Phase 1 Consultation Feedback Report

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Deephams STW Upgrade ECIP1 Phase 1 Consultation Feedback Report V2.0 - FINAL

Deephams Sewage Works Upgrade

Phase 1 Consultation Feedback Report


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Table of contents

Executive Summary 4

1. Introduction 5

2. Phase 1 consultation process 6

3. Overview of phase 1 consultation responses 10

4. Analysis of community responses 11

4.1 The need for the upgrade 11

4.2 Site selection 13

4.3 Treatment option selection 21

4.4 Odour 22

4.5 Design and build 24

4.6 Other comments 28

5 Analysis of technical and statutory consultee responses 29


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EXECUTIVE SUMMARY

The Deephams Sewage Works, located in Enfield in north-east London, is the ninth largestsewage works in England. It treats sewage collected from within its catchment anddischarges treated effluent into the Salmons Brook, a tributary of the River Lee, in

accordance with a discharge consent set by the Environment Agency.

The Environment Agency has issued a new discharge consent that requires us to makeimprovements to the quality of the discharged effluent. The Deephams Sewage Works

Upgrade (the upgrade) will improve the quality of effluent (treated wastewater) dischargedfrom the Deephams Sewage Works into the Salmons Brook. It will also accommodatepopulation growth within the existing sewerage catchment to at least 2031, and improve theinfrastructure at the sewage works, much of which is now over 50 years old.

Having assessed various options for delivering the upgrade, we held a Phase 1 publicconsultation exercise. During phase 1, we consulted on the need for the proposed upgrade,

the sites where we could potentially build the upgrade works, the range of potential sewagetreatment options we are considering for the upgrade, and initial proposals for itsdevelopment. It is important to remember that under all site options the inlet works, stormtanks and sludge treatment plant remain on the existing site.

We consulted with stakeholders, local residents and community groups, and other

organisations through a combination of publication and distribution of information, use of thewebsite and targeted meetings and briefings. We distributed 37,000 leaflets/postcards toover 19,000 local properties, organised or attended 11 events, exhibitions and roadshowsand directly engaged with 725 members of the community in addition to stakeholder

organisations


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1 Introduction

Deephams Sewage Works

1.1 The Deephams Sewage Works, located in Enfield in north-east London, is the ninthlargest sewage works in England. It treats sewage collected from within its

catchment and discharges treated effluent into the Salmons Brook, a tributary of theRiver Lee, in accordance with a discharge consent set by the Environment Agency.

The upgrade project

1.2 The Environment Agency has issued a new discharge consent that requires us to

make improvements to the quality of the discharged effluent. The DeephamsSewage Works Upgrade (the upgrade) will improve the quality of effluent (treated

wastewater) discharged from the Deephams Sewage Works into the SalmonsBrook. It will also accommodate population growth within the existing sewerage

catchment to at least 2031, and improve infrastructure at the sewage works, much ofwhich is now over 50 years old.

1.3 This is a complex project, as the upgrade has to be delivered whilst the existing

sewage works remains operational and continues to treat the sewage to the existingconsent levels. This requirement to remain operational throughout the upgradeplaces significant engineering constraints on our potential upgrade options. Wetherefore considered the use of a number of treatment technology options to deliver

the upgrade both on the existing site, and on a new site, within these engineeringconstraints.


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the upgrade on the preferred site, including the proposed construction programmeand measures to mitigate any adverse impacts that may arise both during its

construction and operation.

1.9 This report provides an overview of the phase 1 consultation process, the commentsthat have been received, and our response to those comments.

2 Phase 1 consultation process

Our approach to consultation

2.1 Prior to our phase 1 consultation, we engaged with local authorities, technical and

statutory consultees at a series of four Stakeholder Forum meetings. These Forummeetings enabled us to present our proposed approach to the project to the

stakeholders and to gain feedback. This included presentations on how to secureearly engagement in the development of our proposals, and our proposed

consultation strategy.

2.2 Relevant local authorities and technical consultees were then formally consulted onour proposed consultation strategy. We formalised our strategy for consulting the

local community in a Statement of Community Consultation, which was published inlocal newspapers (the Enfield Independent, Haringey Independent and WalthamForest Guardian) and on the Deephams consultation website(www.deephamsconsultation.co.uk) on 4 July 2012. The Statement of CommunityConsultation forms part of a wider Consultation Strategy for the Deephams SewageWorks Upgrade, which sets out our approach to consulting all those with an interest

in the upgrade including customers key stakeholder and statutory consultees


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Community consultees, including members of the public, local property

owners/occupiers, local businesses, community representatives and groups,including hard-to-reach or seldom heard groups.

Technical consultees, including local authorities, other statutory consultees,utilities, and pan-north London and pan-London strategic stakeholders. A list is

provided in Appendix 1.

Landowners including property owners and lessees of the shortlisted sites, andoccupiers of properties within the consultation zone around the preferred siteand shortlisted sites. This consultation zone was defined as within 250m fromthe boundary of each shortlisted site and within 1km from the boundary of the

preferred site.

How we consulted

2.8 We consulted with stakeholders and interested parties through the following means:

We sent out over 19,000 letters, leaflets and postcards to properties locatedwithin 250 metres from the boundary of each shortlisted site and within 1 kmfrom the boundary of the preferred site. The leaflets briefly described our

proposals and gave details of the exhibitions. We set up a dedicated website with information on the Deephams Sewage

Works Upgrade (www.deephamsconsultation.co.uk).

We placed adverts in local newspapers (Enfield Independent, HaringeyIndependent and Waltham Forest Guardian).

Posters were displayed and leaflets made available at public buildings such aslibraries, council offices and transport hubs in the local area to promote the

consultation events and give information on the proposed upgrade.


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Edmonton, N9 0PZ

Tuesday 17 July 12pm to 8pm Dugdale Centre, Enfield Town, 39 LondonRoad, Enfield, EN2 6DS

15

Wednesday 18July

12pm to 8pm Edmonton Green Library, 36-44 South Mall,Edmonton, N9 0TN

8

Thursday 19 July 12pm to 8pm Angel Community Centre, Raynham Road,Edmonton, London, N18 2JF

3

Friday 20 July 12pm to 8pm South Chingford Library, 265 ChingfordMount Road, Chingford, E4 8LP

8

2.12 Following the initial round of exhibitions, a further round of consultation roadshowswere organised from 22 September 2012 to give people the opportunity to find out

more about our proposals.

Table 2.2: Phase 1 Consultation Consultation road show Venues

Date Time Venue PublicContacts

Saturday 22September

10am to5.30pm

Edmonton Green Shopping Centre, SouthMall, Enfield, London, N9 0TZ

216

Monday 24September

7am to 11am

4pm to 6pm

Tottenham Hale Train Station, Ferry Lane,Tottenham, London, N17 9LR

172

Tuesday 25September

9am to5.30pm

Palace Gardens Shopping Centre, Enfield,EN2 6SN

102


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2.15 Through a combination of publication and distribution of information, use of the

website and targeted meetings and briefings, we believe that the phase 1

consultation has increased awareness and understanding of the Deephams SewageWorks Upgrade within potentially affected communities. Over 19,000 properties

received information on the upgrade, and we made contact with over 700 people atthe exhibitions and roadshow events that we held.

3 Overview of phase 1 consultation responses

Process for handling responses

3.1 Consultation feedback was able to be submitted by paper or electronic feedbackforms, letter and email. A copy of the Feedback Form is enclosed at Appendix B.

