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A630 Deephams Sewage Works Upgrade Identification of Preferred Site Stage 3 Report

Public consultation version

A630 Deephams Sewage Works Upgrade P1 A630 Identification of preferred site stage 3 report (public consultation version)

Revision Public consultation version

Date June 2012

File Name Description Identification of preferred site stage 3 report, published as part of phase 1 public consultation

Prepared by Name Signature

Checked by

AB

PH/NF/LG

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Table of Contents
1 EXECUTIVE SUMMARY ................................................................................................................... 6 2 INTRODUCTION ............................................................................................................................... 6 2.1 Section objectives ..................................................................................................................... 6 2.2 Background to the Deephams Sewage Works upgrade ........................................................... 7 2.3 Summary of the need for the upgrade....................................................................................... 7 2.4 Summary of the Assessment Methodology ............................................................................... 8 2.5 Structure of this report ............................................................................................................... 9 3 THE IDENTIFICATION AND ASSESSMENT OF SHORTLIST SITES ............................................. 9 3.1 Section objectives ..................................................................................................................... 9 3.2 Site assessment (stage 2a) ....................................................................................................... 9 3.3 Treatment options assessment (Stage 2b) ............................................................................. 10 3.4 How the shortlist sites were assessed in stage 3 .................................................................... 10 4 ASSESSMENT OF DEEPHAMS SEWAGE WORKS SITE ............................................................. 15 4.1 Section objectives ................................................................................................................... 15 4.2 The site.................................................................................................................................... 15 4.3 Summary of our conclusions at the site assessment (stage 2a) stage ................................... 16 4.4 Treatment options for assessment .......................................................................................... 16 4.5 Key outcomes from the assessment ....................................................................................... 17 5 ASSESSMENT OF MERIDIAN BUSINESS PARK SITE ................................................................. 26 5.1 Section objectives ................................................................................................................... 26 5.2 The site.................................................................................................................................... 26 5.3 Summary of our conclusions at the site assessment (stage 2a) stage ................................... 27 5.4 Treatment option for assessment ............................................................................................ 27 5.5 Key outcomes from the assessment ....................................................................................... 29 6 ASSESSMENT OF LEE VALLEY LEISURE COMPLEX GOLF COURSE (SOUTHERN PART) SITE ...................................................................................................................................................... 34 6.1 Section objectives ................................................................................................................... 34 6.2 The site.................................................................................................................................... 35 6.3 Summary of our conclusions at the site assessment (stage 2a) stage ................................... 36 6.4 Shortlist Option for assessment .............................................................................................. 36 6.5 Key outcomes from the assessment ....................................................................................... 36 7 ASSESSMENT OF ARDRA ROAD NORTH INDUSTRIAL SITE .................................................... 41 7.1 Section objectives ................................................................................................................... 41 7.2 The site.................................................................................................................................... 41 7.3 Summary of our conclusions at the site assessment (stage 2a) stage ................................... 42 7.4 Shortlist Option for assessment .............................................................................................. 42 7.5 Key outcomes from the assessment ....................................................................................... 43 8 ASSESSMENT OF LOWER HALL SITE ......................................................................................... 47

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8.1 Section objectives ................................................................................................................... 47 8.2 The site.................................................................................................................................... 48 8.3 Summary of our conclusions at the site assessment (stage 2a) stage ................................... 49 8.4 Shortlist Option for assessment .............................................................................................. 49 8.5 Key outcomes from the assessment ....................................................................................... 50 9 CONCLUSIONS AND IDENTIFICATION OF PREFERRED SITE .................................................. 54 9.1 Section objectives ................................................................................................................... 54 9.2 Conclusions on the Deephams Sewage Works site................................................................ 54 9.3 Conclusions on the Meridian Business Park site .................................................................... 55 9.4 Conclusions on the Lee Valley Leisure Complex Golf Course (southern part) site................. 56 9.5 Conclusions on the Ardra Road site ........................................................................................ 56 9.6 Conclusions on the Lower Hall site ......................................................................................... 57 9.7 Identification of the preferred site ............................................................................................ 57 10 NEXT STEPS .................................................................................................................................. 58

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List of Tables
Table 1: Stage 3 Criteria to inform the identification of preferred site ................................................... 12

List of Figures
Figure 1: Plan showing location of Deephams Sewage Works .............................................................. 7 Figure 2: The assessment methodology ................................................................................................. 8 Figure 3: Plan of shortlist sites .............................................................................................................. 10 Figure 4: Planning and environmental constraints - Deephams Sewage Works site ........................... 16 Figure 5: Illustrative Deephams Conventional Activated Sludge plant layout ....................................... 18 Figure 6: Illustrative Deephams IFAS / Conventional Activated Sludge layout..................................... 19 Figure 7: Illustrative Deephams MBR / Conventional Activated Sludge layout..................................... 20 Figure 8: Illustration of existing Deephams Sewage Works odour generation ..................................... 22 Figure 9: Illustration of potential odour generation from Deephams Sewage Works IFAS option ........ 23 Figure 10: Indicative effluent quality timeline for Deephams conventional AS option ........................... 24 Figure 11: Indicative effluent quality timeline for the Deephams 33% IFAS option .............................. 25 Figure 12: Indicative effluent quality timeline for the Deephams 33% MBR option .............................. 25 Figure 13: Planning and environmental constraints - Meridian Business Park site .............................. 26 Figure 14: Illustrative Meridian Business Park IFAS layout .................................................................. 28 Figure 15: Illustrative layout for infrastructure required at Deephams Sewage Works site in association with any of the off site development options ................................................................................ 29 Figure 16: Illustrative plan of potential odour generation from Meridian Business Park site option ...... 33 Figure 17: Indicative effluent quality timeline for the Meridian Business Park IFAS option .................. 34 Figure 18: Planning and environmental constraints - Lee Valley Leisure Complex Golf Course (southern part) site ....................................................................................................................... 35 Figure 19: Illustrative Lee Valley leisure Complex (Southern part) conventional AS layout ................. 37 Figure 20: Illustrative plan of potential odour generation from Lee Valley Leisure Complex Golf Course (southern part) site option ............................................................................................................ 40 Figure 21: Indicative effluent quality timeline for the Lee Valley Leisure Complex Golf Course (southern part) site conventional AS option ................................................................................. 41 Figure 22: Planning and environmental constraints - Ardra Road site.................................................. 42 Figure 23: Illustrative Ardra Road conventional AS layout.................................................................... 43 Figure 24: Illustrative plan of potential odour generation from Ardra Road site option ......................... 46 Figure 25: Indicative effluent quality timeline for the Ardra Road site conventional AS option ............. 47 Figure 26: Planning and environmental constraints - Lower Hall site ................................................... 48 Figure 27: Illustrative Lower Hall conventional AS layout ..................................................................... 49 Figure 28: Illustrative plan of potential odour generation from Lower Hall site option .......................... 53 Figure 29: Indicative effluent quality timeline for the Lower Hall site conventional AS option .............. 54

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1 Executive summary
1.1.1 Deephams Sewage Works, located in Enfield in north east London, is the ninth largest sewage works in England. It treats sewage collected from within its catchment and discharges treated effluent that flows into the Salmons Brook, a tributary of the River Lee, in accordance with a discharge consent set by the Environment Agency. The Environment Agency has issued a new discharge consent that requires us to make improvements to the quality of the discharge. The Deephams Sewage Works Upgrade (the upgrade) will improve the quality of effluent (treated wastewater) discharged from the Deephams Sewage Works into the Salmons Brook. It will accommodate growth within the catchment to at least 2031, and improve infrastructure at the sewage works, much of which is now over 50 years old. The upgrade has to be delivered whilst the existing sewage works remains operational to treat the sewage to the existing consent levels. This places significant engineering constraints on our ability to implement the upgrade within the boundaries of the existing sewage works site. We have therefore considered the use of a number of treatment technology options to deliver the upgrade both on the existing site, and on a new site, within these engineering constraints. This report documents the process that we have followed in assessing 5 shortlist sites identified through the site assessment work undertaken in stage 2a of the project. The report sets out how we have assessed the shortlist sites against relevant property/legal, planning, environmental and engineering issues that could affect the delivery of the upgrade. The shortlist sites assessed were: 1.1.5 Deephams Sewage Works site Meridian Business Park site Lee Valley Leisure Complex Golf Course (southern part) site Ardra Road North Industrial Area site Lower Hall site

1.1.2

1.1.3

1.1.4

The conclusion of the report is that the Deephams Sewage Works site is the preferred site for delivering the upgrade. The Deephams Sewage Works site has significant advantages over the other shortlist sites and is the most appropriate option. This conclusion will be published as part of the phase 1 public consultation to test the conclusions that we have reached on the shortlist sites.

1.1.6

2 Introduction
2.1 2.1.1

Section objectives
This introduction explains the background to the Deephams Sewage Works upgrade, provides an overview of the assessment methodology process, and explains the purpose and structure of this report.

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2.2 2.2.1

Background to the Deephams Sewage Works upgrade


Deephams Sewage Works is one of our six main sewage works that serve London. It is located off Picketts Lock Lane in Edmonton, as shown in Figure 1 below. It is the ninth largest sewage works in England and serves a population equivalent of 885,000 people (as of 2010). The catchment that Deephams Sewage Works serves extends over large parts of north east London, and northwards beyond the M25.

Figure 1: Plan showing location of Deephams Sewage Works

2.2.2

Sewage treatment has been undertaken in this part of Edmonton since the 1870s when the first Edmonton sewage farm was developed on adjoining land. The sewage treatment works was largely constructed on the current site in the 1950s and 1960s. Despite the various improvements over the last 30 to 40 years, and those under construction, the current sewage works is predominately the works that was first constructed in the 1950s and 1960s. The ageing plant is under increasing pressure to meet and maintain treatment standards.

2.2.3

2.3 2.3.1

Summary of the need for the upgrade


The need for the upgrade is set out in the National Policy Statement for Waste Water, and can be summarised as the requirement to respond to: an increase in the discharge consent requirements an increase in flow to the works:

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2.3.2

a requirement to provide sufficient treatment capacity to meet population growth within the catchment already served by the works. a requirement to respond and adapt to the challenges of climate change.

ageing infrastructure under pressure to meet and maintain treatment standards

The upgrade will also deliver wider social or environmental benefits, for example reduced odour emissions and, depending on the option selected for implementation, increased renewable energy generation.

2.4 2.4.1

Summary of the Assessment Methodology


We have developed an assessment methodology for selecting the most appropriate option for delivering the upgrade, including the assessment of site and treatment technology options. The methodology allows for the assessment of a range of strategies for meeting the need for the upgrade. It allows for the consideration of potential locations for new sewage treatment infrastructure. The construction of the upgrade could be on the existing site, although the site would have to remain operational throughout the upgrade, or it could be on a new site nearby. A suitable treatment technology option has to be selected, to meet the treatment requirements of the new discharge consent within funding, programme, treatment technology and physical site constraints. The proposed methodology is a multi-stage process, with stages undertaken both in parallel and sequentially. Figure 2 below illustrates this process diagrammatically.

