Webinar Q&A

Air quality

The Site is in an Air Quality Management Area (AQMA), designated for exceedances. Does this mean that the area is more likely to exceed London standards for air pollution? How has this affected your plans?

All of Waltham Forest is designated as an AQMA for NO2 and PM10. An AQMA should cover all areas where a Local Authority does not expect air quality targets to be achieved without action.

In practice, this means that emissions from the scheme should not hinder the Council’s Air Quality Objectives set out in their Air Quality Action Plan. In response, we have kept car parking numbers very low to minimise vehicle trips, and adopted an Energy Strategy which mostly relies on Air Source Heat Pumps rather than gas-fired CHP. Our modelling shows that the scheme’s impact on air quality is negligible, and importantly that local Air Quality Objectives will still be achieved with the development in place.

More detail on our approach to air quality can be found in the Detailed Air Quality Assessment, which is appendix 8.1 to the Environmental Statement.

The London Dust guidance provides a list of monitoring requirements for constructions sites. I assume an Air Quality and Dust Management Plan (AQDMP) will be required. Will this AQDMP be public?

The Outline Remediation Strategy and Outline CEMP set out a range of measures that can be used to mitigate for potential air quality and dust impact, including monitoring. The Council have indicated they will require an Air Quality and Dust Management Plan and this could, if necessary, be dealt with by condition after the determination of the planning application.

Berkeley Group

Given that you are already involved in another development dealing with toxic soil linked to health conditions, how are we to trust that - given the soil in this place is toxic - this mismanagement won't repeat itself?

Southall is not a St William site and is instead being delivered by Berkeley West Thames which is a separate division within the Berkeley Group if companies. Southall is different in both size and nature to the Lea Bridge Gasworks site. We have submitted a robust Outline Remediation Strategy for Lea Bridge Gasworks, based on the excavation, removal, and offsite treatment of contamination hotspots. This will be subject to oversight from the Environment Agency and Waltham Forest Council every step of the way.

How diverse is your company? considering there is a high proportion of BAME residents in the local area, do you have anyone from the BAME community working on this development? architects, landscapers, on the St William board?

Respect for people is a core value for the Berkeley Group, and we are proud to have a diverse workforce which reflects the communities in which we work.

Community Benefit

Please explain your strategy for childrens play. What are its target demographics in terms of age groups and access and what are the proposed outcomes in terms of benefit to children? What is the research and knowledge base of the strategy, how you will reach those outcomes? How does this strategy reflect and acknowledge both existing conditions and the cumulative impact of the several developments in the immediate area, of which yours is just one?

Our child play strategy is set out in Section 5.9 of the Design & Access Statement (page 90). Target groups are 0-5s and 5-11s, building on London Plan guidance set out in the Supplementary Planning Guidance on Play and Informal Recreation. It also builds on our assessment of existing provision in the area, which identified play and open space provision already within walking distance of the site. We have responded to this analysis by providing a children’s play area right by the entrance on Clementina Road where it is closest to existing properties, and a mixture of doorstep playable space, play on the way, and two play areas.

Is there a Medical centre?

We are not proposing a medical centre as part of the development. Pre-application discussions with Waltham Forest Council identified a preference for such provision to be provided elsewhere.

Will the new gym be open to Clementina residents or only new residents? You mention it will be for a residents gym.

The gym is a relatively small 175 sq m space for residents of the development only, with its maintenance funded by the estate’s service charge. The space is not designed to suit a commercial gym operator.

Where in Jubilee park can teenagers play?

Leyton Jubilee Park includes a variety of play areas suitable for all age groups, with provision for the 12+ group including football pitches, basketball court, a variety of seating areas and Ive Farm Sports Ground.

Your pitch is coming across as a money making excercise with zero benefit for residents. Our roads our used, we can't use the gym, the bridge won't be improved, our views are spoilt. Is there anything that will benefit locals?

Our planning proposals provide a significant amount of local benefit, including high quality, landscaped spaces, a children’s nursery and much needed new homes including 158 affordable homes. The development will also contribute more than £5 million in Community Infrastructure Levy payments to Waltham Forest Council and the Greater London Authority.

You say you’re building ‘affordable housing” what is the cost of rent for a one bedroom and a two bedroom flat in your complex?

We will be working with a registered provider who will manage both the affordable rented and shared ownership properties within the development. Rent levels will be set by the registered provider, in accordance with the relevant affordability criteria for the London Affordable Rent tenure.

Will this development provide jobs for the local community?

The development will generate about 277 jobs during each year of construction, and we are committed to working with Waltham Forest Council to maximise local access to employment and apprenticeship opportunities.

Can you explain the play value of placing tree trunks and stones around in terms of the play types they facilitate? What play types will not be facilitated by your play strategy?

The examples within the Design & Access Statement are indicative and the exact play equipment will be determined during the detailed design stage. These particular examples form part of our strategy for doorstep play and play on the way.

Construction

Initial demolition and remediation requires the Clementina Road Access point. What concrete measures to compensate residents for 6-8 months (minimum) of construction traffic, noise and dust pollution and contamination are you taking?

The maximum number of vehicles anticipated per day during the enabling stage is 15, or 1.5 vehicles per hour on average per 10 hour working day. Our priority is to create the new access to Orient Way, so construction traffic can be re-routed to avoid the Clementina Estate roads. We are in discussion with the Council on the best approach to vehicle routing and programming of the enabling works.

Full details of methods for dust and noise suppression are included in sections 9.2 and 9.3 of the CEMP, and include restrictions on machinery, water spray and ground covers, and a dedicated contact number for an air quality, dust, and noise liaison displayed at the site entrance.

Figure 8.1 in the ES Vol 1 : Location of Sensitive Human Receptors maps out locations where human receptors are most vulnerable eg at the junction of Clementina and Perth Roads (within 20m of site boundary). What concrete steps are you taking to safeguard these residents in particular, and what compensation do you offer for those residents whose lives will be most significantly impacted by the construction work?

Our primary objective is to deliver to Orient Way junction as early as possible to minimise disruption to Clementina Estate residents. In terms of safeguards, measures will always be put in place to ensure that any site entrance operates safely should it be used by vehicles. This would normally include the use of banksmen to direct both drivers and members of the public and ensure vehicles manoeuvre safely.

