planning R dynamic development solutions TM Local Impact Report Edmonton EcoPark, Advent Way, London N18 3AG For and on behalf of London Borough of Enfield Council ref: 16/01082/DCO April 2016 1 Client: London Borough of Enfield TOWN AND COUNTRY PLANNING ACT 1990 Application by North London Waste Authority for an Order Granting Development Consent for the North London Heat and Power Project Local Impact Report The Edmonton EcoPark, Advent Way, London, N18 3AG Prepared by DLP Planning Ltd London April 2016 DLP reference: LEN5002P
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planning
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dynamic development solutions TM
Local Impact Report Edmonton EcoPark, Advent Way, London N18 3AG
For and on behalf of London Borough of Enfield Council ref: 16/01082/DCO
April 2016
1
Client: London Borough of Enfield
TOWN AND COUNTRY PLANNING ACT 1990
Application by North London Waste Authority for an Order Granting Development Consent for the North London Heat and Power Project
Local Impact Report
The Edmonton EcoPark, Advent Way, London, N18 3AG
Prepared by DLP Planning Ltd
London
April 2016 DLP reference: LEN5002P
planning
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dynamic development solutions TM
Local Impact Report Edmonton EcoPark, Advent Way, London N18 3AG
For and on behalf of London Borough of Enfield Council ref: 16/01082/DCO
April 2016
CONTENTS PAGE
1.0 EXECUTIVE SUMMARY 1
2.0 INTRODUCTION 2
3.0 SITE DESCRIPTION AND CONTEXT 3
4.0 THE PROPOSED DEVELOPMENT 5
5.0 POLICY CONTEXT 7
6.0 IMPACT ON THE LONDON BOROUGH OF ENFIELD 9
7.0 CONCLUSION 50
APPENDIX A: SUGGESTED CHANGES TO DRAFT DCO 52
APPENDIX B: SCHEDULE OF ISSUES WITH DRAFT DCO 53
APPENDIX C: SUMMARY OF CHANGES NEEDED 58
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Local Impact Report Edmonton EcoPark, Advent Way, London N18 3AG
For and on behalf of London Borough of Enfield Council ref: 16/01082/DCO
April 2016
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1.0 EXECUTIVE SUMMARY
1.1 This Local Impact Report has been prepared for the London Borough of Enfield in
accordance with section 60 of the Planning Act 2008 (as amended) which provides
that relevant local authorities can prepare a report giving details of the likely impact of
the proposed development on the authority’s area (or any part of that area). This
report supplements representations already made by the local authority on the
proposed development as part of the application by the North London Waste
Authority for a Development Consent Order to authorise the scheme.
1.2 The local authority is clear that it supports the principle of the development proposed
here. The local authority is one of the seven boroughs that are preparing the joint
North London Waste Plan, and therefore notes that the proposed development will
make a significant contribution to diverting residual waste away from landfill in line
with local, regional and national policy and in line with the waste hierarchy.
1.3 There are, however, a number of issues that the local authority has identified with the
proposed development that are set out in more detail in this report, and in response
to this a number of changes are suggested to the draft Development Consent Order
and supporting documents to overcome these issues.
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Local Impact Report Edmonton EcoPark, Advent Way, London N18 3AG
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2.0 INTRODUCTION
2.1 DLP Planning Ltd has been instructed by the London Borough of Enfield (the local
authority) to prepare a Local Impact Report (LIR) as part of the application for a
Development Consent Order (DCO) which has been submitted by the North London
Waste Authority (NLWA, the applicant), and has been accepted by the National
Infrastructure Directorate of the Planning Inspectorate. The local authority is the
local planning authority for the area in which the DCO is proposed; accordingly, the
local authority is a designated ‘interested party’.
2.2 This LIR has been prepared in accordance with section 60 of the Planning Act 2008
(as amended) which provides that relevant local authorities can prepare a report
giving details of the likely impact of the proposed development on the authority’s area
(or any part of that area).
