Bellway's 2 BNG Anniversaries

Bellway's 2 BNG (Biodiversity Net Gain & Loss) Anniversaries

12 Feb 2025, Anniversary of BNG implementation. Bellway applauded the BNG initiative. By signing a letter championing the BNG initiative.
“We, the undersigned, write to you as a coalition of innovative businesses and organisations to celebrate the first anniversary of Biodiversity Net Gain (BNG) and its role in supporting nature, promoting growth and driving a sustainable housebuilding revolution in the UK.”

14 Feb 2025, Anniversary of Bellway requesting Removal of BNG from their Billet Rd site.
On 14 Feb 2024 Bellway requested the REMOVAL of the 10% BNG from planning permission covering Land at Billet Road. No doubt Bellway applauded Redbridge's agreement to its removal.

The 100% loss of Biodiversity at Bellway's Billet Road site will result in a few BNG units being bought. But what does that mean?

TerraQuest shows that the vast majority of projects ‘side-step’ BNG. The planning system is failing BNG Requirements.

If anyone thinks that BNG units ‘paid’ for by developers will go to creating beautiful green space somewhere in the country that will last forever, provide a home for our radically diminished wildlife, then you are mistaken.

A brief look at what BNG units are used for, one company offers landowners the opportunity to ‘lease’ portions of land for 30 years and the company will then develop a biodiverse habitat to meet BNG. The landowner will be paid a rent and a profit from the sale of BNG units. They promote this as: Put marginal land to good use and Enjoy high returns. But what happens after 30yrs?? how much of the developers' payment will go to managing the business of selling units rather than habitat creation.

Another such company talks of offering camping and glamping along with hosting corporate events.

More Contamination found - outside Bellways confirmed area of landfill contamination

More Contamination found - outside Bellways 'confirmed area of landfill contamination'

The planning application for Site B (contaminated landfill) has been under review by the planning dept for over a year. While Bellway add numerous new documents and applications for removal of conditions.

The latest and most unsuprising shows that archeaologists found contamination outside of the 'confirmed area of landfill contamination'.

So Bellway paid a company to investigate the whole site to find the contaminated landfill area. The report produced by the company conducting the investigation is littered with vagueness.

Despite this Bellway advised local residents that "The locations of the archaeological works are outside of the confirmed area of landfill contamination. The trench locations form part of the partially approved condition 7. Bellway want to reassure the community that there will be no impact upon the landfill contamination".

They got that wrong:

Archaeology Report

Contamination found in 5 trenches outside of the 'confirmed area of landfill contamination'.

How sure can anyone be that they know what is or isn't contaminated?

Nearly all of these 'contaminated trenches' are where the 'drainage system' will run which is meant to be where the squashed out contamination is meant to go to be removed.

Then there is the problem of the contaminated areas which are outside Bellway's confirmed area of contaminated landfill area or rather the now 'unconfirmed area of contaminated landfill'.

Will Redbridge Planning Officers and Environmental Officers be looking into this? no sign of that so far.

Bellways designs for Billet Road Contaminated Landfill - Part 3 -Consultation

Bellway's Consultations were not a discussion more a dictation.

Local residents were shown the 'this is what we will be doing' boards.

The Design and Access report for Site B (contaminated Landfill) details the results of the 'consultation'.

Key Concerns - local residents

1. Wildlife and biodiversity - Ignored,
End result loss of all trees and hedgerows and a whooping NEGATIVE 100% Biodiversity Net Gain aka TBL (Total Biodiversity Loss).
Yesterday Bellway submitted an amendment to REMOVE the 10% BNG requirement.

