Environmental Compliance Statement Our ref 15821/01/HW/IY Date April 2021 Subject Fulham Football Club New Riverside Stand: Non-Material Amendment to Planning Permission Ref: 2019/01880/VAR 1.0 Introduction 1.1 This Environmental Compliance Statement (‘ECS’) has been prepared by Lichfields on behalf of Fulham Stadium Limited (‘FSL’). It accompanies an application seeking non-material amendments (“the Proposal”) to planning permission 2019/01880/VAR for the new Riverside Stand scheme at Craven Cottage football stadium (“the Riverside Stand Development”). 1.2 The Proposal seeks to provide (i) minor adjustments to the hotel entrance on the north end of the building, (ii) an external staircase linking the southern health club terrace at Level 4 with the roof terrace at Level 5, (iii) a lightweight timber pergola at the hotel Level 4 terrace, and (iv) pergola-type modulated frames and repositioned bars at the Hammersmith and Putney end terraces at Level 5 and a horizonal louvred canopy and small bar in the central roof terrace area also at Level 5. 1.3 The Proposal has been discussed with the Planning and Design Officers from London Borough of Hammersmith and Fulham (‘LBHF’) as the designs have developed, most recently on 26 March 2021. Planning Officers have confirmed that they are satisfied the amendments sought are non-material and can be applied for under Section 96A of the Town and Country Planning Act 1990 (As amended). 1.4 As by definition the changes sought are non-material, the Proposal is unlikely to give rise to effects which would need to be addressed under the Environmental Impact Assessment (EIA) Regulations 2017 as amended. Accordingly, the environmental information submitted with the new Riverside Stand Development planning applications comprising the Environmental Statement (ES, November 2017) and Supplementary ESs (January 2018, February 2018 and June 2019) is adequate to assess the effects of the Proposal and no additional environmental information should be required. 1.5 To assist London Borough of Hammersmith and Fulham (“the Council”) in its assessment of the application, this ECS has been prepared to demonstrate the Proposal’s compliance with the ES and Supplementary ESs and that the conclusions on environmental impact remain relevant and do not require the submission of further information. There are no proposed changes to the construction methodology previously assessed so for the purpose of this ECS only the operational impacts of the Proposal are considered. The environmental topics reviewed below are consistent in scope and running order to the ES, and the ECS format is the same that has been used previously for non-material amendment (‘NMA’) applications for the Riverside Stand Development. 1.6 This statement should be read in conjunction with the covering letter to the application (dated 7 April 2021), the amended set of planning drawings prepared by Stuart Forbes Associates (Annex 1 of the application cover letter), and the Design and Access Statement Addendum (April 2021) accompanying the application. Pg 1/8 Lichfields.uk FFC RS NMA 7 ECS 07-04-21.docx 2.0 Water Resources and Flood Risk Environmental effects arising from the Riverside Stand Development 2.1 An assessment of potential effects during construction and operation related to tidal flood risk, encroachment into the River Thames, surface water drainage, contamination of surface water, water demand and pressure on the foul water sewer network was previously undertaken by WSP as part of the ES (Chapter D). The ES was informed by a Flood Risk Assessment (FRA) dated 22 November 2017 undertaken by WSP and a Hydrodynamic Assessment (March 2012) undertaken by HR Wallingford. A Supplementary ES was also submitted in January 2018 to account for some minor changes in the piling arrangement proposed within the River Thames (the Supplementary ES included an updated Hydrodynamic Assessment, December 2017). 2.2 As detailed within the FRA 2017, flood risk mitigation was proposed through a raised internal ground finished floor level and raised external riverside walkway concourse which were both set at 5.96m AODN. This proposed level is above the current day statutory flood defence crest level of 5.54m AODN, 2065-2100 statutory flood defence crest level of 5. 95m AODN, and above the modelled flood breach scenarios (FRA states 2100 breach scenario maximum flood depth of 5.829m AODN). In addition to the ‘in-built mitigation’ of a raised floor level, other mitigation proposed include the preparation and agreement of a Construction Environmental Management Plan (CEMP) and a Flood Warning and Evacuation Plan to manage impacts on the River Thames and the residual risk of a breach in the Tidal Thames Flood Defences respectively. 2.3 Following implementation of these mitigation measures, the ES concluded the Riverside Stand Development to have an overall permanent, direct, long term residual effect of negligible to minor adverse significance during operation of the Riverside Stand Development. Environmental effects of the Proposal 2.4 The Proposal would not affect the consented finished floor levels, access and egress routes into the Riverside Development or the overall vulnerability classification of the development. The overall maximum parameters of the building envelope will remain as approved. 