Within the Site, the remaining structure and gasholder footprints will need to be removed and appropriate remediation works will need to be carried out. As such, there will be an initial stage of demolition works and site clearance associated with the Development before construction works commence. Stated Variously in the planning documents as approximately 6 months and 8 months, how will you access the site during this period? If you plan to use Clementina access point, do you envisage this being for the full duration of 6-8 months? Can you be more precise about this period?

Our priority is to build the new access to Orient Way, so construction traffic can be re-routed there and avoid the Clementina Estate roads. Our aim is to minimise disruption to local residents, and we are in discussion with the Council on the best approach to achieve this. However, as set out in the
Outline Construction Logistics Plan, we propose to use a combination of banksmen, traffic marshals, controlled delivery times, holding areas and other measures to minimise disruption during any temporary use of the existing access.

The precise approach and duration would be confirmed in the Detailed Construction Logistics Plan. This would be prepared after the planning application has been determined.

It is stated in your planning documents that prescribed hours of work would be agreed with LB Waltham Forest. In-line with LB Waltham Forest Guidance1 and the Control of Pollution Act2, it is anticipated that the core working hours for the Development will be as follows: • 08.00 – 18:00 hours weekdays. • 08:00 – 13:00 hours Saturday; and • No noisy activities on-site on Sundays or Bank Holidays. Can you guarantee that this is the case and you will not be working outside these hours?

The construction logistics plan we’ve submitted proposes to adhere to the standard working hours which are 8am – 6pm Monday – Friday and 8am – 1pm on Saturday. In light of COVID-19, the emergency legislation allows longer working hours. The way that St. William use that policy is to enable staggered arrival of our site staff and our contractors, and thereby achieve social distancing. It is not certain how long the extended working hours policy will be in place for, and the hours have therefore not been factored in to our plans at this stage.

On occasion, it is necessary to seek an extention to the standard hours, for instance to facilitate plant movement, and permission would be sought for this from the Council in advance.

Where will the waiting and holding areas facilitated by LB Waltham Forest be? Will it affect our streets and area?

We have submitted an Outline Construction Logistics Plan which suggests the use of holding areas. The holding areas would not be within the Clementina Estate. The location of holding areas will be reviewed and confirmed via a Detailed Construction Logistics Plan.

You state that, "Demolition and construction works will require access to the Site by Heavy Goods Vehicles (HGVs) to deliver plant and materials and remove waste material. To minimise the impact of the access and egress arrangements on-site, vehicles will enter and exit under the supervision of accredited traffic marshals and banksmen to ensure manoeuvres are undertaken safely. It is anticipated that Demolition and Construction Transport Management Plan will be secured by a planning condition for submission to LB Waltham Forest for approval in advance of the commencement of works onsite.". How do we access the planning conditions? Will they be made public and advertised as such? Can you schedule heavy transit away from peak traffic times (morning, school run, and evening)?

Any documents associated with planning conditions become public documents once they are submitted to discharge a planning condition. Waltham Forest Council will be able to confirm where the relevant documents are then made available and how this is publicised.

Can you guarantee that construction workers and development personnel will not be parking on Clementina Estate?

As outlined in the Outline Construction Environmental Management Plan, St William will not permit its staff or contractors to park outside the site. Clementina Estate is covered by a Controlled Parking Zone, and St William staff and contractors will not have access to permits.

If permission is given will you work from 7am until 10pm the new working hours ? If so how are residents to get any peace?

The construction logistics plan we’ve submitted proposes to adhere to the standard working hours which are 8am – 6pm Monday – Friday and 8am – 1pm on Saturday. In light of COVID-19, the emergency legislation allows longer working hours. The way that St. William uses that policy is to enable staggered arrival of our site staff and our contractors and thereby achieve social distancing. It is not certain how long the extended working hours policy will be in place for, and the hours have therefore not been factored into our plans at this stage.

On occasion, it is necessary to seek an extension to the standard hours, for instance, to facilitate plant movement, and permission would be sought for this from the Council in advance.

Can you clear up the discrepancy between what Waltham Forest councillors are saying about the use of the Clementina entrance, what you, the Developers say and what Waltham Forest planning department is saying about access through the Clementina Road entrance and what your architects say?

Our proposals are very clear that there will be no vehicular access through the Clementina Road entrance to the completed development, and this is in response to the conversations we have had with residents about this. The only connection between the development and the Clementina Estate would be for pedestrians and cyclists.

Active discussions are taking place between St William and Waltham Forest Council to address the issues which have been raised with us about access through the Clementina Estate during the construction stage, looking at how we minimise and potentially eliminate requirements for construction vehicles to use the Clementina Estate. We hope to be in a position to confirm our approach very soon.

Will you start you works between March and August?

We will communicate the precise start on the site date to residents once the application has been determined, and the construction programme finalised.

Are you aware that if you could guarantee no vehicular access ever, residents would be so so much more on board?

Our proposals are very clear that there will be no vehicular access through the Clementina Road entrance to the completed development, and this is in response to the conversations we have had with residents about this. The only connection between the development and the Clementina Estate would be for pedestrians and cyclists.

Active discussions are taking place between St William and Waltham Forest Council to address the issues which have been raised with us about access through the Clementina Estate during the construction stage, looking at how we minimise and potentially eliminate requirements for construction vehicles to use the Clementina Estate. We hope to be in a position to confirm our approach very soon.

During your showcases, you presented residents the opportunity to have you build the Orient Way access road first, which would only add 6 months to the length of the project. We articulated our preference for this solution. Why have you gone back on this promise?

We have listened carefully to the concerns expressed to us during last year’s consultation events, and our proposals reflect this for instance by omitting the vehicular drop-off point that we were originally proposing.

Our priority is to build the new access to Orient Way, so construction traffic can be re-routed there and avoid the Clementina Estate roads. Our aim is to minimise disruption to local residents, and we are in discussion with the Council on the best approach to achieve this.