2. Community Safety/ Preservation of privacy for site neighbours/removal of proposal of vehicular route through Coral Close - Ignored

3. Site drainage

4. Affordable housing

5. Capacity of local infrastructure

Design Review - Feedback

1. Fronts and backs within Masterplan should be adjusted to relate to neighbouring Marks Gate - ignored

2. Community engagement should disrupt and enrich the Masterplan - ignored

3. Biodiversity Net Gain must be optimised where it can be delivered - ignored

4. Introduction of some height along the frontage to Billet Road could be justified to define the edge but should not extend into the Masterplan - Ignored

5. Engagement with local community to be deepened and enriched through future applications - ignored

GLA
1 Review large parking courts and set clear design principles for parking provision - ignored

Child friendly Redbridge - feedback

1. Community safety, maintenance, quiet study space, attractive planting and variety of play spaces, cater for all age groups are important local priorities.

Bellway fines -ordered to stop development due to contamination leakage risk and lack of appropriate management and remediation

For residents near Bellway's development site in Billet Road the most concerning:

May 2024	Bellway ordered to halt development	Developer must stop work on a site in eastern Newport over concerns “harmful” substances could enter a protected conservation area in the Gwent Level. The committee heard officers had flagged the presence of substances which are “harmful to health and the environment” The council argues that its efforts to resolve the matter have effectively been ignored, and work is continuing at the site despite its assertion the developer is breaching a condition of its planning permission. Outline planning permission for the site had already been agreed, subject to conditions including that “remediation works” of sampling and groundwater quality monitoring be carried out at each stage of development. Ms Davidson said “tars, heavy metals and petroleum-based oils and fuels” are present there due to the “long industrial legacy” of the wider site, which used to house a steelworks. These substances need “appropriate management and remediation”, she added. Ms Davidson said officers asked Bellway in January to cease building work on the site until the remediation works were sufficiently completed, but the developer “did not stop and indicated to us that they would not stop”. Full Article
Apr 2024	Bellway destroy ancient hedgerow	destroyed 100 feet of hedgerow that has been there for decades, and that offered a habitat for wildlife, including insects, bees and birds.
Feb 2024	Bellway fined £10,000	Bellway connected to an unauthorised and unlicensed standpipe to the clean water main on two separate occasions at developments in Taplow and Greenhithe
Mar 2023	Bellway fined £100,000 for dumping contaminated soil on one of its sites	The Environment Agency discovered that, between 22nd November and 12th December 2017, Bellway imported around 2,688 cubic metres of contaminated waste soil on to the site from one of its developments at nearby Five Mile Park. It said this was to build a soil bund around an attenuation pond.
	Bellway and other developers being investigated over alleged “anti-competitive behaviour” could pay a combined maximum penalty of billions if they are found guilty	accused housebuilders had been sharing “commercially sensitive information” to “influence the price and build-out of new homes”. It warned that such activity may “weaken competition in the market”.
Dec 2020	Bellway fined £600,000 for destroying bat roost	At Woolwich crown court on Tuesday, the company pleaded guilty to damaging or destroying a breeding site or resting place of a wild animal of a European protected species between 17 March and 17 August 2018. The company had been notified in planning documents that it would first need to obtain the appropriate mitigation and a Natural England European protected species licence
Jan 2016	Bellway fined £3500 for failing to protect trees. And lack of wheel washing	“In this case, the developer had endangered trees on the site by not protecting their roots and had risked road safety by failing to ensure vehicles were free of mud when leaving the development.
Oct 2006	Bellway fined £10,000 for polluting stream	Found guilty of causing polluted matter to enter controlled waters

Bellway back out of 10% Biodiversity Net Gain requirement - Billet Road Site B

Bellway are trying to back out of the 10% BNG requirement set by Redbridge Council

When Redbridge approved Bellway's enabling works application to cap the contaminated landfill they stated:
"In order to mitigate this loss (permanent major effect on habitat) and achieve a net biodiversity gain a pre commencement condition will be secured requiring submission of a strategy demonstrating biodiversity enhancement for the site in order to mitigate the loss from the enabling works.
The strategy shall include details of how, where and when a 10% biodiversity net gain calculated in line with Table 2 of CIEEM Biodiversity Net Gain reprt and audit templates (July 2021) and based on the baseline Biodiversity Net Gain Assessment (Urban Edge Environmental Consulting, Sept 2022) can be achieved.
Reasons: In accordance with the National Planning Policy Framework (2021), Policy LP39 of the Local Plan and Policy G6 of the London Plan (requires a net biodiversity gain in schemes). Also relevant LP19 Climate change mitigation, LP37 Green Infrastructure & Blue Ribbon network, LP38 Protecting Trees and Enhancing the Landscape."