2.3 To date the local authority has made two formal representations on the DCO
application which are the Relevant Representation on the 22nd December 2015 and
Written Representation on the 23rd March 2016. This LIR provides more detailed
information on the anticipated impacts within the London Borough of Enfield should
the proposed development go forward in its present form and how unsatisfactory
elements of the application can addressed.
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For and on behalf of London Borough of Enfield Council ref: 16/01082/DCO
April 2016
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3.0 SITE DESCRIPTION AND CONTEXT
3.1 The Edmonton EcoPark site covers to 22.2 hectares and is located wholly within the
Borough and comprises an existing waste management site. The site is located to
the north of the A406 North Circular Road in an area that is predominantly industrial.
The Lee Valley Regional Park (LVRP) is located to the east while land to the north
and west is predominantly industrial in nature. Immediately to the north of the
Edmonton EcoPark is an existing Materials Recycling Facility (MRF) which is
operated by a commercial waste management company, alongside other industrial
buildings. Further north is Deephams Sewage Treatment Works (STW).
3.2 Beyond the industrial area to the north-west is a residential area with Badma Close
being the nearest street, approximately 600m from the Edmonton EcoPark and 60m
from the nearest part of the site boundary (the northern access road – Ardra Road).
Zambezie Drive is the closest residential area to the boundary of the application site,
located approximately 310m north-west of the Edmonton EcoPark. Eley Industrial
Estate located to the west and comprises a mixture of retail units, industrial and
warehousing uses.
3.3 Advent Way is located to the south of the site adjacent to the A406 North Circular
Road (Angel Road). Further south of the A406 North Circular Road is an area that
contains a mix of retail, industrial and light manufacturing use, with some of which is
designated as a Strategic Industrial Location (SIL) and is known as Meridian Water.
A Masterplan document setting out the vision for the development of this area (The
Meridian Water Master Plan) was published by the local authority in July 2013. The
area also sits within the wider the Central Leeside area for which an Area Action Plan
(AAP) is being developed. Central Leeside is one of the most significant
regeneration opportunities in Enfield. It occupies a strategic position in the London
and wider Stansted corridor and lies in the London-Anglia Growth Partnership sub
region.
3.4 The LVRP and River Lee Navigation are immediately adjacent to the eastern
boundary of the Edmonton EcoPark, and the Lee Park Way, a private road which
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also forms National Cycle Route no. 1, runs alongside the Navigation. The LVRP is
located to the east of the River Lee Navigation where the William Girling Reservoir is
located along with an area currently occupied by Camden Aggregates which is used
for the crushing, screening and stockpiling of concrete, soil and other recyclable
materials. The nearest residential areas to the east of the Application Site and LVRP
are located at Lower Hall Lane (in the London Borough of Waltham Forest),
approximately 550m from the Edmonton EcoPark and 150m from the eastern edge of
the Application Site.
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4.0 THE PROPOSED DEVELOPMENT
4.1 The DCO application is seeking consent for an Energy Recovery Facility (ERF)
generating electricity using residual waste as a fuel and capable of an electrical
output of around 70 MW comprising:
two process lines, with each line having a capacity of 350ktpa, a moving
grate, furnace, boiler and a flue gas treatment plant and stack;
a steam turbine and generator set;
‘heat off-take’ equipment within the ERF which will generate an initial heat
supply through a connection to a separate heat network centre that will be
located on the site. This separate heat network centre is not part of the
Project and will be developed by the London Borough of Enfield. The
separate heat network will be designed to be capable of providing heat in the
region of 30 MW which will provide benefit to north and east London;
a waste bunker with two overhead cranes and capacity to hold a minimum
equivalent of 5 days of residual waste;
air or water cooled condenser(s);
a plant control and monitoring system;
an emergency diesel generator;
tipping hall and one way access ramp
4.2 The application also covers:
the decommissioning and demolition of the existing Edmonton EfW facility
(timed to take place following commissioning of new ERF and transition
period of up to a year – this time period is set out explicitly as a requirement
of the draft DCO in Schedule 2 Paragraph 22);
a Resource Recovery Facility (RRF) encompassing a Reuse and Recycling
Centre, transfer hall, and bulky waste / fuel preparation facility;
administrative buildings and visitor centre (EcoPark House);
new internal weighbridges, roads and parking areas;
hard and soft landscaping directly related to main building works
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refurbishment or replacement of the waste water treatment facility;
new site access points from the Lee Park Way and Deephams Farm Rd, in
each case subject to agreement on terms with the land owners, Lee Valley
Regional Park Authority and Thames Water;
works for the creation of a Temporary Laydown Area and its temporary use in
an area of open scrubland located to the east of the River Lee Navigation.