3.2 All responses submitted via the Deephams consultation website and via paper

feedback forms were collated and stored securely by an independent websiteprovider Delib Ltd before being passed to us for analysis at the end of theconsultation period. All responses submitted via letter or email were centrally

collated by our Customer Service department. An acknowledgement of receipt ofcomments was sent back to each respondent.

3.3 We provided our planning consultants (Adams Hendry) with a copy of theconsultation responses, who then checked and analysed the responses.

Consultation responses were summarised to enable comments to be groupedaccording to the topic or issue raised. An important part of this process was to

ensure that specific individual areas of concern were not lost through the

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London Borough of Haringey (x 3)

London Borough of Waltham Forest

Natural England

North London Waste Authority

Thames 21

3.5 In considering the feedback received, we identified the issues raised by each

respondent. Where an issue was raised by more than one respondent, thesecomments have been grouped together and we have provided a single response to

that issue.

3.6 Consultation responses from statutory consultees tended to have more detailedinformation and comments than those made by members of the community. As a

result, we have separately analysed and responded to the issues raised incommunity responses in Section 4 of this report (and in Appendix 3), and technical

and statutory consultee responses in Section 5 of this report.

4 Analysis of community responses

4.0.1 An anonymised summary of these comments with Thames Water responses isincluded within Appendix 2.

4.1 The need for the upgrade

Question 1: Do you agree with the need to improve the river water quality ofthe Salmons Brook and River Lee?


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Summary of main comments in community responsesSupportive

27 (79%)

Concerns expressed for the current poor water quality of Salmons Brookand River Lee, highlighting problems caused by misconnected sewers

Support expressed on the need for the upgrade to deliver improvements

to water quality

Concern at the general filth, dirt and littering along the River Lee

Comment made that the upgrade is for increasing capacity rather than

improving water quality. The quality of life of nearby residents is

considered to be just as important.No viewsexpressed

7 (21%)

4.1.2 The need for the sewage works upgrade as described in the phase 1 consultationmaterial is to:

Improve water quality within Salmons Brook and the River Lee and comply with

Regulations and Directives. Provide sufficient treatment capacity to meet growth within the area served by

the sewage works and to respond and adapt to the challenges of climatechange.

Improve treatment facilities that are becoming old and worn out.

4.1.3 Respondents to the consultation recognised and supported the need for theupgrade, specifically supporting the planned improvement in water quality and

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4.1.7 In conclusion, we welcome the support for the need for the upgrade expressed in

the consultation responses.

4.2 Site selection

Question 2: We think that upgrading the sewage treatment processes on the

existing Deephams Sewage Works site is the best way to meet the need? Doyou agree?

4.2.1 The summary of responses shows that a significant majority of community and

technical respondents who responded to this question agree that upgrading thesewage works on the existing site is the best way to meet the need, although it isclear that there are strongly held views both in favour and against the preferred site.

Figure 4.2: Question 2 feedback results


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It needs to be moved out of London so no one has to live with the odour

It is not clear why the other options are not viable. Need evidence to makethe decision making process more clear

The planned Deephams upgrade is only part of solution, natural drainage

systems also need to be introduced to reduce flow

Concerned about a concentration of noxious substances in the area

For the last 10 years Deephams has been emitting toxic pollution despitesupposedly being capped and despite numerous letters from Andy Love

MP

No viewsexpressed

5 (15%)

Can only trust that experts will choose the best site provided that it doesnot make the stink worse and it eliminates it completely

4.2.2 Those respondents supporting the upgrade of the existing Deephams SewageWorks site highlighted that using an existing site for the upgrade was moreappropriate than developing a new site elsewhere. There was also an acceptance ofthe need to modernise the sewage works and the need to progress with the project

to deliver the required improvements.

4.2.3 One respondent who supported the upgrade of the existing site suggested thatSustainable Drainage Systems (SuDS) also needed to be developed alongside the

upgrade. We have considered the potential contribution of SuDS as part of ourassessment of strategic options, published as part of the phase one consultation.

Our conclusion was that, while there may be localised SuDS solutions available,particularly in conjunction with new residential or other developments, SuDS on itsown would not meet the need for the upgrade. It may provide limited reduction in the

fl t th k d i t t h it ld t lt i d ti i


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to maintain the operation of the sewage works throughout the upgrade requires thefirst phase of construction works to take place away from the three existing

treatment streams, which need to remain in operation until a new stream is broughtinto use. This is expected to result in a need for the first phase of development to

take place on the northern part of the site close to Picketts Lock Lane and Lee ParkWay, as this is the part of the site that has limited areas of undeveloped land, andredundant digestor tanks within it.

4.2.7 Some respondents to the phase 1 consultation commented that the upgrade shouldbe moved to a greenfield site, or a location out of London, away from any residents.

We have given very careful consideration to alternative locations for the upgrade.Our phase 1 technical work considered 22 potential sites for the delivery of theupgrade, including the Deephams Sewage Works site. Our assessment work

concluded that the development of the existing sewage works site was the mostappropriate of all of the potential locations identified.

4.2.8 Deephams Sewage Works is located within a relatively densely developed area ofnorth-east London. Where sites are currently clear of development, it is typically the

case that they are either areas of open space and/or Green Belt or MetropolitanOpen Land. These areas are protected from developments such as sewage worksby restrictive planning policies that would not allow planning permission to begranted for the upgrade, other than in exceptional circumstances. We havepublished details of our assessment of the potential locations for the upgrade as part

of the phase 1 consultation process. This assessment provides clear evidence tosupport the identification of the Deephams Sewage Works site as the preferred site

for the upgrade.


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Concerned

5 (15%)

There is no room for expansion and a danger of polluting the reservoirs

Using the current site is a monetary decision at the expense of publichealth which is much further down the list of priorities

It should be moved away from London due to the smell which is

unbearable to live next to

Using redundant industrial land would be a better option

Consider going to another part of London further along the River Lee

No viewsexpressed

5 (15%)

4.2.15 A number of the comments made in response to this question raise similar issues to

the responses to question 2, addressed above. Those supporting the use of theDeephams Sewage Works site identified that this would be the least disruptive

option, would make good use of the existing space and be more cost effective thanother options.

4.2.16 Those opposed to the use of the site commented that the site is too close to existinghouses and causes an odour problem. Concerns were expressed at the lack ofspace for the upgrade on the existing site. Respondents suggested that the sewage

works should be relocated, either to industrial land, to another part of London alongthe River Lee, or away from London altogether. Our approach to site selection, andour assessment of the 22 potential locations identified for the upgrade, was fullyexplained in our phase 1 consultation material that we published. Potential sites

were identified and assessed against a range of environmental, planning,engineering, and property and legal factors. Our assessment included a number of


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the Salmons Brook, downstream and to the south of the reservoirs, and so notreated effluent from the site could enter the reservoirs.

4.2.20 Some respondents highlighted their concern that the decision to select Deephams

Sewage Works as the preferred site for the upgrade was a monetary decision, andthat this outweighed other factors such as impacts on health. The upgrade will notlead to impacts on health, and this issue is not in any event connected to thefinancial cost of the upgrade. Financial cost is a factor that we used in our

assessment of the potential sites as it is ultimately our customers who will pay forthe upgrade through their water bills. However, financial costs were given the same

level of priority as the many other planning, environmental, engineering andlegal/property factors considered in the decision to choose Deephams SewageWorks as our preferred site for the upgrade. In fact, options to deliver the upgrade at

Deephams may be more expensive than development on a new site elsewhere. Thisis because redeveloping and upgrading the site is technically challenging, as theexisting works must continue to function throughout construction works. There isonly limited space available on the site currently, meaning that an upgrade wouldhave to be built in a series of phases over a number of years. This phased approach

is also necessary to ensure that we continue to meet the current discharge consentrequirements throughout the construction of the upgrade. A multi-phasedredevelopment is also more costly to build than a single phased build on anundeveloped site.