One year on, Bellway now disagree with the 10% BNG saying it was not mandatory at the time and they won't know a strategy demonstrating how, where and when a biodiversity net gain will be delivered before the enabling works start.

Is it true that they don't know? on their website they say 'how' and 'where'.

Bellway are working with landscape consultants to design a dense planted buffer which will not only promote the privacy of existing residents along the length of the eastern boundary of the site, but also provide useful green amenity space and improve local biodiversity

What does Bellway think about Biodiversity?

Bellway Group Head of Biodiversity, said: “This is such an important topic as we look to understand, and enhance biodiversity within our developments. By providing enhancements to habitats, we are working to find the best possible solutions for our customers and the communities we create and increase the prevalence of nature within every new development."

On 12-12-2023 Bellway published "Bellway is committed to achieving at least a 10% Biodiversity Net Gain on all new sites submitted for planning from July 2023"

Over 6 months before 10% BNG became mandatory!

Should it matter when 10% BNG became mandatory?

Redbridge require a 10% BNG for the capping application, due to the complete loss of biodiversity as a result of the application. Relevant LP Policies, LP19, LP37, LP38, LP39
Redbridge can add conditions at their discretion, they provided their reasons. The condition is precise and reasonable.
Bellway did not object to this condition at the time or during the last year.
If Redbridge have to re-consider the application then 10% BNG is now mandatory.
If Redbridge remove the condition they will set a precidence and have to do the same for other approved developments. We have found at least 4 approved around the same time with 10% BNG conditions. Along with many others nationally.
Redbridge declared a climate emergency on 20th June 2019.
Natural England would need to be consulted over any changes.
EIA scoping recommends additional compensatory habitat enhancement and or creation needs to be embedded and secured by condition.

Is Bellway's sudden concern over 10% BNG due to their Site B development proposals NOT SATISFYING the now mandatory BNG trading rules ?

TO COMMENT ON THE APPLICATION TO REMOVE THE CONDITION OF 10% BNG

go to Redbridge Planning Portal
https://planning.redbridge.gov.uk/redbridge/application-details/199878

If the link doesn't work for you click here and search for Application No 3376/22/01

Non-material amendment to approved permission 3376/22: amend the wording of Condition 16 (Biodiversity Net Gain). Refer to cover letter online for full details. (Summary).

Bellways designs for Billet Road contaminated landfill Part 1 - transport network insufficient to support development of this scale says TFL

1300++ homes on Billet Road

The plans for Site B (the landfill) have been out for a while.

One of the most compeling sections is TFL's remarks, here are just a few:

Billet Road RM6 Traffic

Redbridge Climate Change Action Plan. We have "incorporated policies in the Redbridge Local Plan (2015-2030) that limit carbon emissions in new developments, support retroftting of existing building stock to improve energy performance, and, ensure developments are constructed in accessible locations to reduce travel and promote transport "

The existing public and active transport networks around the site are generally insufficient to support a development of this scale.
The road network in this area is subject to congestion for extended periods with severe congestion in the morning, and evening peak periods and the end of the school day.
There are no designated cycling routes around the site Walking connections are generally poor.
footways are either narrow or missing. there is limited permeability to nearby residential areas
The potentially phased nature of the development also raises concerns
mitigation measures and works to improve connectivity may need to be front-loaded to earlier phases
Facilities for active travel are poor and, for some movements, absent, for example with no footway on the north side of the A12
Aside from this, footways are either narrow or missing. there is limited permeability to nearby residential areas

Some of the things TFL want to happen to try and make this site with little or no transport links, work.