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5.0 POLICY CONTEXT
5.1 The national planning policies and policies of the Development Plan, as well as other
planning documents that are relevant to the proposed development and / or its
location are set out as follows:
National
• National Planning Policy Framework
• Planning Practice Guidance
• National Policy Statement for Renewable Energy Infrastructure
• National Planning Policy Statement for Energy
• National Planning Policy Statement for Waste
Regional
• London Plan (March 2016)
• Upper Lee Valley Opportunity Area Planning Framework (2013)
Enfield’s Local Plan
• The Enfield Plan: Core Strategy 2010-2025
• Central Leeside Proposed submission Area Action Plan (2014)
• Enfield Development Management Document (adopted 2014)
The local authority accepts that at some point in the future some form of
development, most likely related to waste management, may be proposed in this
location. However, the local authority does not consider that hardstanding is the
correct approach for what is a large expanse of area. Accordingly, it is the local
authority’s view that this element of the proposed development would result in
negative impact on the Borough, albeit in a modest localised geographical area. The
Design Code Principles document should be amended to overcome to this concern.
The emphasis is to break up the sheer expanse of the area while acknowledging the
need for efficient operations and the Design Code Principles should be updated to
reflect alternative landscaping and material options for the area of the former EfW
facility – this would include the reference to the area on page 35 of the document and
Indicative Drawing ref. D_0007).
6.111 A final detailed concern in relation to the visual assessment of the proposed
development, again reflecting comments that have previous been expressed at
different stages of the project, is the appropriateness of the observation platform to
be installed on the Tipping Hall.
6.112 In essence, it is the local authority’s view that this element of the scheme detracts
from the overall proposed development disrupting the setting down design approach
put forward for the main ERF building. The local authority welcomes this broad
principle, where the massing of the building is broken up and the elevations that face
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towards the Lee Valley (which as noted before lies within the Metropolitan Green
Belt) are stepped down from the larger element of the Process Hall to the smaller
Crane Hall and then the lowest element of the Tipping Hall – with the accent colour
on Crane Hall providing a contrast between Process Hall and Tipping Hall to further
break down the massing. The proposed observation platform, by contrast, goes
against this approach by appearing as a prominent feature sitting above the lower
element of the Tipping Hall and disrupts the view of the Crane Hall which, through its
massing and in particular the aesthetics of the facing materials, is the ‘focus element’
as set out in the submitted Design and Access Statement.
6.113 It is the local authority’s view that no particular need for this facility is provided and
although encouraging access to the facility as part of a wider community education
program is supported, this feature is not seen as key to this to outweigh the concern
regarding the impact on the appearance of the building and its relationship to the
wider area especially given the provision of EcoPark House which would also serve
as a visitor centre. Furthermore, it is not considered that the concerns of the LPA
could be overcome by careful selection of materials and the provision of signage to
this feature – as table in the Design Code Principles – would exacerbate its overall
impact and should be resisted.
6.114 In terms of the visual impact of the proposed development, whilst it is true to say that
on the whole the new buildings will be noticeably larger than the existing ones from a
number of short and long term views, the industrial context in which they sit would
not be materially different and therefore the perception of them would also not
significantly change. The local authority, therefore, accepts the results of the visual
assessment as set out in the ES Volume 3. However, the local authority does have
concerns regarding a number of detailed design matters associated with the
proposed development that must be addressed – these being ensuring the overall
design quality of the materials is high, and is not compromised by overriding costs
factors; the vacant space left once the EfW facility is decommission and demolished
and the need for this to be a high quality soft landscaped scheme in the interim rather
than subject to hard landscaping; and, finally, the visual impact of the proposed
observation platform where this is considered to detract from the overall design
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approach of stepping down the massing of the ERF building as it gets closer to the
boundary with the Green Belt-designated LVPR.
