GASWORKS

REMEDIATION UPDATE

February 2021 Contents

Introduction 3 Remediation at Brighton Gasworks Gasworks Our estimated timeline 16 Then… 5 Ensuring your safety 17 2002 remediation 7 How we will communicate with you 18 Today 8 Brighton Gasworks remediation summary 19 About Remediation About St William When is remediation needed? 11 Who is St William? 21 The remediation process 12 Our experience 22 Remediation checks and controls 13 St William recent projects 23 Ensuring public safety 14 Glossary of Key Terms 24 Contact details 26

Page 2 of 26 Introduction

This first update on the remediation process for Brighton Gasworks will: • Introduce the site and its history, why it is contaminated and why remediation is needed. • Set out the remediation process and the next steps for Brighton Gasworks. • Introduce St William.

Community engagement

Please refer to the Glossary at the end of this document for definitions of key terms on page 24.

Page 3 of 26 THE HISTORY OF BRIGHTON GASWORKS Brighton Gasworks – Then…

• Established in 1819 by the Brighton Gas Light and Coke Company to produce the first gas supply to Brighton. • When it was first produced, gas was mainly used to provide lighting to individual homes and streets, before beginning to play a major role in industrialisation in Britain by the late 1800s. • At this time, the entire site was used for the production and storage of gas, although in later years the site was only used for gas storage. Page 5 of 26 Image: Brighton Gasworks, in the 1930s Brighton Gasworks – Then…

• Gas production involved burning coal in Retort Houses on site, which created by-products such as tar and ammonia, which are common products of industrial processes and are found across many brownfield sites. • This legacy of the site’s use means traces of these by-products are, in our experience, likely to be found in the soil today. • Gas production at Brighton Gasworks ended in the late 1800’s and moved to the larger works at -by-Sea. • Since then, the site has been used for gas storage in the gasholders and underground

mains. Page 6 of 26 Image: Brighton Gasworks, post 1939 Brighton Gasworks – Then… 2002 remediation

• Following the relocation of gas production the southern part of the site became vacant. • This enabled remediation to be carried out in part of this area in 2002, cleaning up some of the most historically contaminated areas of the site. Page 7 of 26 Image: Brighton Gasworks, 2004 Brighton Gasworks – Today

• In 2012, the gas network across the country was modernised and gasholders became redundant. • Short term commercial uses have evolved on site during this time.

Image: Brighton Gasworks, present day Page 8 of 26 Brighton Gasworks – Today

• Brighton Gasworks is allocated in the adopted City Plan Part 1 and the draft City Plan Part 2 alongside Black Rock and as one of Brighton and ’s main development opportunities to provide much needed new homes and jobs. • This allocation aligns with the Government’s national planning policies that expect the Council’s planning decisions to:- – Make as efficient use of brownfield land as possible. – Support the natural environment by identifying opportunities to remediate contaminated land. • Sustainable redevelopment of under-used brownfield land means fewer greenfield sites need to be developed and creates substantial improvements to the local environment.

Page 9 of 26 ABOUT REMEDIATION When is remediation needed?

• Remediation brings environmental benefits for the long-term and regulators encourage voluntary remediation of contaminated land even where development is not proposed. • Remediation is not always linked to planning applications for redevelopment, however it is very common when redeveloping brownfield sites with an industrial heritage such as disused factories, railway sidings and gasworks. • This is because these industrial uses involved materials and processes that have the potential to pollute the ground. Prince of Wales Drive, Battersea • Remediation is highly controlled through government legislation and guidance; • Following this government guidance and setting the requirement and approach for legislation often means that changing the use remediation, which is then enforced by local of contaminated land means remediation is planning authorities (planning, environmental required to take place. and building control), the Environment Agency, New homes warranty providers, and consultant engineers on behalf of the landowner or the developer. Page 11 of 26 The remediation process

The Government sets out this three stage process Land Contamination Risk Management (LCRM) and for the remediation of contaminated land that must Part 2A of the Environmental Protection Act 1990 be followed in this order. The key Government (click here to read the guidance). statutory guidance and legislation include the

Stage 1: Risk assessment Stage 2: Remediation options appraisal Stage 3: Remediation and verification