4.2.21 In conclusion on this question, while concerns have been expressed by respondentsopposed to the use of the existing Deephams Sewage Works site, we consider that

our site assessment work to date is robust and that there is no justification for

h i f d it f th d Th i ti it i th b t


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make better use of redundant land. There

are no great employment opportunities left

with the old derelict factories left in thisarea. The difficulties of trying to upgrade

and operate at the same time would beavoided, and also the cost implicationswould be lessened as the works could becarried out in a shorter time

No views expressed 29 (85%)

4.2.22 The majority of respondents (85 per cent) did not respond to this question. However,two respondents are of the opinion that Meridian Business Park should be used forthe upgrade, two supported the use of the Lee Valley Leisure Complex Golf Course,one considered that Tottenham Marshes had potential, one supported BrimsdownIndustrial Estate, and a further individual suggested either Montagu or Eley Industrial

Estates.

4.2.23 The following paragraphs briefly explain the reasons why Brimsdown IndustrialEstate (Jeffreys Road), Meridian Business Park, Lee Valley Leisure Complex GolfCourse (southern part) site and other shortlisted and longlisted sites are not as

suitable as our preferred site for the upgrade.

Brimsdown Industrial Estate (Jeffreys Road)

4.2.24 This site is a designated Strategic Industrial Land and its redevelopment would havean adverse impact on employment opportunities. The site is assessed as having

complex land acquisition issues due to the number of land interests and land

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the current works are the screening, primary treatment and sludge treatment stagesof the sewage treatment process. Although much of the infrastructure on the site

dates back to the 1950s and 1960s, it has been subject to improvements and we arecommitted to continue improving the site. Most recently, in summer 2012 we

completed a construction project to improve the inlet works and storm tanks on theDeephams Sewage Works site, the part of the treatment process where the sewagefirst arrives at the site. This will reduce the levels of odour produced by that part ofthe existing sewage works. The proposed Deephams upgrade is the next stage of

this improvement process.

4.4.3 We will design the sewage works upgrade to reduce the current odour levels. This islikely to include introducing measures to control odour at the most odourous parts ofthe sewage works. As part of the upgrade proposals we consulted on in our phase 1

consultation, we set out measures to manage and control the odour produced by theprimary treatment stage of the sewage treatment process. This may involve coveringthe large settlement tanks used at this stage, or putting this part of the processinside a large building and treating the gases produced before releasing them higherabove the sewage works.

4.4.4 We also set out measures to cover part of the sludge treatment stage of the sewagetreatment process (the secondary digestors) which will further reduce the amount ofodour produced by the sewage works. We believe that these measures will providea significant reduction in odour, compared to existing levels. We will develop our

proposals in more detail as the design of the upgrade progresses. This work tomanage and control odour produced by the upgraded sewage works will be subject

to approval of the necessary funding by Ofwat (The Water Services Regulation

)


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accompany our planning application. The Odour Management Plan will be in linewith others which we have recently prepared for other Tideway Sewage Works and

will be in accordance with guidelines set out in the Defra Code of Practice on OdourNuisance from Sewage Treatment Works published in 2006. The updated Odour

Management Plan will review impacts and required actions under abnormal andemergency conditions (such as flood), as well as normal baseline operation andmitigation measures.

4.4.9 Any odour emitted from the Deephams Sewage Works is subject to monitoring byEnvironmental Health Officers from the London Borough of Enfield and London

Borough of Waltham Forest who assess and investigate complaints.

4.5 Design and build

Question 7 What are the most important matters for you that we should thinkabout when designing the upgrade?

4.5.1 In response to question 7, a range of issues were raised through the consultation

exercise with odour being the major concern. These have been set out in the tablebelow.

Table 4.7: Question 7 feedback results

Total number ofresponses (% oftotal responses)

Summary of main comments in communityresponses


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effects the upgrade may have on a wide range of environmental areas, including airquality, transport, archaeology, ecology, noise and odour.

4.5.4 Understanding the possible environmental impacts will allow us to change the

design of the upgrade, wherever possible, to avoid negative effects. If there are anynegative effects that cannot be avoided, we will work out where and when we needto do things differently to reduce these effects. The findings of the EIA will be set outwithin a report called an Environmental Statement. This will be submitted with the

planning application for permission to build the upgrade.

4.5.5 Odour is clearly a major concern that the respondents want us to think about whendesigning the upgrade. See Section 4.4 above for our detailed response on odour.

4.5.6 Storm overflows can be an issue when there has been heavy rainfall. Improvementshave been made to storm capacity at Deephams by a separate project, which hastaken place throughout 2012. This has improved the capacity of the inlet works(where sewage enters the works), improved the eight existing storm tanks as well asbuilding two new storm tanks each of 5600m3 capacity. This will substantially

improve the capacity of the works to handle storm overflows. One of the main aimsof the proposed upgrade on which we have been consulting, is to improve thequality of effluent entering the Salmons Brook and then the River Lee. TheEnvironment Agency has issued a new discharge permit that requires us to makeimprovements to the quality of the effluent. The Environment Agency requires that

the current discharge point into the Salmons Brook is maintained, meaning thatwater flow within the Brook will remain at its current levels.

4.5.7 One respondent commented that water systems need to be made less wasteful. We


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Environment Agency, Greater London Authority, Department for Transport, NaturalEngland, English Heritage, Transport for London and others.

4.5.20 Applications for the planning and other consents will be prepared, with a further

formal stage of public consultation held as part of this pre-application process. Thisphase 2 consultation will enable comments and feedback on the proposed design ofthe upgrade, the proposed construction programme and the potential impacts andmitigation proposals to be made. We will amend our plans to incorporate comments

into the design of our proposals, where we can.

4.6 Other comments

Question 9 Please give us any comments you have on the DeephamsSewage Works Upgrade

Table 4.9: Question 9 feedback results

Total number of

responses (% oftotal responses)

Summary of main comments in community

responses

Responded 25 (74%) Good luck - a massive project

Re-locate to a green field site

It is clear that Deephams cant deal with the volumeof sewage when it rains. Need to reduce amount of

rainwater going into the sewage system throughinvestment in natural drainage systems


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for how we will meet the needs of our customers and our legal obligations and howwe maintain and improve the levels of service we provide to them. Ofwat looks in

detail at these plans to make sure that customers only pay for the work andimprovements that are necessary. Ofwat then decides how customers bills will

change over the following five years. This process is known as the Price Review. Atthe last Price Review in 2009, Ofwat allowed us the necessary funding for thepreparation and early construction work for the Deephams Sewage Works Upgrade,covering the period 2010 to 2015.

4.6.3 In mid 2013, we will consult on our draft Business Plan for the 2015 to 2020 period.

We will then submit our final Business Plan to Ofwat in the first quarter of 2014, withOfwat due to make its final decision on the Plan at the end of 2014. Following thetwo phases of public consultation and after we have completed the design work and

submitted an application for permission to build the upgrade, if Ofwat allow us thefunding, our customers will begin paying for the upgrade in 2015. The costs will bespread across many years to make sure price rises are kept to an absoluteminimum.

4.6.4 Recent improvements at the Deephams Sewage Works have included theintroduction of two additional storm tanks. This provide increased capacity at thesewage works to store and then treat storm flows, so reducing the frequency thatstorm releases to the Salmons Brook take place.

