thames desalination plant report by e8ExQFH

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									                                                                     planning report PDU/0953/01
                                                                                  13 October 2004

                                                 Desalination plant, Beckton
                                                                  in the London Borough of Newham
                                                              planning application no. P/04/1102


Town & Country Planning Act 1990 (as amended); Greater London
Authority Act 1999; Town & Country Planning (Mayor of London) Order
2000 – strategic planning application stage 1 referral

Construction of a water treatment plant incorporating desalination
technology, an intake form the River Thames and an electricity
substation, the laying of water distribution pipelines within the sewage
treatment works, retention of the pilot plant for operational purposes and
the use of land in connection with construction activities.

Context
1      On 12 July 2004 Newham Council consulted the Mayor of London on a proposal to
develop the above site for the above uses. Under the provisions of the Town & Country
Planning (Mayor of London) Order 2000 the Mayor has the same opportunity as other
statutory consultees to comment on the proposal. This report sets out information for the
Mayor’s use in deciding what comments to make.

2      The application is referrable under Category 3D of the Schedule of the Order 2000:
“Development –

    (a) on land allocated as Green Belt or Metropolitan Open Land in the development plan in
        proposals for such a plan, or in proposals for the alteration or replacement of such a plan; and

    (b) which would involve the construction of a building with a floorspace of more than 1,000
        square metres or a material change in the use of such a building.”

3     If Newham Council subsequently decides that it is minded to grant planning
permission, it must first allow the Mayor an opportunity to decide whether to direct the
Council to refuse permission.

4       The environmental information for the purposes of the Town and Country Planning
(Environmental Impact Assessment) (England and Wales) Regulations 1999 has been taken
into account in the consideration of this case.

5      The Mayor of London’s comments on this case will be made available on the GLA
website www.london.gov.uk.

Site description

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6       The proposed development site, with an area of approximately 9.1 hectares, is
contained in a disused portion of land currently occupied by the operational Beckton Sewage
Treatment Works. The sewage treatment works site lies within the tidal floodplain of the
River Thames Estuary and as such is low lying and flat and is protected from flooding by
extensive flood defences that line the river. The site is relatively open in appearance as it
contains a number of low-lying structures such as open, ground level storage tanks (most
recently utilised for sludge storage) and precipitation and re-aeration lanes associated with
the historical use of the sewage treatment works. As a result of its disuse this area is
relatively overgrown and quite green in appearance. The re-aeration structures and
precipitation lanes are currently being demolished.

7       The site lies within the London Borough of Newham and is bounded by the Roding
River to the east (which forms the boundary with the London Borough of Barking &
Dagenham) and by the River Thames to the south. Further south, across the River Thames,
are the boroughs of Bexley and Greenwich. The site is within an area designated in the
Newham UDP as Metropolitan Open Land (MOL) and the land around the perimeter of the
site and the Beckton Sewage Treatment Works is designated for its ecological value as a Site
of Nature Conservation Importance (SINC). The River Thames is designated as a Site of
Metropolitan Importance for Nature Conservation. In addition, the southern and eastern
edges of the site are identified within the Newham UDP as part of a ‘Green Chain’ (a series
of elongated green spaces which ideally incorporate footpaths/cycle paths to link broader
areas of open space).

8       The land immediately north and west of the site contains the operational part of the
sewage treatment works. This large tract of land contains a variety of structures including
the visually dominant sludge powered generator building (approximately 35 metres in
height) and associated flue (60 metres) which is located centrally on the site and adjacent to
the sewage treatment works office complex. In the area immediately west of the
development site is the old engine/pump house which forms part of the original 19th
century sewage works. This area is somewhat overgrown and is also disused. Beyond this
to the west are thirty-six large concrete sludge storage tanks. These structures are also
visually dominant within the landscape.

9      The general area is extensively developed, with little in the way of open space and is
predominantly industrial in character. Surrounding activity comprises a mix of uses,
predominantly employment, but also leisure and retail uses. The A13 (main arterial London
to Essex trunk road leading out to the M25) is located approximately 400 metres north of
sewage treatment works and to the west is Royal Docks Road.

10     The wider area is dominated by the Royal Docks which is undergoing extensive
redevelopment and also contains the London City Airport, located approximately 2 km
south-west of the site. Other key features of the area include the former Beckton Gas Works
south-west of the site and the Roding Barrier located to the south-east within Barking &
Dagenham borough. Beyond the industrial estate, to the east, is Barking Reach, an
opportunity area within the London Plan for which growth of up to 10,000 new homes in the
period up to 2016, is planned.

Details of the proposal
Description of the water treatment process
11       The water treatment process proposed can be split into four stages as outlined below:


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        Intake – the intake works will pump water from the River Thames into a salinity
         buffering tank. A new piled fixed pipeline is proposed separate from the existing
         jetty that was previously used to export sludge from the site via the River Thames.

        Pre-treatment – the water extracted undergoes a series of pre-treatment processes
         within four salinity buffering tanks (utilising the existing ground level storage tanks)
         to remove solids and prepare the water so that it achieves the required quality before
         it passes through into the reverse osmosis plant.

        Water treatment (Desalination) – The reverse osmosis process reduces the
         concentration of dissolved salts by forcing the pre-treated water through a series of
         spiral wound membranes at high pressure, resulting in the removal of dissolved
         solids. This process also results in the rejection of bacteria and partial rejection of
         dissolved organic compounds.