Daylight, Sunlight and Overshadowing

The EIA Scoping Opinion received from LB Waltham Forest notes that the lack of massing on the existing Site has resulted in good levels of daylight for a sub-urban environment. This makes the surrounding receptors vulnerable to a significant change in daylight, sunlight and overshadowing levels as a result of the redevelopment of the Site yet no access has been gained into any of the neighbouring properties to clarify the internal room configurations. Clementina Road even numbered properties will be worse affected; is there anything further you can do to minimise effects of loss of daylight? Why have you not requested access into properties?

Our methodology for assessing daylight impacts is set out in Chapter 11 of the Environmental Statement. The scheme has been designed to respect the light to Clementina Road properties and their gardens, with cutbacks undertaken during the design process to mitigate any noticeable effects. This has resulted in the scheme showing full compliance with the BRE guidance in terms of daylight and daylight to existing properties.

It is not standard practice for daylight and sunlight consultants to gain access to properties neighbouring a development for a scheme such as this.  It is acceptable for reasonable assumptions on room layouts to be made or information available on the planning portal and using estate agents plans. It should also be noted that the VSC (Visual Sky Component) and APSH (Annual Probable Sunlight Hours) assessments consider daylight and sunlight to the window face and therefore are not contingent on room layouts.

Your daylight and sunlight study clearly indicates significant loss of daylight and sunlight during winter for the Clementina Estate. Will you compensate for loss of daylight and sunlight?

Our methodology for assessing daylight impacts is set out in Chapter 11 of the Environmental Statement. The scheme has been designed to respect the light to Clementina Road properties and their gardens, with cutbacks undertaken during the design process to mitigate any noticeable effects. This has resulted in the scheme showing full compliance with the BRE guidance in terms of daylight and sunlight to existing properties.

I understand from mock-ups that the majority of Clementina Road will get no direct sunlight from about 10am until sunset. Because of the 6 and the 9 storey ones planned for the back of Clementina Road/edge of the school playing grounds.. Have you taken into consideration the severe shading and loss of light for all those living on Clementina Road?

Only the shadow analysis for 21 December  (winter solstice) shows that the gardens of Clementina Road would see the described shadow as a result of the proposal. Such shadows would be expected during the winter solstice, because at this time of year the sun is lowest in the sky, and this date therefore represents the worst case scenario in the year.  The assessments for 21 March (equinox) and 21 June (summer solstice) show significantly less shadow effect. All three assessments are shown in detail in Appendix 11.3 of the Environmental Statement Volume III.

The scheme has been designed in accordance with BRE guidance, with the levels of sunlight to the gardens meeting the recommended standards. Similarly with sunlight to windows, the scheme has been designed to be fully compliant with BRE guidance during the winter months as well as across the entire year.

The daylight and sunlight report states there is no noticeable impact on neighbours. What is the cut off in terms of what is considered noticeable?

For daylight, there are two tests when considering the effect on  neighbours, Vertical Sky Component (VSC) and No Skyline Contour (NSC).  If both of these are satisfied then the effect would not be considered noticeable.

For VSC if there is a reduction of less than 20% from the existing level, or an absolute retained VSC level of 27% with the development in place, the effect is not likely to be considered noticeable.

For NSC the effect is measured considering reduction only.  If there is a reduction from the existing level of 20% or less the effect is not likely to be considered noticeable.

For sunlight, if the percentage of probable hours of sunlight falls below 25% over the course of a year and with 5% of the probable hours being received in the winter months (21 September to 21 March) with the proposal in place, in order for there not to be a noticeable effect, the level of reduction should be less than 20% from its existing level or an overall annual loss is less than 4% with the development in place.

The scheme has been designed to respect the light to Clementina Road properties and their gardens, with cutbacks undertaken during the design process to mitigate any noticeable effects. This has resulted in the scheme showing full compliance with the BRE guidance in terms of daylight and sunlight to existing properties.

Environment and Ecology

The Site is located within the River Lea & Tributaries Archaeological Priority Area as defined by LB Waltham Forest which has potential to contain Roman remains as well as paleo-environmental evidence and evidence of prehistoric human activity. A desk based assessment is clearly and evidently insufficient. When can we expect the full archaeological survey to take place?

Complementary archaeological work was undertaken as part of the site investigation in late 2019, in the form of Archaeological Watching Brief and Deposit Model.

This work concludes that there are no known assets of high or very significance on the site, and overall the site has a low potential for the prehistoric to post-medieval periods. We also propose to agree on any post-determination archaeological investigation via planning condition, should there be a need to do so.

You site these the following potential environmental effects associated with construction and occupation: • Temporary construction effects relating to traffic, noise, and air quality • Permanent transport effects associated with the predicted increase in vehicular traffic on Orient Way and the local road network for the competed Development • Transport-related air quality and noise effects of the completed Development • Adverse effects on microclimate including daylight, sunlight, and overshadowing effects, for the surrounding properties and amenity areas that may be overshadowed by taller elements of the Development • Accelerated pedestrian level winds through downdraughts and channelling of winds • Temporary adverse townscape and visual effects during the construction phase and other effects of the completed Development on the townscape character of the Site and on representative views to and from sensitive receptors. What concrete measures are being put in place to mitigate these effects in the short, medium and long term?

The Environmental Statement (ES) summarises the extensive technical assessments that we undertook to rigorously test our proposals before we submitted the planning application. The ES concludes that the scheme sufficiently mitigates for temporary construction effects, whilst the potential adverse permanent effects (contamination and wind) are found not to be significant.

Bat roosts are clearly present on site, and bat activity has been observed on three of the four boundaries of the site (North, East and South). How are you going to preserve roosts present on site boundaries during construction?

Our methodology and findings regarding bats are detailed in Section 4.2 of the Ecological Assessment. A physical survey was undertaken to ascertain for potential roosting sites, and a dawn re-entry survey undertaken in June 2019 to verify findings. The report explains that only limited potential was identified for bat roosting (within an existing structure). None of the trees present within or adjoining the site had any potential to support roosting bats, lacking features such as holes, cracks or dense covering of Ivy). Follow-up surveys found no evidence of roosts nor re-entry at dawn.

Bat activity around the site does not necessarily confirm roosts, and is more commonly associated with bat commuting routes. Whilst we are confident that our survey findings are robust, we would be happy to review any further material that may be available regarding bat activity around the site.