2.4.2

2.4.3

Figure 2: The assessment methodology

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2.4.4

The assessment process firstly allows an initial review of strategic options for meeting the need for the upgrade to be undertaken. From this, an assessment of treatment options is undertaken, alongside an assessment of potential development sites. A more detailed assessment of a shortlist of sites is then undertaken to enable a preferred site to be identified. The preferred site is then published for a first phase of public consultation and stakeholder engagement. Alongside, and following on from, the first phase of consultation we will undertake scheme design development work and further work on treatment options. This will confirm the feasibility of our preferred site and treatment technology options for delivering the upgrade. A second phase of public consultation will then be held on our proposals and designs for the upgrade and information on the potential environmental impacts of the upgrade and our plans for mitigating them. An application for permission to build the upgrade will then be submitted. An essential part of the methodology is an ongoing process of review and checking the validity of previous assessments through feedback loops at all stages of the process. This enables the assessment of sites and options to remain valid as information changes and new information is obtained. Thus, where necessary, stages in the process may be repeated (or back-checked) in order to take account of new information or other changes of circumstance.

2.4.5

2.4.6

2.5 2.5.1

Structure of this report


This report documents stage 3 of the assessment methodology process the identification of the preferred site. Section 3 of this report outlines the shortlist sites and how they were assessed against relevant property / legal issues planning, environmental, engineering and property/legal issues that could affect the upgrade. Sections 4 to 8 explain the outcomes of the assessment process for each shortlist option. Section 9 reports the conclusions of this assessment and identifies the preferred site. Finally, section 10 describes the next steps with the project.

2.5.2

3 The identification and assessment of shortlist sites


3.1 3.1.1 3.2 3.2.1

Section objectives
This section provides a description of how the shortlist site options were identified and the process by which they were assessed.

Site assessment (stage 2a)


We identified a longlist of 22 potential sites, including the existing Deephams Sewage Works site, for delivering the Upgrade to meet the new discharge consent standard. Following an assessment of these sites against property/legal, planning and environmental, and engineering criteria, the shortlist sites (Identified in Figure 3) are: Site 1 Deephams Sewage Works Site 6 Meridian Business Park Site 9 Lee Valley Leisure Complex Golf Course (Southern part) Site 11 Ardra Road Industrial Area Site 15 Lower Hall

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Figure 3: Plan of shortlist sites

3.2.2 3.3 3.3.1

Further information on the work that led to this shortlist is reported in the separate Site assessment stage 2a report.

Treatment options assessment (Stage 2b)


As a separate stage of work, we considered a range of sewage treatment technologies that could potentially meet the discharge consent standard. A number of potential treatment technologies were taken forward as a result of that assessment process. Further details of this assessment work are reported in the Treatment options assessment stage 2b report. It should be noted that treatment processes will be considered further through our ongoing scheme design development work on the upgrade.

3.3.2

3.4 3.4.1

How the shortlist sites were assessed in stage 3


Preliminary design work was undertaken on each of the shortlist sites to enable the assessment work to be undertaken. This included the preparation of preliminary layouts showing the extent of the built development and the preparation of potential construction programmes. Due to their size or shape, some of the shortlisted sites may be capable of only accommodating a single treatment technology option, whereas others may be capable of accommodating a number of treatment options.

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3.4.2

The decision on the number of preliminary layouts that were prepared for each site took account of the extent to which different treatment options were considered likely to give rise to significantly different assessment results on the shortlisted sites that may affect the selection of a preferred site. On the Deephams Sewage Works site for example, different treatment technology options could result in different development areas being required, or construction programmes, as a result of the need to phase development alongside the existing operational works. On other sites where there would not be a phasing requirement, the differences between treatment technology layouts and programmes, and the impacts potentially arising from them, is more limited. For these sites we have shown a layout for the treatment technology with the largest footprint compatible with the site. The assessment of each shortlisted site enabled preliminary conclusions to be drawn on the potential impacts arising from the development of the upgrade on each site. Where the potential for significant differences between treatment technology options on a shortlisted site were identified, these were highlighted. Sites were not eliminated at this stage on the basis of the treatment technology that was assessed on the site. The options that we assessed are summarised below: Three treatment options were assessed for the Deephams Sewage Works site at the secondary treatment stage of the process: Conventional activated sludge to treat all of the sewage Integrated Fixed-film Activated Sludge (IFAS) to treat a third of the sewage and conventional activated sludge to treat the remaining two thirds A Membrane Bio-Reactor (MBR) to treat a third of the sewage and conventional activated sludge to treat the remaining two thirds

3.4.3

3.4.4

3.4.5

For the Meridian Business Park site we assessed Integrated Fixed-film Activated Sludge (IFAS) a treatment technology that has the benefit of requiring a slightly smaller footprint than Conventional Activated Sludge. Constraints on available space at the Meridian Business Park site meant that Conventional Activated Sludge could not be accommodated. We assessed a Conventional Activated Sludge treatment process at the Lee Valley Leisure Complex Golf Course (southern part) site. This is a more modern version of the sewage treatment processes on the existing Deephams Sewage Works site. This is a resilient treatment process that has an established track record and is proven on the scale required at Deephams. We also assessed a Conventional Activated Sludge treatment process at the Ardra Road site, and at the Lower Hall site. Our selection of these treatment processes for use in the site assessment process does not mean that alternative treatment technologies will be excluded from further consideration. We have not made any final decisions on the treatment technologies to be used in the upgrade at this stage. The options were subjected to an assessment against a range of property / legal, planning and environment, and engineering key issues relating to the construction and operation of the upgrade.

3.4.6

3.4.7 3.4.8

3.4.9

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3.4.10 These issues are drawn from a range of sources including issues that are key to the project (e.g. energy consumption / site size / odour / land availability / cost), issues that are central to the use of land (e.g. planning designations / neighbouring land uses / access / site shape) and issues key to the likely receiving environment (e.g. nature conservation / amenity / water resources and flood risk / heritage). 3.4.11 These issues are linked to key criteria which form the basis against which each site would be assessed against each issue. The issues and their associated criteria are prepared in an assessment matrix, divided by the different topics. The assessment criteria are identified in Table 1 below.
Table 1: Stage 3 Criteria to inform the identification of preferred site CRITERION Basis for assessment

Property/legal criteria
Ownership of site and tenancies Estimated acquisition cost Crown land and special land Lee Valley Regional Park Authority controlled land Assessment of likelihood of need for Compulsory Purchase Order Access and material transfer rights Assessment of ownership and tenancy constraints to development Assessment of potential acquisition costs Assessment of any legal procedures relating to special land Assessment of any legal procedures required under the 1966 Act Assessment of risk of needing to use a Compulsory Purchase Order to acquire land Assessment of any legal issues relating to access or material transfer

Planning and environmental criteria


Description of route to consent and consents required or the construction/operation of the option. Planning application and consents Assessment of planning history of site and constraints arising from consented or current applications, including conditions and legal agreements Assessment of planning history of adjoining land and constraints arising from consented or current applications, including conditions and legal agreements London Plan/Unitary Development Plans/Local Development Frameworks/Supplementary Planning Documents allocation or special policy areas Green Belt and Metropolitan Open Land Heritage designations Assessment of compliance or conflict with specific land use allocations or planning objectives

Assessment against Green Belt and Metropolitan Open Land policy and guidance Assessment of potential impacts on archaeological priority areas, Scheduled Monuments, Listed Buildings, Conservation Areas, Historic Parks and Gardens, Local Site Register

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CRITERION Landscape designations

Basis for assessment Assessment of potential effects on landscape, townscape, visual, gap or open space designations Assessment of potential effects on European site (Special Protection Areas, Special Areas of Conservation and Ramsar sites) Assessment of potential effects on Sites of Special Scientific Interest Assessment of potential effects on local nature conservation and biodiversity designations Assessment of potential effects on nature reserves Assessment of potential effects on protected species

Nature conservation designations

Water resources

Assessment of potential effects on groundwater source protection zones Assessment of potential effects on surface water resources (flow and quality)

Sustainability

Assessment of carbon emissions during construction (including embodied carbon) and operation Assessment of potential for renewable energy generation Assessment of potential for climate change adaptation Assessment of waste generation opportunities for waste minimisation, reuse or recycling Assessment of risk of contamination and scope of mitigation Assessment of opportunities for reusing previously developed land Assessment of opportunities for recreation enhancement Assessment of opportunities for biodiversity enhancement

Transportation and access

Rail connection practicability: availability/location of connection and suitability of interconnecting access route Water freight practicability: availability/location of connection and suitability of interconnecting access route Suitability of road/interconnecting road access: particularly for Heavy Goods Vehicles/abnormal indivisible loads Sensitivity of access route Assessment of potential impacts associated with operational transport and access

Community and amenity effects/proximity to sensitive receptors

Assessment of potential impacts on Lee Valley Regional Park, other recreational or sports sites, navigation and recreational water use, public rights of way, permissive paths and access sites, De facto or non-designated open space, and allotments

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CRITERION

Basis for assessment Assessment of sensitivity to noise, dust, on-site construction vehicle emissions and odour during construction Assessment of sensitivity to odour, dust and noise effects during operation Assessment of visual effects Assessment of socio-economic and regeneration effects Assessment of health considerations

Engineering criteria
Site size and shape Comparison to minimum/optimum size for the specific treatment option Assessment of whether the shape and layout of the site constrain the optimum layout for the treatment option Construction duration, high level description of construction phasing, Heavy Goods Vehicle and Large Goods Vehicle routing, and level of traffic movements Connection feasibility/location Description of construction duration and phasing (not assessed against specific criteria) Description of routing and movements (not assessed against specific criteria)

Distance from Deephams/sewer interception Infrastructure/structures between Deephams/sewer and site, including requirements to facilitate discharge of treated effluent to the Salmons Brook and return of sludge to Deephams Sewage Works for treatment

Site features

Above and below ground conditions (including third party assets) Geology Site levels Other engineering considerations

Flood risk and scope for mitigation Site efficiency

Assessment against technical guidance to the National Planning Policy Framework Ability to accommodate all requirements on-site (and if not describe how development can be achieved using a combination of sites) Ability to secure all required site services needed to facilitate the technology being assessed for development e.g. power supply/communications/other Potential for effects from development upon existing site or adjacent services e.g. power supply/communications/other

System engineering

Process risk during construction

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CRITERION requirements Odour generation during operation and scope for mitigation Whole life cost Value for money

Basis for assessment Effluent quality timeline (quality improvements in discharge over time) Assessment of potential odour generation and costs of mitigation

Assessment of whole life cost Availability/likelihood of competitive tenders and risk of implementation of project to customers bills

3.4.12 We assessed each site against the criteria, using professional judgement, knowledge and expertise to inform that assessment. The assessment is a qualitative description of the options performance against the relevant criteria, serving as an indicator as to the potential significance of a particular issue for the progression of a particular site. 3.4.13 The assessment was undertaken on the basis of the information available at the time of the assessment between late 2011 and Spring 2012. We undertook a process of review and analysis throughout the assessment to ensure that its conclusions remained valid as any new information was generated or circumstances change. 3.4.14 Members of the Stakeholder Forum were engaged on the assessment criteria, both in forum meetings and in stakeholder workshops, during the site assessment process to ensure that the approach being taken to the assessment of options was appropriate. For further information on the stakeholder forum, please refer to our Consultation Strategy document. 3.4.15 The outcomes of our assessment of each of the shortlist sites is reported in the following sections 4 to 8 of this report.

4 Assessment of Deephams Sewage Works site


4.1 4.1.1 4.2 4.2.1

Section objectives
This section describes the assessment of the Deephams Sewage Works site.