4.6.5 One consultee requested that we consider options for constructing a biogasrefuelling station as part of the Deephams upgrade. This could serve as a potential

fuel source for local employer fleets. Currently all of the biogas we create fromsludge treatment at Deephams is used within the combined heat and power plant to


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5.9 We are currently developing our Water Resources Management Plan (WRMP),

which will cover the period 2015-2040, and one of the potential options for providing

additional water resource is an effluent diversion project at Deephams. The effluentdiversion project could see effluent from Deephams being transferred to one of our

nearby reservoirs instead of into the local river, however we are not proposing directpotable reuse of Deephams effluent. This potential effluent diversion project is likelyto be consulted on during our WRMP consultation in May 2013.

5.10 The EA also asked the question The proposal to reuse Deephams effluent forpotable supply is likely to result in a proportion of the existing Deephams site being

set aside for the reuse infrastructure. What impact if any will this have on thedecision making process for the design of the upgrade?

5.11 If an effluent diversion scheme is approved, this will affect the quantity of effluentdischarged into the Salmons Brook, but it will not adversely affect the treatment ofthe effluent. There may, nonetheless, be a treatment synergy between the upgradeproject and any WRMP-related scheme.

5.12 The Deephams Sewage Works Upgrade will be designed to take account of apotential future scheme and space will be retained for any associated infrastructurethat may be required.

5.13 The EA also highlighted a number of other strategies and schemes in its response,

which are of relevance to the Deephams Sewage Works, including the SludgeStrategy, Combined Sewer Overflows, the Environment Agency flood alleviation

study, and the Hoddesdon Transfer Scheme.


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5.24 LBE highlights that the key issue to be addressed as part of the upgrade is the

odour levels, which currently have an unacceptable impact on the area. In its

response, LBE note that our proposals do address the odour issues but the Boroughwould like to see a more proactive approach to odour management, including

achieving at the very least the lowest levels of odour achievable from the site, asoutlined in our consultation materials. LBE would also like to see an accompanyingaction plan showing how we propose to manage the smell on particularly odorousdays (such as in extreme heat or flood events), and how background odour will be

regularly monitored to ensure that the gains achieved by the improvement works arenot lost over time as issues occur.

5.25 As set out in our phase 1 consultation material, reducing odour is one of our toppriorities for the upgrade. However, we also need to ensure that the proposed odour

mitigation represents value for money, as the cost of the works will ultimately bereflected in our customers bills. Therefore, we will undertake a detailed review ofbest practicable means of odour mitigation with potential contractors and use this toinform our odour mitigation proposals (and to support any request for Ofwat to allowfunding) as part of our next five-year Business Plan (2015 to 2020). We will consult

on our more detailed proposals to reduce odour as part of our second phase ofpublic consultation in 2013.

5.26 We will deliver a proactive approach to odour management via an update of ourOdour Management Plan, including the proposed upgrade. This will accompany our

planning application. The Odour Management Plan will be in line with others whichwe have recently prepared for other Tideway Sewage Works and will be in

accordance with guidelines set out in the Defra Code of Practice on Odour Nuisancefrom Sewage Treatment Works published in 2006. The Odour Management Plan will


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5.38 Applications for the planning and other consents will be prepared, with a further

formal stage of public consultation held as part of this pre-application process. This

phase 2 consultation will enable comments and feedback on the proposed design ofthe upgrade, the proposed construction programme and the potential impacts and

mitigation proposals to be made. We will amend our plans to incorporate commentsinto the design of our proposals, where we can.

5.39 We have also noted the Boroughs request for information to understand the traffic

flows and implications for the highway and waterway network of freight and buildingmaterials during the construction period.

5.40 We have commissioned a comprehensive traffic survey of the highway networksurrounding the Deephams site and critical junctions further afield. The purpose of

the survey is to obtain a greater understanding of the existing base traffic flows inorder to calibrate Transport for Londons local network traffic model and enable us toidentify and mitigate any potential impacts of the upgrade on traffic movements.

5.41 Our consultants are now in the process of determining the likely number of

construction vehicles required for the upgrade and the duration of the constructionprocess. This will enable us to establish the likely construction vehicle profile overthe construction period. We will put this information into a traffic model, which willenable us to identify traffic hot-spots and put in place suitable mitigation andmanagement measures. This will mean that there will be no discernible impact

resulting from the introduction of the upgrade construction traffic to the highwaynetwork.

5.42 As part of this process, a servicing and delivery plan will be prepared as well as a


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5.46 We support the Lee Valley Heat Network (LVHN) in principle and have had a

number of meetings with the LVHN Local Planning Authorities and their consultants

to discuss the plans. As discussed at those meetings, there are potentialopportunities for Deephams Sewage Works to connect with the LVHN in the future

and reference has been made to the possibility of exporting gas to the grid.

5.47 At Deephams Sewage Works we currently use all of the biogas produced in theexisting Combined Heat and Power (CHP) plant and it is our current preferred

strategy to continue this approach with an upgraded CHP plant provided inassociation with the Sewage Works Upgrade. However, we will review all other

opportunities with potential contractors for the upgrade and consult the LVHNauthorities/Deephams Stakeholder Forum on any proposals.

Enterprise Enfield

5.48 Enterprise Enfield responded to phase 1 consultation exercise via an email and theycommented We are concerned about traffic congestion in Meridian Way once theworks start.

5.49 We responded stating that as part of the proposed upgrade we are assessing allpotential impacts arising from the proposals and identifying appropriate mitigationmeasures. A key issue is the potential for the construction works to cause trafficcongestion.

5.50 We have commissioned a comprehensive traffic survey of the highway network

surrounding the Deephams site and critical junctions further afield. The purpose ofthe survey is to obtain a greater understanding of the existing base traffic flows in


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Greater London Authority

5.55 The Greater London Authority (GLA) in its letter highlights that Effective wastewaterinfrastructure is fundamental to sustainable urban life, investment and expansion to

meet the needs of Londons growing population is therefore necessary. While theimpact of these works needs to be minimised and mitigated, it is essential that a

positive planning approach is in place to support such developments.

5.56 We note that Policy 5.14 of the London Plan states the Mayor will work inpartnership with the boroughs and appropriate agencies to ensure London has

adequate and appropriate wastewater/sewage infrastructure and to protect andimprove water quality. Development proposals to upgrade Londons sewagetreatment capacity to support planning growth within the catchment area is therefore

strongly supported.

5.57 The GLA is pleased to note that the preferred site for the upgraded works is theexisting Deephams Sewage Works site. Further, the GLA states, Thames Waterare significant landholders in the Meridian Water growth area and the potential use

of other land such as the Lower Hall Lane site would impact up on the aspirations ofthe draft opportunity area planning framework, in particular on flood mitigationmeasure for the growth area.

5.58 The GLA encourages us to work together with Enfield Council, the Environment

Agency, the Lee Valley Regional Park Authority, British Waterways and the GLA tosecure complimentary sewage treatment, flood mitigation and water management

measure for the growth area.


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All of the biogas we currently create from sludge treatment at the works is used

within the combined heat and power plant to create heat and renewable energy.

Our recent modelling indicates we do not need to upgrade the sludge treatmentplant in order to meet the new effluent consent. Therefore, there is unlikely to beany spare biogas in the future for a refuelling station. We may at some stage inthe future need to upgrade the sludge treatment process and, if this is

undertaken, we will make sure that the idea of a biogas refuelling station isincluded in the options review.

Biogas produced from sewage sludge digestion is around 65 per cent methane,

the rest being mainly carbon dioxide and water vapour. It also contains asignificant concentration of hydrogen sulphide. To make the gas suitable for avehicle fuel it would need to be scrubbed to reduce the carbon dioxide content

and remove the hydrogen sulphide. It would also need to be dried to avoidcondensation of water during storage. We currently do not have the technology

on site to undertake the necessary cleaning as the combined heat and powerengines do not require clean biogas.

