BRIGHTON GASWORKS REMEDIATION UPDATE February 2021 Contents Introduction 3 Remediation at Brighton Gasworks History of Brighton 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 Portslade-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 Brighton Marina as one of Brighton and Hove’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