The site
The 35 hectares existing Deephams Sewage Works site is located to the west of the William Girling Reservoir (A) and is bordered by the A1055 (Meridian Way) to the west, beyond which lies a railway line and then an area of residential development (B). Another small area of housing (C) lies immediately north of the site, beyond which lies Picketts Lock Lane and then the Lee Valley Leisure Complex (D). Picketts Lock Lane runs into Lee Park Way which together form part of the northern and eastern boundaries of the site respectively. A builders merchants site, highways maintenance depot and car park (E) are located further to the north-east and east of the site and the Ardra Road Industrial Estate (site 11) is situated immediately to the south. The planning and environmental constraints for the site are identified in Figure 4 below.

4.2.2

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Figure 4: Planning and environmental constraints - Deephams Sewage Works site

4.3 4.3.1

Summary of our conclusions at the site assessment (stage 2a) stage


Our site assessment (stage 2a) conclusions on the Deephams Sewage Works site was that the site had fewer property / legal, planning and environmental constraints than the other longlist sites. The delivery of the upgrade on this site was assessed as representing a major challenge in engineering terms due to the lack of spare land and the need to retain a fully operational sewage works throughout the upgrade. However, we concluded that if those engineering constraints could be overcome and an upgrade scheme designed that was acceptable in planning and environmental terms, within the environmental and financial constraints imposed by the regulators and at an acceptable level of treatment process risk to us, then the Deephams Sewage works site would be an appropriate location for the upgrade.

4.4 4.4.1

Treatment options for assessment


The treatment technology options used as the basis for the assessment of the Deephams Sewage Works site are: Conventional Activated Sludge (AS) treatment to treat all of the sewage Integrated Fixed-film Activated Sludge (IFAS) treatment to treat a third of the sewage and conventional Activated Sludge (AS) to treat the remaining two thirds

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4.4.2 4.5 4.5.1

A Membrane Bio-Reactor (MBR) to treat a third of the sewage and conventional Activated Sludge (AS) to treat the remaining two thirds

The options are illustrated in figures 5, 6 and 7 on the following pages.

Key outcomes from the assessment


The assessment of the Deephams Sewage Works site resulted in the following key outcomes. Many of the outcomes are the same for the 3 treatment technology options, however where they significantly differ this is identified in the report. Property/Legal issues

4.5.2

The site presents a good opportunity for the development of the upgrade in property terms as the land is our ownership. It is anticipated that there will be a need for an offsite construction compound during the Upgrade build process, however this could be accommodated on land we own at Lower Hall (site 15) to the south of William Girling Reservoir. Planning and Environmental Issues

4.5.3

Development of the Upgrade on this site will require an application for planning permission to be submitted to the London Borough of Enfield. The site is an existing sewage works and the use of this site for the Upgrade will not conflict with the existing use, nor with any specific land use planning designations. The site lies within the wider Central Leeside Area Action Plan area, proposals for which are currently in preparation by LB Enfield, and the Council is supportive of the principle of upgrading the existing sewage works. The Deephams Sewage Works site lies outside the Green Belt and Lee Valley Regional Park (LVRP). Land at Lower Hall which could be used for a temporary construction compound lies within the Green Belt and LVRP. The need for the compound will have to be justified as part of the planning application in order to meet the requirements of national guidance and development plan policy. We consider that we will be able to demonstrate a need for the compound should it be required, and that the temporary use of that site, coupled with the implementation of a restoration scheme and long term appropriate after-use would be shown to be acceptable in planning terms. The initial layout plans for the three options at Deephams identify that there is the potential for loss of some of the mature wooded bund forming the eastern site boundary as well as some mature woodland along the north western and north eastern boundaries as part of the Upgrade. Mitigation for this would need to be provided, involving replacement planting of the boundary edges to the northwest, northeast and east.

4.5.4

4.5.5

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Figure 5: Illustrative Deephams Conventional Activated Sludge plant layout

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Figure 6: Illustrative Deephams IFAS / Conventional Activated Sludge layout

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Figure 7: Illustrative Deephams MBR / Conventional Activated Sludge layout

4.5.6

Part of this area is within the Lee Valley Site of Metropolitan Importance for Nature Conservation (SMINC). Mitigation of impacts on the SMINC will require compensatory measures that will provide, at worst, no net loss of biodiversity value or, at best, a net gain in biodiversity. This could be delivered by like for like habitat creation within or adjacent to the existing site, with Lower Hall providing a potentially suitable offsite location, or through habitat enhancement of the existing site.

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4.5.7

Potential environmental effects upon the Chingford Reservoirs SSSI are likely to be restricted to impacts of disturbance upon birds, as the boundary of the Deephams site is approximately 100m from the edge of the SSSI. The potential effect of disturbance upon bird species utilising the SSSI is likely to be low as the reservoirs are at an elevated level compared to that of the development site and, due to the size of the SSSI, there is ample habitat into which the birds can relocate following disturbance. On site, there is the potential for impacts through disturbance and loss of habitat which could affect common breeding birds, bats, reptiles and invertebrates, for which mitigation would need to be provided. There is the risk of potential impacts on groundwater and surfacewater during construction and operation of the Upgrade, although these risks are considered capable of mitigation with normal good practice construction techniques and our normal operational management procedures. There would be the need to divert a drainage ditch within the northern part of the Deephams Sewage Works site to accommodate the upgraded works, although this could be achieved without impacts on flood risk and with only temporary ecological and physical disruption to habitats pending its reinstatement in its new location. Should it prove necessary to incorporate flood mitigation as part of the upgrade then there is some limited space available on site. Once the phased implementation of the Upgrade is underway, there will be a positive impact on water quality in the Salmons Brook, increasing as each phase of the upgrade is implemented. Road access to the site is very good with the site located in close proximity to the A1055. Access is gained via a traffic light junction into Picketts Lock Lane. Access to the site will involve two sharp turns, and could possibly constrain delivery of abnormal or indivisible loads (AILs). Outside peak hour material delivery times may be imposed by LB Enfield / TfL, and appropriate routing will need to be identified and mitigation provided if required. Construction traffic should be routed away from residential areas to avoid emissions, severance, accident risk, fear and intimidation problems. There is the potential to consider the use of water freight transport for some construction materials or items, pending detailed examination of the constraints within the Lee Navigation. Travel planning will also be required and initiatives implemented, including ensuring ease of access for staff / workers to/from nearest rail station.

4.5.8

4.5.9

4.5.10 Construction activities are likely to cause some temporary disruption to recreational users of the LVRP. These impacts would principally be on users of public rights of way (PRoW) immediately adjacent to the site, particularly along Picketts Lock Lane, including the Pymmes Brook Trail, to the north, and along Lee Park Way to the east, which is used as a footpath and includes a cycle route. It is also possible that users of surrounding PRoW, including users of the Lee Valley Walk, Lee Valley Pathway and Lee Valley Cycle Route may be affected by noise, dust and odour emissions and by visual impacts and increased traffic associated with construction activities. There is the potential for temporary noise impacts on the southern part of the Lee Valley Leisure Complex and Athletics Centre. However, all these impacts would be temporary and short term and would be mitigated through implementation of a Construction Environmental Management Plan (CEMP). 4.5.11 Potential impacts on the local community, including nearby sensitive receptors, are predicted to arise during construction including from noise, dust, traffic and odour. The extension of the Sewage Works closer to the northern boundary of the site could result in impacts to residents along Picketts Lock Lane, but mitigation, such as retention of trees and additional tree planting around the periphery of the site, may assist in reducing these.

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4.5.12 The highest levels of construction noise would usually occur during demolition, site clearance, earthworks and piling activities, impacting on residential properties in Picketts Lock Lane, Hudson Way, Prespa Close, Volta Close and Badma Close (within 100m) and minor impacts in Dunnock Close and Lee Valley Golf Course (within 150m). 4.5.13 Construction traffic could cause disturbance to residential receptors although the use of Meridian Way should not cause significant noise increases as this is already a busy commercial route. Dust impacts are likely to occur, however residential properties are unlikely to be significantly adversely affected as smaller airborne particles are likely to settle out within approximately 100m of the site. Odour could arise during demolition of the disused digesters in the north west corner of the site, however this would be mitigated by controlled removal of any residual organic materials prior to demolition. Our contractors would work to a CEMP which should ensure that residual construction noise and air quality impacts are generally negligible but no more than minor to moderate at the closest receptors. 4.5.14 During operation of the upgraded works, operational noise would be typically less than existing baseline noise levels during the daytime. At night there may be some audibility of the operational noise at receptors located at less than 100m from the site, but the impact would be no more than minor. Through the detailed design of the scheme it should be possible to reduce operational noise to be of negligible impact by appropriate design of buildings housing noisy plant, achieved by screening and enclosures or through sound insulation. Dust emissions during operation would not be expected to be significant. 4.5.15 Figure 8 below illustrates how odour from the sewage works currently leaves the existing Deephams Sewage Works site and affects the surrounding area. The red area of the map is where the odour is strongest and the yellow area is where it is weakest.
Figure 8: Illustration of existing Deephams Sewage Works odour generation

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4.5.16 The upgraded works will include odour controls to a standard to be agreed with LB Enfield through the planning application process. These, coupled with implementation of an Odour Management Plan for the site will result in a reduction in odour experienced from the site. Initial modelling works have been completed for the proposals, with the covering of the primary settlement tanks (PSTs) and secondary digesters as part of the odour mitigation strategy. In this scenario, using the IFAS technology option as an example, approximately 290 properties would be within the 5ouE/m3 contour (the majority of recorded complaints about odour from the existing Deephams Sewage Works site originate within this 5ouE/m3 area), as shown in Figure 9 below. Different treatment technologies could result in minor changes to the number of properties affected.
Figure 9: Illustration of potential odour generation from Deephams Sewage Works IFAS option

4.5.17 Compared to other sites, the development of the upgrade on the Deephams Sewage Works site would have lower carbon emissions during construction and operation because all treatment remains on site and there is no requirement for pipeline materials and pumping energy to transfer sewage to and from another site. Engineering Issues 4.5.18 The site is large enough to accommodate any of the three secondary treatment technology options (conventional AS, IFAS and MBR) used as the basis of the assessment. When comparing the three options, the two phase Conventional AS treatment process layout requires revised process loads to allow a smaller footprint layout to be designed. The partial IFAS and MBR options could offer advantages in terms of reducing the footprint of the construction works.

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4.5.19 The need to maintain the existing works functioning throughout dictates the layout for each of the options as the first phase of construction works has to take place outside of existing streams A, B and C which need to remain in operation until a new stream is commissioned. This results in a need for development to take place on the site of the old digesters (disused) in the north west corner of the site, and also in areas close to the northern and north eastern boundaries between the site and Picketts Lock Lane/Lee Park Way. This would bring new development closer to housing located on Picketts Lock Lane. 4.5.20 We tested the speed at which the 3 treatment options could potentially be developed on the Deephams Sewage Works site, and the potential phasing of the improvements in treated effluent quality that they would deliver. 4.5.21 Construction of the conventional AS based technology option is assumed to last until January 2020. The construction would proceed as a 2 phase construction project, requiring the installation of temporary IFAS units in the existing B&C stream AS tanks. These would subsequently be removed as these phases are themselves redeveloped. It would also be necessary to reduce the peak flow treated by the works from the current 443 Ml/d to approximately 370 Ml/d, in agreement with the Environment Agency. This option would deliver a series of staged improvements in effluent quality as indicated in Figure 10 below.
Figure 10: Indicative effluent quality timeline for Deephams conventional AS option

Deephams Conv AS (Temp IFAS B&C)


Progress towards future discharge permit
Construction Start Construction Finish

BOD SS Amm

50% AS

New Permit Limits


RGF Built

Time

4.5.22 We consider the conventional AS treatment process to be reliable and to be proven on this scale (it is the current treatment process at Deephams). However, there may be a need for revised process designs to accommodate the two phase upgrade on this site. These would need to be verified with contractors to ensure that they can be delivered. It is considered likely that multiple competitive tenders would be received for the project and that value for money to our customers could be achieved. 4.5.23 Construction of the 33% IFAS based technology option on the Deephams Sewage Works site is assumed to last until April 2021. This option would deliver staged improvements in treated effluent quality as indicated in Figure 11 below.