6.115 Therefore, until these matters are addressed, it is the local authority’s view that the
proposed development would have a negative effect with regards to the visual impact
of the scheme.
Other considerations
6.116 The submitted Deadline 2 Written Representations has already set out the local
authority’s views on the need for the proposed development to contribute to the
delivery of the Lee valley Heat Network (LVHN) but given the importance of this
matter it is set out again in full in this report. The Edmonton EcoPark SPD makes
clear that the development of this site is to provide the key heat source for the LVHN
and supply low carbon heat to local homes and business. This is a key strategic
policy, with policy DMD52 of the Development Management Document adding to this
by requiring certain types of major developments which provide heat and/ or energy
to contribute to the supply of decentralised energy networks. The Council’s evidence
base confirms that it is feasible to and viable for existing and future waste
development on the Edmonton EcoPark Site to provide heat to a decentralised
energy network. Given this context, the DCO proposals must explicitly address this
policy requirement by including a firm commitment to providing a heat supply to the
Lee Valley Heat Network and making adequate provision for associated
infrastructure within the site. The Edmonton Eco Park SPD and Central Leeside
Proposed Submission AAP (CLAAP) provide more specific requirements in this
regard.
6.117 It is noted that a CHP Strategy has been prepared to demonstrate the opportunity for
CHP. This opportunity is also confirmed by the Council’s own evidence which
concluded that it is feasible to and viable for existing and future waste development
on the Edmonton EcoPark Site to provide heat to a decentralised energy network.
The detailed design of the Energy Recovery Facility, specifically the arrangements
for how/when the heat off take occurs, should ensure that it does not prevent this
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identified opportunity while also ensuring the supply of energy for a decentralised
energy network is as efficient as possible and is not made less viable which could
prejudice its benefits to the wider area. The submitted DCO proposal must include a
firm commitment to supplying heat to a decentralised network in order to satisfy
national, regional and local planning policies. While it is noted that the draft DCO
contains a requirement for the provision of a CHP, the exact wording of the
requirement is not agreed at this stage and dialogue is ongoing. In particular the
LPA object to the caveat of ‘commercial arrangement’ and a reference to ‘economic
viability’. Commercial arrangements are beyond the scope of the DCO and should
not be featured as part of the requirement. Further economic viability is not defined
nor is it stated who would verify the viability of connection. The processes involved in
CHP operation inevitably provide waste heat and as such the provision of such heat
is guaranteed and whilst the heat output and associated infrastructure for the CHP
needs to be secured via the DCO and Section 106 Agreement, the detailed
contractual arrangements between the commercial operator and the applicant is not
relevant to the DCO nor is relevant to any subsequent Section 106 Agreement. Any
reference to such contractual arrangements should be removed, and until such time
as this occurs it is the local authority’s view that the failure of the scheme to commit
to providing heat to the LVHN has a negative impact on the Borough in terms of the
potential for the strategic project to not be delivered. Appendix A sets out the local
authority’s suggested change to this part of the DCO.
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7.0 CONCLUSION
7.1 In terms of the principle of the development, the local authority has already made
clear its view that it supports the proposed development at a strategic level and
considers that it is broad accordance with the Development Plan as this supports the
continued use of Edmonton EcoPark as a strategic waste site, and maximising its
use with more sustainable and efficient waste management processes.
7.2 In strategic terms it is the local authority’s view that the majority of the potential
effects identified as part of the Environmental Statement assessment would, subject
to suitable controls and mitigation set out in the various application documents (and
in particular the Code of Construction Practice), have a neutral impact on the
Borough.
