North London Heat and Power Project

Representations received regarding North London Heat and Power Project

The list below includes all those who registered to put their case on North London Heat and Power Project and their relevant representations.

SourceRepresentation - click on an item to see more details
Members of the Public/Businesses
KTI Energy Limited
"1. National Planning Policy for Waste 2014 insists a power project should deliver as much heat as feasible to its community. The project as specified is essentially a waste incinerator giving little priority to the Dclg requirement. Much more detail is required for 20,000 or more existing and new dwellings in Enfield, Haringey, Waltham Forest and Hackney which may be connected to an extensive district heating main. 2. The Energy Secretary, Amber Rudd, is keen that a major community should own a CHP scheme which supplies it with low carbon electricity and heat. Section 38 of the Infrastructure Act 2015 refers. The project as specified is essentially a waste incinerator to be owned by North London Waste Authority contrary to the objectives of the Energy Secretary. 3. The Environment Agency is keen for least stack emissions from the project based on tonne per MWh generated. If the project is to generate 70MWe gross, then firing SRF in lieu of crude waste should yield two-thirds the mass of stack emissions to the surrounding area of North London. 4. The North London Waste Local Plan specifies the management of around 1.9 million tonne per annum of municipal/household, commercial/industrial, demolition/construction and agricultural waste arising amongst the 7 boroughs of North London. The proposed incinerator at Edmonton will destruct less than half of these arisings. So what is the programme proposed by North London Waste Authority for managing the balance?"
Members of the Public/Businesses
Marine Society and Sea Cadets
"I am in favour of this project as I believe it will enhance the area and specifically support the work of this organisation to encourage the development of local young people between the ages of 10 and 18."
Members of the Public/Businesses
E Roberts Timber Ltd
"Dear Sir or Madam We at E Roberts Timber would like to raise our concerns over the possible affects the proposed development will have on our business while works are being carried out and after completion i.e. potential road closures to Advent Way and general disruption to us and our customers , our business relies on the easy access we have to our premises from both the A406 and Eley Trading Estate . I look forward to hearing from you on this matter . Yours sincerely Malcolm Roberts Malcolm Roberts"
Members of the Public/Businesses
David Arweny
"North London waste should compensate all resident of Edmonton for poor quality of air since inception. the planning inspectorate should investigate first the impact of the site on resistents. It should also consider the fact that the consultation should be extended and widely advertised in all seven borough. All the resident should be asked how the feel if that site is moved to their area. As for heat regeneration there is a nuclear plant in Essex. There is no need for one in the area. it is obstructive and an eye to the area. The area in 2025 should be returned to how it was before as weir Hall. Or at best a housing estate linked with pymmes. having the waste site has been a hinderance in positive development and value of properties in the area. Like the A406 it has create restriction in using the area for housing estates and people do not want to purchase homes in Edmonton just because of north London waste. besides that it doest not offer any contribution to the area in terms of jobs or anything. so it should not be granted opportunity to generate heat from waste from the 7 borough"
Members of the Public/Businesses
Bestway Cash and Carry Ltd
"Our representation will be in relation to the potential impact on the operation and access to an existing occupier - The Bestway Cash and Carry on Ardra Road."