Creating a suitable route for walking, wheeling and cycling on the north side of A12 tying in with the development to the east of Padnall Lake, and extending west to Newbury Park station
Provision of a new signalised crossing of the A12 for pedestrians and cyclists near Somerville Road and Brian Road, with closure of the existing underpass
Improvements to the east along A12 and local roads (for example Mawney Road) towards Romford, given that Romford.
Improvements at to crossings at the A12 Little Heath junction, ideally to reduce signal stages required to cross and/or progression across the road, but at the very least to make it suitable for cyclists.
Cycling infrastructure improvements on Somerville Road or Brian Road and on to Chadwell Heath station, and on Barley Lane to Goodmayes station
Waiting controls on Billet Road and Hainault Road together with enforcement against footway parking, to ensure that these routes remain clear for pedestrians. This includes the area close to Little Heath School and the football academy.
Based on indicative phasing, it is likely to be necessary to provide improvements to the footway on the Billet Road frontage and to the westbound “Red House Farm” and “Hainault Road/Little Heath” bus stops
central pedestrian refuge island to ensure a good level of convenience for pedestrians. The footway on the Billet Road frontage of the site should be carefully considered from the point-of-view of the perception of safety at night: a more visually open design.
improve the following routes as a minimum:
a) northwest from Padnall Road connecting to Fairlop Waters,
b) west to Fairlop Waters/Quarry at both Painters Road and nearer Hargreaves Scout campsite if possible
c) along Seven Kings Water if possible. Existing footpaths should ideally be upgraded to bridleways to allow for cycling.

To be killed by development - historic boundary hedgerows.

Why kill the hedgerows?

If you are a developer with planners and architects and landscape designers on your payroll why can't you design your new site to incorporate the mature hedgerows especially as the plans show they will kill them and then replace them .. is there any sense in that?

Redbridge and Climate change .. its ok they are putting in electric car charging facilities.

The hedgerows of Billet Road support pollution control, wildlife and are beautiful.

Billet Road Contaminated landfill - Site A Masterplan

Bellway have announced their plan for Site A of the contaminated landfill at Billet Road, Little Heath RM6.

Bellway have christened it 'Kingsgate Park' Despite the fact there is no approved planning application for any of the development they are already advertising the properties for sale!

Apparently 'boasting fantastic transport links and local amenities'. Local residents would disagree with this along with the very low PTAL rating.

Although their website very much suggests its all a done deal with Redbridge they are holding a Public Consultation to present their proposals for Site A next week. The planning application to be submitted in Autumn 2023.

There is also the issue of the Environmental Permit required by The Environment Agency.

Site A - was Hainault House, Kennels, container and waste depot and prior to that an unregulated, now contaminated, landfill.

This some of what lies beneath Site A:

Loose Asbestos fibres

Methane concentrations above 1%
carbon dioxide concentration above 5%
Soft greenish black clay with strong hydrocarbon odour

Lead concentrations that exceed applicable human health criteria

TPH concentrations in exceedence of Water Supply Regulations 2016

Cooper concentrations exceeded applicable assessment criteria

Zinc concentration exceeded applicable assessment criteria
Benzo(b)fluoranthene & benzo(a)pyrene: exceeded the applicable criteria
Dibenzo(a,h)anthracene: exceeded the applicable criteria

Xylene exceeded the applicable screening level
Phenol exceeded the applicable screening level
Hydrocarbon contamination
TPH Aromatic C10-C21: 430ug/l exceeded applicable screening criteria
TPH Aliphatic C10-C35: 410ug/l
TPH Aromatic C10-21: 260ug/l
Perched water strikes
Benzo(a)anthracene exceeded applicable criteria
Chrysene: exceeded applicable criteria
Dibenzo(a,h)anthracene: exceeded applicable criteria
The natural ground had concentrations of benzo(b)fluoranthene, benzo(a)pyrene
and dibenzo(a,h)anthracene (MWS09a) greater than the screening level for residential homes with private gardens

Due to leaching from the landfill (yellow area shown above) the contamination extends outside of the yellow area as shown by the red and blue blobs. Some contamination may also be due to the waste that was constantly burned on site.