7.3 There are a number of impacts that would arise that are identified as having a
negative impact on the Borough. These are (in no particular order):
- Minor impact on the Linnett protected bird species through loss of habitat;
- Loss of a number of jobs associated with the operation of the existing Energy
from Waste facility and a net reduction in overall jobs needed for the
operation of the new Energy Recovery Facility;
- There is a need to agree an employment and training strategy consistent with
the principles of the Section 106 SPD (and emerging SPD)
- Lack of an appropriate strategy for the Temporary Laydown Area in terms of
its restoration following the completion of the project, with particular regards
to the lack of an appropriate Sustainable Urban Drainage Scheme and
potential flood compensation measures for the Meridian Water regeneration
development;
- Lack of agreement of SuDS Strategy including drainage and run-off rate
- Visual impacts in terms of the design of the proposed development, with
particular regard to the proposed hardsurfacing treatment of the vacant space
following the demolition of the existing Energy from Waste facility, and
concerns regarding the impact of the proposed observation platform on top of
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the Tipping Hall where this disrupts the visual pattern of the dropping down in
height and massing of the other two elements of the Energy Recovery Facility
(the Processing Hall and the Crane Hall)
- Need for an unqualified commitment to the use of high quality materials with
no overriding caveat that the decisions on this are driven by costs at the
expense of other factors.
7.4 The local authority accepts that the impacts identified are, on the whole, modest, but
respectfully requests that there are changes to the draft DCO to overcome these.
The changes requested are:
- Removal of the proposed observation platform from the draft DCO;
- Revisions to the Design Codes Principles to amend references to the
hardsurfacing of the area of the existing Energy from Waste facility following
its demolition;
- Revisions to the Design Codes Principles to secure an explicit commitment to
high quality materials, and the installation of PV or heat generating panels;
- Revised and additional wording is proposed to the draft DCO in Appendix A to
address the issue of the Temporary Laydown Area.
7.5 With respect to the concerns expressed regarding the use of the wording
‘commercial arrangement’ and a reference to ‘economic viability’ in connection with
the connectivity to the Lee Valley Heat Network, Appendix A sets out the local
authority’s suggested changes to the draft DCO to overcome this
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APPENDIX A: SUGGESTED CHANGES TO DRAFT DCO
1. Schedule 1, paragraph 2(e)(x) be amended to read as follows:
“restoration of the temporary laydown area to include suitable landscaping,
Sustainable Urban Drainage Scheme and compensatory flood storage.”
2. Schedule 2, paragraph 19, removal of the following text from this requirement:
“…should a commercial arrangement be identified for combined heat and power
which is economically viable.”
3. Schedule 2, additional paragraph:
Temporary Laydown Area
“23. — (1) The restoration of the Temporary Laydown Area shall be in accordance
with a scheme submitted to and approved by the relevant planning authority. No
works of this stage of the development shall take place prior to the approval of the
scheme.
(2) The scheme referred to paragraph (1) shall include details of the following—
(a) suitable soft landscaping;
(b) a Sustainable Urban Drainage Scheme;
(c) compensatory flood storage.
(3) The relevant stage must be carried out in accordance with the details approved
pursuant to requirement 23(1)
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APPENDIX B: SCHEDULE OF ISSUES WITH DRAFT DCO
Reference Issue
Definitions
“authorised development”
Definition too wide – if an item does not constitute development, then the process under section 35 – 35A must be followed for a direction from the SoS. Not aware that the process has been followed here. If, alternatively, “not” has been included in error then please remove.
Definitions “carriageway”
Should reference section 329 of the 1980 Act.
Definitions
“code of construction practice”`
The LPA support the inclusion of this definition consistent with the comments of TfL at the issue specific hearing.
Definitions
“commissioning”
The LPA would agree with the comments by the Examining Authority. The definition of commissioning must be clearly defined and should not be based on a reliability test – however this test may be defined.
Definitions “commence”
Definition too wide. The LPA contend that the definition should not include “site clearance” given the scale of clearance required. Any definition must be consistent and used within the draft s106
Definitions
“design code principles”
Words after “which” not required.
Definitions
“environmental commitments and mitigation schedule”
Words after “which” not required.
Definition “maintain”
Definition too wide. Anything but very minor adjustment, alteration, removal, clearance and refurbishment is inappropriate. Reconstruction, decommissioning, demolition, replacement and improvement are far too wide and should be removed. Note that the Hinkley C DCO refers only to “maintain”.