Local Authorities
Greater London Authority
"The GLA: - supports the principle of the Heat and Power Project as it helps to achieve self sufficiency in line with London Plan policy. - recognise the work carried out to date to deliver a combined heat and power plant and provide heat to potential customers, as this is necessary to meet the Carbon Intensity Floor as required by London Plan policy. -will seek to work with NLWA to provide further detailed information regarding heat off-take. -will seek to agree via a Statement of Common Ground a commitment to secure heat off-take (noting the draft s106agreement). "
Other Statutory Consultees
National Grid Electricity Transmission Plc and National Grid Gas Plc
"Representation by National Grid Electricity Transmission Plc (NGET) and National Grid Gas Plc (NGG) (together ‘National Grid’) to the North London Heat and Power Project (Reference EN010071) National Grid wishes to make a relevant representation to the North London Heat and Power Generating Order to protect its position in light of apparatus, land and any other equipment not already identified which is within or in close proximity to the proposed DCO boundary. National Grid’s rights to retain its apparatus in situ and rights of access to inspect, maintain, renew and repair such apparatus located within or in close proximity to the order limits including should be maintained at all times and access to inspect such apparatus must not be restricted. The documentation and plans submitted for the scheme have been reviewed in relation to impacts on National Grid’s existing apparatus, and it has been identified that protective provisions will be required to be included within the DCO to ensure that apparatus and land interests are adequately protected and to include compliance with relevant safety standards. National Grid has identified that both existing land interests/apparatus and assets for which powers to construct and acquire rights recently secured within the North London (Electricity Line) Reinforcement Development Consent Order 2014 (the “2014 Order”) (http://infrastructure.planninginspectorate.gov.uk/projects/london/north-london-electricity-line-reinforcement/) are affected by this Order and will need to be protected/safeguarded. NGET will liaise with the promoter to agree a form of protective provisions for inclusion within the DCO. National Grid has the following existing assets and interests located within or in close proximity to the order limits: Electricity Transmission: ZBC 400kV Overhead Transmission Line – Brimsdown – Tottenham – Waltham Cross ZBD 400kV Overhead Transmission Line – Brimsdown – Tottenham – Waltham Cross Gas Distribution: Low or Medium pressure (below 2 bar) gas pipes and associated equipment Above ground gas governor and equipment The effects of the exercise of the 2014 Order will be explored with the promoter and further details provided by National Grid as part of its written representations or as part of a joint statement to the Examining Authority at the next stage(s). As a responsible statutory undertaker, National Grid’s primary concern is to meet its statutory obligations and ensure that any development does not impact in any adverse way upon those statutory obligations. National Grid reserves the right to make further representations as part of the examination process but in the meantime will continue negotiations with the promoter with a view to reaching a satisfactory agreement. "
Other Statutory Consultees
Natural England
"Natural England has been working with the applicant in order to work through any and all issues prior to examination and we have come to agreement on the various areas for which we are the statutory consultee. There have been a number of consultations over the past 18 months, including an initial meeting, agreeing the approach to EIA, our response to the HRA position paper and the final HRA comments. The areas on which we have agreed (there are none left on which there is no agreement at present) are as follows: Identification of sites, Surveys (including methodology), Replacement and enhanced habitat creation, Environmental statement and the Habitats Regulations Assessment (HRA). A further review of the areas which we are agreed upon is due to take place in the new year. At this point in time Natural England wouldn't have any further comments to make above those already submitted as part of our ongoing engagement with the North London Heat and Power Project. Further representation subsequently received from Natural England as follows: The proposal is within the vicinity of two European designated sites, a Ramsar Wetland of International Importance, and two Sites of Special Scientific interest (SSSI). These are: Epping Forest Special Area of Conservation (SAC), the Lee Valley Special Protection Area (SPA), the Lee Valley Ramsar, the Walthamstow Reservoirs SSSI, Epping Forest SSSI, and the Chingford Reservoirs SSSI. Based on the information provided in the Environmental Statement and in particular Section 5, we are satisfied that the Project will not have a likely significant effect upon the European sites, or result in harm to the SSSIs listed above. Natural England is satisfied with the survey and impact methodology as detailed in the submitted documentation. This is further reinforced by the Codes of Constructions Practice. Furthermore, we envisage no issues relating to protected species for the Project, however licenses may be required if there is a requirement to later cause disturbance. Please refer to our standing advice. The applicant can also obtain advice on licensing through our Pre-Submission Screening Service. In summary, we have no outstanding issues or concerns with regard to this Project, and furthermore do not envisage attending any hearings or site visits that may be forthcoming. We would however of course be happy to assist with any further matters, including any changes to the proposed scheme, if required. "
