The Twickenham Station Scheme: The June Letter to Solum

• [Jul 04]: THIS is the full text of the letter from the LBRuT Planning Department to Maddox & Associates, who act for Solum Regeneration re the Station redevelopment scheme [# 11/1443/FUL], requesting additional information. It is published here to aid public debate on this important proposal. The application remains 'suspended' until this information has been supplied and validated, when formal public consultation on the scheme will begin.

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22 June 2011

Contact: Mr. B. Staff Contact No.:020 8891 7300

Mr D. Maddox

Maddox & Associates 70-74 Cowcross Street London EC1M 6EJ

Dear Mr Maddox

Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999.

Town and Country Planning Act 1990 (as amended}.

Town and Country Planning (General Development Procedure Order) 1995. Twickenham Station, London Road, Twickenham Application Ref: 11/1443/FUL

On 9 May 2011 you submitted the above planning application on behalf of Solum Regeneration. This application was accompanied by an Environmental Statement (ES).

Further to my letter to you dated 25 May 2011 regarding the suspension of determination of the application reference 10/3465/FUL, the London Borough of Richmond Upon Thames has again considered the Environmental Statement submitted with the application and, pursuant to Regulation 19 (1) and 19 (10) of the Town and Country Planning (Environmental Assessment}( England and Wales) Regulations 1999, is of the opinion that the document should contain additional information in order for it to be an Environmental Statement. This will require amendments to both the Environmental Statement, its appendices and the non-­technical summary as appropriate.

Once the further information has been provided, the London Borough of Richmond upon Thames will advertise the availability of the information. The advertisement will explain where the information can be viewed for a period of 21 days from the date of the advertisement. The London Borough of Richmond upon Thames will also write to statutory consultees notifying them that this information has been received and requesting comments within a 21 day period.

The information required under Regulation 19 (1) and 19 (10) is detailed in the attached Detailed Comments on Environmental Statement and has in part been informed by the European Commission's Guidance on EIA - EIS Review Checklist (http://ec.europa.eu/environment/eia/eia-guidelines/g-review-full-text.pdf) and the relevant sections within the Scoping Opinion dated 10 June 2010. A detailed list of issues is appended but in principal the environmental impacts requiring additional information and reassessment! mitigation are as follows:

Ecological Impacts to River Crane:

• Constructional - Noise and artificial light

• Operational- Noise, artificial light, overshadowing and wind impacts not covered sufficiently

Wind:

• No data or forecast wind impacts on pedestrian environment to Mary's Terrace and River Crane

Cumulative and Residual Impacts:

• Approved housing development at the RFU not assessed in terms of cumulative impact on available education places (primary and secondary)

• Station Platform Lengthening proposals - impact on queuing on event days

I have not highlighted those matters raised in my previous letter related to construction, education, parks, noise and vibration, transport and day/sunlight given that these are issues currently under discussion and where it is evident that some progression [sic] is being made.

One issue not raised in my previous letter that I would like to advise you on is that an independent assessment of the solar glare section is currently being undertaken and it is immediately obvious that no impact on train drivers has been assessed. Clearly as this is still being assessed there may be other areas of this chapter that may require additional information or elaboration.

Whilst the application has been validated, I should advise that under Regulation 19 the Council is required to suspend determination of the Planning Application until the requested additional information has been received and look forward to hearing from you accordingly. Upon receipt of the requested information the Environment Statement and Planning Application will be re-instated and formal consultation commenced with the local community.

Yours sincerely

Jon Freer

Assistant Director of Environment

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Detailed Comments on Environmental Statement

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Chapter 2: EIA Methodology

• Not all relevant national and local agencies have been identified with this chapter in terms of collecting baseline data. No reference is made to the Primary Care Trust INational Health Service, Transport for London or Thames Water.

• With the above in mind it is not evident that full consultation was carried out during Scoping and the views of these consultees has not been presented.

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Chapter 3: Alternatives and Design Evolution

• With regard to the 'No Development Alternative' it is not agreed that an adverse impact would occur as a result of this Project not materialising. No baseline situation is set out and no identification of harm is expressed i.e. no description of harm from the continued use of the station or retention of site buildings although it is acknowledged that a negative description of the station is provided.