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Figure 11: Indicative effluent quality timeline for the Deephams 33% IFAS option

Progress Towards Future Discharge Permit

Deephams 33%IFAS
Construction Start Construction Finish

BOD SS Amm

33% IFAS

33% Conv

Permit Limits
RGF Built

Time

4.5.24 The IFAS technology is not widely used on the scale envisaged for Deephams and there are only a limited number of suppliers of the IFAS variants that we consider represent proven technology. Nevertheless, the IFAS component of the project is not a major part of the overall cost and we consider that value for money to our customers could be achieved through a competitive tendering process. 4.5.25 Construction of the 33% MBR based technology option on the Deephams Sewage Works site is assumed to last until April 2021. The construction would proceed as a 3 phase construction project. This option would deliver staged improvements in treated effluent quality as indicated in Figure 12 below. The installation of the 33% MBR plant and disc filters early in the programme would deliver significant benefits early in the construction programme.
Figure 12: Indicative effluent quality timeline for the Deephams 33% MBR option

Progress Towards Future Discharge Permit

Deephams 33% MBR


Construction Start Construction Finish

BOD SS Amm

33% MBR 33% Conv

New Permit Limits


Disc Filters

Time

4.5.26 The MBR technology is not widely used on the scale envisaged for Deephams and we consider that there are therefore process risks for us associated with this option. We consider that value for money to our customers could be achieved through a competitive tendering process.

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Conclusions on the Deephams Sewage Works site 4.5.27 The conclusions on the Deephams Sewage Works site are reported in section 9.2 of this report.

5 Assessment of Meridian Business Park site


5.1 5.1.1 5.2 5.2.1

Section objectives
This section describes the assessment of the Meridian Business Park site.

The site
This site is approximately 14 hectares in size and comprises existing and vacant employment land in mixed industrial uses. The site is located to the west of the William Girling Reservoir (A). The A1055 (Meridian Way) lies to the west of the site, beyond which is the railway and Woodall Road Industrial Area (Site 5). Residential areas (B) lie further to the west beyond the A1055 and Site 5. There is a Flour Mill and open space (C) to the north and open space (D) to the south in the Lee Valley Regional Park. The Lee Navigation forms the eastern boundary. The planning and environmental constraints for the site are identified in Figure 13 below.
Figure 13: Planning and environmental constraints - Meridian Business Park site

5.2.2

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5.3 5.3.1

Summary of our conclusions at the site assessment (stage 2a) stage


Our site assessment (stage 2a) conclusion was that of all the 12 industrial sites on the longlist, this site, together with Ardra Road (Site 11) were assessed by us as being the industrial sites with the most potential for accommodating the upgrade. We concluded that both sites should become shortlist sites, enabling their development potential for the upgrade to be assessed in more detail. This more detailed assessment needed to include further consideration of issues relating to land acquisition, flood risk, and issues relating to the loss of employment opportunities as a priority.

5.4 5.4.1

Treatment option for assessment


The treatment technology option used as the basis for the assessment of the Meridian Business Park site is Integrated Fixed-film Activated Sludge (IFAS). This treatment technology has the benefit of requiring a slightly smaller footprint than Conventional Activated Sludge. Constraints on available space at the Meridian Business Park site meant that Conventional Activated Sludge could not be accommodated. An illustrative layout for the infrastructure that would need to be built at the Meridian Business Park site as part of this option is shown in Figure 14 on the following page. Figure 15, below that, identifies the infrastructure that would need to be built at Deephams Sewage Works as part of this option.

5.4.2

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Figure 14: Illustrative Meridian Business Park IFAS layout

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Figure 15: Illustrative layout for infrastructure required at Deephams Sewage Works site in association with any of the off site development options

5.5

Key outcomes from the assessment


Property/Legal issues

5.5.1

The Meridian Business Park site is in multiple ownerships with in excess of 20 individual land interests identified. Parts of the site are in active employment use. Other areas have planning consent for redevelopment, with large parts of the site cleared ready for future redevelopment. The existing industrial use, together with current and potential future planning consents for employment development indicate that the site would be expected to have high land acquisition costs. There is considered to be a high risk that a Compulsory Purchase Order may be required, although this can be applied for as part of an application for a Development Consent Order.

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5.5.2

The site does not include any crown or special land and therefore aside from the potential need for a Compulsory Purchase Order it is not considered that there are additional legal complexities relating to land acquisition. A small part of the site lies within the Lee Valley Regional Park (LVRP), although this land is allocated as Strategic Industrial Land and is currently in industrial use. It is not considered that the designation of that small part of land would lead to additional constraints to the development of the site, given its current use. Planning and Environmental Issues

5.5.3

Development of the Upgrade on this site will require an application for Development Consent to be submitted to the National Infrastructure Directorate of the Planning Inspectorate under the Planning Act 2008. The site comprises the entire Meridian Business Park, together with adjoining employment uses to the north. The site is occupied by several users, although large areas of the site formerly occupied by Aesica Pharmaceuticals have been cleared pending redevelopment for employment uses. Planning permission exists for warehousing units on the eastern part of the site, one of which has been constructed and is operational. Pre-application discussions with London Borough of Enfield (LB Enfield) are taking place about the future employment redevelopment of large parts of the site. The site is a safeguarded Strategic Industrial Location (SIL) promoted by the London Plan policy 2.17 and implemented by the LB Enfield Core Strategy Policy 14. Paragraph 2.79 of the London Plan explains that utility developments (such as sewage treatment) would be suitable uses of SIL. Although not a policy requirement, LBE policy interpretation suggests that use of SIL for utilities development would only be acceptable if compensation SIL is provided to overcome any loss of SIL land. Whilst utility development on SIL does not conflict with London Plan Policy, London Borough of Enfield has raised significant concerns about potential loss of employment opportunities through the redevelopment of SIL sites for the Deephams Sewage Works upgrade. The site also falls within the designated LB Enfield Core Strategy Ponders End Place Shaping Priority Area (PEPSPA). Core policy 41 explains that the PEPSPA will seek to create new homes, development, employment, public realm improvements, community facilities, leisure access and flood storage. The retention of employment opportunities is identified as a particular objective of the policy. The inclusion of the site within the PEPSPA raises additional policy conflicts given the planned regeneration within the area around the site, particularly to the north and west, including the introduction of additional residential and leisure uses. If the site were to be developed for the upgrade then there would be a specific conflict with the PEPSPA objective of retaining and promoting employment opportunities within the local area. The Meridian Business Park site is not located within the Green Belt and the majority of the site lies outside the LVRP. However the Green Belt and Regional Park adjoins the site to the south and east. Development within the boundaries of the site would avoid direct impacts on the Green Belt and Regional Park. However, there is the potential for development on the site to indirectly affect the Green Belt and Regional Park designation through indirect impacts relating to odour, noise, dust and visual impacts.

5.5.4

5.5.5

5.5.6

5.5.7

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5.5.8

The design of the scheme will need to take account of any potential visual impacts on recreational users within the green belt and Regional Park, and on the openness of the Green Belt. In terms of recreational uses, the Lee Valley Leisure Complex Golf Course is a key recreational asset, lying immediate south of the Meridian Business Park site. The sites landscape context is formed by heavily modified landscape elements including transport and water/utilities infrastructure considered to be of low sensitivity. Redevelopment of the Meridian site (existing industrial estate) would not materially change this wider landscape character. Due to the largely open site boundary with the LVRP, construction and operational impact would also affect wider perceptual landscape character. The layout plan for the Option identifies that there is very limited space at the eastern boundary to accommodate structural landscaping to mitigate these impacts.

5.5.9

5.5.10 Space for mitigation at the northern boundary, to screen the development from the Ponders End Mills Conservation Area, is also limited and potential impacts on this Conservation Area and listed buildings would need further detailed assessment as part of preparing the detailed design for the option. The site also lies within the LB Enfield Area of Archaeological Importance and the impact of the development of the Upgrade on this unknown archaeological resource would have to be established. There are similar archaeological risks relating to the implementation of a pipeline transfer from this site to the Deephams Sewage Works site, across the Lee Valley Leisure Complex Golf Course. 5.5.11 Potential environmental effects upon the Chingford Reservoirs SSSI are likely to be restricted to impacts of disturbance upon birds, as the boundary of the site is approximately 100m from the SSSI. The potential effect of disturbance upon bird species utilising the SSSI is likely to be low as the reservoirs are at an elevated level compared to that of the development site and, due to the size of the SSSI, there is ample habitat into which the birds can relocate following disturbance. 5.5.12 The Lee Valley SMINC is located adjacent to the Meridian Business Park site with no physical barriers between the site and the SMINC. Potential environmental effects upon the SMINC are unlikely as although the SMINC falls within the Meridian Business Park site boundary, this area is already developed and works at the Deephams site are contained within the existing developed area. The proposed pipeline connection will require disturbance of vegetation within the northern part of the Lea Valley Golf Course around its waterbody. This area forms part of the SMINC. The use of the waterbody by great crested newts is unknown and this would need to be investigated as the transfer pipeline passes in close proximity. There is also the potential for impacts through disturbance and loss of habitat on common breeding birds, bats, reptiles and invertebrates, for which mitigation would need to be provided. 5.5.13 There is the risk of potential impacts on groundwater and surfacewater during construction and operation of the Upgrade, although these risks are considered capable of mitigation with normal good practice construction techniques and our normal operational management procedures. The assessment work identifies that it may be necessary to incorporate flood mitigation as part of the upgrade and there is some limited space available to incorporate this on site. Once the implementation of the upgrade is completed on the Meridian Business Park site there will be a positive impact on water quality in the Salmons Brook.

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5.5.14 Access to the site from the A1055 (Meridian Way) is via Morson Road. Access to the site will involve a sharp turn on to Morson Road off the A1055, which could possibly constrain delivery of abnormal or indivisible loads (AILs). Outside peak hour material delivery times may be imposed by LB Enfield / TfL, and appropriate routing will need to be identified and mitigation provided if required. Construction traffic should be routed away from residential areas to avoid emissions, severance, accident risk, fear and intimidation problems. There is the potential to consider the use of water freight transport for some construction materials or items, pending detailed examination of the constraints within the Lee Navigation. Travel planning will also be required and initiatives implemented, including ensuring ease of access for staff / workers to/from nearest rail station. 5.5.15 Construction activities are likely to cause some temporary disruption to recreational users of the LVRP. These impacts would principally be on users of public rights of way (PRoW) immediately adjacent to the site, particularly along the Lee Valley Walk, Lee Valley Pathway and Lee Valley Cycle Route. Users may be affected by noise, dust and odour emissions and by visual impacts and increased traffic associated with construction activities. There is the potential for temporary noise impacts on the northern part of the Lee Valley Leisure Complex golf course. 5.5.16 Potential impacts on the local community, including nearby sensitive receptors, are predicted to arise during construction including from noise, dust, traffic and odour. The nearest sensitive receptors are at the high rise residential developments on Alma Road at a distances of approximately 175m and 200m. Others include further residential properties on Alma Road and Sandhurst Road at 250 to 300m. The Lee Valley Golf course is located at a distance of 200m to the south of the site, and the Lee Valley Camping and Caravan Park at a distance of approximately 500m. 5.5.17 The highest levels of construction noise would usually occur during demolition, site clearance, earthworks and piling activities, impacting on residential properties to the north of the site and beyond the A1055 and railway line at Ponders End, including the Academy school that is under construction. There are likely also to be impacts on visitors/users of Lee Valley Camping and Caravan Park and Lee Valley Leisure and Golf course during construction of the pipeline connections. However, all these impacts would be temporary and short term and would be mitigated through implementation of a CEMP. 5.5.18 Construction traffic could cause disturbance to residential receptors although the use of Meridian Way should not cause significant noise increases as this is already a busy commercial route. Dust impacts are likely to occur, however residential properties are unlikely to be significantly adversely affected as smaller airborne particles are likely to settle out within approximately 100m of the site. Our contractors would work to a Construction Environmental Management Plan (CEMP) which should ensure that residual construction noise and air quality impacts are generally negligible but no more than minor to moderate at the closest receptors. 5.5.19 Through the detailed design of the scheme it should be possible to reduce operational noise to be of negligible impact by appropriate design of buildings housing noisy plant, achieved by screening and enclosures or through sound insulation. Dust emissions during operation would not be expected to be significant.