Stage 1 : Develop a detailed understanding After Stage 1 is complete an assessment Stage 3 is to develop the remediation of the site to characterize the environmental of suitable remediation options can be strategy and carry out the remediation conditions and potential risks. This is split is performed, as follows:- works:- split into these tiers:- 1. Identify potential remediation options. 1. Develop a detailed strategy using the risk 1. Desk-based research to understand the 2. Carry out a detailed evaluation of the assessment and options appraisal. history of the site. options to determine which is most 2. Gain regulatory approval for the detailed 2. Initial risk assessment using desk-based suitable. strategy from the Council and the research and other published sources. 3. Select the most feasible remediation Environment Agency. 3. Complete intrusive site investigation option. 3. Start environmental monitoring and works to provide site-specific information maintain throughout and after the for assessment. remediation works. 4. Develop a detailed risk assessment based 4. Specialist contractor carries out on the investigation findings. remediation works. 5. When the works are complete specialist consultant produces a verification report to confirm the works have been successful. 6. Long-term monitoring and maintenance throughout construction. Page 12 of 26 Remediation checks and controls

• The remediation process is highly regulated • The Environment Agency and the Council’s and subject to numerous checks and controls Environmental Health Department act in the established in guidance and legislation. public interest and are strategically involved • St William will fully comply with all relevant throughout the development, planning, Government guidance and regulations to delivery and verification of the remediation ensure the health and safety of the public, works. environment and our employees. • Specific checks and controls are not limited to, but will include:- – Approval of a detailed risk assessment and remediation strategy before works can start. – The environmental standards the site must meet as agreed with the Regulators, ensuring suitability for its new land-use as residential and amenity space. – Permitted levels of noise, air quality, odour and vibration that must not be exceeded during the works. – What monitoring and mitigation measures are required.

– How we will verify that the works have Page 13 of 26 been completed successfully. Ensuring public safety

Remediation has the potential to release contaminants into the air, making monitoring (measuring what is in the air and ground) an essential part of the process. Monitoring starts long before construction begins to understand local air quality fully and, together with site investigations, will inform what measures need to be put in place to avoid harm - this is called mitigation. The process of monitoring continues throughout construction to ensure the mitigation measures are effective and whether any further measures are needed. It is important to recognise that odour is different Real-time monitoring unit for noise, dust and air quality to air quality and does not mean it is harmful to health, or that mitigation measures are not being effective.

Page 14 of 26 REMEDIATION AT BRIGHTON GASWORKS Our estimated timeline

Below is our indicative programme for the The timing of the later stages of the process may remediation approvals and works. change over time however the sequence will not change and we will keep local residents and other The first stage is to carry out a detailed site key stakeholders up to date with our progress. investigation, which we are seeking to start on site in March 2021. This will allow us to develop the risk assessment and resulting remediation strategy for regulatory approval at the earliest opportunity. 2021 2022 2023 2024 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 • Carry out on site investigation and collate Pre-application results for analysis

• Submit planning application BHCC & EA consultation • Develop draft strategies in consultation with the Council and the Environment Agency

• Agree strategies and obtain approvals Site preparation • Commence monitoring • Commence mitigation • Dewater and desudge the gasholders Demolition & • Dismantle the gasholders Remediation • Carry out remediation works • Verification report

Construction • Commence construction Ensuring your safety

Our key priority during remediation is to prevent adverse air quality effects and to minimise odour nuisance. First and foremost is the health of the community and of those working on the site. Monitoring and mitigation strategies will be agreed with the authorities through the approval process for Brighton Gasworks, however, we are committed to the following:- • Real-time monitoring of dust and contaminants relating to air quality. • We will assess any change detected by All mitigation will be managed from within the the monitoring and review to check that site boundary. mitigation measures are effective and adapt At times residual odour may be noticeable nearby them where required. but we aim to minimise disruption and nuisances • If monitoring shows that we are at risk of to the local community. meeting the agreed maximum levels, we will stop works immediately and agree a new Odour is not equivalent to poor air quality or approach with the authorities. health risks.

Page 17 of 26 How we will communicate with you

We are committed to an ongoing process of communication with the community from now until all construction works are complete. Before any remediation begins on site we will:- • Host further public engagement events so you can ask us directly any questions you may have;

• Keep you updated of our timeline for starting Prince of Wales Drive, Battersea works; We envisage the Community Engagement Plan • Publish our strategies following approval by will include: the authorities so we can discuss them with you and answer any questions; and • A dedicated member of the construction • Develop a Community Engagement Plan team to liaise with the local community; with the local community to guide how we • Community engagement events - such as will continue to engage with you throughout site visits, coffee morning, school visits, and remediation stage and the rest of the attending community meetings; construction works. • Regular communications - newsletters, site noticeboard and website updates; and • Dedicated contact details you can use to get in touch with us at any time.