Bat activity has been noted around the site, we are adapting our public lighting design. Existing mature trees are also being retained and this will help maintain existing foraging routes.

Groundwork and remediation are currently scheduled to begin in nesting season of 2021. Can we have a guarantee that this initial work will have no impact on trees and other vegetation? If protected species are encountered during demolition or construction works, will you share this information? What is your strategy for dealing with protected species?

There are clear statutory obligations around bird nesting and protected species, and St William will comply with these.

The Outline Construction Environmental Management Plan confirms in section 9.4 that tree removal will take place outside the nesting season, unless Waltham Forest Council have approved a mitigation scheme in writing. It also confirms that all works will cease and an ecologist consulted if a protected species is encountered.

You state that "Potential human health effects during construction and operation phases are not significant and have been scoped out." Will you clarify which effects were identified, even though considered "not significant", despite clear evidence provided by the EIA that human health effects could potentially be highly significant?

This statement on page 13 of Environmental Statement Volume III refers to a standalone chapter on human health, and goes on to confirm that human health is assessed in Section 12 of the same document. Section 12 states that the development itself is unlikely to result in significant adverse
effects, being mostly residential, whilst indirect effects already considered in detail in Chapters on ground conditions, transport, noise etc.

How safe is it to build around the Pressure Reduction Station? What safety measures have been put in place around this?

The Health & Safety Executive regulate development around utility assets through various regulations including COMAH and PADHI. A Pressure Reduction Station (PRS) is low risk, and can be built around safely with measures contained within the compound. Pressure Reduction Statements are a common feature on St William sites given their historic use for gas infrastructure, and we have an established track record in delivering safe schemes that incorporate a PRS.

There are several schools near the site. Sybourn Primary School and Early Excellence Centre is located approximately 180m to the north and Lammas School, Saint Joseph’s Catholic Infant School and Willow Brook Primary School are located approximately 150m, 325m and 480m east of the Site boundary respectively. What discussions have been had with the schools regarding Health and Safety and are these conversations recorded anywhere?

We consulted the local schools on our proposals, and this is recorded in the Statement of Community Involvement which was submitted with the planning application.

You pledge to install new insect hotels and pollinator friendly planting, bird and bat boxes on new buildings and walls. I have witnessed bats flying in and out of the site. How will provision be made for protecting them? What time of day was the bat study completed?

Our methodology and findings regarding bats are detailed in Section 4.2 of the Ecological Assessment, and follows best practice guidelines issued by Natural England, the Joint Nature Conservation Committee and the Bat Conservation Trust.

The survey was carried out at dawn.

The lighting design has been developed to achieve a level of consistent illumination across the Site, minimising dark areas to create a safe environment whilst avoiding light pollution. Clementina residents currently back on to darkness from the park. Are these permanent lights not considered light pollution?

The reference to light pollution in the Ecological Assessment relates to the potential impact on wildlife that could pass through or over the site.

The detailed design of the lighting scheme will commence once the application has been determined, and the potential impact on adjoining residents will be considered at that stage as part of our design development. The lighting design could, if necessary, be dealt with by condition after the determination of the planning application.

GLAAS Historic England have expressed that archaeological investigations have not been thourough enough to rule out any assets. Are you considering a further archaeological exploration and if not, why?

GLAAS’ response related to the Desk Based Archaeological Assessment submitted as part of the EIA Scoping Request. In response, further investigations were commissioned and are summarised in the Archaeological Watching Brief and Deposit Model Report (Appendix 13.2 to ES Volume I). We also propose to agree any post-determination archaeological investigation via planning condition, should there be a need to do so.

Policy 5.19 ‘Hazardous Waste’ of The London Plan states that sites will be identified for the temporary storage, treatment and remediation of contaminated soils and demolition waste during major developments. Do you know yet where you will carry out your soil remediation?

Any treatment and disposal will take place off-site, at a facility licensed by the Environment Agency. This will be determined as part of the Detailed Remediation Strategy, after the application has been determined.

Whilst not a ground contamination issue, a preliminary review of the UXO risk using online mapping indicates that the Site is an area of high risk of encountering unexploded ordnance What is the procedure for dealing with an unexploded bomb?

All construction activity is risk assessed including the potential for UXO. Where appropriate, a suitably qualified UXO specialist is employed to supervise works and ensure any encounter is controlled and managed. As an example, a UXO specialist supervised St William’s site investigations at Lea Bridge Gasworks in late 2019.

In the proposed building plans will there be included roof ledges for birds to perch to complement the trees already but unsafe in that part of Leyton?

We are proposing brown roofs, bee hotels, bat boxes, etc to promote biodiversity. We are not specifically proposing roof ledges to accommodate birds perching.

Within the proposed plans has consideration been made to install an interactive art focus or an heritage plaque to commemorate the social and industrial heritage of the historical site and what archaeological safe-guards are in place before any construction might begin?

We are keen to include an appropriate feature within the development that commemorates the site’s industrial heritage. We have identified the threshold space within Blocks B & G as a suitable location, as shown on page 78 of the Design & Access Statement. The feature’s design will be developed in more detail once the application has been determined by the Council, and could, if necessary, be dealt with by condition.

What justification is there for clearing the broadleaf woodland noted in the Ecological survey sitting to northeast of the site when the ecological report acknowledges the site provides a suitable habitat for nesting birds and invertebrates?

Biodiversity is very important to St William as part of our landscape-led development approach and commitment to net biodiversity gain on all our sites. We have thoroughly surveyed the site, and whilst the overgrown tennis court was noted as providing opportunities for birds, it offers fewer opportunities for invertebrates. Overall, the area was found to offer limited value in the context of the wider area. More importantly perhaps, as part of our remediation strategy, we need to apply a clean capping layer, also requiring this area to be cleared which we were originally hoping to avoid.

We will be replacing the current vegetation on the site boundary currently formed by the tennis court with dense replacement planting, and are delivering a significant biodiversity gain across the site.

Water pressure in the neighbourhood is already very poor. What steps are being taken to ensure residents will not suffer from a further drop in pressure given the huge increase in demand on the mains that will result from the proposed development?