• No identification of the harm due to the handling of event days by the station is set out such as impacts to the River Crane, local residents' amenities, road closures or other (non-rugby) rail passengers/commuters due to the continued functioning of the existing station.

• The environmental effects of the alternatives compared to that proposed are not fully addressed.

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Chapter 4: Description of Development

• Within the description of development there is no statement or assessment of the improved station facilities that have been discussed (i.e. platform lengthening, improved facilities and WCs etc).

• The form and appearance of any structures and other works is not adequately described. For example the details on surfaces, planting. fencing along the river and the play area adjacent to footbridge is lacking.

• In terms of the description of new populations/business communities and their characteristics, this is not adequately addressed. In terms of child yield from the development the document does not tally with the yield set out in the Planning Obligation Strategy SPD. Furthermore the likely characteristics of the D2 use are not described.

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Chapter 5: Planning Policy

• It is not accepted that limited weight should be given to the SPD for Twickenham Station.

• There is no detail of the Development Policy Development Plan Document polices?? and these are currently being tested at an Examination in Public.

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Chapter 6: Site preparation and construction

• With regard to Chapter 6, more information is required within Table 6-1. This table requires at least two more labels setting out start/finish dates and the duration of the operation of the existing station.

There is no mention of Block C (other than fit out), or the riverside walk construction programme within this table. Whilst no gantt chart has been set out in this chapter the gantt chart in Chapter 17 and appendix A-5 is out of date which references construction in February 2011. As such a new updated and detailed gantt chart is required.

• With regard to the programme of implementation there is no mention of bus stops and temporary transport facilities or works to the station itself (as highlighted above) and phased plans are required in terms of demonstrating the operation of the station during construction.

• With regard to the activities involved in decommissioning, commuter parking is not clear, bay displacement on Mary's Terrace and cycle space provision during construction is not mentioned and there are no details of the temporary ticket office and gantries.

• The area of land required temporarily for construction and compounds is not clearly quantified and mapped and clearer information is required with regard to paragraph 6.3.6 (i.e. is the station car park the area accessed from station yard, what is the extent of the island platform (is this the podium)? These areas should also include the bus lane and footpath closures.

• With regard to quantity of raw materials and energy needed for construction and operation there is no quantification of energy required during construction, no information on the sourcing of raw materials or details relating to the recycling and transportation thereof i.e. what is happening with platform 1 and the buildings being demolished?

• There is no information on any sub station removed or any other electricity demand from the station.

• There is no quantification of traffic movements involved in bringing workers or visitors to the site and the Environment Statement skips to mitigation.

• The Site Waste Management Plan is only in draft form and there seems to be various sections that haven't been filled in. Bearing in mind that this was completed in October 2010 a final version is required.

• With regard to construction, the impact on ecology is not considered thorough enough and with regard to construction the chapter is too vague in term of noise impact on the River Crane.

• With respect to risk of accidents and hazards, the chapter does not discuss this thoroughly such as the impact on rail services if an accident were to occur. No accident strategy is outlined or measures to prevent and respond to such.

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Chapter 7: Socio economic impact

• With regard to local employment during construction little information is supplied on this and how it will be secured. Table 7-35 sets out that construction investment is anticipated to support 37 permanent jobs directly. Elaboration of this statement is required.

• Confirmation of a local job agreement is required to support the argument of benefits towards the local economy

• Table 7-35 under the classification of 'negligible' there is no significance or time frame attributed to this.

• Paragraph 7.6.59 is based upon an impact in 2011 and not 2015 when the development is completed. Education advises that. Regeneris have apparently chosen to ignore the data, comments and links sent to Amy Gilham on 21 July, and have instead used out-of-date and irrelevant sources, e.g. 2001 Census data, the Planning Obligations Strategy (POS) 2005 and the Primary Strategy for Change 2008. The use of census data for school place planning has been repeatedly discredited as it provides a decade-out-of-date snapshot that is no longer relevant. The POS was updated by the January 2007 Cabinet Member decision that was made following the Sandy Lane planning inquiry. The Primary Strategy for Change has twice since been superseded by public documents (see below).