Members of the Public/Businesses
Biffa Waste Services Ltd
"On the basis of the application documents we have major concerns about the traffic assessment and the subsequent impact upon our recycling facility. For the reasons described below, Biffa objects to the proposals for the following reasons: 1. We raise significant concerns regarding congestion on Ardra Road which could lead to detrimental impacts to the operation of our existing MRF; 2. The cumulative impact of the proposed development upon neighbouring land uses has not been fully considered. Biffa operates a major waste recycling facility at the Edmonton Materials Recycling Facility (‘MRF’) located on Ardra Road, located to the north of the application site. The Edmonton MRF is an established business and is of key strategic importance to Biffa’s waste management capacity in the region. The facility processes up to 250,000 tonnes per year of commercial and municipal waste. The site also serves the North London Waste Authority (‘NLWA’) area. All vehicles associated with Biffa’s operational MRF facility access the site via Ardra Road and utilise the access with Meridian Way. This development in principle is supported as part of an improved, sustainable and strategic waste management network and we recognise that the site is an important part of the NLWA’s future strategy for the management of residual wastes. However our facility is also an important part of that strategic network. As a recycling facility it moves waste further up the waste hierarchy than ERF processes and as such its efficient operation should be safeguarded. Schedule 1 of the draft North London Waste Plan (July 2015) (‘WLP’) identifies Biffa’s Edmonton MRF as an existing safeguarded site in North London. Policy 1 states that “all existing waste management sites identified in Schedule 1: Existing safeguarded waste site in North London are safeguarded for waste use…Development proposals in close proximity to sites allocated for waste use which would prevent or prejudice the use of those sites for waste purposes will be resisted unless suitable compensatory provision has been made”. At this stage we therefore object to this proposal due to concerns over congestion on Ardra Road which will lead to detrimental impacts to the operation of the existing MRF owned and operated by Biffa. The proposals may therefore be contrary to Core Policy 22 of the Enfield Council Core Strategy. Additionally we object to the proposals as it is unclear at this stage whether the cumulative impacts of the proposed development have been fully considered, in particular with those existing facilities that utilise Ardra Road. The proposals therefore may impact upon the efficient operation of Biffa’s existing MRF facility, contrary to Core Policy 22 of the Core Strategy. Given the above it is important for the Planning Inspector to consider impacts of traffic and the creation of a new access from Deepham Farm Road upon our existing, well-established operation. It is essential to ensure that the impacts from the development are properly taken into account and suitable mitigation measures or other necessary amendments are included in the proposed development as appropriate. "
Other Statutory Consultees
Canal & River Trust
"Dear Sirs, The Canal & River Trust is a statutory consultee under the Town and Country Planning (Development Management Procedure) (England) Order 2015. The Trust is a company limited by guarantee and registered as a charity. It is separate from government but still the recipient of a significant amount of government funding. The Trust has a range of charitable objects including: • To hold in trust or own and to operate and manage inland waterways for public benefit, use and enjoyment; • To protect and conserve objects and buildings of heritage interest; To further the conservation, protection and improvement of the natural environment of inland waterways; and • To promote sustainable development in the vicinity of any inland waterways for the benefit of the public. After due consideration of the submission details, the Canal & River Trust will be making further representations on the following topics: 1. Landscaping to the towpath and canalside 2. Lighting 3. Flood Risk Assessment 4. Movement of Waste by Water 5. Surface Water Discharge 6. Edmonton Sea Cadets facilities 7. Use of Lee Navigation for cooling 8. Boater/Canal & River Trust refuse facilities 9. Canal & River Trust third party works process We have already met with NLWA regarding the proposal and its potential impacts on the Trust's infrastructure, and will continue to discuss these and prepare a joint Statement of Common Ground. Yours faithfully, Claire McLean Area Planner London Canal & River Trust"
Members of the Public/Businesses
Edmonton residents
