MERA comments on Foul and Surface Water "Scheme"

Tower Hamlets Planning now have MERA's comments on Telford Homes' proposed "Scheme" to address Planning Condition 21 relating to the disposal of Foul & Surface Water from new residential units on the Eric & Treby Estate redevelopment. 

Just so everybody knows what we're talking about....

• Foul drainage removes the waste from the toilet, bath, basins, sinks, washing machines, dishwashers and showers. 
• Surface water drainage deals with rainfall as it collects around a property (eg roofs, gutters and land) 

Planning Condition 7 (application for approval not yet submitted) deals with the required scheme of water and sewerage infrastructure delivery for the whole development.  In short whether the existing water supply and sewerage system can cope with delivering an effective supply of drinking water and the disposal of waste water and sewerage (ie what needs checking before any homes can be occupied) 

Planning Condition 21 deals with the micro site level aspects (pipes and connections required and planned)  and is worded as follows

Prior to commencement of the development, with the exception of site investigation works and the digging of foundations, a scheme to dispose of foul and surface water shall be submitted to and approved in writing by the Local Planning Authority.

The Development shall not be carried out otherwise than in accordance the particulars so approved.

Reason: To protect and conserve water resources and to prevent increased risk of flooding and pollution of the water environment in accordance with:

• policy 4A.16 of the London Plan (Consolidated with Alterations since 2004),
• policies U2 and U3 of the Unitary Development Plan 1998 and
• policies DEV5, DEV7 and DEV21 of the Interim Planning Guidance (2007): Core Strategy and Development Control.

Summary of MERA Comments

MERA consider that this Application fails to satisfy as to the adequacy of arrangements for foul water and surface water drainage at a specific site level.  It is inadequate for the purposes of discharging this planning condition.

REASONS INCLUDED:

• This pre-commencement planning condition has already been breached at Site 14 through unlawful development in advance of the discharge of ALL pre-commencement planning conditions.  Note the drains and manhole covers in place on Site 14 on Monday evening - when the consultation did not even finish until today.
  

Drains and Manholes - development contravenes planning permission/conditions

• A Scheme is a plan of action. A Scheme requires explanation. A set of drawings is not a Scheme.  Drawings support the narrative text of a Scheme, they do not explain it.  PA/10/1159 is the application for approval of details PRIOR to commencement of the development.  If you click the link in the Application Reference you can see the quality of the documentation submitted.
• The application for approval of details fails on the grounds of accessibility for the purposes of consultation.   Technical drawings and no report renders this application completely inaccessible to most people.
• The Scheme does not revisit issues raised in the Flood Risk Assessment Scheme - as recommended in that report.  
• The Scheme for Site 10 fails to indicate how the drains connect to the main sewer.  However, in doing the research to respond to the proposal we have identified a probably reason why Brokesley Street has problems with drainage.  This is because the main drain under the road is only 300mm wide according to the documents submitted, making it the smallest drain in the area by quite some way.  It's very unlikely that Planning Condition 7 (Water and Sewerage Infrastructure) which covers capacity issues can be satisfied without a comprehensive review of what a 500+% increase in people living on Site 10 will have on the rest of Brokesley Street given the tiny size of the drain.  We will be keeping a very careful eye on this issue which generated several comments from local residenrs during the course of consultation.

As noted in section 3.1.2, there is a residual risk of sewer flooding as a result of the increase in foul sewerage requirements for the new properties on the site.
Flood Assessment

• The Scheme fails to demonstrate any awareness of the implications for pipework underground  resulting from remarks about and recommendations arising from the Expert Report on Site Contamination.   (see Eric & Treby Estate: Site Contamination)  The nature of the contamination requires protective sleeves for the pipework underground to avoid any contamination transferring into the water.  
  
• The drawings give no indication to the layman of how greywater is captured for recycling - which contravenes planning policy as well as being very silly if no effort is being made! 
• This "scheme" gives inadequate consideration to how surface water drainage will change following the soft landscaping.    

The risk of surface water flooding to and from the development will be increased as a result of the conversion of permeable to impermeable land cover.
Flood Assessment

MERA considers that the nature of concerns raised by residents (particularly those near Site 10) means that these need to be adequately addressed by the developer

• BEFORE submitting a Scheme for the disposal of foul water and surface water
• BEFORE the proposals for meeting this planning condition can be approved; and
• BEFORE the planning condition can be discharged

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