Thames Water has indicated that there is some spare capacity on the local network, however, there will also be a need for some reinforcement to accommodate the development. A detailed modelling study will be undertaken once the application has been decided, and this will confirm the precise level of reinforcement needed. This will be funded by the development.

Why is it impossible to grow edible plants on the site?

The site will be able to accommodate a variety of species, including edible varieties. Various options including orchard trees are shown in the Design & Access Statement, and the detail will be developed at a later stage.

We're sufficiently connected to the park to the south - how will you financially compensate local residents for disruption, pollution and permanent visual impact?

Our planning proposals provide a significant amount of local benefit, including high quality, landscaped spaces, a children’s nursery and much needed new homes including affordable
housing. We are not proposing to financially compensate individual residents.

Can you give us concrete reassurance you won't be removing mature trees around the outside perimeter of the planned development? This is a site for woodpeckers, bats and many other indigenous wildlife including the trees themselves. These old trees are always vital for air quality in this area of heavily polluted local air.

St William is committed to retaining the existing trees on the site boundaries with Leyton Jubilee Park, which are on council-owned land. We have been careful to ensure that their root areas are protected during the remediation, as well as taking care of the design and placement of the proposed buildings to avoid root protection areas.

What measure have been taken to address the current climate emergency? Will this be a zero carbon development?

The development will comply with the latest energy efficiency standards within the draft London Plan and the draft Waltham Forest Local Plan, including renewable heat via air source heat pumps and the provision of solar panels. It will not be a zero-carbon development, however, it is zero carbon ready.

Have you dug bore holes along the route of the new road exit to Orient Way?

Yes, the scope of the site investigation included the route down to Orient Way, within St William’s ownership boundary

How will you respond to GLASS request for proper and detailed archaeological studies to rule out Roman remains?

Chapter 13 of the Environmental Statement (ES) sets out the findings from archaeological studies undertaken as part of our planning application and concludes there is low potential for Roman remains within the site. Within the ES, we propose to agree on any post-determination archaeological investigation via planning condition, should there be a need to do so.

What do you know about the Roman Road running through the site?

Our knowledge of local archaeological interest is clearly set out within the Archaeological Desk Based Assessment as well as the Archaeological Watching Brief and Deposit Model.

Height and Visual Impact

Omission of sites in cumulative impact report: • 3 Station Sites • Elm Park Road development • Orient way Pocket Park Development • Lea Bridge Train Station. In your own Environmental Impact statement, you include sites with a reasonable "expectation that they will be built out during construction". While planning permission has not been submitted for these sites, there is every indication that planning, clearing and construction will take place during the construction of the Gasworks site. Why have these sites been omitted when they should be included based on your own criteria?

There are no live planning applications or planning permissions for these sites. Inline the criteria set out within the EIA Scoping Request, in accordance with the EIA Regulations, these sites should therefore not be included in the cumulative assessment.

The height and massing of the development directly contravene the Mayoral Draft London Plan (Intent to Publish D9 Ciii Tall Buildings) where developments should “transition in scale between tall buildings and surrounding context” in cases where the “edges of the site are adjacent to buildings of significantly lower height or parks and other open spaces”. The Gasworks plan places 18 story towers directly adjacent to the open land of Jubilee Park, negatively and permanently affecting the amenity and privacy of park users. How is this plan a) justifiable? and b) possible to mitigate?

The Planning Statement addresses planning policy around tall buildings in paragraphs 11.7 – 11.19. The purpose of Policy D8 c(iii) is to protect the park’s amenity and privacy. Both are unaffected as the towers adjoin the park’s northern boundary and therefore minimise overshadowing whilst overlooking from lower floors is prevented by existing trees on the
boundary.

The same policy goes on to encourage the use of tall buildings to reinforce local wayfinding and legibility, and in this case, they are effective in providing a marker for both the development and the entrance to Leyton Jubilee Park.

The Townscape and Visual Impact Assessment concludes there are minor to moderate beneficial visual impacts on the park, whilst Chapter 11 of the Environmental Statement, on Daylight, Sunlight and Overshadowing concludes there is no significant impact from overshadowing on the amenity spaces within the park.

Can you please explain why 18 storeys would now be considered appropriate on this site when policy 2.D Urban Form in the Olympic Legacy Supplemental Planning Guidance suggests the site should accommodate heights of 4-6 storeys. What justifies such a huge step change in what would be considered appropriate?

The accompanying narrative on page 45 makes it clear that more height is supported for the Leyton sites to reflect Leyton’s town centre status, referring to 7-10 storeys. It is also clear from this narrative that Waltham Forest Council are supportive of taller buildings in gateway locations, as we have proposed. This also aligns with London Plan policy on taller buildings to aid legibility and wayfinding.

Could you please explain how the visual impact assessment has arrived at the conclusion that towers up to 18 storeys will have a minor and beneficial impact on views from Jubilee Park, Hackney Marshes and Lee Valley, and how 9 storeys within approx 25 metres from south facing Victorian terraces will have a minor and beneficial impact on the views from these houses?

The Townscape and Visual Impact Assessment (TVIA) takes into account the Landscape Institute’s Guidelines for Landscape and Visual Impact Assessment and other applicable guidance. The taller elements of the proposals are deemed to have a minor and beneficial impact as they reinforce the urban setting of these particular open spaces, whilst not compromising amenity and privacy.

The 9 storey blocks in excess of 50 metres away from existing rear elevations. The TVIA assesses the impact to be minor and beneficial as despite a transition in height, these blocks fit within the existing townscape and given the material palette do not create a discordant element.

Have other building typologies been considered when determining what it the most efficient to keep heights down but still not create a site impenetrable to sunlight to the estate to the north?

The design team explored a number of typologies and layouts during the early master planning stages. These were found to be less suitable on this site, as they introduced longer east-west building elevations. These options, therefore, obstructed north-south movement through the site to the park, and also caused overshadowing for longer continuous periods.

The original vision document for the area that included the site suggested the gas holder on the eastern part of the site would be retained and this part of the site landscaped and converted into a park. This suggests a viable development was envisaged on the remainder of the site, presumably acknowledging the saving on costs of remediating this part of the site. Why are there now 2 9 storery towers and a 4 storey building behind the houses on Clementina Road now proposed?

