principle, been supportive, as the project will achieve a substantially more efficient and technically advanced ‘Energy Recovery Facility’ with improved emission controls, designed to cater for increased demand. Regular meetings and discussions between Authority officers and the NLWA has helped in understanding areas of detail around building design, landscaping, the laydown area and access and has enabled the consideration of property and legal issues in relation to the Lea Park Way. Schedule 2 Requirements A number of the consultation representations made by the Authority concerned the detail of the development and how it might impact upon the Park, in particular its design and appearance, the associated landscaping and the ecological commitments all of which have yet to be finalised. It is appreciated that the application submission documents provide considerable detail on all these matters and the methodologies used to make decisions and set the design parameters. However these matters will not be resolved until the DCO is approved and a contractor appointed with 2019/20 identified as the earliest start for construction. This means there is still uncertainty as to the final appearance and design of the main built structures and associated landscaping and the degree to which provision is made for ecological enhancement. The visual and ecological impact on the Park, and its recreational use and amenity also therefore remains uncertain. For example the Authority raised a number of points about the design, appearance and choice of materials during the phase 2 Consultation (see letter attached as Appendix C). Under DCP 39 ‘Project Colour Palette’ there is reference to further testing at detailed design stage to assess the appropriateness of the proposed colours and whilst both the DAS and DCP provide examples of external cladding and architectural screens these are for illustrative purposes. DCP38 ‘Roofs’ includes the statement that “Where possible, green or brown roofs should be used to slow down run off …and provide additional ecological benefits”, the Design and Access Statement states (Section 6.5 end of page 107) that “A green and a brown roof would be incorporated onto the roof structures of the tipping hall and the crane hall of the ERF respectively to enhance biodiversity, slow down rainwater runoff as well as help connect the building with its setting adjacent to the LVRP.” (Refer to Fig 6.103 which illustrates this point). Schedule 2 of the draft DCO sets out the decision making process for finalising the detail of those areas of interest to the LVRPA under a series of ‘requirements’ 3 namely - detailed design approval (3), parameters (4), mitigation measures as set out in the environmental statement (5), landscaping provisions (10), maintenance of landscaping (11), access and roads (12) and ecology (15). In each case details are to be approved by the local planning authority. The LVRPA should be involved in this final consultation/decision making process in order to ensure the open space and recreational assets of the Regional Park are protected, that adverse impacts arising from the Works are minimised and that opportunities to enhance the landscape and ecology are maximised. The LVRPA seeks an amendment to Schedule 2 ‘Requirements’ so that where reference is made to the Local Planning Authority approving the requirements under sections (3) to (5), (10) to (12) and (15) there is the addition of the words …” in consultation with the Lee Valley Regional Park Authority.’ This will be consistent with the Authority’s statutory role in the planning system. Temporary Laydown Area Associated with Point 1 above is the final landscape treatment and reinstatement of the Temporary Laydown area which forms part of the Regional Park, adjacent to the Lea Valley SMINC and Chingford Reservoirs SSSI. Whilst it is understood that this awaits the outcome of discussions with other parties/landowners; given the scale of its potential impacts on the Regional Park as much information is required at the outset of the process and this should not be left to ‘Requirements’. The Temporary laydown area forms part of Thames Water’s land ownership south of William Girling Reservoir, which also includes the Camden Plant operation, originally permitted on a temporary basis. This site is the subject of an extant enforcement notice requiring phased re-instatement (the LB Enfield will have the details of this). This site is likely to be released from use as an aggregates recycling plant in the next 5 years and it is intended that the whole area south of the reservoir could become a venue for a mix of active recreation, natural play and fitness activity to complement the Meridian Water development. Restoration of this site and land south of the North Circular could provide opportunities to create new habitats, improve public access linked to the development of the site for flood mitigation as set out in draft proposals included in the Meridian Water masterplan. This area is an important component in the continuity of the Regional Park and its openness, given the fragmentation caused by road crossings and adjacent industrial activities and land use. The restoration and enhancement of this area of green belt has been a long held aim of the LVRPA, and current plan proposals as set out in the Park Development Framework Area 4 Proposals seek a comprehensive restoration scheme across land on both sides of the North Circular which would include: - habitat creation and enhancement to strengthen ecological connectivity between the reservoir Site of Special Scientific Interest, the waterway and open grassland habitats on Tottenham Marshes. - New habitat creation on land lying between the North Circular and William Girling Reservoir to be explored with stakeholders; all options to accommodate public access to enable people to enjoy the wildlife, for 4 example through the provision of boardwalks and a bird hide offering views over the reservoir. - Exploration of options for recreational and formal sports use of land to the north and south of the North Circular, complementary to the creation of new habitats, for example natural play, sports pitches, urban gym.
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