5.62 Therefore, there are a number of issues/constraints to the inclusion of a biogasrefuelling station as part of the Deephams Sewage Works Upgrade. We will review itin further detail as part of our Energy Statement, after the phase 1 consultation.

London Borough of Haringey

5.63 As requested in its response, we will keep the London Borough of Haringey (LBH)

informed of developments in regard to this proposal especially the developmentspotential environmental and amenity impacts such as noise, odour, pollution, traffic


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5.75 The ICE notes that the new standard of treatment for the Deephams works, at

10mg/l suspended solids, 5mg/l BOD and 1mg/l Ammonia and Phosphate isextremely stringent. We recognise the importance of improving the quality of

especially designated water bodies, and appreciate the value of leaving a long termlegacy for future generations that encourages improved safe use of fluvial rivers in

the urban environment. However, although increased levels of treatment may beappropriate locally for Salmons Brook, it may not represent the most sustainable

solution for the environment as a whole. It will also impact upon Thames Watercustomer's bills. What is the full rationale and assessment behind this stringent

requirement, and if appropriate, what are you doing to challenge the levels oftreatment required?

5.76 The National Policy Statement for Waste Water published by Defra in March 2012sets out the need for the Deephams Sewage Works Upgrade. Paragraph 2.6.11states: The Governments environmental regulators of the water industry (theEnvironment Agency) have approved the need for the improvements at DeephamsSTW in NE London in order to meet the requirements of the Urban Waste Water

Treatment Directive, Freshwater Fish Directive and Water Framework Directive.These requirements are such that the cost-effective solution is likely to necessitatethe replacement of the existing treatment infrastructure at Deephams.

5.77 We recognise that the new permit conditions applied to Deephams are very

stringent. It is the responsibility of the Environment Agency to establish and justifythe river quality required (and hence set the standard of treatment) to ensure

compliance with statutory environmental quality standards.


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we have also piloted our own work experience scheme, providing work experiencefor over 30 unemployed people in the London and Thames Valley area.

5.102 Because we are appointing the contractors that will build the upgrade at an earlier

stage than for our previous projects, this provides an opportunity to work with thecontractors and local authorities early in the application process to develop astrategy prior to the submission of the planning application. The details of thisstrategy can subsequently be agreed via conditions or a S106 Agreement if

necessary.

5.103 We will develop our proposals in more detail as the design of the upgradeprogresses. We will set out our draft proposals and consult on these before anyplanning application is made.

Thames 21

5.104 Thames 21 supports the need for the upgrade and the proposal to upgrade theexisting Deephams Sewage Works site. It noted that it has first hand experience of

the poor water quality in the Salmons Brook, Pymmes Brook and River Lee.Thames 21 highlighted the existing sewage works inability to adequately cope withthe wastewater flowing into it as being a source of concern and highlighted the needfor a sewage works that is fit for purpose.

5.105 Thames 21 considered that a combination of Conventional Activated Sludge andIntegrated Fixed Film Activated Sludge treatment processes would use less space

on the site and therefore provide greater capacity at the works.


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grey and green infrastructure. Thames 21 is concerned that a failure to take this dualapproach will only see the problem re-occur a few years after the upgrade has been

completed.

5.109 Any proposals for long-lived assets, such as the Deephams Sewage Worksupgrade, involve a balance of planning for known conditions and speculativeprovisioning. We aim to provide a works that will have the flexibility to adapt to futurerequirements rather than second-guess now what those requirements might be.

Accommodating future flows to the sewage works is a good example of suchuncertainty; whilst some population growth appears likely, and the more probable

growth accommodated, this must be set against the outcome of other initiatives suchas reducing domestic water use and removing surface water flows from the foulsystem. The proposed upgrade will be designed to allow the addition of further

upgrades and treatment capacity (tanks) within the layout of the site. These will beplanned for and added in the future if and when required.

6 Analysis of comments about the consultation process

6.0 These questions sought responses on the phase 1 consultation process weundertook.

Question 10 If you visited an exhibition, please tell us which one and any

suggestions you have for how it could be improved.Table 6.1: Question 10 feedback results


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to the main problems of odour and pollution

A large part of the target groups have not received

the information

6.2 As part of the Strategic Options Review, which was carried out as part of the siteselection for the upgrade, the options for reducing flows at source were considered.

Water efficiency, metering and Sustainable Drainage Systems (SuDS) are alreadyand will continue to be implemented within the catchment, which will help to reduce

the amount of wastewater/sewage arriving at Deephams Sewage Works, particularlystorm flows. However, these measures will not make a big enough reduction in

wastewater/sewage flows in the next few years to permit one of the three treatmentstreams at Deephams to be taken out of commission while it is upgraded.

6.3 It is also important to note that savings from water efficiency and metering arealready taken into account in predicting the future flows to Deephams SewageWorks. SuDS would have to be implemented on a very large scale before part of the

existing sewage works could be taken out of service for upgrading, but this is notpracticable or likely within the timescales for the upgrade. Furthermore, while these

measures will reduce the volume of sewage entering the sewage works, it will stillcontain largely the same polluting load which will need to be treated.

6.4 In preparing consultation materials we have sought to make them as clear and

accessible as possible and have taken the advice of local authorities and otherstakeholders, via our Stakeholder Forum, in preparing for the consultation. Keepingmaterials simple is not easy when we are communicating technical information abouta large and complex project. We will take all comments on board and in our phase 2


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Appendix 1 Copy of Blank Feedback Form


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3DUW7KHQHHGIRUWKHXSJUDGHTo help you understand and answer the questions in this section, you may find it useful to read the Why we need the upgrade leaflet.

This is available at our public exhibitions, on our website and via our customer centre. Please give us as much explanation as you can

to help us fully understand your comments and take them into account.

'R\RXDJUHHZLWKWKHQHHGWRLPSURYHWKHULYHUZDWHUTXDOLW\RIWKH6DOPRQV%URRNDQG5LYHU/HH"


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3DUW2XUSUHIHUUHGRSWLRQTo help you understand and answer the questions in this section, you may find it useful to read the following leaflets: Our preferred

site, Shortlisted sites, Longlisted sites, Treatment options, Treatment technologies assessment, How we will build the upgrade,

Odour, Environmentand Being a good neighbour. These are available at our public exhibitions, on our website and via our

customer centre. Please give us as much explanation as you can to help us fully understand your comments and take them

into account.

'R\RXDJUHHWKDWWKHH[LVWLQJ'HHSKDPV6HZDJH:RUNVVLWHLVWKHEHVWORFDWLRQIRUEXLOGLQJWKHXSJUDGH"

(See the Our preferred site, Shortlisted sites, Longlisted sites leaflets.)


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:KDWDUHWKHPRVWLPSRUWDQWPDWWHUVIRU\RXWKDWZHVKRXOGWKLQNDERXW ZKHQGHVLJQLQJWKHXSJUDGH"

(See the Odour Environment and Being a good neighbour leaflets.)

07


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,I\RXGLGQWYLVLWDQH[KLELWLRQLVWKHUHDQ\WKLQJZHFRXOGKDYHGRQHWRPDNH\RXPRUHOLNHO\WRYLVLW"

'R\RXWKLQNZHKDYHSURYLGHGHQRXJKLQIRUPDWLRQOHDHWVPDSVGLDJUDPVHWFDERXWWKHXSJUDGH


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Appendix 2 Schedule of Responses toAnonymised Individual Public Comments


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Deephams STW Upgrade ECI


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p pgP1 - Phase 1 Consultation Feedback Report Appendix 2 - V2.0 - FINAL

Phase 1 Consultation Feedback Report Appendix 2, Page 3 of 58 December 2012

Question 1 Do you agree with the need to improve the river water quality of the Salmons Brook and River Lee?