        Treated Water – the treated water undergoes a final chemical treatment to ensure
         compatible taste and quality. Lime and carbon dioxide are added to the water at this
         stage as the RO process strips the hardness out of the water. Following this the
         water enters the pumping station and is pumped to Woodford Reservoir (14 km
         north-west of the site) through the proposed distribution pipeline. Waste products
         would be piped into a separate chamber adjacent to salinity buffering tank number 1
         before being mixed with the sewage treatment works effluent in the effluent channel
         and subsequent discharge into the River Thames.

Proposed structures
12     The proposal would require the construction of a number of structures to enable the
water treatment process.

        Intake – The intake pumps extract water from the Thames and this is taken via 2 x
         1400mm diameter pipes to the salinity buffer tanks. The pipes are supported on a
         piled trestle structure separate from the jetty. The pipes pass over the flood defence
         wall and underneath the riverside walkway. Wedge wire screening and an acoustic
         fish deterrent will be incorporated into the design.

        Pre-treatment – pre-treatment processes are generally housed within open structures
         or small individual buildings. The storage tanks will be converted for use as salinity
         buffer tanks. From here water passes on to a further treatment process situated
         within a concrete structure approximately 5 metres in height and covering a plan
         area of 77m x 30m. Water then passes from the clarifiers into a holding tank.
         Attached to this is the clarifier pumping station, a building of approximately 7 metres
         in height with a plan area of 27m x 9m. Before passing to the reverse osmosis
         building the water is passed through three further filtration processes; sand filters
         (17 filters located along the southern edge of the reverse osmosis building with a
         diameter of 3.5m and a length of 15m) pre-coat filtration and cartridge filters (both
         contained within the reverse osmosis building).

        The main filtration and reverse osmosis processes will be contained within the
         largest building (75 x 75 metres in plan area with a maximum height above ground
         level of 12.5 metres) located at the eastern end of the site adjacent to the River
         Roding.


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        Treated water storage – the treated water passes through to the re-hardening area
         which is contained within a building with a plan area of 14m x 7m and a height of 4
         metres. The re-hardening building sits within a further enclosed area of 24m x 16m
         which also accommodated two silos with a maximum height of approximately 18
         metres. To the south of the re-hardening area is the chemical storage area
         comprising of 2 buildings with dimensions of 29m x 15m and 37m x 12 m
         respectively and with a height of approximately 7 metres. Further storage tanks are
         also located in this area along with additional carbon treatment accommodated
         within another building with a height of 7 metres and a plan area of 45m x 25 m.

13     The water is then passed to the on-site pumping station housed within a 30m x 21m
building and pumped via a 13 km pipeline from the water treatment plant at Beckton to the
Woodford Reservoir. The existing network would not be able to accommodate the volume
of water being transferred between Beckton and Woodford and therefore a new dedicated
1200mm diameter main is required. This current application does not seek planning
permission for the pipeline. This permission will be sought from the relevant borough
councils if planning permission is granted for the water treatment plant. The proposed
water treatment plant would be powered by connecting to the national grid.

Case history
14     Officers from the GLA were originally approached for pre-application discussions
relating to the water treatment plant in April 2003.

Strategic planning issues and relevant policies and guidance
15       The relevant issues and corresponding policies are as follows:

 Need                                London Plan
 Loss of MOL                         London Plan; PPG2
 Energy                              London Plan, Mayor’s Energy Strategy
 Biodiversity                        London Plan; the Biodiversity Strategy; PPG9
 Design                              London Plan: PPG1
 Flooding                            London Plan; PPG25
 Transport                           London Plan; the Mayor’s Transport Strategy; PPG13

Need
16       There is a clear strategic need to ensure a reliable supply of high quality drinking
water expressed within the London Plan. Policy 4A.11 of the London Plan states that the
“Mayor will work in partnership with appropriate agencies within London and neighbouring regions
to protect and conserve water supplies in order to secure London’s long term needs by:

        Ensuring that adequate sustainable water resources are available for major new development
        Minimising the use of treated water
        Maximising rainwater harvesting opportunities
        Using grey water recycling systems
        Reaching cost-effective minimum leakage levels
        Keeping under review the need for additional sources of water supply.”


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17      The London Plan (paragraph 4.22) recognises that additional water infrastructure
will be required to facilitate London’s growth and that a clean and reliable supply of water is
a fundamental need for all. The London Plan also acknowledges that the concentration of
people and services within London can lead to pressure on supply during periods of
prolonged dry weather when water usage increases.

18     Thames Water has identified a significant gap of (150 million litres (Ml)/day)
between demand and supply following a review of their water supply forecasts for London.
This gap exists even after potential leakage savings are taken into account and Ofwat
require a solution to the water supply shortfall to be implemented within 2-3 years.

19       Thames Water has stated that the need for the desalination plant is two-fold:
        to provide additional water supply in the short to medium term for London; and
        to achieve a sufficient safety margin (as required by the water industry regulators,
         Ofwat and the Environment Agency) to provide security of supply in dry weather
         conditions.

20     It is considered that further information is required to prove this need. In particular,
the more information should be submitted regarding the pattern of rainfall in London, both
annually and monthly, over the last 50 years.