• What Regeneris should have used are: the S106 education calculator on the Council website, which reflects the Cabinet Member decision amendments made in January 2007; the Consultation on School Expansions Strategy 2009-2013; the St Margaret's school place planning leaflets (both available at: http://www.richmond.gov.uk/home/education and learning/schools and colleges/pri mary schools/consultation on primary school expansions.htm); and the numbers on roll that I sent to them If they had contacted me again, they would also have discovered that the Council revised Its Primary School Expansions Strategy in December 2010.

• The tables at 7. 6 53 and 7.6 58 take no account of admissions patterns, re whether children In TW1 m general, and in the proposed development specifically, would stand any chance of admission to schools within the arbitrary two- and three-mile catchment areas that Regeneris have used For example, the cut-off distance this year for admission to the closest community primary school (Orleans Infant) to the Station was Just 466 metres Demand for that school and for St Mary's, the only other primary school In Central Twickenham/St Margaret's, has risen to the extent that this year Orleans received 376 applications for its 90 places and St Mary's received 324 applications for Its 60 places As a result, there are currently 50 children m TW1 for whom we have so far been unable to find Reception class places for September

• The closest secondary schools - Orleans Park and Waldegrave School for Girls - are equally oversubscribed this year, Orleans Park received 1,005 applications for ItS 200 places and Waldegrave received 787 for its 200 places. Whilst we currently have spare capacity at three schools outside TW1 - i.e. Hampton Academy, Twickenham Academy and Richmond Park Academy - the Council's forecasts are that, unless new schools are established in the Interim, it will not be able to meet demand from m-borough residents Please see Section 5 at http://cabnet.richmond.gov.uk/mgConvert2PDF.aspx?ID=23720.

• For Regeneris to conclude that the development would have 'moderate adverse' or 'negligible' impact on the Council's ability to provide school places for Its residents is wholly erroneous. Taken In conjunction with the development at the RFU, and the proposed development of the Royal Mail sorting office, it would compound the Council's difficulties to the extent that demand for places could not be met within existing resources.

• Mitigation measures in terms of full Planning Obligation Strategy contribution towards both primary and secondary needs to be agreed

• With regard to the impact on health services, the PCT advises that the statement in 7 4.78 that practices close to Twickenham Station are operating under capacity does not fit With the PCT's perception

Two of the surgeries listed under 7.4.79 (Dr Kooner and the St Margaret's Medical practice) are connected to the Hounslow PCT and if these are to be included the list sizes in Table 7-10 requires updating.

The PCT does not agree that with the conclusion that there are no problems with the GP estate with particular regard to the availability of space and physical condition where there IS a significant shortfall where current space availability is compared with target space need based on list size and number of GPs.

Under paragraphs 7.4.78 and 7.6.60, the PCT advise that they have no record of consultation with Solum or Regeneris and remains unclear as to where this information and assertions are derived.

Paragraph 76.60 states that provision within 1 5km of the site covers over 46,200 residents whereas the PCT advise that the total number of patients served by Twickenham based contractors is closer to 41,000 .

Furthermore there is no appraisal of other public facilities such as sports grounds, indoor facilities and adult recreation in general.

• It is not accepted that the assessment that the Impact of this proposed development is 'minor adverse' on parks and Public open space and the rationale behind this classification lacks substance.

Jubilee gardens not identified within paragraph 7 4.88 and there is reference to figure 7 -16 which cannot be found.

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Chapter 8: Transport

• The Capita Symonds pedestrian information for the station in Appendix B is from 2007 and more up to date information is required in this respect.

• Similarly the car park accumulation count is dated from 2007 and more up to date information in this respect is required.

• With regard to the programme of implementation, the construction method statement and the construction logistics plan do not provide this detail Fig.37 in the main Transport Assessment is a diagram showing the podium construction only and some details appear here about possessions and time frame. This plan is already out of date as February 2011 is detailed as the start of London Road footway closures. The footway closure area is also shown incorrectly although changes are shown in the addendum

• The submitted documents rely on pre-commencement conditions to provide the detail on all activities involved in construction, demolition, traffic movements etc. With this in mind some detail is described such as fire brigade access during the closure of Mary's Terrace but in the main there is a reliance on conditions to provide full information.