Definition “order land”
Should this not refer to ‘book of plans’ not ‘book of references’. Is the definition of ‘Order Land’ and ‘Order Limits’ appropriately linked to the wide ranging powers conferred under subsequent articles?
Definition “relevant planning
Definition can end after Enfield
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authority”
Definition “stage” Should not include “enabling works”. “Enabling works” are only referred to in the schedule 2 definition, and here, and so effectively this is a carve out from approval by the LBE. Not clear why such enabling works as are required cannot form a defined “stage” in and of themselves.
Definition “undertaker”
Need only to name undertaker, other text not necessary – article 8 and section 156(1) achieves the same thing
Article 4(2)(b) Normal position is to specify depth in metres below the seabed. Issues relating to ground water contamination must be addressed. Upward limits of deviation are not agreed as per paragraph 8.11 of LBE written representations.
Article 5 Article 5(1) is a general provision. Why is there then a need to specify within article 5(2). If specification is necessary need to define “apparatus” – possibly could use definition in article 10(4). Why are the items in article 5(3) excluded?
Article 6(1) Article 8 would cover the circumstance of a contractor operating the plant, so wording associated with that is not needed here (bar the exclusion in article 8(4) which the LBE are proposing is removed).
Definitions are required here – potential to use the already defined term “authorised development”.
Article 8(4) This exclusion is entirely inappropriate. A wholly owned company ought to be subject to the same requirements of approval in order that the SoS can verify that the entity is an appropriate one to operate the facility.
Article 9(b)(ii) This sub clause is not needed if the requirements set out in 9(b)(i) are complied with.
Article 10(1)(e) & (f)
Support deletion of (e) and (f)
Article 12(5) Insert ‘highway’. Any public right of ways will need to be replaced and there is insufficient detail to confirm replacement rights of way are acceptable. Objections to all plots / items in this section relating to Schedule 6.
Article 13 and (6) Removal of the highway status may not be the most appropriate course of action therefore objections to the legal process. (6) This is not standard drafting and should be removed.
Article 18(4)(b) Remove “shall not be unreasonably withheld or delayed”.
Article 19 For certainty, this article should refer explicitly to schedule 10. Also unclear why it is subject to articles 23 and 27
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Article 20 The time scale should be the normal 5 years. There is no reason that we can see why it should be extended to 7 years.
Article 21 Wording relating to successor not required given the provisions in article 8.
Article 22 Not needed due to provisions of section 152 and 158 of the Act.
Article 23 Not clear how this ties in with article 21(1)(b) and schedule 12.
Article 24 Is this needed in light of articles 19 and 21?
Not clear how this ties in with article 21(1)(b) and schedule 12.
Article 24(5) Missing some words at the end – suggest include “applies”.
Article 27 Relationship with article 20(2) unclear
The end of sub-paragraph (4) and (5) are duplicated.
The requirement for restoration in sub-paragraph (4) should also be subject to the consent of LBE. Sub-paragraph (3) – two years are not justified.
Article 28 Sub-paragraph (3) should require 28 days notice (as referenced in sub-paragraph 13)
Article 32(3) This article should be removed.
Article 37 The decommissioning of the energy from waste facility should be carried out under requirement 20, and the decommissioning of the proposed electricity and heat generating station in accordance with requirement 21, but it is not clear why this article is required.
Article 38 This article is unnecessary. Instead the provisions of sections 78 and 79 of the TCPA 1990 should be imported.
If the article and schedule 3 are to be accepted, sub-paragraph (3) is not appropriate. Deemed consent is not utilised anywhere within the statutory regime and is not required in this instance.
Schedule 1 Article 3
The judgement of whether a change is material must be with the Local Planning Authority and should feature as a requirement
Schedule 2
Definition
“enabling works”
Definition is too wide. Should not include demolition.
In any event, the definition is used only in the definition of “stage” and effectively therefore operates as a carve out for a vague list of matters which ought properly to form a stage in themselves.
Schedule 2
Article 3
Requirement 3 be amended to incorporate the installation of photovoltaic (or heat generating) panels as per paragraph 4.9 of written
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representations.