We have taken a fresh look at the site, and believe the proposed masterplan has significant benefits compared to the original vision, including clear connections through the site as well as the optimal use of brownfield land. Having appraised the site in detail, we have concluded that the vision’s ideas
are not viable or deliverable. Our detailed technical assessments show that the proposed massing will work on the site, both with immediate neighbours and the wider context.

Given the large costs of decontamination, the land value is negative. Therefore would it not be simpler for the developer to only build on half of the site still generating the same % profit and landscape the remainder therefore saving on remediation and development costs of that other part.

We have taken a fresh look at the site, and believe the proposed masterplan has significant benefits compared to the original vision. Both the National Planning Policy Framework and the draft London Plan require the optimum use of brownfield land. Having appraised the site in detail, we have concluded that the vision’s ideas are not viable or deliverable, nor do they optimise the use of this brownfield site. Our detailed technical assessments show that the proposed massing will work on the site, both with immediate neighbours and the wider context.

The parkside gateway buildings impose significantly and negatively on the amenity of park users. How will park users be compensated for this?

The Townscape and Visual Impact Assessment concludes there are minor to moderate beneficial visual impacts on the park, whilst Chapter 11 of the Environmental Statement, on Daylight, Sunlight, and Overshadowing, concludes there is no significant impact from overshadowing on the amenity spaces within the park.

Given the tragic events at Grenfell tower, is there any reason other than naked financial interest in high rise towers at the very limit of safety for non-specialised fire services?

The Planning Statement addresses planning policy around tall buildings in paragraphs 11.7 – 11.19. The purpose of Policy D8 c(iii) is to protect the park’s amenity and privacy. Both are unaffected as the towers adjoin the park’s northern boundary and therefore minimise overshadowing whilst overlooking is prevented by existing trees on the boundary.

The same policy goes on to encourage the use of tall buildings to reinforce local wayfinding and legibility, and in this case, they are effective in providing a marker for both the development and the entrance to Leyton Jubilee Park.

The Townscape and Visual Impact Assessment concludes there are minor to moderate beneficial visual impacts on the park, whilst Chapter 11 of the Environmental Statement, on Daylight, Sunlight, and Overshadowing, concludes there is no significant impact from overshadowing on the amenity spaces within the park.

With regard to fire safety, we have submitted an Outline Fire Safety Strategy as part of the planning application.

Why have the developers proposing such high buildings that have historically struggled to sell in this area (I reference Motion in particular) when a matching 2 storey development would be welcomed by the community, subject to all our other concerns?

We have been very mindful of the comments we have received about the proposed height of the buildings. There is a pressing need to optimise the use of brownfield land to address Waltham Forest’s need for new homes, and this includes the use of taller buildings in appropriate locations.

We have rigorously tested our proposals, and conclude that the height and massing of the proposals is justified on this site.

The blocks planned for behind Clementina Road are enourmous. 9 storey building behind our 2 story houses will make our properties look small, will block light, limit privacy and greatly impact our mental well being. Why not have 2 storey blocks to match the current community? Is the only focus to squeeze all possible profit out of the area?

We have been very mindful of the comments we have received about the proposed height of the buildings. The proposed buildings immediately to the rear of existing properties are a mixture of 2, 3 and 4 storey buildings, and taller buildings are significantly further away.

There is a pressing need to optimise the use of brownfield land to address Waltham Forest’s need for new homes, and this includes the use of taller buildings in appropriate locations. We have rigorously tested our proposals, and conclude that the height and massing of the proposals is justified on this site, and makes the best possible contribution to the urgent need for new, high-quality homes.

Could you lower the height of the taller blocks?

We have been very mindful of the comments we have received about the proposed height of the buildings. There is a pressing need to optimise the use of brownfield land to address Waltham Forest’s need for new homes, and this includes the use of taller buildings in appropriate locations. We have rigorously tested our proposals, and conclude that the height and massing of the proposals is justified on this site.

Why does most of your promotional material show the new development from strange angles where the towers look their shortest. We know how high they are and how inappropriate they are. Can we ask for more transparency?

The positions for the verified views in the Townscape and Visual Impact Assessment were selected to provide a comprehensive and representative overview of the proposals from short, medium and long viewpoints, and these positions were agreed with the Council as part of the EIA Scoping Request.

Masterplan, Design & Estate Management

What are the plans for the 6 commercial spaces in block B? What guarantees and plans are in place to ensure these spaces are occupied?

We are proposing a single non-residential unit in Block B, which is intended to be a residents’ gym and will therefore be occupied from the outset.

Who will be entitled to use the proposed gym included in your plans?

The gym will be accessible to residents within the development, who will contribute to its upkeep through the service charge. It is a relatively small space at 175 sq m, which would not suit a commercial operator.

How do brick divisions emphasise rest?

We have proposed brick as the predominant external finish across the development, which is laid in horizontal bands of subtly different tones. This calm architectural language is designed to encourage people to rest in the public spaces framed by these buildings.

How many retails units are there? will there be the stink of food wafting into Clementina Estate?

We are not proposing any retail units within the development. The proposals include a residents’ gym, children’s nursery and a concierge, and we are not anticipating any odours to arise from these uses.

Despite being outside your site area, have you discussed any plans with local authority to upgrade the bridge crossing over the railway into Hackney Marches, as part of your SIL / Secition 106 obiligations? It is well used by local residents and will be a benefit to any future new development residents, but currently it is not disable accessible and is difficult for parents and cyclists.

Improving connectivity within Lea Bridge is at the heart of our proposals. Our understanding is that the footbridge is jointly controlled by Network Rail, Waltham Forest Council, and the Secretary of State for Transport, spanning almost 100 metres across operational railway sidings, the railway line itself, and the public highway. Replacing or upgrading it would be a complex and significant project that St William is not in a position to lead. Our proposals will contribute in excess of £5m in Community Infrastructure Levy contributions towards social infrastructure projects led by the Council and Greater London Authority.

Have the police been consulted to review proposal?