Water supply and demand
21      In assessing the most appropriate option for addressing the water supply issues
above, Thames Water has undertaken an analysis of water supply and demand in London.
Predictions of future growth are reliant upon statistical information relating to population
growth, number of households, climate change and consumption levels. The London Plan
forecasts a growth in London’s population of approximately 700,000 by 2016 with a high
proportion of this growth to be accommodated in East London. Growth is also expected in
the employment sector (636,000 jobs). This level of growth will obviously require new
water infrastructure. Thames Water has indicated that even without the forecast level of
growth, rises in per capita consumption, business demand and potential source reductions (as
a result of sustainability work being undertaken by the Environment Agency) will result in
there being an inadequate supply of water to meet projected demand during dry weather
conditions, in the short to medium term, as well as to make allowance for an appropriate
safety margin.

22      The other factor that impacts significantly upon water supply in London is leakage.
Leakage rates are particularly high in London given the age of the mains infrastructure,
pressure requirements for water supply and ground movements which are particularly
pronounced within the London clays through saturation and shrinkage. The London Plan
(paragraph 4.24) recognises that a lack of progress on leakage and demand reduction will
result in a water supply deficit over the plan period (15-20 years) and wishes to closely
review this situation so that if it becomes clear that water shortages are likely then suitable,
sustainable measures can be put in place within an appropriate timeframe. Thames Water
proposes (with agreement from Ofwat) to implement a series of measures designed to reduce
the predicted gap between demand and supply and these measures include demand
management measures (leakage reduction and mains renewal, domestic water metering and
water efficiency measures) in addition to water resource development. It is not considered
that the case has been made to justify why an enhanced mains replacement/leakage
reduction programme could not be put in place to address the stated water supply shortfall.
The London Plan clearly seeks to ensure that loss of water through leakage is minimised and

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further information should be submitted to demonstrate why this policy direction cannot be
delivered.

23      Leakage reduction and mains replacement forms a major component of the
methodology for ensuring security of water supply within London. The application states
that leakage reductions are forecast to provide savings of approximately 240 Ml/day by
2009/2010, arising from 1,850km of mains replacement and from active leakage control
(patch repairs). The application states that the proposed rate of mains replacement over the
next five year period is high equating to replacement of 20% of the mains in Greater London.
The reduction in water usage as a consequence of legislation introducing free domestic
meter installation has not been as high as originally forecast and although Thames Water
continues to promote water metering the savings from this source of demand management
are relatively low. Similarly, savings associated with water efficiency measures such as low
flow devices, are lower than original projections and are likely to achieve savings of only 20
Ml/day. On this basis, in order to meet forecast future demand in dry weather conditions
and to create the necessary safety margin, Thames Water states that additional water supply
resources are necessary.

Alternatives
24      Thames Water examined a number of options. These had to meet two criteria:
delivery of water into supply in the relatively short timeframe set by Ofwat; and delivery of
the 150Ml/day volume. These options included bulk sea importation; indirect re-use of
treated effluent; desalination plant; and a combination option consisting of a range of
measures that individually could not meet the required volume but in combination could go
some way towards achieving the volume required. These comprised artificial recharge and
recovery, canal transfer, white goods replacement and grey water recycling. Thames Water
states that none of the alternative options were able to deliver water supply at the volume or
within the time frame required, in a sustainable manner at a reasonable cost.

25     Ofwat (the water industry regulator) wishes to ensure that the gap between supply
and demand is closed as soon as possible and accordingly Thames Water has developed a
strategy to achieve this. This strategy involves a programme of leak reduction through
patch repairs, replacement of mains infrastructure, water metering and water efficiency
measures and an increase in available water resources. These types of methods are
supported by the London Plan as being the most sustainable method of achieving adequate
water resources for London. However, in this instance Thames Water states that these
methods alone will not achieve the volume of water supply required.

26      The information submitted with the application goes to some length to support
desalination as the only feasible option, but it is difficult for the GLA to robustly test this
analysis. It is known that a large river regulation reservoir in south west Oxfordshire has
been suggested for some time, but is also known that this would take in excess of ten years
to design and implement. Information from the applicant indicates that this desalination
plant is needed regardless of the development of the strategic reservoir in Oxfordshire.
There may be a period when supply (as a result of the operation of the desalination plant)
outstrips demand. This will allow for easier maintenance arrangements for other reservoirs.
Furthermore, due to the cost of running the desalination plant, Thames Water has indicated
that other water supplies are likely to be used in preference to this whenever there is excess
supply. The Environment Agency and Ofwat are in support of the desalination plant.



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27     The need argument has not been robustly made and the scheme must still be
considered in the context of its overall sustainability, having particular regard to energy use,
impacts on biodiversity and MOL.

Loss of MOL
Special circumstances
28     The site is located on land that is identified within Newham’s Unitary Development
Plan as being within metropolitan open land (MOL). Policy 3D.9 of the London Plan aligns
the presumption against inappropriate development for Green Belts, set out in national
guidance, to MOL and gives both the same level of protection. Built development of the
nature proposed constitutes inappropriate development in terms of both government
guidance and the London Plan. Accordingly, such development should not be permitted
except in very special circumstances.