Schedule 2
Article 3(3)
Wording “unless otherwise approved by the relevant planning authority” ot required
Schedule 2
Article 4
Limits of deviation are too wide. See comments in relation to article 4(2)(b) above.
Lists of works in column 1 do not tally with listed works in schedule 1
Further comments as per paragraph 8.11 of written representations
Schedule 2
Article 6
There should be a limit on the tonnage of waste to be managed/treated at the authorised development.
Schedule 2 Article 9
Confirmation of certification against BREEAM required. Relevant BREEAM Version year / number required.
Schedule 2
Article 10
Sub-paragraphs (e) and (f) are properly design issues and should be included in schedule 2, article 3.
Wording “unless otherwise approved by the relevant planning authority” not required
Cross-reference to environmental commitments and mitigation schedule and Design Code Principles required as per written representations required
Schedule 2
Article 11
Remove “reasonable”. Goes without saying that the opinion will be reasonably held.
Schedule 2
Article 12
“Access management scheme” requires definition.
Schedule 2
Article 13
In sub-paragraph (2) to drainage scheme must be constricted before the commissioning of the electricity and heat generating scheme.
Schedule 2
Article 14
The LPA would express concern that requirement 14 does not include relevant clauses for the verification and ongoing monitoring of remediation works. The LPA request that such measurements be included within the requirement.
Schedule 2
Article 15
Should be amended to “Commissioning of the electricity and heat generating…”
Cross-reference to environmental commitments and mitigation schedule and Design Code Principles required as per written representations required
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Schedule 2
Article 16
The LPA would express concern that requirement 16 does not include relevant clauses for a mechanism to amend and review the CoCP. The LPA request that such measurements be included within the requirement to be agreed with LBE in consultation with TfL.
Schedule 2
Article 17
Should be amended to “Commissioning of the electricity and heat generating…”
Schedule 2
Article 19
Should end after “its later connection to such systems”. Whether or not a commercial arrangement is available should not impact on whether the development has the ability to operate as described. This is particularly so where an agreement may not be reached before the issue of a DCO.
Also insufficiently precise as to location and provision of pipes.
Schedule 3 Not required. See comments at article 38 above.
In particular the fees cited are unacceptable and are not consistent with government direction for determination of fees.
Schedule 5 - Concerns over repositioning of the cycle ways and footways (plots 14, 15, 21, 22, 32)
- Work to Advent way access acceptable (plot 31)
- Works to Ardra Road acceptable (plot 34)
- Works to Lee Park Way acceptable (plot 28 and 29)
- Work to Deephams Farm Road not referenced with a plot. Objection.
Schedule 6 Any public right of ways will need to be replaced and there is insufficient detail to confirm replacement rights of way are acceptable. Objections to all plots / items in this section.
Schedule 7 As with Schedule 6 insufficient info on the replacement public rights of way. Objections to all plots / items in this section.
Schedule 8 Stopping up cannot be supported. Removal of the highway status may not be the most appropriate course of action therefore objections to the legal process
APPENDIX C: SUMMARY OF CHANGES NEEDED
Limits of Deviation Plans:
planning
R
dynamic development solutions TM
Local Impact Report Edmonton EcoPark, Advent Way, London N18 3AG
For and on behalf of London Borough of Enfield Council ref: 16/01082/DCO
April 2016
59
- requires maximum downwards depth for excavation to be defined and if
necessary piling separately defined.
- Wider limits of deviation for works 1b need to be defined or additional
requirement for detail of structures
SuDS Strategy (and if necessary FRA) – Updated to reflect discussions and concerns of
Council. The LPA would invite continued dialogue
Design Code Principles – amended to reflect LPA requirements for high quality materials,
alternative surfacing options to the former Energy from Waste site and Requirement 3 to be
amended to reflect installation of photovoltaic or heat generating panels to the ERF, RRF
and Ecopark House
Employment and Training Strategy – needs to be agreed with the local authority via Section
106 Agreement
Highway Mitigation measures – needs to be agreed with the local authority via Section 106