• There is no discussion on use of alternative modes of transport such as rail for removal or delivery of construction materials.

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Chapter 9: Air quality

• Monitoring results - Doubts have been expressed regarding the accuracy of the monitoring for N02 taken at the site, even after the one month of monitoring is scaled up to annualised concentrations (Table 9-7). The results come in quite a bit lower than the neighbouring Sites, as monitored by the London Borough of Richmond upon Thames over a true calendar year. Further monitoring should be carried out to establish a more accurate level. The monitoring should preferably be carried out for at least 3 months, to give greater precision on the annualised estimate. It is possible that the Air Quality Significance Criteria would be 'major adverse'.

• Air inlets - The Table 9-11 conclusion, indicating the possible advantage in venting buildings from the rear, is accepted. The building design will then need to ensure that sufficient clean air can be supplied to the rooms facing the road, when their windows are closed against the road/rail noise and air pollution. The mechanical ventilation should be acoustically treated so that noise from the rear of the property is not funnelled Into the front rooms.

• CHP emissions - the composition, toxicity and other hazards of all emissions to air produced by the Project, methods for collecting, treating and discharging these and locations for discharge of and emission and characterises of these are not fully discussed. There does not appear to be any discussion in the Environment Statement or Energy Statement about dispersion from the CHP flue/flues. If dispersion is inadequate, the risk is that flue emission odours/products of combustion could be drawn in to the properties via the mechanical ventilation ducts or through open windows.

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Chapter 10: Noise and vibration

• The London Borough of Richmond upon Thames understands that discussions have been taking place with the Environmental Health department and further information is forthcoming. This information is understood to be an update on the acoustic report and a noise model requested several weeks ago however at the time of writing no new information was produced to the planning authority. As such the following concerns still stand:

• PPG24 - it is noted from the report that the short method was used to determine the NEC categories. A requirement for longer term measurements are undertaken in order to establish more accurate ambient and background noise data. Therefore we require measurements to undertaken over at least 24hour period for a weekday, under typical operating conditions of the road and rail network. Also in order to determine the lowest background noise levels in order to determine mechanical services max thresholds measurements should be undertaken over a weekend period to include a Sunday (day, evening and night).

• The PPG24 assessment must also include the nighttimes LMAX levels from train movements and indicate if this a determining factor as (1 Night-time noise levels (23.00 - 07.00): sites where individual noise events regularly exceed 82 dB LAmax (S time weighting) several times in any hour should be treated as being in NEC C, regardless of the LAeq,8h (except where the LAeq,8h already puts the site in NEC D).

• Mechanical Services- the London Borough of Richmond upon Thames acoustic design criteria for this site is a BS4142 rating level of -5 (-10 if any tonal or discreet [sic] component) and must also comply with BS8233 good criteria.

• PA Noise - The acoustic report to demonstrate the affect of PA announcements on the proposed development, bearing in mind the content of such noise no just the absolute level is required. Where appropriate an intelligent PA system should be employed.

• 10.7.2 Vibration- Details of the vibration magnitude with height to be included in the report and the types of mitigation that maybe required to mitigate this.

• 10.7.2 Point 4- LMax levels included in order to determine the necessary mitigation.

• A noise model shall be provided which includes horizontal and vertical grid noise contours to demonstrate the affect of transportation noise on new and existing residential receptors with and without the proposed development in place. The London Borough of Richmond upon Thames uses Bruel & Kjaer Predictor noise modelling software, we would ideally want the model in a format that can be imported into predictor.

• Sound Insulation between commercial to residential units - London Borough of Richmond upon Thames design standards - Approved Doe E plus 5 to 10.

• Kitchen Extraction - Odour risk assessment and mitigation is required as set out by DEFRA.

• Construction- The acoustic report should include the assessment methodology detailed within Bs5288 2009 in order to determine the underlying ambient levels, the predicted significance thresholds and if the predicted construction and vibration thresholds will be exceeded. If this is the case what mitigation as detailed within BS5288 will be employed including the use of noise insulation grants?