29      The MOL designation protects strategically important open spaces within the built
environment and can be seen as performing three valuable functions: protecting open space
to provide a clear break in the urban fabric and contributing to the green character of
London; protecting open space to serve the needs of Londoners outside their local area; and
protecting open space that contains a feature or landscape of national or regional
significance.

30     Thames Water, before choosing the proposed location at Beckton, considered a
number of alternative sites for the desalination plant. However, the range of options were
limited as Thames Water, due to the timeframe for delivering the water supply solution in
the short term, was restricted to properties already within its ownership. Of the suitable
properties (located near or adjacent to the river, of an adequate size and able to deliver
through an appropriate pipeline routing) all were within MOL.

31      In this instance the need argument outlined above, requiring additional water
infrastructure to bridge the gap between demand and supply for water resources within
London and to provide an adequate margin of safety during times of water shortages,
coupled with the lack of alternative sites, constitutes very special circumstances.

32      Newham’s UDP caveats the general presumption against development within the
MOL (paragraph 9.27) by stating that the “MOL designation is not intended to restrict potential
plans of organisations such as Thames Water in carrying out their statutory functions.” It is unclear
whether this was intended to refer to such major infrastructure proposals, as the UDP goes
on to state that in all cases, “development on MOL must complement its open character, nature
conservation value and recreational use and seek to improve access to and enjoyment of the designated
area.” Policy 3D.9 of the London Plan also seeks to preserve the openness of MOL.

Impacts on the openness and character of the MOL
33      PPG2 states that even if very special circumstances can be demonstrated, that in all
cases, the layout, design and landscaping of the scheme must preserve, so far as possible, the
openness and visual amenity of the Green Belt. The London Plan affords land designated as
MOL the same level of protection as land within the Green Belt.

34     The subject site is an existing developed site and accordingly the openness and
character of this tract of MOL is already compromised by its historical use as a waste-water
treatment facility. Despite the rather derelict appearance of the site it remains relatively

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open in character as it contains low-lying structures only (several layers of concrete
channels, old pipe work and sludge lanes). The proposal to construct a water desalination
plant will obviously have impacts on the open character of the site as a number of large
structures are proposed as, in contrast to the existing structures on site, the proposal would
result in a number of large and bulky buildings and structures.

35      The main filtration and reverse osmosis process will be housed within one building
(75m x 75m) sited at the eastern end of the site adjacent to the River Roding. This building
would have a height (above ground level) of between 10 and 12 metres. The building will be
dug into the ground to reduce its overall height and bulk but it may be possible to sink it
lower to further reduce its height and bulk. This should be explored. The style of the
building is somewhat bland in appearance and utilises metal sheet cladding with areas of
glazing, and has a curved roof profile. This could be improved by using bold, simple lines
and by increased use of glazing, particularly on the elevation adjacent to the River Roding.
The building could contribute more positively to the adjacent areas of MOL by making the
industrial processes inside more visible. The other buildings proposed (with the exception of
the silos, ranging in height to a maximum of 18 metres) would all be lower and smaller in
mass than the proposed desalination plant but area also substantial bulky buildings and
would obviously reduce the openness of the site. As the largest building on the site, the
desalination plant and the adjacent silos will be the main focus of views, and the development
would be visually apparent from a number of locations, particularly from the park adjacent to
the Roding River Barrier.

36      The proposed water intake structure would be constructed separate from the existing
jetty structure. The two intake pipes are large having a diameter of 1400mm and are
elevated above the intertidal area on steel trestles. The pipes will be tunnelled underneath
the Riverside Walkway but will be clearly visible and particularly visually obtrusive when
viewed from the walkway and from the Thames River. It is not clear whether the scale and
bulk of the structure could be reduced in any way to make it less visually obtrusive. The
visual impact of the intake structure would be lessened if it were attached to the existing
jetty. These matters should be investigated.

37      A landscape strategy is proposed to soften the building, to create distinctive
boundaries around site development and provide screening, but this screening will take time
to establish (the landscape strategy indicates planting would start to achieve some benefits
within 5 years and would be fully established within fifteen years). The landscape analysis
submitted acknowledges that, particularly when viewed from the park adjacent to the River
Roding Barrier, the desalination plant would have a visual impact. This impact needs to be
balanced against the need for plant, and should also be assessed in the context of existing
development in the immediate area. Although large, when viewed in the context of the
nearby 35 metre high sludge powered generator (and 60 metre flue) the scale of the building
may not be visually obtrusive but it will clearly reduce the openness of the MOL. The
landscaping strategy proposes formal lines of vegetation in order to partially screen the
building. Over time, the proposed landscaping would soften the appearance of the
structures, but it is preferable to improve design rather than attempting to screen the
building from view. This matter is discussed in more detail in the design section of this
report but options such as sinking the building lower, improving the form of the building
through the use of simple, bold lines and the use of lighter more transparent building
materials, should be explored.

38     PPG2 (paragraph 3.14) states that planning obligations may be used to offset the loss
of amenity/adverse impacts of development. The MOL designation promotes the

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encouraged public use and enjoyment of MOL and, where appropriate, increased access to
these areas. There is a strategic aspiration to bridge the Roding River and improve
linkages across into Barking & Dagenham and beyond, particularly in order to enhance
accessibility and connectivity of the Barking Riverside development. A framework has been
prepared for the Roding Creek area that suggests that linkages into the industrial area and
Barking Riverside could be significantly improved as part of a strategic open space and
movement network. There is a recognised need to improve existing pathway networks in
the area. It is possible that this could be achieved as part of the planned DLR extension or
independent of it. The current proposal would also result in a delay in the opening of the
Riverside Walkway as a result of construction work. Given the visual impacts associated
with the scheme, particularly the loss of openness across the site, and the delays in the
opening of the Riverside Walkway, Newham Council should seek a substantial contribution
towards construction of a bridge crossing. This would achieve a positive outcome in terms
of delivery of improved accessibility and enjoyment of the MOL along the Riverside.