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5.5.20 The development of the Meridian Business Park option will introduce a new odour source into this location. The development of the upgrade at Meridian Business Park will require the design and implementation of odour controls to a standard to be agreed with LB Enfield as part of the preparation of the Development Consent Order application. These, coupled with implementation of an Odour Management Plan for the site will need to result in no significant odour impacts from the site. Initial modelling works have been completed for the proposals, with the covering of the primary settlement tanks (PSTs) on the Meridian Business Park site, and secondary digesters on the Deephams Sewage Works site, as part of the odour mitigation strategy. In this scenario, approximately 250 properties are within the 5ouE/m3 contour (the majority of recorded complaints about odour from the existing Deephams Sewage Works site originate within this 5ouE/m3 area), as shown in Figure 16 below. Different treatment technologies could result in minor changes to the number of properties affected.
Figure 16: Illustrative plan of potential odour generation from Meridian Business Park site option

5.5.21 The Meridian Business Park site has higher carbon emissions during construction and operation than the Deephams site as there is a requirement for pipeline materials and pumping energy to transfer sewage to and from the Deephams Sewage Works site.

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Engineering Issues 5.5.22 The size of the site is only just large enough to accommodate the IFAS treatment processes, themselves being a reduced footprint than conventional AS processes. The layout for the Option highlights that further work will be required in consultation with contractors to refine the proposals to allow for necessary separation between the development and the Lee Navigation and Wharf Road. 5.5.23 Construction of the Meridian Business Park IFAS Option is assumed to last until February 2021. The construction would proceed as a single phase construction project, once the land has been acquired and existing occupiers and users have been relocated off site. This relocation results in a delayed construction start date. The improvements in treated effluent quality that would be delivered as a result of the implementation of the option are indicated in Figure 17 below.
Figure 17: Indicative effluent quality timeline for the Meridian Business Park IFAS option

Progress Towards Future Discharge Permit

Construction Finish

Meridian IFAS
Construction Start

BOD SS Amm

Permit Limits

RGF Built

Time

5.5.24 The IFAS technology is not widely used on the scale envisaged for Deephams and there are only a limited number of suppliers of the IFAS variants that we consider to represent proven technology. Nevertheless, we consider that value for money to our customers could be achieved through a competitive tendering process. Conclusions on Meridian Business Park site 5.5.25 The conclusions on the Meridian Business Park site are reported in section 9.3 of this report.

6 Assessment of Lee Valley Leisure Complex Golf Course (southern part) site
6.1 6.1.1

Section objectives
This section describes the assessment of the Lee Valley Leisure Complex Golf Course (southern part) site.

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6.2 6.2.1

The site
This is a 23 hectare site forming part of the wider Lee Valley Leisure Complex. The existing uses on this site include part of the wider golf course, and the camp site and related car park. The wider leisure complex includes the remainder of the golf course, together with a cinema, indoor bowls, indoor and outdoor athletics and large areas of car parking. The site is located to the north of Deephams sewage works (site 1), west of the William Girling Reservoir (A). It is bound by the A1055 (Meridian Way) to the west with residential areas (B) located further beyond the A1055, and also immediately to the south. Open space (C) located to the north is part of the existing Leisure Complex. Picketts Lock Lane (D) forms the southern boundary and the Lee Navigation (E) its eastern boundary, beyond which lies the William Girling Reservoir. A builders merchants (F) is located adjacent to the south east corner of the site and a disused industrial/warehousing unit (formerly occupied by Coca Cola) (G) to the south west. Meridian Business Park (Site 6) is situated further to the north, beyond the golf course. The planning and environmental constraints for the site are identified in Figure 18 below.
Figure 18: Planning and environmental constraints - Lee Valley Leisure Complex Golf Course (southern part) site

6.2.2

6.2.3

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6.3 6.3.1

Summary of our conclusions at the site assessment (stage 2a) stage


Our site assessment (stage 2a) conclusions on this site was that it was considered to represent a good opportunity to accommodate the upgrade in engineering terms, given its close proximity to the Deephams Sewage Works site. However, the site was assessed as having significant and complex land acquisition risks given that it is in public ownership by the Lee Valley Regional Park Authority and the Authority has indicated that the site would not be made available for the upgrade. Notwithstanding the land acquisition risks and complexities, given the close proximity of the site and the relative lack of engineering constraints, we concluded that this site should become a shortlist site. Further assessment of the land acquisition issues needed to be undertaken, and formal (written) confirmation of the Lee Valley Regional Park Authoritys position on the future of the site secured and assessed.

6.4 6.4.1

Shortlist Option for assessment


The treatment technology option used as the basis for the assessment of the site is a more modern version of the sewage treatment processes on the existing Deephams Sewage Works site Conventional Activated Sludge treatment process. This process is robust and resilient, has an established track record and is proven on the scale required at Deephams. An illustrative layout for the infrastructure that would need to be built at the Lee Valley Leisure Complex Golf Course (southern part) site as part of this option is shown in Figure 19 below. Figure 15 above identifies the infrastructure that would need to be built at Deephams Sewage Works as part of this option.

6.4.2

6.5

Key outcomes from the assessment


Property/Legal issues

6.5.1

The Lee Valley Leisure Complex Site is owned by the Lee Valley Regional Park Authority (LVRPA) which has statutory responsibility for the planning and management of the Regional Park. The site is in active use for recreation and open space uses, and the adjoining land includes the nationally and regionally significant Lee Valley Athletics Centre. The LVRPA has clearly stated in writing that the site is not available for use to deliver the upgrade, and that it would strongly resist any attempts made to acquire the land compulsorily. It considers that there would be significant local, regional and national support for its opposition to the use of the site for the upgrade. Whilst a compulsory purchase order may be applied for as part of an application for a Development Consent Order, the open space use of the site, and LVRPA ownership bring additional complexities, including the need for special parliamentary procedures to also be followed to acquire control of the land. Land owned by the LVRPA has special protection under the terms of the Lee Valley Regional Park Act 1966. Our assessment is that a Compulsory Purchase Order and further legal procedures would need to be followed to acquire the site. As a result, we have assessed the land acquisition risks as complex with the likelihood these could delay or frustrate the development of the upgrade on this site.

6.5.2

6.5.3

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Figure 19: Illustrative Lee Valley leisure Complex (Southern part) conventional AS layout

6.5.4

Given the landowners strongly stated position, and the legal position with acquisition of open space and land owned by the LVRPA, it is not possible to conclude that the site could be successfully acquired. Planning and Environmental Issues

6.5.5

Development of the upgrade on this site will require an application for Development Consent to be submitted to the National Infrastructure Directorate of the Planning Inspectorate under the Planning Act 2008. The site comprises the southern part of the Lee Valley Leisure Complex Golf Course, including a campsite. The site is protected from non open space or recreational developments by national guidance and by a number of development plan policies. The site lies wholly within the Green Belt and also within the LVRP. It is also designated as public open space. The development of the upgrade on this site would conflict with relevant national guidance and development plan policy.

6.5.6

6.5.7

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6.5.8

In addition to direct impacts on the Green Belt, Regional Park and open space, there would also be indirect impacts on the wider Green Belt and Regional Park designation through impacts relating to odour, noise, dust and visual impacts. The design of the scheme would also need to take account of visual impacts on recreational users within the Green Belt and Regional Park, and on the openness of the green belt. The Lee Valley Athletics Centre immediately to the west of the site is a key recreational asset, that could be materially affected by the development of the upgrade on this site. Potential environmental effects upon the Chingford Reservoirs SSSI are likely to be restricted to impacts of disturbance upon birds, as the boundary of the site is approximately 80m from the SSSI. The potential effect of disturbance upon bird species utilising the SSSI is likely to be low as the reservoirs are at an elevated level compared to that of the development site and, due to the size of the SSSI, there is ample habitat into which the birds can relocate following disturbance.

6.5.9

6.5.10 No habitat loss from the Lee Valley SMINC is considered likely with the proposed development as the boundaries of the proposal do not encroach into it. Mitigation measures to control the impacts of disturbance upon the Lee Valley SMINC should be incorporated to ensure encroachment of works beyond the site does not occur, for example through the erection of screening and/or barrier fencing. There is also the potential for impacts through disturbance and loss of habitat on site which could affect common breeding birds, bats, reptiles and invertebrates, for which mitigation would need to be provided. The site lies within the LB Enfield Area of Archaeological Importance and the impact of the development of the Upgrade on this unknown archaeological resource would have to be established. 6.5.11 There is the risk of potential impacts on groundwater and surfacewater during construction and operation of the Upgrade, although these risks are considered capable of mitigation with normal good practice construction techniques and our normal operational management procedures. Our assessment work identifies that parts of the site fall within Flood Zone 2 and the upgrade would need to avoid developing within these areas or provide flood mitigation as part of the upgrade scheme. Once the implementation of the upgrade is completed on this site, there will be a positive impact on water quality in the Salmons Brook. 6.5.12 Good access to the site is available either from the A1055 (Meridian Way) or from Picketts Lock Lane. Outside peak hour material delivery times may be imposed by LB Enfield / TfL, and appropriate routing will need to be identified and mitigation provided if required. Construction traffic should be routed away from residential areas to avoid emissions, severance, accident risk, fear and intimidation problems. There is the potential to consider the use of water freight transport for some construction materials or items, pending detailed examination of the constraints within the Lee Navigation. Travel planning will also be required and initiatives implemented, including ensuring ease of access for staff / workers to/from nearest rail station. 6.5.13 Construction activities are likely to cause some temporary disruption to recreational users of the LVRP. These impacts would be on users of facilities within the Lee Valley Leisure Complex and the public rights of way (PRoW) immediately adjacent to the site, particularly along the Lee Valley Walk, Lee Valley Pathway and Lee Valley Cycle Route. Users may be affected by noise, dust and odour emissions and by visual impacts and increased traffic associated with construction activities.