Page 18 of 26 Brighton Gasworks remediation summary

• Remediation is required for many brownfield including air quality, dust and odour. redevelopment sites and is a highly regulated – Implement all necessary mitigation as process. agreed with the authorities. • Remediation works to part of the site have – Stop remediation works and replan if already been carried out safely and effectively necessary to avoid exceeding approved in 2002. limits. • We are at the very start of the process for – Employ only specialist environmental Brighton Gasworks. There will be further consultants and contractors. stages of communication as the proposals • We are seeking to commence Site progress through planning and before works Investigations in March 2021 to assess the start. condition of the site and how we will clean it • The health and safety of the community and up. our workers is our top priority. We will:- • Any mitigation will be managed on site. – Fully adhere to all Government guidance • We will aim to minimise noticeable odour at and legislation and any other site specific all times. checks and controls to ensure the health • We are committed to regular dialogue with and safety of the public and environment. the local community and quick responses to – Carry out multiple forms of monitoring any concerns raised.

Page 19 of 26 ABOUT ST WILLIAM Who is St William?

• A Joint Venture formed in 2014 between National Grid and the Berkeley Group, our combined expertise makes us well placed to regenerate redundant gasworks sites, to deliver essential new homes and jobs. • Our landscape-led ethos restores brownfield sites into beautiful new places that have a significant long term contribution on the environmental, social and economic fabric of the community. Prince of Wales Drive, Battersea

Page 21 of 26 Our experience

The Berkeley Group specialises in the regeneration of brownfield land. We have remediated and established new communities on formerly underutilised sites across London and the South East, many of which are located in urban areas surrounded by existing communities. We are highly experienced in managing the challenges these sites can present and the community benefits that they can unlock. We only employ highly competent expert consultants, contractors and staff for review, advice and to carry out the works. Courtyard Gardens, Oxted

Page 22 of 26 St William recent projects

Since St William was established in 2014, we have and the South of England. Nearly 5,000 of these been granted planning permission for more than homes are currently under construction and we 9,000 homes across 13 brownfield sites in London have completed over 600 homes.

Elmswater, Rickmansworth (remediation and Cottonworks, Highbury (remediation and Fairwood Place, Borehamwood (remediation and construction complete) construction complete) construction complete)

Prince of Wales Drive, Battersea (remediation Courtyard Gardens, Oxted (remediation complete The Arches, Watford (remediation complete and complete and first phase of homes delivered) and under construction) under construction) Page 23 of 26 GLOSSARY OF KEY TERMS Contamination Monitoring

• Land may be classified as contaminated because of • Monitoring alerts us to any changes and whether actual or likely presence of pollution that is, or has further mitigation is needed, especially in relation to the potential to impact people or the environment. air quality and dust. Baseline monitoring establishes conditions before any works start, then active Remediation monitoring during works monitors performance • The process we go through to clean the site up to against agreed safe levels. achieve new standards required by the Environment Mitigation Agency and the Council for the new proposed uses of a site. It involves removing polluting substances • Mitigation is the process of avoiding or reducing from the soil, or limiting the effect that they have on potential adverse effects to a safe level. A range of the environment to an approved level. mitigation measures are available depending on the scale of the impact and monitoring of live emission Odour data from the site allows us to implement the most • Odour can be characterised as pleasant, neutral appropriate measures at any given time. or unpleasant. There are standard methods for Brownfield Land categorising and assessing odour which define when odour is a nuisance. Odour nuisance does not • Brownfield land is also know as ‘previously equate to harmful health effects. developed land’ meaning land that has or used to be built on, for example for buildings or Air Quality hardstanding.

• Air quality is the term we use to describe how Dewatering and Desludging (gasholders) polluted the air we breath is. • Dewatering and desludging is the process of draining and cleaning the gasholder tanks by removing contaminated waters and sediment that is sitting within the below ground structure. Page 25 of 26 CONTACT DETAILS

Please get in touch By phone: 020 3725 8980 By email: [email protected] By post: Brighton Gasworks Team, St William Homes LLP, 15b St George Wharf, London SW8 2LE Or visit our website at: www.brightongasworks.co.uk