Energy
39     The Mayor’s energy strategy, in addition to reducing emissions of C02, states that
London should seek to maximise its own generation of renewable energy, and sets a
renewable energy target for London. The energy strategy also states that for applications
referable to the Mayor, at least 10% of a major development site’s energy needs should be
generated from renewable energy where feasible.

Energy demand assessment
40      Policy 4A.8 requires an assessment of the energy demand of proposed major
developments. The applicant has carried out an energy demand assessment and the
development will on average consume electricity at a rate of 5.67 MW (megawatts). This is
roughly equivalent to the continuous minimum demand (known as “base load”) of
approximately 3,000 homes. This is a significant rate of consumption, which needs to be
measured against the stated need for the proposal. It is therefore essential firstly to establish
that the plant is necessary and if it is, that the process used is as efficient as possible. The
applicants have been operating a pilot plant at the site and this has allowed Thames Water
to refine the treatment process and to slightly reduce electricity demand. The preliminary
engineering design for the desalination plant predicted a maximum power demand of 20
MW. The current forecast, as a result of design improvements is 18.3 MW. These
improvements in energy efficiency whilst welcomed, are not considered to reduce the level of
energy consumption by a significant enough degree to address concerns regarding the
overall sustainability of the scheme.

Technologies considered
41      Policy 4A.7 requires the inclusion of renewable energy technologies wherever
feasible, and policy 4A.9 requires the applicant to demonstrate the proportion of the above
energy demand to be met by renewable energy technologies. The applicant has given a
commitment to securing a renewable energy solution as part of the scheme, however the
level of commitment proposed is inadequate given the highly energy consumptive nature of
the proposed plant. Furthermore, the proposed 10% renewable energy contribution would
not be in place when the plant first starts consuming energy. This is of concern. Any

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renewable energy solution reached should be able to be bought on-line concurrently with the
operation of the plant.

42      The amount of new electricity generating capacity that can be connected to a point
on the local electricity distribution network (LDN) is constrained by the “fault level” on that
part of the network. This applies equally to wind turbines as to any other generating
technology. Thames Water has claimed that the maximum new generation capacity at the
development site is 5MW. Confirmation of this figure is required from EdF, as it constrains
the range of feasible options for the site.

43      The key technical requirement with regard to power supply for the application site is
one of security of supply. The water treatment process requires maximum power to be
available at all times regardless of actual usage at a given point in time. The application
states that the importance of security of supply has particular consequences for the cost of
on-site generation, as full back-up from the LDN would be required at all times and that
funding 100% on-site renewable back-up is not viable. Therefore, the application proposes
to take energy direct from the LDN and to export any energy generated from on-site
renewable technology (such as wind turbines) to the LDN grid.

44      A number of on and off-site renewable energy options were considered by the
applicant. The use of solar photovoltaic cells was discounted due to excessive cost.
Investigations on behalf of Thames Water estimated the capital expenditure required to
achieve 2MW base load would fall within the range of £66-120 million. Further
information should be submitted to demonstrate the accuracy of these figures. Tidal and
hydro energy generation was also determined to be unacceptable due to physical and
environmental constraints and excessive capital costs. An on-site solid biomass plant was
also investigated. The assessment undertaken indicated that economic viability would
dictate a plant of at least 20MW, however the fault level could prevent this. A 1MW plant
(to deliver the 10% renewable energy required) would have a significantly higher cost with
an estimated payback period of 30+ years. The applicant also pointed to environmental
concerns relating to emissions and to increased traffic generation associated with the
delivery of bio-mass fuels.

45      The only on-site renewable energy technology that Thames Water has identified as
being potentially feasible is wind energy. Thames Water has indicated a preference for the
turbines to be built, financed and operated by a third party, and has approached Ecotricity to
undertake initial feasibility studies. Ecotricity has undertaken similar wind analysis
studies/feasibility studies for a nearby site at South Dagenham Ford and it would be useful
to see its initial conclusions to date. The applicant (in consultation with Ecotricity) has
identified a number of constraints associated with wind energy, principally the presence of
overhead power lines and microwave corridors, City Airport radar and height restrictions
and on-site space limitations. In order to determine whether an on-site renewable energy
generation option is possible, these constraints will need to be fully explored in a thorough
and transparent manner. The applicants propose a s106 mechanism to achieve this in order
to ensure that an alternative water supply for London is secured within a timely manner. An
appropriately worded s106 agreement may be an appropriate mechanism for securing
renewable energy generation however the level of provision should be significantly higher
than 10% given the energy intensive nature of the desalination plant. The details of any
agreement would need to be clearly set out prior to referral back to the Mayor for a
direction.



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46      On the basis of the aforementioned constraints, Thames Water argues that it will not
be in a position to provide on-site renewable energy provision at the start of the
development. It is considered that any s106 agreement should seek to deliver renewable
energy provision concurrently with the development.