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6.5.14 Potential impacts on the local community, including nearby sensitive receptors, are predicted to arise during construction including from noise, dust, traffic and odour. There are a number of residential receptors close to this site in Picketts Lock Lane, Chaffinch Close, Linnet Close and Charlton Road, at distances of up to 250m. Other receptors are located in Bunting Close, Penfold Road, Cambourne Avenue and Wellstead Road, at distances of 250-350m. 6.5.15 The highest levels of construction noise would usually occur during demolition, site clearance, earthworks and piling activities, impacting on residential properties on Picketts Lock Lane and to the west of the site beyond the A1055 and railway line. These impacts would be temporary and short term and would be mitigated through implementation of a CEMP. 6.5.16 Construction traffic could cause disturbance to residential receptors although the use of Meridian Way should not cause significant noise increases as this is already a busy commercial route. Dust impacts are likely to occur, however residential properties are unlikely to be significantly adversely affected as smaller airborne particles are likely to settle out within approximately 100m of the site. Our contractors would work to a CEMP which should ensure that residual construction noise and air quality impacts are generally negligible but no more than minor to moderate at the closest receptors. 6.5.17 Through the detailed design of the scheme it should be possible to reduce operational noise to be of negligible impact by appropriate design of buildings housing noisy plant, achieved by screening and enclosures or through sound insulation. Dust emissions during operation would not be expected to be significant. 6.5.18 The development of the option will introduce a new odour source into this location. The nearest sensitive receptors are the adjoining Lee Valley Athletics Centre and residential properties immediately adjoining the site to the south of Picketts Lock Lane. The development of the upgrade at this site will require the design and implementation of odour controls to a standard to be agreed with LB Enfield as part of the preparation of the Development Consent Order application. These, coupled with implementation of an Odour Management Plan for the site will need to result in no significant odour impacts from the site. Initial modelling works have been completed for the proposals, with the covering of the primary settlement tanks (PSTs) on this site, and the secondary digesters on the Deephams Sewage Works site, as part of the odour mitigation strategy. In this scenario, approximately 250 properties are within the 5ouE/m3 contour (the majority of recorded complaints about odour from the existing Deephams Sewage Works site originate within this 5ouE/m3 area), as shown in Figure 20 below. Different treatment technologies could result in minor changes to the number of properties affected. 6.5.19 The Option performs well when considering carbon impacts from the construction phase, although the transfer pipeline requirements of this option give greater carbon emissions during the construction phase than the Deephams site options we assessed. In terms of operational power, this option performs well except for the power required for pumping to and from Deephams Sewage Works and the Lee Valley Leisure Complex Golf Course site.

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Figure 20: Illustrative plan of potential odour generation from Lee Valley Leisure Complex Golf Course (southern part) site option

Engineering Issues 6.5.20 Construction of the conventional AS option is assumed to last until December 2020. The construction would proceed as a single phase construction project, once the site has been acquired and alternative golf course provision provided. This acquisition and re-provision results in a delayed construction start date. The improvements in effluent quality that would be delivered as a result of the implementation of the option are indicated in Figure 21 below. 6.5.21 The conventional AS technology is widely used on the scale envisaged for Deephams and we consider represents proven technology. We consider that value for money to our customers could be achieved through a competitive tendering process.

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Figure 21: Indicative effluent quality timeline for the Lee Valley Leisure Complex Golf Course (southern part) site conventional AS option

LVRP Golf Conv AS


Progress Towards Future Discharge Permit Construction Finish
Construction Start

BOD SS Amm

Permit Limits
RGF Built Time

Conclusions on Lee Valley Leisure Complex Golf Course (southern part) site 6.5.22 The conclusions on the Lee Valley Leisure Complex Golf Course (southern part) site are reported in section 9.4 of this report.

7 Assessment of Ardra Road North industrial site


7.1 7.1.1 7.2 7.2.1

Section objectives
This section describes the assessment of the Ardra Road North industrial site.

The site
This 21 hectare industrial estate site is located off Ardra Road, south of Deephams sewage works (site 1) and north of the Edmonton incinerator (A). The industrial estate consists of a small number of industrial uses, including a major distribution depot, a strategic waste materials handling and transfer facility, and other mixed industrial uses. The A1055 (Meridian Way) runs immediately to the west and the Lee Park Road to the east. The Lee Navigation lies adjacent to the Lee Park Way. To the west of the A1055 and the adjacent railway line lies open space (B) surrounded by housing (C). The planning and environmental constraints for the site are identified in Figure 22 below.

7.2.2

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Figure 22: Planning and environmental constraints - Ardra Road site

7.3 7.3.1

Summary of our conclusions at the site assessment (stage 2a) stage


Our site assessment (stage 2a) conclusions on Ardra Road were that of all of the 12 industrial sites on the longlist, this site, together with Meridian Business Park (Site 6) was assessed by us as being the industrial sites with the most potential for accommodating the upgrade. We concluded that both sites should become shortlist sites, enabling their development potential for the upgrade to be assessed in more detail. This more detailed assessment needed to include further consideration of issues relating to land acquisition, flood risk, and issues relating to the loss of employment opportunities as a priority.

7.4 7.4.1

Shortlist Option for assessment


The treatment technology option used as the basis for the assessment of the site is a more modern version of the sewage treatment processes on the existing Deephams Sewage Works site Conventional Activated Sludge treatment process. This process is robust and resilient, has an established track record and is proven on the scale required at Deephams.

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7.4.2

An illustrative layout for the infrastructure that would need to be built at the Ardra Road North site as part of this option is shown in Figure 23 below. Figure 15 above identifies the infrastructure that would need to be built at Deephams Sewage Works as part of this option.
Figure 23: Illustrative Ardra Road conventional AS layout

7.5

Key outcomes from the assessment


Property/Legal issues

7.5.1

The Ardra Road site is in multiple ownership and the majority of the site comprises relatively recently constructed industrial and warehousing units. The existing warehousing and industrial use indicates that the site would be expected to have high land acquisition costs. There is considered to be a high risk that a Compulsory Purchase Order may be required in order to acquire the site for the Upgrade, although this can be applied for as part of an application for a Development Consent Order. The site does not include any crown or special land and therefore aside from the potential need for a Compulsory Purchase Order it is not considered that there are additional legal complexities relating to land acquisition.
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7.5.2

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Planning and Environmental Issues 7.5.3 Development of the Upgrade on this site will require an application for Development Consent to be submitted to the National Infrastructure Directorate of the Planning Inspectorate under the Planning Act 2008. The site is a safeguarded Strategic Industrial Location (SIL) promoted by the London Plan policy 2.17 and implemented by the LBE Core Strategy Policy 14. Paragraph 2.79 of the London Plan explains that utility developments (such as sewage treatment) would be suitable uses of SIL. Although not a policy requirement, LB Enfield policy interpretation suggests that use of SIL for utilities development would only be acceptable if compensation SIL is provided to overcome any loss of SIL land. Whilst utility development on SIL does not conflict with London Plan Policy, LB Enfield has raised significant concerns about potential loss of employment opportunities through the redevelopment of SIL sites for the Deephams Sewage Works upgrade. The site also lies within the Central Leeside Area Action Plan area, for which the LB Enfield is preparing policies to retain and promote employment opportunities. If the site were to be developed for the upgrade then there would be a specific conflict with the Core Strategy objective of retaining and promoting employment opportunities within the local area. The Ardra Road site is not located within the Green Belt or the Lee Valley Regional Park, however the Green Belt and Regional Park adjoins the site to the east. Development within the boundaries of the site would avoid direct impacts on the Green Belt and Regional Park. However, there is the potential for development on the site to indirectly affect the Green Belt and Regional Park designation through indirect impacts relating to odour, noise, dust and visual impacts. The design of the scheme will need to take account of any potential visual impacts on recreational users within the Green Belt and Regional Park, and on the openness of the Green Belt. The retention of the existing boundary vegetation on the eastern boundary of the Ardra Road site would significantly contribute towards this. The sites landscape context is formed by heavily modified landscape elements including transport and water/utilities infrastructure considered to be of low sensitivity. Redevelopment of the site would not materially change this wider landscape character. The site lies within the LB Enfield Area of Archaeological Importance and the impact of the development of the upgrade on this unknown archaeological resource would have to be established. Potential environmental effects upon the Chingford Reservoirs SSSI are likely to be restricted to impacts of disturbance upon birds, as the boundary of the site is approximately 100m from the SSSI. The potential effect of disturbance upon bird species utilising the SSSI is likely to be low as the reservoirs are at an elevated level compared to that of the development site and, due to the size of the SSSI, there is ample habitat into which the birds can relocate following disturbance. The Lee Valley SMINC is located adjacent to the site, however no habitat loss from the SMINC is considered necessary as the proposals do not extend into the SMINC. There is also the potential for impacts through disturbance and loss of habitat on site which could potentially affect common breeding birds, bats, reptiles and invertebrates, for which mitigation would need to be provided.

7.5.4

7.5.5

7.5.6

7.5.7

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7.5.8

There is the risk of potential impacts on flood risk, groundwater and surfacewater during construction and operation of the upgrade on the Ardra Road site. Some 7 hectares of the 21 hectares site is estimated to fall within Flood Zones 2 and 3 and an area of existing flood storage area will require relocation. Flood compensation storage will be required for this layout. In addition, both the Salmon's Brook and the Deephams effluent outflow channel will require diversion under this option. Salmon's Brook will temporarily be disrupted physically and ecologically and may experience a minor decline in water quality. Standard mitigation measures for river diversion would be required such as restoration of bank vegetation. Other groundwater and surfacewater risks are considered capable of mitigation with normal good practice construction techniques and our operational management procedures. Once the implementation of the Upgrade is completed on the Ardra Road site there will be a positive impact on water quality in the Salmons Brook. There is good access to the site off A1055 (Meridian Way) via Ardra Road for all vehicles. Outside peak hour material delivery times may be imposed by LB Enfield / TfL, and appropriate routing will need to be identified and mitigation provided if required. Construction traffic should be routed away from residential areas to avoid emissions, severance, accident risk, fear and intimidation problems. There is the potential to consider the use of water freight transport for some construction materials or items, pending detailed examination of the constraints within the Lee Navigation. Travel planning will also be required and initiatives implemented, including ensuring ease of access for staff / workers to/from nearest rail station.

7.5.9

7.5.10 Construction activities are likely to cause some temporary disruption to recreational users of the LVRP. These impacts would principally be on users of public rights of way (PRoW) immediately adjacent to the site, particularly along the Lee Valley Walk, Lee Valley Pathway and Lee Valley Cycle Route. Users may be affected by noise, dust and odour emissions and by visual impacts and increased traffic associated with construction activities. 7.5.11 Potential impacts on the local community, including nearby sensitive receptors, are predicted to arise during construction including from noise, dust, traffic and odour. The nearest residential receptors to this site are located in Montague Road, Zambezie Drive, Congo Drive and Hudson Way at a distance of approximately 350m. Montague Recreation Ground is located at 300m to the west of the site. 7.5.12 The highest levels of construction noise would usually occur during demolition, site clearance, earthworks and piling activities, impacting on residential properties to the west of the site and beyond the A1055 and railway Line. However, all these impacts would be temporary and short term and would be mitigated through implementation of a Construction Environmental Management Plan (CEMP). 7.5.13 Construction traffic could cause disturbance to residential receptors although the use of Meridian Way should not cause significant noise increases as this is already a busy commercial route. Dust impacts are likely to occur, however residential properties are unlikely to be significantly adversely affected as smaller airborne particles are likely to settle out within approximately 100m of the site. Our contractors would work to a CEMP which should ensure that residual construction noise and air quality impacts are generally negligible but no more than minor to moderate at the closest receptors.