CustomerID number

Detailed comment Thames Water response

hopefully this will address, in time, by the WFD and the Lee PilotCatchment Project. Every body at the project meeting last Novemberat Bow accepted the plight of the Lower Lee and the unacceptability

in 2012 especially with all the money being spent in the OPD area.

009 Yes -

It is full of raw sewerage, some from poorly plumbed local houses,some from the overflow of sewerage works following heavy rain.

0010 Yes -

The water quality of the Salmons Brook, and then the Pymmes Brookand the Lea south of Tottenham is poor. At Thames 21 we carry outwater quality tests with University College London so we know thisfirst hand. The inability of Deephams STW to adequately cope withthe wastewater that enters it affects the quality of life of those that livenear it, and visit it.

North East London needs a sewage works fit for purpose.

The need for the sewage works upgrade as described in the phase 1consultation material is threefold, to:

Improve water quality within Salmons Brook and the River Leeand comply with Regulations and Directives.

Provide sufficient treatment capacity to meet growth within thearea served by the sewage works and to respond and adapt tothe challenges of climate change.

Improve treatment facilities that are becoming old and worn out.

0011 No response

0012 Yes -

In parts there is filth and dirt, lots of littering and large householditems dumped, terrible for wildlife and passers by

The proposed sewage works upgrade at Deephams will improve thequality of the effluent, which is discharged into the Salmons Brookwhich flows into the River Lee, but there is a wider problem relating tomisconnections from properties. Misconnections are where poorbuilding work has led to the sewage from some properties beingconnected to surface water drains rather than foul sewers. Thismeans that untreated sewage from peoples homes can drain directlyinto the rivers including the River Lee and the Lee Navigation,contributing to poor water quality. We have been working with the

Environment Agency to tackle the problems caused bymisconnections.

0013 Yes -

Its inevitable to keep modernisation at the forefront of change

Noted


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P1 - Phase 1 Consultation Feedback Report Appendix 2 - V2.0 - FINAL


Question 2 We think that upgrading the sewage treatment processes on the existing Deephams Sewage works site is the best way to meet theneed? Do you agree?

CustomerID number


0011 Not answered

0012 Yes -We need to move forward

Noted

0013 No -

For the last TEN years the existing plant has been emitting toxicpollution, despite supposedly being capped and numerous lettersfrom MP Mr. Andy Love expressing the health concerns!

We do not think the comments made by respondents referring totoxic pollution accurately or fairly represent the operations at theDeephams Sewage Works site. We are not aware of, and do notbelieve there is any emission of toxic materials from the site now, norwould there be after the upgrade.

0014 No -

Deephams sewage works has to be shut and moved outside London.No one has to live within 1 mile radius as it stinks incredibly!

We have given very careful consideration to alternative locations forthe upgrade. Our phase 1 technical work considered 22 potential sitesfor the delivery of the upgrade, including the Deephams SewageWorks site. Our assessment work concluded that the development ofthe existing sewage works site was the most appropriate of all of the

potential locations identified.Deephams is located within a relatively densely developed part ofnorth-east London. Where sites are currently clear of development, itis typically the case that they are either areas of open space and/orGreen Belt or Metropolitan Open Land. These areas are protectedfrom developments such as sewage works by restrictive planningpolicies that would not allow planning permission to be granted for theupgrade. We have published details of our assessment of thepotential locations for the upgrade, as part of the phase 1 consultationprocess. This assessment provides clear evidence to support theidentification of the Deephams Sewage Works site as the preferredsite for the upgrade.

0015 No -Concentration of noxious substances in area

We do not think the comments made by respondents referring tonoxious substances accurately or fairly represent the operations atthe Deephams Sewage Works site. We are not aware of, and do notbelieve there is any emission of noxious substances from the sitenow, nor would there be after the upgrade.

Deephams STW Upgrade ECIP1 Phase 1 Consultation Feedback Report Appendix 2 V2 0 FINAL


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CustomerID number


0016 Yes -

It keeps things in the one place rather than disrupting other areas inthe process, from what I can understand of the process planned.

Noted

0017 No -

Not clear why other options are not viable and need to evidence thedecision making process more clearly.

We have given very careful consideration to alternative locations forthe upgrade. Our phase 1 technical work considered 22 potential sitesfor the delivery of the upgrade, including the Deephams SewageWorks site. Our assessment work concluded that the development ofthe existing sewage works site was the most appropriate of all of thepotential locations identified.

Deephams is located within a relatively densely developed part ofnorth-east London. Where sites are currently clear of development, itis typically the case that they are either areas of open space and / orGreen Belt or Metropolitan Open Land. These areas are protectedfrom developments such as sewage works by restrictive planningpolicies that would not allow planning permission to be granted for theupgrade. We have published details of our assessment of thepotential locations for the upgrade, as part of the phase 1 consultationprocess. This assessment provides clear evidence to support theidentification of the Deephams Sewage Works site as the preferredsite for the upgrade.

0018 Yes -

Upgrading means replacing the old system. This means improving thewaterworks and savings financially. The old system needs repairs allthe time and some key replacements are no longer in production. Alsothe old system cannot meet the growing populations needs andcommercial needs.

Noted

0019 Yes -

Makes sense to develop an existing site

Noted

0020 Yes -

If you went to a different site presumably it would cost still more

Upgrading the existing site will take advantage of this existinginfrastructure and avoid the need for costly and complex pipeline

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CustomerID number


leading to more expensive water bills. transfers of sewage, effluent and sludge to and from Deephams.

0021 Yes -Sewage problems relating to smell has been a big issue in this areafor over 10 years and during summer months especially as you drivealong the Meridian Way from the north and the A406 towards PicketsLock and Ponders End the smell is disgusting and you have to drivewith the windows shut. Even this does not guard against the smell. Ifeel sorry for the residents in the properties over the other side of therailway line. I know what it is like for them and I know how long it tookto resolve a similar issue in Enfield Local approximately 5 years.During summer months you had to live in your property with thewindows shut due to smell. Thank goodness the situation wasresolved and I have moved from that property.

We are very aware of the proximity of local residents to theDeephams Sewage Works site, and recognise the potential impactsupon them during the construction and operation of the upgrade. Weare committed to working closely with the London Borough of Enfield,London Borough of Waltham Forest and with other stakeholders, andwith potentially affected residents as the designs for the scheme aredeveloped, and as we assess potential impacts in detail and identifyappropriate mitigation. We are confident that we can design, constructand operate the upgrade on the Deephams Sewage Works site in away that minimises impacts on nearby residents.

0022 Yes -

I think that an upgrade is a good idea

Noted

0023 Yes -

Impractical and too expensive elsewhere

Upgrading the existing site will take advantage of this existinginfrastructure and avoid the need for costly and complex pipelinetransfers of sewage, effluent and sludge to and from Deephams.

0024 I have no expertise or knowledge to know the best - I can only trustthat experts will choose the best site. This is provided that it does notmake the 'stink' that we get worse and does in face eliminate itcompletely as at present it is often unbearable.