47      The applicant also investigated off-site biogas as a means of generating renewable
energy. The process, called ‘sonication’ reduces the volume of sewage sludge through the
destruction of microbial cells in the digestion process. This produces increased methane
volumes which can then be used to generate electricity. On-site biogas is not possible at
Beckton because sludge is disposed of in the sludge powered generator. Thames Water has,
however indicated that in utilising the sludge digestion process at several of Thames
Water’s other sewage treatment works there is potential to generate up to 10 MW from
biogas. Notwithstanding the fact that the Mayor’s Energy Strategy (Proposal 13) and
London Plan Policy 4A.9 require renewable energy provision on-site, this off-site option
offers a fall back position should on-site generation prove unfeasible. In this case,
additionality (i.e, that this renewable electricity would be generated whether or not the
application proceeds) would need to be proven.

48      Thames Water has submitted a draft s106 agreement designed to secure delivery of
an appropriate level of renewable energy generation. This draft agreement, as currently
worded, would provide no guarantee to Newham Council that renewable energy would ever
be used, either on or off-site. The timeframe for implementation of renewable energy
technologies is lengthy and Thames Water would have the ability to back out of the
agreement for a variety of reasons, including on costs grounds, without any independent
appraisal of their trial reports. The Council should ensure that funding is made available
within any agreement for independent scrutiny of any conclusions reached by Thames
Water. Whilst a s106 agreement may be an appropriate mechanism to utilise, it is essential
that the parameters of the agreement are clearly set out and agreed in principle to provide
certainty to all parties that the renewable energy targets within the London Plan and
Mayor’s Energy Strategy will be met as a minimum and should be exceeded given the
energy intensive nature of the proposed water treatment facility.

Biodiversity
49      The application site is adjacent to (and parts of the works encroach into) the River
Thames, a Site of Metropolitan Importance for Nature Conservation. There are potentially
significant impacts on the ecology of the river. The footprint of the proposed treatment plant
is not within a Site of Importance for Nature Conservation, but does support some wildlife
habitats and protected species, so there are minor biodiversity impacts relating to this. The
proposed pipeline to Woodford Reservoir crosses a number of Sites of Importance for
Nature Conservation, including internationally important parts of Epping Forest. There are
potentially significant impacts on these sites; while the pipeline does not form part of the
current planning application, it is an integral part of the proposals, and these impacts should
be considered at this time.

River Thames
50      Potential impacts on the ecology of the River Thames relate to the abstraction of
water (entrapment of fish and crustaceans at the intake pipe), discharge of effluent
(potentially of high salinity), and the construction of the structures which will carry the
intake pipes to the existing jetty. The Environmental Statement addresses the first two of
these in detail in chapter 8, but there is no consideration of the impacts of encroachment onto

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the tideway to carry the intake pipes. There are also potential impacts on birds on the
Thames, resulting from noise and visual disturbance during construction. This is addressed
in chapter 9 of the Environmental Statement.

51      Entrapment of fish and crustaceans is likely to be the most significant impact on the
ecology of the Thames. Without mitigation, there could be highly significant effects on fish
populations in the area. With all the mitigation detailed in the Environmental Statement,
the impact would be considerably reduced, and the small residual impact may be within
acceptable levels. Prior to planning permission being granted, further details regarding the
level of entrapment of fish and crustaceans should be submitted.

52      The Environment Statement concludes that there would be no significant ecological
impacts from the discharge of effluent from the plant, as the effluent would be highly diluted
by the existing discharge from the sewage treatment works. The proposal includes the
construction of piled trestles to carry the two intake pipes across the inter-tidal zone to an
exiting concrete jetty, to which the pipes will be attached. The hydrological impact of these
structures, and therefore the impact on ecology, has not been appraised in the
Environmental Statement. The proposed trestles could cause changes to the flow of the river
resulting in damage to the flood defences, foreshore, banks, fisheries and general ecology.
Any such impacts could be avoided if the intake pipes used the existing jetty, rather than
new structures. Further work should be undertaken to assess the feasibility of using the
existing jetty and, if this is shown not to be possible, to assess the hydrological and
ecological impacts of the proposed new structures within the foreshore and tideway.

53      The River Thames in the vicinity of the application site supports large numbers of
waterfowl and waders, including populations of shoveler, teal and redshank of at least
regional importance. Teal are known to be particularly susceptible to human disturbance.
The Environmental Statement suggests that the impact of noise and visual disturbance is
likely to be minimal, citing the fact that these species are occurring in an urban situation as
evidence that they are likely to be accustomed to human disturbance. However, this section
of the river is not heavily used by people, and the potential for disturbance may have been
underestimated. Consideration should be given to further mitigation of these impacts,
including screening of the worksite from the river (to reduce both noise and visual impact),
and carrying out works within the foreshore during the spring and summer, when waterfowl
and wader numbers are lowest. Suitable planning conditions could be imposed to secure this
mitigation.

The proposed water treatment plant site
54      The proposed site of the plant contains scrub and rough grassland of only moderate
nature conservation value. It does, however, support common lizards, which are protected
under the Wildlife & Countryside Act 1981 (as amended) against killing and injury. A
programme to translocate lizards from the application site to nearby areas which will not be
affected by the application, as outlined in chapter 9 of the Environmental Statement, should
be undertaken before any site clearance work begins. This should be secured by a planning
condition.