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7.5.14 Through the detailed design of the scheme it should be possible to reduce operational noise to be of negligible impact by appropriate design of buildings housing noisy plant, achieved by screening and enclosures or through sound insulation. Dust emissions during operation would not be expected to be significant. 7.5.15 The development of the Ardra Road option will extend odour sources further to the south from the existing Deephams Sewage Works site, although in practice it is considered that as the sites are adjacent to each other there would not be a significant change to existing odour contours resulting from the development. The development of the upgrade at Ardra Road will require the design and implementation of odour controls to a standard to be agreed with LB Enfield as part of the preparation of the Development Consent Order application. These, coupled with implementation of an Odour Management Plan for the site will need to result in no significant odour impacts from the site. Initial modelling works have been completed for the proposals, with the covering of the primary settlement tanks (PSTs) on this site and the secondary digesters on the Deephams Sewage Works site, as part of the odour mitigation strategy. In this scenario, approximately 250 properties are within the 5ouE/m3 contour (the majority of recorded complaints about odour from the existing Deephams Sewage Works site originate within this 5ouE/m3 area), as shown in Figure 24 below. Different treatment technologies could result in minor changes to the number of properties affected.
Figure 24: Illustrative plan of potential odour generation from Ardra Road site option

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7.5.16 The Option performs well when considering carbon impacts from the construction phase, although the transfer pipeline requirements of this option give greater carbon emissions during the construction phase than the Deephams site options we assessed. In terms of operational power, this option performs well except for the power required for pumping to and from Deephams Sewage Works and Ardra Road. Engineering Issues 7.5.17 The size of the site is large enough to accommodate the conventional AS treatment processes, however the site is bisected by the Salmons Brook and this and the Deephams effluent outflow channel would need to be diverted to provide for an acceptable treatment process layout. The site is otherwise large enough to provide necessary separation between the development and the Lee Navigation and to accommodate landscaping boundary treatment with the green belt and regional park. 7.5.18 Construction of the Ardra Road AS Option is assumed to last until March 2021. The construction would proceed as a single phase construction project, once existing occupiers and users have been relocated off site. This relocation results in a delayed construction start date. The improvements in effluent quality that would be delivered as a result of the implementation of the option are indicated in Figure 25 below.
Figure 25: Indicative effluent quality timeline for the Ardra Road site conventional AS option

Ardra Rd Conv AS
Progress Towards Future Discharge Permit

BOD
Construction Finish Construction Start

SS Amm

Permit Limits
RGF Built Time

7.5.19 The AS technology is widely used on the scale envisaged for Deephams and we consider it proven technology. We consider that value for money to our customers could be achieved through a competitive tendering process. Conclusions on the Ardra Road site 7.5.20 The conclusions on the Ardra Road site are reported in section 9.5 of this report.

8 Assessment of Lower Hall site


8.1 8.1.1

Section objectives
This section describes the assessment of the Lower Hall site.

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8.2 8.2.1

The site
The 16 hectare site is part of our retained operational land, located to the south of William Girling Reservoir (A). The majority of the site is currently in use as a construction and demolition waste recycling / management facility operated by Camden Plant Ltd under a lease with us. The southern part of the site is currently not in use. The site is bound by the River Lee to the east and by the Lee Navigation to the west, whilst the A406 (North Circular Road) runs to the south. Beyond the Lee Navigation further to the west are Industrial estates (Sites 11, 14 and 16), with Site 1 (Deephams sewage works) located further to the north west. To the east, beyond the River Lee, are residential areas (B). The Meridian Water regeneration area (including sites 17 and 18) lies to the south beyond the A406. The planning and environmental constraints for the site are identified in Figure 26 below.
Figure 26: Planning and environmental constraints - Lower Hall site

8.2.2

8.2.3

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8.3 8.3.1

Summary of our conclusions at the site assessment (stage 2a) stage


Our site assessment (stage 2a) conclusions on the Lower Hall site were that notwithstanding the planning, environmental and engineering constraints to the development of the site, Lower Hall represented the single largest off site opportunity within our ownership for delivering the upgrade. The lack of land acquisition risks and costs means that the upgrade could potentially be delivered quicker on Lower Hall than on any of the other 22 longlist sites. Our conclusion was that the Lower Hall site should become a shortlist site. This enabled the Green Belt, Regional Park and other designations and constraints to be explored in more detail, alongside the assessment of engineering and other issues relating to its potential future development through the shortlist assessment.

8.3.2

8.4 8.4.1

Shortlist Option for assessment


The treatment technology option used as the basis for the assessment of the site is a more modern version of the sewage treatment processes on the existing Deephams Sewage Works site a Conventional Activated Sludge treatment process. This process is robust and resilient, has an established track record and is proven on the scale required at Deephams. An illustrative layout for the infrastructure that would need to be built at the Lower Hall site as part of this option is shown in Figure 27 below. Figure 15 above identifies the infrastructure that would need to be built at Deephams Sewage Works in this option.
Figure 27: Illustrative Lower Hall conventional AS layout

8.4.2

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8.5 8.5.1

Key outcomes from the assessment


The assessment of the Lower Hall conventional AS Option resulted in the following key outcomes. Property/Legal issues

8.5.2

The site presents a good opportunity for the development of the upgrade in property terms as the land is our ownership. The site is currently mostly in use as a waste management operation, although the use does not currently benefit from an extant planning permission. The existing use would need to cease with stored waste removed from the site for the site to be used for the upgrade. Planning and Environmental Issues

8.5.3

Development of the upgrade on this site will require an application for Development Consent to be submitted to the National Infrastructure Directorate of the Planning Inspectorate under the Planning Act 2008. The site lies wholly within the Green Belt and also within the LVRP. The development of the upgrade on this site would conflict with relevant national guidance and development plan policy that seeks to prevent inappropriate development within the green belt. The upgrade would be inappropriate development and very special circumstances would need to be demonstrated before consent could be granted for the development of this site. The Lee Valley Regional Park Authority (LVRPA) and LB Enfield have indicated that they would not support the development of the upgrade on this site. Both authorities are seeking to secure the restoration of the site to Green Belt compatible uses. In addition to direct impacts on the Green Belt, Regional Park and open space, there would also be indirect impacts on the wider Green Belt and Regional Park designation through impacts relating to odour, noise, dust and visual impacts. The design of the scheme would also need to take into account of visual impacts on recreational users within the Green Belt and Regional Park, and on the openness of the green belt. The Lower Hall site lies on the open valley floor and the Upgrade would be visible in views from the local area, including from the A406. There is limited potential for providing boundary or landscape planting as part of the current layout for the site given space constraints. Opportunities for off site planting would need to be explored. Potential environmental effects upon the Chingford Reservoirs SSSI are likely to be restricted to impacts of disturbance upon birds, as the boundary of the site is approximately 100m from the SSSI. The potential effect of disturbance upon bird species utilising the SSSI is likely to be low as the reservoirs are at an elevated level compared to that of the development site and, due to the size of the SSSI, there is ample habitat into which the birds can relocate following disturbance.

8.5.4

8.5.5

8.5.6

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8.5.7

The upgrade would however lead to a direct loss of habitat from the Lee Valley SMINC located within the southern part of the Lower Hall site and along the northern, eastern and western boundaries. Biodiversity mitigation would need to be provided through replacement habitat off site within the local area. There is potential for this to be provided on other land in our ownership to the east of the River Lee. There is also the potential for impacts through disturbance and loss of habitat on site which could potentially affect common breeding birds, bats, reptiles and invertebrates, for which mitigation would need to be provided. The site lies within the LB Enfield Area of Archaeological Importance and the impact of the development of the upgrade on this unknown archaeological resource would have to be established. The site also lies in proximity of a group of Grade II Listed Buildings comprising Chingford Mill Pumping Station, Water Turbine House and associated metal railing. Potential impacts on these would need to be the subject of further work at detailed design stage. There is the risk of potential impacts on groundwater and surfacewater during construction and operation of the upgrade, although these risks are considered capable of mitigation with normal good practice construction techniques and our normal operational management procedures. Once the implementation of the upgrade is completed on this site, there will be a positive impact on water quality in the Salmons Brook.

8.5.8

8.5.9

8.5.10 Our assessment work identifies that the site is located in Flood Zones 2 and 3. Flood risk is therefore a significant constraint to the development of the site. The limited amount of space on site to cater for the existing flood risk would mean that off site flood storage would be required. It is also relevant to note that the Lower Hall site has been identified by LB Enfield as a potential flood storage solution to the flood risk constraints affecting its planned Meridian Water regeneration scheme. The development of the upgrade at Lower Hall would mean that the site was not available for the Meridian Water flood mitigation proposals. 8.5.11 Good access to the site is available from the A406 to the south of the site via Lower Hall Lane. Outside peak hour material delivery times may be imposed by LB Enfield / TfL, and appropriate routing will need to be identified and mitigation provided if required. Construction traffic should be routed away from residential areas to avoid emissions, severance, accident risk, fear and intimidation problems. There is the potential to consider the use of water freight transport for some construction materials or items, pending detailed examination of the constraints within the Lee Navigation. Travel planning will also be required and initiatives implemented, including ensuring ease of access for staff / workers to/from nearest rail station. 8.5.12 Construction activities are likely to cause some temporary disruption to recreational users of the Lee Valley Regional Park, including in particular during the construction of transfer pipelines to and from the Deephams Sewage Works site. These impacts would be on users of the public rights of way (PRoW) immediately adjacent to the site, particularly along the Lee Valley Walk, Lee Valley Pathway and Lee Valley Cycle Route. Users may be affected by noise, dust and odour emissions and by visual impacts and increased traffic associated with construction activities.

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8.5.13 Potential impacts on the local community, including nearby sensitive receptors, are predicted to arise during construction including from noise, dust, traffic and odour. The nearest sensitive receptors are residential properties in Mandeville Court, Lower Hall Lane and Russell Road at distances of 150 to 250m. Other receptors are located in Hall Lane and Hollywood Road at distances of 270 to 320m. 8.5.14 The highest levels of construction noise would usually occur during demolition, site clearance, earthworks and piling activities, however as baseline noise levels at the site are high given the close proximity of the A406, and impacts would be temporary and short term. It is considered that temporary construction impacts would be capable of mitigation through implementation of a Construction Environmental Management Plan (CEMP). 8.5.15 Construction traffic could cause disturbance to residential receptors although the use of access from the A406 to the south should not cause significant noise increases as this is already a busy commercial route. Dust impacts are likely to occur, however residential properties are unlikely to be significantly adversely affected as smaller airborne particles are likely to settle out within approximately 100m of the site. Our contractors would work to a CEMP which should ensure that residual construction noise and air quality impacts are generally negligible but no more than minor to moderate at the closest receptors. 8.5.16 Through the detailed design of the scheme it should be possible to reduce operational noise to be of negligible impact by appropriate design of buildings housing noisy plant, achieved by screening and enclosures or through sound insulation. Dust emissions during operation would not be expected to be significant. 8.5.17 The development of the option will introduce a new odour source into this location. The development of the upgrade at this site will require the design and implementation of odour controls to a standard to be agreed with LB Enfield and LB Waltham Forest as part of the preparation of the Development Consent Order application. These, coupled with implementation of an Odour Management Plan for the site will need to result in no significant odour impacts from the site. Initial modelling works have been completed for the proposals, with the covering of the primary settlement tanks (PSTs) on this site and the secondary digesters on the Deephams Sewage Works site, as part of the odour mitigation strategy. In this scenario, approximately 230 properties are within the 5ouE/m3 contour (the majority of recorded complaints about odour from the existing Deephams Sewage Works site originate within this 5ouE/m3 area), as shown in Figure 28 below. Different treatment technologies could result in minor changes to the number of properties affected. 8.5.18 The Lower Hall conventional AS Option is considered to perform well when assessing carbon impacts from the construction phase. However, in terms of operational power, Lower Hall conventional AS option performs less well due to the power required for pumping to and from Deephams Sewage Works and Lower Hall.