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Chapter 11: Ground conditions

• As previously mentioned, the Site Waste Management Plan is only in Draft form and there seems to be various sections that haven't been filled in. Bearing in mind that this was completed in October 2010 a final version is required.

• There is no mention of toxicity in the submitted report.

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Chapter 12: Water resources

• The London Borough of Richmond upon Thames can confirm receipt of the revised Flood Risk Assessment and Drainage Management Plan received on 11 and 12 April 2011 respectively and will receive comment from the statutory bodies in due course.

• No reference has been made to the Thames River Basin Management Plan and mitigation and site enhancement needs to be integrated into the Environment Statement. New development near the River Crane must seek to enhance and restore sections of the river and river corridor in line with this Plan which also highlights mitigation measures that are designed to help rivers achieve good status. (This is a statutory plan that was prepared by the Environment Agency and approved by the Secretary of State in December 2009; it sets out what is required to improve the water environment over the next 20 years and is a key component of the EU Water Framework Directive, the aim of which is to achieve set environmental quality objectives. Policy 7.24 of the draft London Plan refers to the Thames RBMP in the main policy text. Draft policy DM SD 9 of the DM DPD refers to the Water Framework Directive under paragraph 3.1.68).

• With regard to paragraph 12.6.15 a commitment should be made to maintaining the condition, access to and the minimum standards of protection of the existing flood defence for the lifetime of the development.

• No part of the submitted FRA refers to the 8 meter buffer zone between flood defences/river banks and development required by the Environment Agency. Where encroachment into the buffer zone is required, appropriate justification and mitigation should be provided within the FRA and this is not the case. Details of the load within this area are also required to demonstrate no adverse impact on the stability of the existing river bank.

• With regard to the use of Sustainable Urban Drainage Systems, the surface water drainage hierarchy set out in London Plan Policy 4A.14 and the Development Management Plan policy DM SD7 has not been followed.

• The proposed footpath along the river crane is welcomed but a large brick wall separates the site and the river and it would be disappointing to see a new proposed riverside square and riverside walk without being able to see the river. Confirmation of this wall's removal and details of the proposed timber screen and metal rail fence (drwg no W103556Y04) as shown on the landscape master plan are required.

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Chapter 13: Ecology

• This chapter does not consider the extent of the shadows cast over the River Crane and its implications on the ecology of the river and its banks and the combined effect of the new buildings and extra tree planting should also be considered. The overshadowing impact on the proposed ecological site enhancements and existing ecology of the site also needs assessment

• This chapter and chapter 15 regarding wind do not consider the implications of wind generated by the buildings on the proposed ecological site enhancements and existing ecology of the site and the River Crane and its banks.

• A variety of deadwood habitats is mentioned within the trees section of the identified habitats but this has not been considered or evaluated as a separate habitat type.

• Given the proximity of the River Crane appropriate precautionary measures will be required to ensure protection of this sensitive ecological feature. Stating that the River Crane and associated habitats will be maintained throughout the development is not sufficient and detailed information to guarantee proper precautionary systems of work and protective measures must be provided as should a full method statement for the management of Japanese knotweed. Can you confirm that the removal and control of Japanese knotweed to prevent the risk of downstream transfer is set out within this chapter?

• The discounting of the presence of herpetofauna without carrying out any survey is not acceptable.

• Recommendations for appropriate ecological mitigation, compensation and site enhancement are missing and should be provided.

• With regard to lighting (13.6.3), no details have been submitted that plot lighting columns, light spillage, lux levels and the effect of mitigation measures. Confirmation is thus required from a lighting consultant that the impact of the lighting will not have an adverse impact on ecology, secure by design principles and neighbour amenity. The use of sodium lighting is generally recommended by ecologists however there are other negative environmental Impacts from sodium lighting including higher energy use and because the lamps are large it is more difficult to control the light emitted resulting in higher levels of spill and more light than necessary

• Details of the protective fencing beside the Crane Path referred to in paragraph 13.6.3 should be submitted.

• Paragraph 13.5.2 references a 70m area that would be lost to facilitate the footpath however there is no detail of this and it is not defined on plan. The defined development boundary or zone of ecological influence is thus required.