The pipeline route
55     While the pipeline which would supply water from the new plant to Woodford
Reservoir does not form part of the planning application, it is an essential part of the
proposals. The pipeline would be the subject of a separate planning application and as the

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proposed treatment plant would not be viable without it, its impacts need to be considered at
this stage.

56      The pipeline route runs most of the way through open spaces, including several
important nature conservation sites, both statutory and non-statutory. The route passes
through part of the Epping Forest Special Area of Conservation, designated under the EU
Habitats Directive; this is an internationally important site. It also passes through the
Epping Forest Site of Special Scientific Interest, a statutory, nationally important site. The
route also passes through two Sites of Metropolitan Importance (Epping Forest North and
Epping Forest South), four Sites of Borough Importance and one Site of Local Importance.
There is thus the potential for very serious nature conservation impacts from the proposed
pipeline. These are addressed in chapter 9 of the Environmental Statement.

57      With regard to the statutory sites, considerable effort has been made to avoid and
minimise the impacts. Many sections have been routed within roads and existing hard-
surface paths. One section will be tunnelled under Hollow Pond (part of the Special Area of
Conservation), and the only parts within the statutory sites which will be cut-and-cover are
located in areas where the habitat is already degraded. Mitigation includes the restoration of
some of these degraded areas after the work is complete.

58      There is some uncertainty regarding the potential for hydrological impacts caused by
the tunnelling under Hollow Pond, and there is always a danger that habitat restoration will
not be carried out, or will not be successful. Nevertheless, English Nature, the body
responsible for statutory nature conservation sites, is apparently satisfied that there will not
be significant residual impacts on the statutory sites which would outweigh the social and
economic benefits of the proposed new water treatment plant.

59      Less effort appears to have been made to avoid damage to the non-statutory Sites of
Importance for Nature Conservation (although the location of a section of the pipeline within
Bushwood Road to avoid damage to the adjacent ancient woodland is welcomed). In
particular, substantial areas of high quality acid grassland at Wanstead Flats and Manor
Park Flats (both within the Epping Forest South Site of Metropolitan Importance) would be
damaged. While it is proposed to restore these to their original state after the work is
completed, there must be a degree of uncertainty whether the restoration will succeed.
Further consideration should be given to the pipeline route across Manor Park Flats and
Wanstead Flats, to try to reduce the impact on grassland, perhaps by following existing
paths (for example in the section west of Centre Road) and horse ride (east of Centre Road).
Further information should be provided to demonstrate the anticipated recovery of the
grasslands over time (for example after 5 years, 10 years and up to 20 years after the works
are undertaken).

60     The habitats affected by the pipeline within the various Sites of Borough and Local
Importance are of lower quality, and are more readily replaceable. In view of the high social
and economic importance of the project, the proposals for habitat restoration after cut-and-
cover pipe laying across these sites could be considered acceptable.

Design
61      The applicant’s design statement largely justifies the design of the buildings by
reference to the industrial processes associated with water treatment. The design of the RO
building is somewhat bland and unimaginative and could be improved in order to make a
positive contribution to the site. In particular, the appearance and presence of the building

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from the river could be enhanced as it will be sited adjacent to several bold, large scale
structures (for example the Roding flood barrier, the sludge powered generator and the
jetty) and the use of simple, bold building lines should be explored. The building design and
its legibility could also be greatly enriched if the industrial processes within were more
visible to passers-by. Increased glazing could be used to achieve this. The colour and
cladding of the building is also very significant for a building of this scale, which can be seen
from an unusual range of vantage points. An innovative external lighting strategy for the
building should also be developed. The design of the building should be reconsidered and
further details submitted prior to the application being referred back to the Mayor.

62      The proposed landscaping also appears inappropriate in what was historically an
open marshland environment. It is preferable to improve the form and design of the
building, by making a more bold statement and making the industrial processes within the
building more visible to passers-by, rather than attempting to screen the somewhat bland
industrial building with a row of trees. If the design of the reverse osmosis building was
improved this could be a great space for the views to open out on all sides and for a sense of
the river and wider industrial space to be visible.

63      Improved pedestrian linkages are sought within the development to connect with the
wider strategic aspirations of the Green Grid that the Mayor’s Architecture and Urbanism
Unit are developing. In particular, there are strategic aspirations for a pedestrian bridge
across the creek, and a significant contribution should be sought from this development.



Flooding
64     The site is within the indicative tidal flood plain but is defended to a high standard by
existing flood defences. The Flood Risk Assessment covers the relevant issues and sets out
a maintenance plan for existing structures. Buildings are not proposed right up to the river
edge.

Transport for London’s comments
Public transport
65        The development site has low public transport accessibility. There are 3 bus routes
which serve the development area every 15 to 20 minutes. These routes include Service 366,
325 and 262. The Underground network is not within close proximity to the site and the
nearest mainline station (Barking Station) is located over 1 mile away. This is outside of the
typical walking catchment of 800 metres between a development and public transport
facility.

Transport for London Road Network
66     TfL believes that the only traffic generated by this development that could have a
potential impact on the TLRN road network will be created during the construction of the
development. However, this is a relatively small amount of traffic which would not have a
noticeable adverse effect on the TLRN.