" waste plan in place when the existing disposal contract expired in 2014. We need that land for housing. Which is badly need in the area rather than this obsolute structure chuning in fumes. This lot that run the council are not interested in building anything or solving housing problems and that is why I cannot stand them any more. Rugby council has completed several estates in the last 5 years. You can name them. Eden park now under construction and several others . Now they are a much smaller council compare to enfield. Deliberately delaying tendering process to run down time. Basically what that means is that since 2010 nothing has happened for 6 years. 6 long years. 6. And then they agree in January 2016 and then there is a long wait while the land is prepared and you will not see 50 homes come 2020. It is political and deliberate and the cry wolf when buying Golf clubs. And it is deliberate not doing something because it is Edmonton. And why should we be stuck around to a borough not interested in investing in Edmonton. And it goes to that Civic ACt 1963. It has to be revised and Edmonton reinstated. We would rather have Ms Brady as the lord for the area so that things get done. If Enfield what golf course and farms they can get that out of their own budget. Given the background. the council enfiled should be building homes and they are instead giving priority to refuse over residents. And this means that in the scheme of things resident in Edmonton are of least priority . the NWLA is hazardous and has been for the last several years. Its time has expired and each local authority in the 7 mix should look for their own recycling sites in their own area. This site should be sold off to a developer to be used for housing as in lime house for much needed housing "
Other Statutory Consultees
Historic England
"North London Heat and Power Project Application Response from the Greater London Archaeological Advisory Service [Please Note: GLAAS operates within, and is co-located with, Historic England]. The Greater London Archaeological Advisory Service (GLAAS) provides archaeological advice to London boroughs in accordance with the National Planning Policy Framework and GLAAS Charter. The National Planning Policy Framework (Section 12) and the London Plan (2011 Policy 7.8) emphasise that the conservation of archaeological interest is a material consideration in the planning process. Paragraph 128 of the NPPF says that applicants should submit desk-based assessments, and where appropriate undertake field evaluation, to describe the significance of heritage assets and how they would be affected by the proposed development. This information should be supplied to inform the planning decision. If planning consent is granted paragraph 141 of the NPPF says that applicants should be required to record and advance understanding of the significance of any heritage assets to be lost (wholly or in part) and to make this evidence publicly available. A very similar approach is set out in section 5.8 of the ‘Overarching National Policy Statement for Energy (EN-1)’. Having initially suggested scoping archaeology out of the Environmental Statement, we are pleased that the applicant acted upon our advice and assessed the potential for significant effects on buried archaeological interest, identifying three zones all having moderate-high potential for palaeo-environmental evidence, and one (LV3) has moderate archaeological potential for Mesolithic activity (flint scatters) and wetland exploitation such as timber trackways. The current nature of the site as an operational facility and the likely depth and nature of the archaeological interest has limited field evaluation to boreholes and geo-archaeological modelling which give an indication of potential, but cannot demonstrate conclusively whether heritage assets of archaeological interest are actually present or not. We therefore refer to paragraph 5.8.22 of EN-1 which states: Where the IPC considers there to be a high probability that a development site may include as yet undiscovered heritage assets with archaeological interest, the IPC should consider requirements to ensure that appropriate procedures are in place for the identification and treatment of such assets discovered during construction. We note that this is essentially what is proposed in the ES and Code of Construction Practice, but the embedding of mitigation within the Code has the unfortunate effect that table 3.3.2 of the ES indicates no proposed mitigation is required. The information submitted with the application indicates that the development is likely to cause some harm to archaeological interest but such harm is not likely to be so substantial as to justify refusal of planning permission provided that a condition is applied to require investigation to be undertaken to advance understanding of whatever is found. Following the Historic Environment Good Practice Advice in Planning Note 2, paragraph 37, the archaeological interest should be conserved by attaching a condition as follows: Condition No development shall take place until a written scheme of investigation (WSI) has been submitted to and approved by the local planning authority in writing. For land that is included within the WSI, no development shall take place other than in accordance with the agreed WSI, which shall include the statement of significance and research objectives, and A. The programme and methodology of site investigation and recording and the nomination of a competent person(s) or organisation to undertake the agreed works B. The programme for post-investigation assessment and subsequent analysis, publication & dissemination and deposition of resulting material. this part of the condition shall not be discharged until these elements have been fulfilled in accordance with the programme set out in the WSI Whilst the approach set out in Section 6 of the Code of Construction Practice is generally acceptable, there is little detail provided. We do not agree withthe statement in ES