As set out in our phase 1 consultation material, reducing odour is oneof our top priorities for the upgrade. However, we also need to ensurethat the proposed odour mitigation represents value for money, as thecost of the works will ultimately be reflected in our customers bills.Therefore, we will undertake a detailed review of best practicablemeans of odour mitigation with potential contractors and use this to

inform our odour mitigation proposals (and to support any request forfunding from Ofwat) as part of our next five-year Business Plan. Wewill consult on our more detailed proposals to reduce odour as part ofour second phase of public consultation in 2013.

We will deliver a proactive approach to odour management via an


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P1 Phase 1 Consultation Feedback Report Appendix 2 V2.0 FINAL


Question 3 - Do you agree that the existing Deephams Sewage Works site is the best location for building the upgrade?

CustomerID number


a number of industrial sites, although none were assessed as beingas suitable for the upgrade as the existing sewage works site, whenconsidered against the full range of factors.

We will design the new sewage works to reduce the current odourlevels. This is likely to include introducing measures to control odourat the most odourous parts of the sewage works. As part of theupgrade, we plan to include measures to manage and control theodour produced by the primary treatment stage of the sewagetreatment process. This may involve covering the large settlementtanks used at this stage, or putting this part of the process inside alarge building and treating the gases produced before releasing themhigher above the sewage works.

We can clearly state in response that there is no risk of pollution tothe reservoirs arising from the upgrade. The Deephams SewageWorks discharges into the Salmons Brook, downstream and to the

south of the reservoirs, and so no treated effluent from the site couldenter the reservoirs.

The potential positive or negative impact of the planned upgrade onthe cost of properties in the area near the Deephams Sewage Worksis not a material consideration in the determination of the planningapplication.

003, 004,005, 006,007, 008

Yes Noted

009 Carefully designed it should make good use of an existing space. Noted

0010 Using the current site is the least disruptive option. Noted

0011 Its there already why move it? Noted

0012 The only reason is a monetary decision at the expense of the publics The financial cost of the upgrade is one of the factors that we used inour assessment of the potential sites, as it is ultimately our customers

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CustomerID number


health which is much further down the list of priorities. who will pay for the upgrade through their water bills. However,financial costs were given the same level of priority as the many otherplanning, environmental, engineering and legal/property factors

considered in the decision to choose Deephams Sewage Works asour preferred site for the upgrade. In fact, options to deliver theupgrade at Deephams may be more expensive than development ona new site elsewhere. This is because redeveloping and upgradingthe site is technically challenging, as the existing works must continueto function throughout construction works. There is only limited spaceavailable on the site currently, meaning that an upgrade would haveto be built in a series of phases over a number of years. This phasedapproach is also necessary to ensure that we continue to meet thecurrent discharge consent requirements throughout the constructionof the upgrade. A multi-phased redevelopment is also more costly tobuild than a single phased build on an undeveloped site.

0013 We used to live on Hennessy Road within 200m from DeephamsSewage and it is a real health hazard to breathe in that odour comingfrom works at any time mainly during hot summer months. After 6months living next to the sewage we had to sell our house and moveaway from the area despite the fact that the house was lovely andspacious.

Deephams sewage was built long time ago and cannot meet currentdemand and volume of waste coming in. It is very outdated and thetreatment technology has to be improved.

It has to be shut and moved away from London altogether!

We believe because this plant was built in Edmonton, which is poorindustrial area no one pays much attention to it.

As set out in our phase 1 consultation material, reducing odour is one

of our top priorities for the upgrade. However, we also need to ensurethat the proposed odour mitigation represents value for money, as thecost of the works will ultimately be reflected in our customers bills.Therefore, we will undertake a detailed review of best practicablemeans of odour mitigation with potential contractors and use this toinform our odour mitigation proposals (and to support any requestfunding from Ofwat) as part of our next five-year Business Plan. Wewill consult on our more detailed proposals to reduce odour as part ofour second phase of public consultation in 2013.

We will deliver a proactive approach to odour management via anupdate of our Odour Management Plan (OMP), including theproposed upgrade. This will accompany our planning application. TheOMP will be in line with others which we have recently prepared forother Tideway Sewage Works Upgrades and will be in accordancewith guidelines set down in the Defra Code of Practice on OdourNuisance from Sewage Treatment Works. The OMP reviews impactand required actions under abnormal and emergency conditions

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CustomerID number


(such as flood), as well as normal baseline mitigation measures.

We are very aware of the proximity of local residents to theDeephams Sewage Works site, and recognise the potential impacts

upon them during the construction and operation of the upgrade. Weare committed to working closely with the London Borough of Enfield,London Borough of Waltham Forest, and other stakeholders and withpotentially affected residents as the designs for the scheme aredeveloped, and as we assess potential impacts in detail and identifyappropriate mitigation. We are confident that we can design, constructand operate the upgrade on the Deephams Sewage Works site in away that minimises impacts on nearby residents.

0014 No - Better options using redundant industrial land Our approach to site selection, and our assessment of the 22potential locations identified for the upgrade was fully explained in ourphase 1 consultation material that we published. Potential sites wereidentified and assessed against a range of environmental, planning,

engineering, and property and legal factors. Our assessment includeda number of industrial sites, although none were assessed as beingas suitable for the upgrade as the existing sewage works site, whenconsidered against the full range of factors.

0015 Yes Noted.

0016 No -

Could another part of London be considered further along River Lea?

As part of our phase 1 work we assessed the potential to relocate thesewage works or to transfer flows for treatment either in other parts ofthe catchment or out of catchment. Our approach to site selection,and our assessment of the 22 potential locations identified for theupgrade was fully explained in our phase one consultation materialthat we published. Potential sites were identified and assessedagainst a range of environmental, planning, engineering, and property

and legal factors. Our assessment included a number of industrialsites, although none were assessed as being as suitable for theupgrade as the existing sewage works site, when considered againstthe full range of factors.

The search area focused within the London Borough of Enfield, but



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p pp



CustomerID number


extended into London Borough of Waltham Forest to the east andLondon Borough of Haringey to the south. The search area extendsalong the floor of the Lee Valley, to its maximum distance of 3km to

the north and south of the existing sewage works. To the east andwest the search area is constrained by the increased elevation up thesides of the valley, particularly to the east. The cost of constructing atransfer pipeline or tunnel from the Deephams Sewage Works to anew site is also a significant additional cost to the upgrade. On thisbasis, we believe that expanding the search radius beyond the 3kmlimit is also uneconomic as well as unsustainable.

0017 Yes -

This site is more industrial than residential. Therefore controlledemissions and will not have a long term impact on the community.

We are very aware of the proximity of local residents to theDeephams Sewage Works site, and recognise the potential impactsupon them during the construction and operation of the upgrade. Weare committed to working closely with the London Borough of Enfield,London Borough of Waltham Forest, and other stakeholders and with

potentially affected residents, as the designs for the scheme aredeveloped and as we assess potential impacts in detail and identifyappropriate mitigation. We are confident that we can design, constructand operate the upgrade on the Deephams Sewage Works site in away that minimises impacts on nearby residents.

0018 Yes -

This site is more industrial than residential. Therefore controlledemissions and will not have a long term impact on the community.

0019 Yes-

It makes sense to develop an existing site. Site 6 - not good asdeveloping a fairly green area around the flour mill. Site 9 - very badchoice to build over/ destroy an existing golf course and camp site.

For further details on the assessment of the shortlisted sites, pleaserefer to the Identification of Preferred Site report.