The Environment Permit, if obtained, will mean tons of soil can be placed on top of the contamination and then the new homes will be built.

The current Site A Masterplan proposal.

149 homes

98 car parking spaces
Are they all needed for a site with fantastic transport links?

Landfill Leachate at St Chad's Well Billet Road

Bellways Billet Road contaminated landfill site is adjacent to St Chad's Well but its contaminating the well and stream.

The existing slurry wall is obviously not working and its getting worse!

Leachate - the liquid that percolates through a landfill site - can contain dangerous substances such as heavy metals, pesticides, harmful bacteria and volatile organic compounds (VOCs).

These can seep from the waste and into the soil and groundwater, and therefore contaminate the air, soil and water supply around the site.
Source DailyMail Online

Is the demolition of Hainault House and outbuildings safe?

Is the demolition of Hainault House and outbuildings safe?

Most of 'Parcel A' which includes Hainault House and outbuildings, is on contaminated landfill at Billet Rd. Bellway applied for prior approval to demolish the house and all the other buildings on the site.

Testing shows that it's surrounded by Asbestos. 'A' equals Asbestos. The yellow line and shading shows the inferred landfill boundary. No testing has been done on the Hainault House area including the outbuildings and kennels.

Here's some of the things they found on the left hand section of 'Parcel A'
(the red & blue blobs):

Loose Asbestos fibres

Methane concentrations above 1%
carbon dioxide concentration above 5%
Soft greenish black clay with strong hydrocarbon odour

Lead concentrations that exceed applicable human health criteria

TPH concentrations in exceedence of Water Supply Regulations 2016

Cooper concentrations exceeded applicable assessment criteria

Zinc concentration exceeded applicable assessment criteria
Benzo(b)fluoranthene & benzo(a)pyrene: exceeded the applicable criteria
Dibenzo(a,h)anthracene: exceeded the applicable criteria

The 'Method Statement' says that the works includes:

'Re-cycling /removal of material'

All the resulting debris such as hard core, concrete and steel will be processed and graded at ground level using 360 degree excavators with hydraulic shear, concrete pulveriser/nibblers, grapple and bucket attachments.

Will any of this debris and the soil/natural ground removed with it be contaminated material ?

Where will it go?

Dust control measures will continue to be implemented during the grading and loading of materials

Emergency Proceedures for site personnel :
Excavation of contaminated material with visual discolouration/noxious smell. Withdraw to a safe distance, make immediate contact with Site Manager.

What was in the planning application for Risk Assessment and contamination?

Environmental control measures covers mitigation for dust, emmissions and noise - NOTHING about contamination

Environmental Plan - Activities undertaken on site will be subject to an environmental risk assessment by Oakwood and Bellway.

Methodology says that the working practices have taken due account of the following: The Environmental Protection and Pollution Control Act 1990 along with several other heath and safety regulations.

Method Statements will be reviewed by the Site Environmental Manger, and, where necessary, by an appropriate environmental specialist.

If required all method statements will be submitted to the enforcement

agencies (Environment Agency, Environmental Health Officer, HSE etc.) as appropriate.

Planning Officer's Report - application granted

Constraints - no mention of contamination

Planning Considerations - no mention of contamination

Public comments - includes concern of spread contamination during demolition

See also Demolition of Hainault House copies of the reports mentioned here are available on the London Borough of Redbridge Planning Portal application number 3840/22

Save Billet Road's H4 Hedgerow

Save H4 Hedgerow - Billet Road

You would think that with an application to cap contaminated land, also know as 'enabling works', by Bellway Homes which results in a Permanent MAJOR NEGATIVE effect on extent of habitat that every opportunity would be taken to retain some.