Yes, we engaged with Waltham Forest’s Secure by Design Officer as part of the pre-application process and this discussion is summarised Section 6.10 of the Design & Access Statement (page 121).

Have you considered that you may need to revisit your plans in the light of Covid 19. for example, it is well known that high density housing has exacerbated the spread of Covid 19. surely this is a good time to consider creating more modern and innovative housing that is better for human health?

We have been very mindful of the comments we have received about the proposed height of the buildings. There is a pressing need to optimise the use of brownfield land to address Waltham Forest’s need for new homes, and this includes the use of taller buildings in appropriate locations.

We have rigorously tested our proposals, and conclude that the height and massing of the proposals is justified on this site, and makes the best possible contribution to the urgent need for new, high-quality homes. With regard to Covid-19, there is no aspect of our development which is harmful to
human health.

Your representatives promised a chicane or barracade that was permeable for bike and push chairs, but not for scooters. You've completely ignored this promise and created complete open access. Why have you gone back on your commitment?

We understand the concerns that have been expressed about rat-running by scooters. Inevitably, there is a trade-off between permeability, accessibility and physically preventing unauthorised access by scooters. Transport for London’s London Cycling Design Standards discourage the use of chicanes and physical barriers (section 4.5.15), and recommends the application of clear codes of conduct and enforcement instead.

Who will manage the proposed nursery?

We will look to work with a nursery operator to manage this space on a long-term basis.

Does your concierge system and ongoing site management amount to permanent on site security?

The concierge and on-site site management are principally there to provide customer service to residents within the development and do not amount to on-site security.

The Clementina Estate residents request that written confirmation be provided confirming that in spite of their private status, they can and will be used for everyone and that the roads and footpaths cannot and will never be closed off to the general public.

St William is committed to public access to public spaces and play areas on all its developments, and confirms this commitment applies to Lea Bridge Gasworks. Our estate management strategy will include 24-hour public access to the new Orient Way junction, and the non-vehicular entrances on Clementina Road, whilst the two sets of park gates will be closed overnight by estate management.

Some exceptional circumstances may apply to maintain open access, such as when parts of the site may need to be temporarily closed for maintenance, to comply with statutory requirements, or in response to any security matters.

Planning Process

Given significant objection to this plan from community, councillors and park users, what changes will you be making to the proposed plan if the application as-is is rejected?

We have submitted a planning application that we believe is robust in its justification for our proposals. We will continue to engage with Waltham Forest Council, as well as residents, councillors and all other stakeholders, whilst the application is being determined.

Given resistance to the development from the local community, do you regret any part of your proposal?

St William have undertaken extensive consultation and engagement within the local community, both before and following the submission of the planning application. We have submitted high-quality proposals that we believe are appropriate for this site and context.

Why are you working on site indoors? You are definitely not key workers.

The government’s advice on working within offices when necessary is clear. We were keen to have direct representation from St William staff responsible for the application on the panel. The panelists remained socially distanced at all times and did not travel by public transport.

There are already well over 100 objections to this development. how will this affect your attempts to communicate, reassure and indeed compensate residents?

We are committed to continued engagement with all local stakeholders, whether before, during or following the determination of the planning application. Should planning permission be granted and construction start on site, we will provide direct access to our site management teams via a dedicated phone number, and keep residents informed using a variety of methods such as newsletters.

Have you consulted Waltham Forest friends of the earth?

We did not specifically consult Waltham Forest Friends of the Earth.

Do you think it's reasonable to go ahead with this planning proposal during a pandemic, when residents may have other things to worry about, rather than dealing with this? I understand the economy needs to recover but waiting a few months for things to return to some kind of normality would have shown good faith on your part.

We understand the disruption and challenges caused by Covid-19, and the pressure many of us are under both economically and socially. The Government has been clear from the outset of this crisis that it views housing and construction as critical to the economic recovery that will need to happen following this crisis, and Ministers have been clear with both developers and local authorities that they expect planning processes to continue, using virtual tools like this wherever possible, so that the country is well placed to create jobs and address the housing shortage as we go forward.

Public Transport

How are you working with he council to ensure there is enough public transport for the new residents?

Both Transport for London and Waltham Forest encourage new developments to prioritise walking, cycling and public transport use, as part of a shift away from a reliance on cars. We have assessed the potential impact of the additional trips on local transport as part of our Transport Assessment.

Given the number of bus services as well as the increased number of train services now provided from Lea Bridge Station, the additional trips are not anticipated to have a noticeable impact on the capacity of the local public transport network.

This development will house over 1400 new residents. if even 1/4 of those residents walk to catch the 9:23am train at Lea Bridge Station, that’s approx 350 people walking along this narrow one way street, that becomes crowded with only 45 people filling it in Covid social-distancing times how will you mitigate social distancing and over crowding and noise that will result from this radical increase in pedestrian traffic?

Transport for London’s street design guidance encourages active travel options such as walking and cycling between homes and public transport. We have assessed the walking route down Perth Road to reach the station as part our Transport Assessment, and whilst the pavement is acknowledged to be narrower it is found to be of high quality overall for its intended use.

In Chapter 7 of the Environmental Statement, Socio-Economics, we estimate the number of new residents that would live in the development at 1,150.

Site Remediation

Table 6.4 in ES Vol1 outlines the following risks: Air Quality -Temporary generation of windblown dust from cleared surfaces, stockpiles, vehicles, work areas and demolition activities. Ground Conditions and Contamination - Exposure of receptors (including workforce and soils) to potential ground contamination and ground gas effects. What will be offered to the residents to help mitigate this dust? Will you: i) Slow down the extraction process and provide days of respite and communicate which days these are to the community? This could allow the community to gauge how much time they are spending outside during times of high air pollution. ii) Hire an independent air pollution consultant to advise on mitigation techniques for reducing dissipation? iii) Demonstrate through a publicly accessible digital tool (website) that all promised precautions have been implemented to reduce air pollution exposure to residents? iv) On this public website publish air pollution data daily.? This will both inform the public of the progress made by St Thames but also allow St William to understand fluctuations in air pollution. This could help inform future decisions and mitigations. v) On days that are hotter, ensure that construction methods are changed accordingly as heat can make the health effects

The safe remediation of our sites is St William’s top priority. Remediation is a complex and highly site-specific issue, and St William was created as a specialist joint venture between the Berkeley Group and National Grid specifically to focus on the redevelopment of redundant gasworks sites.