paragraph 3.6.3 which says that a written scheme of investigation (WSI) would be provided ‘in the event that archaeological materials are found…’ . We would expect pro-active provision of appropriate procedures to identify such materials – these procedures would be specified in a WSI. We would also expect provision for palaeo-environmental sampling and analysis, which may require further boreholes. In addition, there may need to be some trial trench excavation to inform mitigation, although the difficulties of working at depth with a risk of trenches flooding will have to be considered. For instance, a major discovery, such as an in-situ hunter-gatherer camp site or a timber trackway could be considered of national importance, and should trigger special contingency arrangements to ensure appropriately proportionate mitigation. Thank you for the opportunity to comment on this application. Please contact me if further clarification is required. Sandy Kidd MA MCIfA MRTPI Principal Archaeology Advisor (GLAAS) Direct line: 020 7973 3215 Email: [email protected] Historic England | 1 Waterhouse Square 138 – 142 Holborn | London | EC1N 2ST "
Members of the Public/Businesses
Kennet Properties Limited
"Plots 6 and 34 These two plots form part of Deepham's Farm Road, a gated private road forming part of the wider estate belonging to Kennet Properties Limited in this area. Kennet Properties is a subsidiary company within the Thames Water Group. These plots are described in the statement of reasons, together with Ardra Road as being part of the Northern Access to the site. It further states that the land is required for both a construction access and the provision of a permanent secondary access to the Ecopark, together with an emergency access. In respect of Plot 34 the statement of reasons says that the land is required to lay pipes and services within the land. The Guidance on the use of CPO powers in DC orders advises: 8 The applicant should be able to demonstrate to the satisfaction of the Secretary of State that all reasonable alternatives to compulsory acquisition (including modifications to the scheme) have been explored. The applicant will also need to demonstrate that the proposed interference with the rights of those with an interest in the land is for a legitimate purpose, and that it is necessary and proportionate. And 11 The applicant should be able to demonstrate to the satisfaction of the Secretary of State that all reasonable alternatives to compulsory acquisition (including modifications to the scheme) have been explored. The applicant will also need to demonstrate that the proposed interference with the rights of those with an interest in the land is for a legitimate purpose, and that it is necessary and proportionate. The applicant is not seeking to acquire the freehold interest in Plot 7 (Ardra Road), yet is doing so in respect of Plots 6 and 34. The owner objects to the acquisition of the freehold in the land when all that is needed is either a right of way or an easement to lay and use pipes and services. The owner would be willing to grant a right of way or an appropriate easement limited to the purposes sought and therefore the CPO of the freehold interests goes further than is necessary and proportionate. "
Non-Statutory Organisations
Lee Valley Regional Park Authority
"The Lee Valley Regional Park Authority’s representation should be considered together with comments made in response to the Phase Two consultation (letter 2nd Oct 2015). An amendment is sought to the DCO, Schedule 2 ‘Requirements’ to ensure the Authority’s statutory consultee requirements are fully met (under Section 14 of the Lee Valley Regional Park Act 1966), specifically in relation to the provision of further details and consultation by the local planning authority on matters identified under sections (3) to (5), (10) to (12) and (15). The Design Code Principles and Code of Construction Principles address a number of the Authority’s concerns and provide some comfort in respect of how the proposed development will impact upon the ecology, recreational use and general amenity of the Regional Park during construction phases and operation. However the detailed design stages, choice of materials, the landscaping scheme and ecological commitments have yet to be finalised. It is understood this will not be possible until the DCO is approved and a contractor appointed. Given the lengthy timescale of this project (earliest start date of 2019/20) ecological and landscape commitments and their delivery in respect of the Lea Valley SMINC and other Park areas will require further assessment. Further detail is also required on management of landscape and habitats and provenance of species. The Authority would also wish to be consulted on the final treatment of the ‘public’ entrance to the EcoPark from Advent Way and along Lea Park Way as this will continue to be a ‘gateway’ to the Regional Park. There is also a need to maintain access to and along the existing strategic foot and cycleways. Associated with this is the final landscape treatment and reinstatement of the Temporary Laydown area which forms part of the Regional Park, adjacent to the Lea Valley SMINC and Chingford Reservoirs SSSI. Whilst we understand that this awaits the outcome of discussions with other parties/landowners; given the scale of its potential impacts on the Regional Park as much information is required at the outset of the process and this should not be left to ‘Requirements’. The Lee Valley Regional Park Authority is prepared to consider granting the NLWA the legal rights to use the land they require to implement the North London Heat and Power Project. The Authority’s preferred mechanism to achieve this is via a lease arrangement for a term of 60 years by which the use, landscaping, security issues, repairs, maintenance and management of the land and structures are agreed and made legal obligations under the lease terms. "