Especially the hedgerow outside of the capping / landfill area, namely Hedgerow Number 4 (H4).

Under Hedgerow Priority Habitats hedges H1, H2,H3,H4 are of intrinsic ecology value and provide habitats suitable for a range of protected species, including amphibians, nesting birds, invertebrates, bats, hazel dormouse and reptiles.

H1, H3 and H4 are to be removed, resulting in a LOSS of approx 500m (77%) of Hedgerow Priority Habitat. Only 150m of H2 hedgerow is to remain.

Although not mentioned in the supporting documents the boundary hedging along the eastern side of the site would need to remain in situ as it marks the boundary between the site and the neighbouring properies as well as the borough boundary.

H4 is outside the landfill capping area (yellow and red above)

Please sign the Petition to Save the Hedgerow (H4) here

How old are the hedgerows?

The Hooper Formula says: The number of tree and shrub species in a 30 metre length of hedge can indicate its age, with one species for each 100 years.

The Billet Road 'Hedgerow Assessment' by Urban Edge states, H1 and H2 have an average of 3 species within 30m and H3 and H4 have 4 species within 30m.

Suggesting that H1 & H2 are 300 years old and H3 & H4 are 400 years old!

That takes us back to 1623, a little difficult to find maps showing hedgerows back then.

However, we know that the original medieval Hainault House (Henhault House) is shown on the 1777 map by Chapman & Andre.

The boundries and various hedgerows are clear on this 1862 - 1871 map (source National Library of Scotland, Essex Sheet LXVI survey 1862 - 1871).

Back then Red House farm was called Heath Farm and St Chad's Well is further into the road plus the A12 didn't exist.

This is a close up of some of the H2 hedgerow on Billet Road.

Bellway Capping - Permanent MAJOR NEGATIVE effect on extent of habitat says Ecology Assessment

The Significant effect on important ecology and nature conservation

Bellways 'enabling works' will cause Permanent, significant negative effect at local level according to the Ecology Assessment.

Permanent Major negative effect on breeding bird assemblage at the Local level

Habitat loss and damage, degradation and pollution, killing and injury of animals, displacement of animals.

Breeding Birds

Of the native species recorded during the 2022 surveys, the Site was found to support six confirmed breeding species, eleven probable breeding species, and eight possible breeding species, including ten Red and Amber Listed species and five SPI. Loss of c.7.63ha of grassland-scrub mosaic and woodland habitat for breeding birds and c.500m of hedgerow during the construction phase represents a major magnitude negative impact resulting in a permanent reduction in the available extent of breeding habitat during the short term. The impact is permanent and is of significance at the Local level.

Disturbance to birds breeding in adjacent areas may result from construction activities, including people and vehicle movements, noise and vibration, and has the potential to cause reductions in breeding bird territory occupancy and density.

No replacement semi-natural habitats will be provided within the Site under the current proposals. The site supported a moderately rich breeding bird assemblage in a relatively urban context, including 10 species of conservation concern (though two of these are not of concern as a result of rarity or declines in a UK context). The site is considered to be of Local Importance for its breeding bird species.

Hedgerows, scrub and woodland were the most important breeding habitats, but the larger grassland areas provided foraging areas for some species, including red listed house sparrow and starling.

Confirmed breeding birds:
Dunnock, Whitethroat, Great Tit, Long-tailed tit, Goldfinch, Swallow.

Possible breeding birds:
Song thrush, Wren, Woodpidgeon, Robin, Blackbird, Chiff Chaff, Black cap, Lesser whitethroat, Pied wagtail, Collared Dove, Carrion Crow,

Possible breeding birds:
Greenfinch, House Sparrow, Linnet, Starling, Sparrowhawk, Blue Tit, Magpie, Great spotted woodpecker.

Bio Diversity Net Gain -100%