0020 Yes -

If you went to a different site presumably it would cost still moreleading to more expensive water bills

The search area focused within the London Borough of Enfield, butextended into London Borough of Waltham Forest to the east andLondon Borough of Haringey to the south. The search area extends

along the floor of the Lee Valley, to its maximum distance of 3km tothe north and south of the existing sewage works. To the east andwest the search area is constrained by the increased elevation up thesides of the valley, particularly to the east. The cost of constructing atransfer pipeline or tunnel from the Deephams Sewage Works to anew site is also a significant additional cost to the upgrade. On this



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CustomerID number


basis, we believe that expanding the search radius beyond the 3kmlimit is also uneconomic as well as unsustainable.

0021 Yes -

Cannot comment as only been given Deephams Sewage WorksUpgrade leaflet. Seems a good idea as the plant is already there, you

just need to get a move on. What has happened in the last 10 years?

Although much of the infrastructure on the site dates back to the

1950s and 1960s, it has been subject to improvements and we arecommitted to continue improving the site. Most recently, in summer2012 we completed a construction project to improve the inlet worksand storm tanks on the Deephams Sewage Works site, the part of thetreatment process where the sewage first arrives at the site. This willreduce the levels of odour produced by that part of the existingsewage works. The proposed Deephams upgrade is the next stage ofthis improvement process.

0022 Yes -

I think it is the best site because it is not in the middle of an urbanarea. Although some housing is in the area, there is not a crowdedarea.

We are very aware of the proximity of local residents to theDeephams Sewage Works site, and recognise the potential impactsupon them during the construction and operation of the upgrade. Weare committed to working closely with the London Borough of Enfield,

other stakeholders and with potentially affected residents, as thedesigns for the scheme are developed and as we assess potentialimpacts in detail and identify appropriate mitigation. We are confidentthat we can design, construct and operate the upgrade on theDeephams Sewage Works site in a way that minimises impacts onnearby residents.

0023 Yes -

Impractical and too expensive elsewhere

The financial cost of the upgrade is one of the factors that we used inour assessment of the potential sites, as it is ultimately our customerswho will pay for the upgrade through their water bills. However,financial costs were given the same level of priority as the many otherplanning, environmental, engineering and legal/property factorsconsidered in the decision to choose Deephams Sewage Works asour preferred site for the upgrade. In fact, options to deliver theupgrade at Deephams may be more expensive than development ona new site elsewhere. This is because redeveloping and upgradingthe site is technically challenging, as the existing works must continueto function throughout construction works. There is only limited spaceavailable on the site currently, meaning that an upgrade would have



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CustomerID number


to be built in a series of phases over a number of years. This phasedapproach is also necessary to ensure that we continue to meet thecurrent discharge consent requirements throughout the construction

of the upgrade. A multi-phased redevelopment is also more costly tobuild than a single phased build on an undeveloped site.

0024 Without leaflets or expert knowledge I could not say. I have requestedsome leaflets but although promised they never came!

We apologise for the requested material not being delivered.

We sent out over 19,000 letters, leaflets and postcards to propertieslocated within 250 metres from the boundary of each shortlisted siteand within 1 km from the boundary of the preferred site. The leafletsbriefly described our proposals and gave details of the exhibitions.

We set up a dedicated website with information on the DeephamsSewage Works Upgrade (www.deephamsconsultation.co.uk).

We placed adverts in local newspapers and posters were displayed,leaflets made available at public buildings such as libraries, counciloffices and transport hubs in the local area.

Question 4 If you think we should have chosen a different site, please tell us which one, and why

CustomerID number


001 I think the existing site is best but as a second choice the BrimsdownInd. Estate as it is not in such a residential area.

Brimsdown Industrial Estate (Site 3): This site is designated asStrategic Industrial Land in the Enfield Local Plan and itsredevelopment would have an adverse impact on employmentopportunities. The site is assessed as having complex landacquisition issues due to the number of land interests and landacquisition costs are assessed as being relatively high. There

remains the potential for flood risk issues to constrain availabledevelopment land, and the distance from Deephams requires atransfer of flows that is assessed as unsustainable.

002 Site 6 -

1. Further to residential area.

Meridian Business Park (Site 6): Meridian Business Park is inmultiple ownership and we would need to acquire the land and



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CustomerID number


2. More room for future expansion.3. Less maintenance cost.

My ideal choice is Tottenham Marshes if not for the conservationarea.

1. It is far away from residential areas.2. It has much room for future expansion.3. Would cost less to maintain.4 Firmly located within industrial area.

relocate any existing uses before construction of the upgrade couldcommence. Given the existing use of the site, the cost of landacquisition and relocation of uses was assessed as being, increasing

the overall costs of the upgrade. The site is also a designatedStrategic Industrial Land and is important for the job opportunities thatit provides. The site also lies within one of the London Borough ofEnfields place shaping priority areas, for which it is an important areaof job opportunities. The development of an upgrade on this site wasassessed as conflicting with the London Borough of Enfields planningpolicies relating to employment and regeneration.

Development of the Meridian Business Park for the upgrade wouldintroduce a new odour source in the Ponders End area, which wouldneed to be controlled and mitigated to avoid odour impacts. The siteis also in close proximity to residential properties, a new AcademySchool and close to the Green Belt, Lee Valley Regional Park and theLee Valley Leisure Complex Golf Course.

Development of the upgrade on the other long listed or short listedsites is assessed as leading to potential impacts on the environmentand local community. The development of the upgrade would bewithin close proximity of residential properties and close to the GreenBelt and Lee Valley Regional Park. Some of the sites are at risk offlooding and flood mitigation would be required to be provided eitheron or off site. All these sites would require laying transfer pipelines forsewage, treated effluent and sludge to Deephams Sewage Works,which incur additional financial costs and environmental impacts. Forthe combination of these reasons, other industrial sites were not thepreferred location for the upgrade.

Tottenham Marshes (Site 22): is a semi natural wetland. The

development of the site would impact on a large number of natureconservation designations. The site is in the ownership of the LeeValley Regional Park Authority and is assessed as having complexland acquisition issues. The site is constrained by neighbouring landuses sensitive to change.



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CustomerID number


003, 004,005, 006,007, 008,

009, 0010,0011, 0012

No comments

0013 Meridian Park or Lee Valley SouthThe potential dangers and health risks should be evenly displaced.

Meridian Business Park (Site 6): Meridian Business Park is inmultiple ownership and we would need to acquire the land andrelocate any existing uses before construction of the upgrade couldcommence. Given the existing use of the site, the cost of landacquisition and relocation of uses was assessed as being, increasingthe overall costs of the upgrade. The site is also a designatedStrategic Industrial Land and is important for the job opportunities thatit provides. The site also lies within one of the London Borough ofEnfields place shaping priority areas, for which it is an important areaof job opportunities. The development of an upgrade on this site was

assessed as conflicting with the London Borough of Enfields planningpolicies relating to employment and regeneration.

Development of the Meridian Business Park for the upgrade wouldintroduce a new odour source in the Ponders End area, which wouldneed to be controlled and mitigated to avoid odour impacts. The siteis also in close proximity to residential properties, a new AcademySchool and close to the Green Belt, Lee Valley Regional Park and theLee Valley Leisure Complex Golf Course.

Lee Valley Leisure Complex Golf Course (southern part) (Site 9): This site is wholly owned by the Lee Valley Regional Park Authorityand it is in active use as a golf course and camp site. It forms part ofthe wider Lee Valley Leisure Complex, including the regionallyimportant athletics centre. In addition, the Regional Park Authority hasconfirmed that it would not make the land available for developmentand would strongly resist any attempts to acquire it. It is consideredthat there would be significant local, regional and national support forits opposition to the use of the site for the upgrade.

The site is also within the Green Belt and Lee Valley Regional Park

Deephams STW Upgrade ECIP1 - Phas

Phase 1 Consultation Feedback Report

Documents