Local Authorities
London Borough of Enfield
"Dear Sirs Although as host authority I recognise we are automatically registered as an interested party, I understand it would be of assistance if we were to indicate the main outstanding issues. We continue to have a positive dialogue with the NLWA and should be in a position to agree a Statement of Common Ground shortly. However, presently the matters that remain to be agreed are focused around 1. The relationship of the lay down area as a component of the flood relief strategy for the regeneration of Meridian Water and proposals for its reinstatement; 2. The proposals for dealing with the vacant site once the Energy form Waste facility is demolished to minimise any adverse visual impacts; 3. Ensuring appropriate connections to any Lee Valley Heat Network are incorporated into the development proposals 4. Finalising discussions on elements of the s106 Agreement although we again envisage agreement on this being reached shortly; 5. Agreeing necessary transport mitigation measures to ensure there is no adverse impacts on the surrounding highway network and measures to maximise sustainable transport modes are maximised. 6. The appearance of the observation platform in terms of its design and relationship to the development and the wider Lee Valley corridor Our Stage 2 Consultation response also sets out in more detail some of these issues. If any further clarification is required, please contact me on Robert Singleton on 020 8379 3837"
Other Statutory Consultees
Thames Water Utilities Limited
"Plots 16, 18,19 and 20 are owned by TWUL and are stated to be required for the purposes of a temporary laydown – Works No 5. The draft DCO sets out that these works involve: (i) Areas of hardstanding (ii) fencing, hoarding etc; (iii) security facilities (iv) vehicle parking (v) office and staff welfare accommodation (vi) storage, fabrication, laydown area (vii) foul and surface water storage/attenuation and pumps (viii) utility works (ix) the creation of access from Lee Park Way; and (x) restoration of the area.” The land in question is TWUL retained Operational Land and forms part of the land associated with the William Girling Reservoir. The site is secured for security and health and safety reasons and there is no public access. TWUL’s retained operational land can only be released for other uses should it be proven that it is not required either now or in the foreseeable future for Thames Water’s operational use. However, Thames Water are currently co-operating with NLWA in this respect and TWUL's operational clearance request under the OFWAT Guidance Note (April 1996) "Disposal of Land by Appointed Companies" under the Water Act has been submitted but has not yet been granted by TWUL. As such this plot has not yet been declared surplus to operational requirements. If clearance is forthcoming TWUL will require the land to be reinstated to its present condition, including the same ground levels, once it is no longer required by the applicant. However, TWUL has not been provided with a detailed restoration plan setting out an agreed specification for the return of the land to its current condition and levels. The Planning Statement sets out at paragraph 6.10.16 that : “The Temporary Laydown Area is a temporary feature which will be operational for the duration of the construction and demolition of the existing EfW facility only, a period of approximately five years, after which this land will be returned to its original state. When construction and demolition is complete the Draft DCO requires the Temporary Laydown Area to be reinstated to its former condition, or other such reasonable and proportionate condition as LB Enfield may approve” TWUL only agree to the use of its retained operational land on the basis that it is returned to its existing condition so as not to restrict any future use. It would not be acceptable to reinstate the land in a way which could restrict future use. In addition the DCO Drawing - D_0008 – “Drawing of Indicative Soft Landscaping Types of reinstatement of Temporary Laydown Area” proposes to reinstate the plot as “meadow species-rich mown grass” with areas of “Habitat enhancement and creation including open woodland, tree planting and scrub planting” . These areas of habitat enhancement are scattered across the site and have not been agreed with TWUL. Such scattered woodland planting across the site would constrain future uses. Until a detailed restoration plan has been agreed TWUL objects to the inclusion of these plots within the Order. Plot 22 is owned by TWUL and is stated to be required for the diversion of various pipes and infrastructure. The land in question is TWUL retained Operational Land and forms part of the land associated with the William Girling Reservoir. To date insufficient information has been provided to TWUL to enable it to assess whether and if so how the works can be undertaken without detriment to TWUL's operational requirements. "
Other Statutory Consultees
The Environment Agency