• The impact of noise on the River Crane is not fully addressed and details of both human activity and construction on the ecology of this area is required.

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Chapter 14: daylight, sunlight, overshadowing and solar glare

• This chapter and its appendices do not differentiate between the shadows cast by the development and the existing built form beyond the northern bank of the River Crane i.e. the blue shade does not extend beyond the river bank.

• It is also noted that the shadow cast by the approved hotel adjoining Regal House to the south has not been shown or its implications on the station's plaza or

development contained within the southern wing of Block B and a conclusion of negligible impact is made without demonstration.

• There is no consideration within this chapter of the impact of the development on itself, i.e. levels of light and glare between Block A and B or comment on the impact on the new plaza and other public spaces proposed.

• No consideration has been given to the impact of daylight, sunlight and solar glare on the rooms within the approved hotel now under construction. It is not accepted that consideration should only be given primarily to residential properties.

• Within the chapter and associated appendices there is no 'skylight indicator chart' submitted to demonstrate the VSC figures set out in Appendix I.

• Under paragraph 14.3.32 can clarification be given to what these loss values are and where these are?

• No difference has been made between primary and secondary windows tested for BRE compliance in the document or the tables submitted.

• Paragraph 14.6.2 references no. 5 Cole Park Road although this property is not referred to elsewhere. Can you confirm that this is a typographical error?

• Table 14.3 and 14.4 do not tally in terms of the number of windows tested. The title 'windows/rooms' is confusing and logically should table 14.4 refer to rooms solely?

• The information on solar glare is currently being assessed and the London Borough of Richmond upon Thames reserves the right to offer further comment on this part of the chapter once this exercise has been completed.

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Chapter 15: Wind

• This chapter does not consider the impact (cumulative or otherwise) on the pedestrian environment and amenity of those occupants residing on Mary's Terrace to the east of the site nor to the River Crane Corridor.

• The independent assessment of the chapter disagrees with the assessment of the wind conditions around both the existing site and the proposed development and that wind conditions are likely to be more onerous than those predicted.

• Paragraph 15.3.11, the term 'category' is used but this term is not explained properly in the text and an assumption has been made that this is a prescribed usage of pedestrian activity.

• Under paragraph 15.4.5 assertions are made about the expected wind conditions around the existing site however the basis of these is not stated and the localised effects of the existing buildings are not taken into account by the BREVe2 methodology used.

• With regard to the proposed balconies, the Environment Statement sets out that the wind effect for downwind balconies is negligible on calm summer days however no assessment is made outside of these conditions.

• There is a contradiction between paragraphs 15.6.4 and 15.7 where it is stated that wind conditions at the entrances in the thoroughfare between the buildings are 'one category windier than desired (i.e. unsuitable) for entrances yet in section 15.7 it is stated that the effects are 'negligible'.

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Chapter 16: Electronic interference

• The chapter identifies that 98 dwellings would be affected however the actual addresses are required particularly for identifying mitigation and for S 106 purposes.

• No information is provided in terms of the increase in height required for aerials and the degree of affect is not discussed.

• The information which has been submitted in respect of electronic interference is currently being assessed and the London Borough of Richmond upon Thames reserves the right to offer further comment on this part of the chapter once this exercise has been completed.

• The provision of telecommunications infrastructure is not mentioned or indeed details on the blocking/reflection of signals from the apparatus on Regal House. As such the London Borough of Richmond Upon Thames is awaiting comments from the operators of radio equipment on Regal House to establish the impact.

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Chapter 17: Cumulative and Residual Impacts

• In terms of cumulative impact it is noted that the housing development to the north of Twickenham Stadium has not been considered or assessed particularly in terms of the impact on education (primary and secondary).

• The impact on event day queueing from the station platform lengthening has not been considered or assessed.

• Given that it is not agreed that the impact on secondary school places is negligible Table 17.1 would require a section on mitigation for such.

• Arrangements to monitor and manage residual impacts are not clear and no negative effects of mitigation are described i.e. the impact on lighting along the River Crane, the impact of providing a riverside walk on the public open space in Moormead Park.

• Given the comments on the chapter relating to wind, mitigation measures will be required to be identified within Table 17-1.

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