As part of the planning application, we have submitted an Outline Remediation Strategy. This transparently sets out the results of our site investigations. We propose to remove contamination hotspots through the excavation and removal of contaminated soil from the site. For groundwater, we are using in-situ containment methods which is the safest option for groundwater. A capping layer of imported clean soil will be added. Once measures are in place, all remediation activities will be verified by the Environment Agency before the remediation is formally completed, and conditions will be monitored afterward as well.

You state that a final remediation strategy will be confirmed and provided in due course. How can residents view this remediation strategy? When will it be produced?

We will prepare the detailed remediation strategy once the application has been determined by the Council. This would be controlled via planning condition, and will subject to review by the Environment Agency and Waltham Forest Council.

Any documents associated with planning conditions are public documents once they are submitted to discharge a planning condition. Waltham Forest Council will be able to confirm where the relevant documents are then made available and how this is publicised.

You state that, "Should concentrations of asbestos fibres, vapours or odours in on-site soil be found to be elevated, boundary air monitoring may be required as a line of evidence when considering potential effects upon off-site residents". For boundary monitoring to be effective, it must be in place prior to any work on site. As this is the case, why is it not being set up prior to demolition and remediation?

The submitted Environmental Statement concludes that the risk of odour nuisance is small, and can be mitigated effectively through the measures identified in the Outline Remediation Strategy such as the off-site treatment of contaminated soils, and covering all vehicles removing contaminated material from the site. Where a localised issue is encountered, we will respond with measures such as soil dampening, odour suppression and dust curtains to contain this. With regard to asbestos, if any asbestos is encountered as part of the construction, it will be assessed and removed in accordance with all applicable legislation and best practice.

The appropriate measures will be determined as part of the detailed remediation strategy. This will be a public document subject to review and approval by the Council and Environment Agency.

Odour Emissions will present an amenity risk and you state this will be removed from Site in covered vehicles and treated off site (i.e. away from Lea Bridge Road). Can we have a guarantee that vehicles will be covered? What measures will be taken to limit the effects of this odour?

The submitted Environmental Statement concludes that the risk of odour nuisance is small, and can be mitigated effectively through the measures identified in the Outline Remediation Strategy. In addition, we are committed to all vehicles removing arisings from the site being covered on entry and exit, and this is confirmed on page 21 of the Outline Construction Environmental Management Plan (CEMP).

The final measures be determined as part of the detailed remediation strategy and detailed CEMP, which be subject to stringent oversight by the Council and Environment Agency.

According to the Local Plan land affected by contamination will require site visits and desk-based research, along with appropriate remediation strategies where new development is expected. The Local Plan will support developments which have proposed mitigation measures to reduce the impact of land contamination on people and the environment, whilst also managing the impact of development on sensitive receptors. Will the results of these site visits be public? Are your mitigation strategies thorough enough, particularly in the light of what happened in Southall?

A detailed remediation strategy will have to be submitted before any work is undertaken on site. This will happen after the application has been determined by Waltham Forest. This will be a public document subject to review and approval by the Council and Environment Agency.

Southall is a much larger development in both site area and scale, and remediation strategy for Southall Gasworks includes the treatment and cleaning of soils whilst they are still on the site.

Lea Bridge Gasworks was a smaller gasworks facility, and we are proposing to remove contaminated soils from the site. Southall is therefore not comparable to the proposed development nor the proposed remediation strategy at Lea Bridge Gasworks.

You mention in your plans that there is likely to be a chemical smell from removing contaminated soil. What can we expect during contruction in regards to this and can you guarantee this smell won't continue and disrupt us beynd this initial removal period? I cite your Southall development as example of substantial negative impact to residents in this regard.

The submitted Environmental Statement concludes that the risk of odour nuisance is small, and can be mitigated effectively through the measures identified in the Outline Remediation Strategy such as the off-site treatment of contaminated soils, and covering all vehicles removing contaminated material from the site. Where a localised issue is encountered, we will respond with measures such as soil dampening, odour suppression and dust curtains to contain this.

The appropriate measures will be determined as part of the detailed remediation strategy, which will be controlled by planning conditions. This will be a public document subject to review and approval by the Council and Environment Agency.

Will you install barriers comprising filters to help protect neighbours along Clementina Road from airborne particulate and in particular asbestos from the remediation work?

Appropriate risk mitigation measures will be outlined within an Asbestos Management Plan and employed on a precautionary basis. It should be noted that asbestos is a highly regulated material. If any asbestos is encountered as part of the construction, it will be assessed and removed in accordance with all applicable legislation and best practice. As noted in the Outline Remediation Strategy, such measures could include dust curtains.

Can you give example of specific measures to control airborne particles like asbestos during construction e.g will you erect physical barriers that will capture dust and asbestos that is disturbed?

Appropriate risk mitigation measures will be outlined within an Asbestos Management Plan and employed on a precautionary basis. It should be noted that asbestos is a highly regulated material. If any asbestos is encountered as part of the construction, it will be assessed and removed in accordance with all applicable legislation and best practice. As noted in the Outline Remediation Strategy, such measures could include dust curtains.

What support will there be for those right on the edge of the development to mitigate the effect of dust pollution?

The submitted Environmental Statement concludes that the risk of dust nuisance is small and can be mitigated effectively through the measures identified in the Outline Construction Environmental Management Plan (CEMP). Where a localised issue is encountered, we will respond with measures such as soil dampening and dust curtains to contain this.

The final measures will be determined as part of the detailed CEMP, which Waltham Forest Council are likely to seek by planning condition. This will be a public document subject to review and approval by the Council and Environment Agency.

What happens if asbestos is discovered before the new road is built?

Appropriate risk mitigation measures will be outlined within an Asbestos Management Plan and employed on a precautionary basis. It should be noted that asbestos is a highly regulated material. If any asbestos is encountered as part of the construction, it will be assessed and removed in accordance with all applicable legislation and best practice.