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Figure 28: Illustrative plan of potential odour generation from Lower Hall site option

Engineering Issues 8.5.19 The site is large enough to accommodate the conventional AS treatment processes, but only with revised process loads that allow a smaller footprint layout to be designed. The layout for the site would require the diversion of the footpath to the north of the site, and also working in close proximity to the high voltage overhead power lines that cross and run along the western boundary of the site. The layout currently does not leave space for on site flood mitigation, sufficient biodiversity mitigation or boundary treatment and landscaping. As a result there would be a need for further refinement of the layout in discussions with contractors if this site were to become the preferred option, to design an acceptable layout for the site. Development of the upgrade at Lower Hall would also represent challenges in constructing pipeline transfers to and from the Deephams Sewage Works site, either under or over the Lee Navigation. 8.5.20 Construction of the Lower Hall AS Option is assumed to last until November 2018, making this the fastest option for delivering the upgrade. The construction would proceed as a single phase construction project. The improvements in effluent quality that would be delivered as a result of the implementation of the option are indicated in Figure 29 below.

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Figure 29: Indicative effluent quality timeline for the Lower Hall site conventional AS option

Lower Hall Conv AS


Progress Towards Future Discharge Permit
Construction Finish Construction Start

BOD SS Amm

Permit Limits

RGF Built

Time

8.5.21 The conventional AS technology is widely used on the scale envisaged for Deephams, however there may be a need for revised process designs to accommodate the upgrade on this site. These would need to be verified with contractors to ensure that they can be delivered. We consider conventional AS to be proven technology, and that value for money to our customers could be achieved through a competitive tendering process. Conclusions on the Lower Hall site 8.5.22 The conclusions on the Lower Hall site are reported in section 9.6 of this report.

9 Conclusions and identification of preferred site


9.1 9.1.1 9.2 9.2.1

Section objectives
This section outlines the conclusions of our assessment work and identifies our preferred site.

Conclusions on the Deephams Sewage Works site


The Deephams Sewage Works site is an established site that has been in use for sewage treatment for decades. The continuation of this use is an appropriate use for the site, and the principle of developing the upgrade on the existing site is consistent with national, regional and local planning policies. All the existing sewers within the catchment drain to the existing Deephams Sewage Works site and the consented discharge point for treated effluent is at the Salmons Brook. Upgrading the existing site will take advantage of this existing infrastructure and avoid the need for costly and complex pipeline transfers of sewage, effluent and sludge to and from Deephams.

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9.2.2

Redeveloping and upgrading the existing site is technically challenging, as the existing works must continue to function throughout construction works. There is only limited space available on the site currently, meaning that an upgrade would have to be built in a series of phases over a number of years. There are resulting risks to our ability to meet the current discharge consent requirements during this period. A multiphased redevelopment is also more costly to build than a single phased build on an undeveloped site. The development would bring sewage treatment operations closer to some existing residential properties and other sensitive receptors. This will require further detailed assessment and the preparation of appropriate design solutions and the inclusion of any necessary noise, odour or other mitigation. Our assessment of the three treatment technologies gives us confidence that the conclusions of our assessment of the site would be robust for whichever treatment technology is selected for the upgrade. Our assessment showed that whilst the options resulted in variations to the extent of the built development, construction programme and costs, there were not significant differences between the assessment outcomes for each option. We therefore have confidence that an appropriate treatment technology can be identified for development on the Deephams Sewage Works site.

9.2.3

9.2.4

9.3 9.3.1

Conclusions on the Meridian Business Park site


This site is in multiple ownerships and we would need to acquire the land and relocate any existing uses before construction of the upgrade could commence. It was assessed that there was a risk that a compulsory purchase order might be required to achieve this. Land acquisition costs and risks were assessed as being complex, with the potential to delay commencement of construction at best, or at worst to frustrate the delivery of the upgrade on this site. Given the existing use of the site, the costs of land acquisition and relocation of uses was assessed as being high, increasing the overall costs of the upgrade. The site is designated as Strategic Industrial Land and is important for the job opportunities that it provides. The site also lies within one of LB Enfields place shaping priority areas, for which it is an important area of job opportunities. The development of an upgrade on this site was assessed as conflicting with the LB Enfields planning policies relating to employment and regeneration. The development of the upgrade on this site is assessed as leading to potential impacts on the environment and local community. It would introduce a new odour source into the Ponders End area, which would need to be controlled and mitigated to avoid odour impacts. The development of the upgrade would also be within close proximity of residential properties and a new Academy school and close to the Green Belt, LVRP and the Lee Valley Leisure Complex Golf Course. The layout that has been prepared for this site indicates that there would be limited space available for any on site landscaping or other environmental mitigation. The site would not be capable of being screened from views, and flooding, nature conservation and other mitigation may have to be provided off site.

9.3.2

9.3.3

9.3.4

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9.3.5

There would be a need to build transfer pipelines to and from this site to the existing Deephams Sewage Works for sewage, treated effluent and sludge, incurring additional financial costs and environmental impacts during construction. There would then be ongoing financial and carbon costs associated with pumping during the operation of the upgraded works.

9.4 9.4.1

Conclusions on the Lee Valley Leisure Complex Golf Course (southern part) site
This site is wholly owned by the Lee Valley Regional Park Authority and it is in active use as a golf course and camp site. It forms part of the wider Lee Valley Leisure Complex, including the regionally important athletics centre. The Regional Park Authority has confirmed that it would not make the land available for development and would strongly resist any attempts to acquire it. It considers that there would be significant local, regional and national support for its opposition to the use of the site for the upgrade. Our assessment is that a compulsory purchase order would be required to acquire the site. We have assessed the land acquisition risks as complex with the potential to delay or frustrate the development of the upgrade. Given the landowners strongly stated position, it is not possible to conclude that the site could be successfully acquired, and therefore the site should not be considered to be readily available for the upgrade. The site is also within the Green Belt and LVRP and it is in active open space/recreational use. The development of the upgrade on this site would conflict with national, regional and local planning policy that seeks to prevent inappropriate development within the Green Belt, to protect the Regional Park and to prevent the loss of designated Open Space. The development of the upgrade on this site is also assessed as leading to potential impacts on the environment and local community.

9.4.2

9.4.3

9.5 9.5.1

Conclusions on the Ardra Road site


This site is in multiple ownerships and we would need to acquire the land and relocate any existing uses before construction of the upgrade could commence. It was assessed that there was a risk that a compulsory purchase order might be required to achieve this. Land acquisition costs and risks were assessed as being complex, with the potential to delay commencement of construction at best, or at worst to frustrate the delivery of the upgrade on this site. Given the existing use of the site, the costs of land acquisition and relocation of uses was assessed as being high, increasing the overall costs of the upgrade. The site is designated as Strategic Industrial Land and is important for the job opportunities that it provides. The development of an upgrade on this site is assessed as conflicting with the LB Enfields planning policies relating to protection of these employment opportunities. The development of the upgrade on this site is assessed as leading to potential impacts on the environment and local community. The development of the upgrade would be within close proximity of residential properties and close to the Green Belt and LVRP. Parts of the site are at risk of flooding and flood mitigation would be required to be provided either on or off site.

9.5.2

9.5.3

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9.5.4

As the site lies immediately adjacent the Deephams Sewage Works site, the transfer pipelines for sewage, treated effluent and sludge would only need to be short, incurring less additional financial costs and environmental impacts than the other shortlist sites.

9.6 9.6.1

Conclusions on the Lower Hall site


We already own the Lower Hall site. There would be a need to end the current waste processing operations on the land (Camden Plant) in order to build the upgrade on this site. However, apart from this there are no property or legal costs or risks associated with the development of the upgrade at this site. As the site would not need to be acquired, and the upgrade could be built in a single phase, Lower Hall is the option that could deliver the upgrade in the shortest timescale, subject to securing consents for the scheme. The site is within the Green Belt and LVRP. The development of the upgrade on this site would conflict with national, regional and local planning policy that seeks to prevent inappropriate development within the Green Belt and to protect the Regional Park. In relation to the Green Belt policies, we would need to justify why an exception to normal policies should be made in order to secure permission on this site. This would have to include consideration of the availability of alternative options including the options on the existing Deephams Sewage Works site. The development of the upgrade on this site is also assessed as leading to potential impacts on the environment and local community. Development would introduce a new odour source into the local area, which would need to be controlled and mitigated to avoid odour impacts. The development of the upgrade would also be within close proximity of residential properties and within the flat valley floor for which mitigation of visual impacts would be limited. Parts of the site are subject to nature conservation and flood risk constraints, and on or off site mitigation would be required. The layout that has been prepared for this site shows that there would be very limited space available for any on site landscaping or other environmental mitigation. The site would not be capable of being screened from views, and flooding, nature conservation and other mitigation may have to be provided off site.

9.6.2

9.6.3

9.6.4

9.7 9.7.1

Identification of the preferred site


The Deephams Sewage Works site is an existing operational site where sewage treatment processes have been undertaken for many years. The development of the upgrade on this site would be in compliance with planning policy. It would not involve the potential compulsory purchase of land, land acquisition costs and related risks to the timetable and delivery of the upgrade. This means that the use of the Deephams Sewage Works site for the upgrade has significant advantages over other shortlist sites.

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9.7.2

Provided that the challenges of upgrading the existing site alongside the continued operation of the existing works can be met, the conclusion of our assessment is that our preferred site for delivering the upgrade is the existing Deephams Sewage Works site. We will undertake further work to ensure these challenges can be met and that an upgrade can be delivered on the Deephams Sewage Works site to a timetable acceptable to the Environment Agency (the environmental regulator), at a financial cost to our customers that is acceptable to Ofwat (our financial regulator) and to a design with potential environmental impacts and associated mitigation proposals that is acceptable to London Borough of Enfield (the local planning authority), other stakeholders and affected communities. However, should the options for delivering the upgrade on the existing Deephams Sewage Works site prove not to be deliverable following further assessment, we believe that the Lower Hall site would be the next most appropriate site for the delivering the upgrade. This site lies within our ownership, in close proximity to the existing Deephams Sewage Works site. Whilst it is designated Green Belt and within the Lee Valley Regional Park, we consider it represents the next most appropriate site to accommodate the upgrade. The other shortlist sites, Meridian Business Park, Ardra Road, and the Lee Valley Leisure Complex Golf Course (southern part) sites, have existing use and acquisition costs and risks such that they are not preferred sites for delivery of the upgrade.

9.7.3

9.7.4

10 Next steps
10.1.1 Details of our preferred site will be published as part of the phase 1 public consultation. We will invite the submission of comments both on our conclusions and the assessment work we have undertaken to date. 10.1.2 Alongside and following the consultation we will undertake further work on the design of the upgrade, including the treatment technology options that could be adopted on our preferred site. This work will be informed by feedback from the consultation process, our own design work, and input from potential contractors. 10.1.3 We will then continue to develop and assess the upgrade in accordance with our Assessment Methodology. This will involve a further phase of consultation, further design development work and environmental impact assessment. At the conclusion of this process, we will select the scheme we intend to take forward for application.

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