67    TfL recommends that the hourly traffic flows illustrated in the Transport
Assessment are revised as TfL considers these figures to be inaccurate.


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Docklands Light Railway
68      TfL recognises that the development site is within the DLR Barking Reach extension
area. TfL’s plans show that the DLR extension runs beneath the development site at a depth
of 15 metres. Whilst there may not be any conflicts with the proposed development, TfL
would like to reserve its position on this matter until there has been further discussion with
Thames Water regarding timescales, work areas, structures, any piling and foundations and
work methodologies. TfL believes this is necessary in order to protect the DLR corridor for
future implementation without additional risk, complication and cost.

East London Transit
69     TfL considers that the proximity of the water treatment plant will not conflict with
present and future alignments of the ELT.

Car parking
70      TfL is satisfied with the proposed level of 15 car-parking spaces for staff and with the
6 visitor car parking spaces. TfL recognizes that this site has a low public Transport
Accessibility Level, however in order to promote sustainable travel patterns, TfL
recommends that the car parking provision does not exceed this level. TfL recommends that
at least 2 of these car-parking spaces are reserved for people with mobility impairments.

Cycle parking
71     TfL welcomes the provision of 50 cycle parking spaces proposed by the applicant
which is in line with London Cycle Network Design Manual standards of 1 space per 500sq.
m. TfL recommends that cycle parking should be covered, well lit and secure.

Green Travel Plan
72     TfL considers that a Green Travel Plan should be prepared in order to promote
sustainable Travel, particularly walking and cycling for employees.
Servicing and delivery
73      TfL recommends that a management strategy is developed so that servicing and
deliveries can be combined and co-ordinated to reduce their impact.


London Development Agency’s comments
74     The London Development Agency considers that more work needs to be undertaken
to demonstrate the need for the proposed desalination plant and/or that appropriate
consideration has been given to alternative, sustainable options to meet London’s water
supply needs. Whilst the Agency acknowledges short-term supply objectives, care should be
taken to avoid a solution that fails to meet longer-term sustainability objectives. Should it
subsequently be demonstrated that a facility of the scale and type proposed is necessary, the
applicant should commit to providing a substantial portion of energy through renewable
sources. In addition, the Agency considers that the design issues raised in this report should
be addressed to ensure that the proposed plant does not adversely impact on the amenity of
the area.


Local planning authority’s position

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75       The Local Authority’s recommendation is not known at this stage.

Legal considerations
76      Under the arrangements set out in article 3 of the Town and Country Planning
(Mayor of London) Order 2000 the Mayor has an opportunity to make representations to
Newham Council at this stage. If the Council subsequently resolves to grant planning
permission, it must allow the Mayor an opportunity to decide whether to direct it to refuse
planning permission. There is no obligation at this present stage for the Mayor to indicate
his intentions regarding a possible direction, and no such decision should be inferred from
the Mayor’s comments unless specifically stated.

Financial considerations
77       There are no financial considerations at this stage.

Conclusion
78      The need for a good quality, reliable water supply for London is clearly articulated
within the London Plan as is the need to use sustainable methods to secure this supply
wherever possible. The principle of the development is not in line with strategic planning
policy as the case has not been strongly made to justify both the need for the plant and the
unsustainable solution to securing additional water resources for London. The London
Plan aims to encourage sustainable solutions to maintaining an adequate water supply for
London and a desalination plant (a very high energy process) does not achieve this objective.
The desalination plant is only one component of a series of measures proposed by Thames
Water to reduce the stated gap between demand and supply and these measures include
sustainable methods of protecting and conserving the city’s water resources such leakage
reduction and mains renewal, domestic water metering and water efficiency measures. It is
considered that these sustainable strategies could be made to go further towards addressing
any shortfall in water supply.

79      The strategic need for the desalination plant needs to be balanced against the need to
achieve an appropriately sustainability development, particularly in terms of energy supply,
biodiversity and impacts on metropolitan open land. These objectives must not be
compromised as a result of the need to achieve a quick solution to the stated shortfall in
water supply.
The proposed desalination plant is a highly energy intensive method of producing water and
on this basis if the principle of a desalination plant were to be accepted it would, as a
minimum, have to generate energy from renewable sources.

80      The applicant has conducted an energy demand assessment and stated its
commitment to providing 10% of energy from renewable sources based on this assessment
but the exact means of securing this commitment has not been agreed. The applicant has
looked at various alternatives and concluded that only two options are feasible, either on-site
wind generation or off-site biogas energy generation. The feasibility of these two options
requires further detailed analysis. A draft s106 has been submitted which provides only 10%
renewables. This approach is within London Plan targets, however, given the highly energy
consumptive nature of the proposal, a far higher target of renewable energy provision should
be sought. Such an agreement is of course subject to making a case for the need for the
plant, and why that need cannot be met using a more sustainable solution to the stated
shortfall in water supply.

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for further information, contact Planning Decisions Unit:
Giles Dolphin, Head of Planning Decisions
020 7983 4271 email giles.dolphin@london.gov.uk
Colin Wilson, Strategic Planning Manager (Development Decisions)
020 7983 4783 email colin.wilson@london.gov.uk
Lee Ogilvie, Case Officer
020 7983 4493 email lee.ogilvie@london.gov.uk




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