"Dear Sirs, Following the notification that the Planning Inspectorate has accepted the Development Consent Order (DCO) application for the North London Heat and Power Project (NLHPP) please find a summary of our formal relevant representations – provided by email 22 December 2015. The Environment Agency has a responsibility for protecting and improving the environment, as well as contributing to sustainable development. As part of our regulatory role we must ensure that the design, construction and operation of the NLHPP reduces environmental impacts, mitigates unavoidable impacts and maximises positive environmental opportunities. An Environmental Permit is required under the Environmental Permitting (England and Wales) Regulations 2010. This process is separate from the DCO and has been initiated by the applicant. In addition, the applicant is also required to apply for a ‘Flood Defence Consent’ (FDC) for any works in, under, over or within 8 metres of the top of bank of any watercourse designated as a ‘main river’ as per the requirements of the Water Resources Act 1991 and the Thames Land Drainage Byelaws 1981. Areas covered within our formal response include; • Flood risk & mitigation We are broadly content with the level and detail of the Flood Risk Assessment and proposed mitigation. • Bridges We have no objections to the principle of the proposed bridge over the Enfield Ditch (main river), although further details are required. The applicant will need to demonstrate free passage of mammals and allow connectivity of riparian habitats. • Ecology We welcome the plans to improve and enhance the Enfield Ditch and the proposed lighting strategy. However, we wish to see a requirement to maintain the riparian buffer zone. • Groundwater protection and land contamination The site is located within a Source Protection Zone for public water supplies. The proposal includes the excavation of lower permeability strata that overlies the Chalk aquifer thereby increasing the vulnerability of the underlying aquifer. We believe that the DCO should be updated to include additional requirements, listed below, in order to protect the water environment: - Verification Plan - Verification report - Long-term monitoring - Unsuspected contamination - Piling - Lateral and vertical limits of deviation; We have concerns regarding vertical deviation due to the potential increased risk to groundwater. • Discharge of requirements and appeals The current timeframes for responding to consultations for the discharge of requirements are inadequate. We therefore request that timeframes within the DCO are amended to allow us a minimum of 21 days to provide our response on these matters to the relevant authority. We would also like the appeal provisions relating to the discharge of requirements to be amended so that appeals are determined by arbitration. Mr Andy Goymer Planning Advisor Telephone: 0203 025 5486 E-mail: [email protected] Address: Environment Agency, Ergon House, Horseferry Road, London SW1P 2AL Please click on link below to view formal relevant representation from the Environment Agency: http://infrastructure.planninginspectorate.gov.uk/wp-content/uploads/2016/01/Environment-Agency-Relevant-Representations.pdf If the above link does not work please copy and paste into your browser "
Other Statutory Consultees
Transport for London
"Representation by Transport for London (‘TfL’) to the North London Heat and Power Project application for development consent promoted by the North London Waste Authority (reference EN010071) Transport for London (TfL) wishes to make a relevant representation to the application for development consent for the North London Heat and Power Project promoted by the North London Waste Authority in order to protect its position in light of TfL land in the area, which is located within and in close proximity to the proposed order limits, and its transport and highway authority functions. The documentation and plans submitted for the scheme have been reviewed in relation to impacts on TfL’s land and functions and TfL has been liaising with the promoter in relation to the impacts of the proposed scheme on its land and its functions. It will continue to do so in order to ascertain what the impacts are likely to be and what protections will need to be put in place in order to ensure that its land interests are adequately protected and in order to ensure that its functions as transport and highway authority are not compromised. TfL is generally supportive of the application but wishes to ensure that the construction and operation of the facility will not have a detrimental impact on the TfL road and bus networks as well as on the local highway and the safety of road and public transport users. TfL’s preliminary view is that the applicant’s Transport Assessment, as currently available, appears to consider these issues appropriately and TfL wishes to ensure that the mitigation proposals within the Transport Assessment are complied with through the mechanism of requirements and a section 106 Agreement, as appropriate. In addition, TfL wishes to ensure that any impacts are limited as far as possible and that any works and decisions are made in consultation with it. The above are the issues of main concern to TfL but are not necessarily exhaustive. Further outstanding issues will be highlighted in future written representations and other evidence. In particular, TfL reserves the right to raise other matters of concern as part of the examination process, as further information about the project and promoter’s proposed powers over TfL’s land come to light during ongoing discussions and the examination process. In the meantime, TfL confirms that it will continue liaising with the promoter with a view to reaching a satisfactory agreement."