2.5 The raised entrance threshold into the stadium is maintained at 5.96m (AODN) to ensure consistency with the flood mitigation provided in the approved scheme and assessed in the ES (November 2017). 2.6 Other mitigation in the form of adhering to the approved Construction Environmental Management Plan (CEMP, Rev 3, June 2019) and a Flood Warning and Evacuation Plan (to be agreed prior to occupation of the Riverside Stand Development) will also help to minimise the environmental effects. 2.7 Accordingly, the Proposal is not expected to give rise to any new significant environmental effects. The conclusions of the ES are therefore considered to remain valid. 3.0 Ecology and Nature Conservation Environmental effects arising from the Riverside Stand Development 3.1 An assessment of the ecology and nature conservation effects arising from the Riverside Stand Development, particularly regarding potential impacts on habitats and protected and notable species, was previously undertaken by WSP (Chapter E of the ES). Pg 2/8 Lichfields.uk FFC RS NMA 7 ECS 07-04-21.docx 3.2 The assessment concluded that the residual effects of the Riverside Stand Development in terms of the installation of the river wall and Riverside Stand infrastructure will result in no significant effects, and with the habitat enhancements, including a gain of soft-sediment inter-tidal habitat and new planted reedbeds, some beneficial effects will arise by increasing the availability of a soft interface between the structure and the River Thames. Greener landscaping and installation of planted areas in and around the Riverside Stand Development will also provide ecology benefits. Timber rubbing strakes to be provided on the walkway frontage also offer additional habitat. 3.3 Regarding lighting, tangible benefits were identified from match day light spill effects, brought about by the new directed integral lighting in the new Riverside Stand roof, and the removal of the two floodlight masts either side of the Riverside Stand; while an insignificant adverse effect was identified due to incidental light spill from the proposed glazed façade. Environmental effects of the Proposal 3.4 The Proposal is for minor design amendments to areas that form part of the new Riverside Stand building. This will mean the new building remains set back from the river and will not lead to additional significant impacts on river ecology. 3.5 Accordingly, the Proposed Development will not give rise to new significant environmental effects, with the conclusions of the ES remaining valid. 4.0 Heritage Environmental effects arising from the Riverside Stand Development 4.1 An assessment of the potential environmental effects of the Riverside Stand Development on above and below ground heritage assets was previously undertaken by Lichfields and Archaeology South-East (Chapter F of the ES). 4.2 The assessment established that the operational development will not affect the significance of any of the identified above-ground heritage assets except for the Grade II listed Johnny Haynes Stand and Craven Cottage where significance will be enhanced, and the locally listed Craven Steps, where there will be a negligible adverse effect on heritage significance. None of the operational effects were identified as significant in ES terms. 4.3 Regarding below-ground heritage assets, it was noted that the development will potentially result in the loss of in situ archaeological remains, and as such under the criteria of assessment the overall impact of the development will be adverse on buried assets. However, the magnitude of impact is moderated due to the implementation of an archaeological mitigation programme (see separate Written Scheme of Investigation, Revision 2, March 2019, approved by the Council pursuant to condition 35, App Ref: 2019/00472/DET), that will ensure a record of lost buried assets is made in line with current Greater London Archaeology Advisory Service (‘GLAAS’) guidelines and archaeological professional best practice. As such, the impact of Riverside Stand Development was considered to be of minor adverse magnitude. Environmental effects of the Proposal 4.4 The Proposal has the potential for both direct and indirect effects on above ground heritage assets due to its location within the boundary of the Fulham Reach Conservation Area and its proximity to other above ground heritage assets, the settings of which may be affected. Pg 3/8 Lichfields.uk FFC RS NMA 7 ECS 07-04-21.docx 4.5 The Proposal principally involves small-scale, discreet additions to the Hotel entrance at ground level and terraces at Levels 4 and 5. Overall, the Proposal therefore amounts to minor modifications to small, focussed parts of the external design of the Riverside Stand Development rather than constituting anything more fundamental.