Members of the Public/Businesses
North London Waste Plan
"The summary of points to be made will be as follows • How the North London Waste Plan (NLWP) is being drawn up by the seven north London boroughs of Barnet, Camden, Enfield, Hackney, Haringey, Islington and Waltham Forest as waste planning authorities • Scope of NLWP comments to PINS. Comments are from Boroughs as Waste Planning Authorities. Individual boroughs may comment separately on the DCO proposals, having regard to specific details and any potential impacts for their areas. Therefore, this response is without prejudice to any views expressed individually by boroughs in their broader role as local planning authorities. • Purpose of the NLWP • Relationship of the North London Waste Authority (NLWA) to the NLWP • Progress and timetable of the NLWP • Relationship of the NLWP Data Study to the NLWA assessment of need • The key elements and preferred approach of the draft NLWP • Results of the consultation on the draft NLWP that took place between 30 July and 30 September 2015 • Is the application for the DCO for the NLHPP at Edmonton EcoPark consistent with the emerging NLWP? "
Other Statutory Consultees
Public Health England
"Thank you for the consultation regarding the above development. Public Health England (PHE) welcomes the opportunity to comment on the proposals at this stage of the project and can confirm that:- We have assessed the documentation submitted with the application for a development consent order and can confirm the following: 1. PHE is satisfied with the methodology used to undertake the environmental assessment. 2. PHE understands that the applicant has engaged with the environmental health officers at LB Enfield, LB Waltham Forest and LB Haringey to agree the methodology as set out in the ES (AD06.02) and that the officers agreed with the proposed methods and scope of the air quality assessment. 3. Emissions from the proposed development will be controlled via the Environmental Permitting regime, under the provisions of the Environmental Protection Act 1990. The permitting regime is administered by the Environment Agency (EA), separately from Nationally Significant Infrastructure Planning and PHE will be formally consulted by the EA as part of the permitting process. We will provide detailed comments at that stage. 4. Potential impacts arising from historic ground contamination have been considered in the draft development consent order and there is a requirement that a scheme to assess and manage these impacts, be agreed with the relevant Planning authority in consultation with the Environment Agency. As the Local Authority / Environment Agency are the relevant regulatory authorities with regard to land contamination, PHE is satisfied that this matter should be adequately controlled and has no further comment. 5. Document AD05.12, The Code of Construction Practice, includes provisions for the management, assessment and control of dust, odour, pollution incidents, land contamination, plant and vehicle movements, and impacts on water resources and waste management. The document proposes full consultation / agreement with the appropriate regulatory bodies. 6. There still appears to be no reference to an electric and magnetic field (EMF) assessment in the submitted documentation. Given that this project will be generating significant amounts of electrical power the applicant should be able to either demonstrate that risks from EMF can be scoped out or that suitable assessment / mitigation has been undertaken. PHE does not wish to register an interest in this matter but we recommend that the planning inspector satisfy themselves that the applicant has fully considered this matter prior to the granting of a development consent order or that the matter is being addressed outside of the Nationally Significant Infrastructure Planning regime. We have no additional comments to make at this stage and can confirm that we have chosen NOT to register an interest with the Planning Inspectorate on this occasion. Please do not hesitate to contact us if you have any questions or concerns. "