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."

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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).

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?

What was found in the Billet Road Contaminated Landfill ?

 

Industrial, Domestic, potentially clinical waste, found [SD 2.4.10]

Landfill contaminated with:

Acenaphthene	Fluorene	TPH Aliphatic >EC10 - EC12
Acenaphthylene	Free Product	TPH Aliphatic >EC12 - EC16
Arsenic	Gross Phenol	TPH Aliphatic >EC16 - EC21
Asbestos	Hexavalent Chromium	TPH Aliphatic >EC21
Asbestos amosite fibres	Hydrocarbons	TPH Aliphatic >EC5 - EC6
Asbestos chrysotile	Indeno(1,2,3-c,d)pyrene	TPH Aliphatic >EC6 - EC8
Benz(a)anthracene	Lead	TPH Aliphatic >EC8 - EC10
Benzene	Mercury	TPH Aromatic >EC10 - EC12
Benzo(a)pyrene	Methane	TPH Aromatic >EC12 - EC16
Benzo(b)fluoranthene	Naphthalene	TPH Aromatic >EC16 - EC21
Benzo(b)fluoranthene	Nickel	TPH Aromatic >EC21 - EC35
Benzo(g,h,i)perylene	PAH (total)	TPH Aromatic >EC5 - EC7
Benzo(k)fluoranthene	PAH **	TPH Aromatic >EC7 - EC8
Cadmium	pH	TPH Aromatic >EC8 - EC10
Chromium	Phenanthrene	Volatile TPH & BTEX
Chrysene	Phenol	Xylene
Cooper	Phytotoxic Metals	Zinc
Cyanide	Pyrene	Zootoxic Metals
Dibenz(ah)anthracene	Sulphate
Ethylbenzene	Toluene

Numerous exceedances of applicable human health criteria were encountered in several PAH compounds. These exceedances are summarised below [SD 7.1.8.1]

Hazadous Gas/Vapours in soil. The monitoring indicates that the site may fall into NHBC Red Classification based on Methane.

Pits tended to be unstable and therefore the maximum depth of the waste deposits was not proven in all cases. [SD. 3.2.3]

Whilst there is some uncertainty due to the instability [SD 3.2.11]

the groundwater distribution is heterogeneous and there does not appear to be a clearly defined water table. [SD 3.1.3]

The base of the made ground is considered to be saturated in most parts of the site. [SD 3.1.4] Contaminants of concern in groundwater.

There is also potential for impacted groundwater to migrate laterally off site; [SD 3.3.1. iv]

is considered that the loading of the landfill will not result in the generation

of ground gas or the creation of a new pathway. [SD 5.4]

The soil barrier will offer a design life of 75 years. [SD 6.5.5.12]

The permeable reactive sections would require a four-metre standoff and will be

installed to have a 50 year design life [SD 6.5.5.16]

Due to the odorous nature of groundwater beneath the site and the likely presence of some degree of residual contamination following remediation [SD 6.6.1]

The variable nature of landfill material and the extensive area of the site indicated

that local contamination can easily be missed during investigative works without adequate coverage. [SD 4.1.3]

Fears ‘orange’ water has contaminated land near school and farm

Orange water runs through Willow Farm on Billet Road and near a special needs school on Hainault Road. (Ilford Recorder)

The environment Agency is investigating the water course although the likely reason for this is the contaminated landfill which was an unlicensed tip in the 1970's. 

"In November 2019 the owner, Sunshine Island Properties Ltd, an entity registered in the British Virgin Islands, built fences around the land and dug a large hole in one corner.

It followed a hearing at Romford County Court in which Sunshine re-asserted its claim to the site over a group of local businessmen.

When approached by the Recorder the company did not comment.

Redbridge Council said the works carried out were “routine ground works” and investigations would be carried out at the same time."

Redbridge accused of keeping Marks Gate residents in the dark

Redbridge accused of keeping Marks Gate residents in the dark about Billet Road site development.

According to the article in Barking & Dagenham Post Jon Cruddas MP wrote to the (Redbridge) authority’s housing chief after people in Coral Close and Uplands Road in Marks Gate raised concerns over a series of issues during work in nearby Billet Road, Aldborough Hatch.

The MP for Dagenham and Rainham has urged Redbridge Council not to leave neighbours “in the dark” over building work on green belt land.

As the local residents know, this is totally accurate. None of the LBBD residents were informed by Redbridge or the site owners that these works were to be carried out nor have they been told what and when to expect any further developments.

They have also not been told that this is contaminated land due to the unlicensed tip there in the 1970's and what precautions should have been taken while they dug up the land, none were. 

Should any LBBD residents decide to look at Redbridge planning (why would they?) they would see the planning application for the hoarding fence  but as the site is adjacent to LBBD residents in Billet Road, Rowan Way, Coral Close, Uplands Road, Hope Close and a short distance from Kallar Lodge Residential Care Home they should have all been informed.

Not only about the work on the site but also its removal from Green Belt by Redbridge despite the Mayor of London refusing this request.

Gold Rush: Developer, Redbridge family and football tycoon in scrap over former rubbish tip that could soon be worth £10million. 

Building on Polluted Land - Hydrocarbons shut down site

As previously discussed the land at Billet Road is unlicensed landfill and therefore polluted. Its also polluted from the lorry park and car traders on the site.

A Redevelopment was halted last year at a site in Hackney Wick when Hackney council confirmed the cause of horrendous smells as the historic contamination of the site's land by hydrocarbons, including bensene and naphthalene.  Hackney Citizen  "Furious Hackney Wick residents demand answers over contaminated construction site" 

The same Hydrocarbons that shut down this site, have a High risk of occurrence with a High overall risk rating as the land at Billet Road (site 99), which also has a long list of additional pollutants.

And according to the Guardian a redevelopment site in Southall London, (Guardian Families hit out at London gasworks redevelopment ) Parents claim lack of Pollution regulations at a new brownfield development is putting children's health at risk.
"In early 2017, work began on cleaning the soil on the site, using a process (remediation) to remove contaminants in an open-air “soil hospital” (that bank) behind the homes. The soil was found to contain hydrocarbons including benzene , a known carcinogen, naphthalene, asbestos and cyanide, and it was decided cleaning the soil was safer than transporting contaminated material along residential streets."
Local residents are complaining of rashes, migraines and asthma.  

"A toxicology report obtained via a freedom of information request contains the line: “There are no private gardens proposed cannot grow vegtables on the contaminated soil ever! [sic]”

Unlicensed landfill AND gravel extraction?

Unlicensed Landfill and/or Former Gravel Extraction at Billet Road Site 99? Does anyone know?

In Mar 2016 Savills were asked to report on the site (now Site 99) at Billet Road and provide advice on Minerals there.

Savills  say:  Environment Agency told them that the site was an unlicensed tip and received waste between 1970 and 1973 and that the Environment Agency have NO additional information including whether the tipping was illegal or undertaken via a waste exemption.

Savills say: it is designated Mineral Search Area. Area where the presence of significant mineral reserves is indicated by the BGS mapping but not yet confirmed by bore hole drilling (boreholes shown in purple below are insufficient and do not cover the whole area).

Savills File: CHMI361971 Plan: WillowSite1 Drwn by: AEH Date: 22 Feb 2016

Savills say: the Minerals Local Plan notes that Brett Lafarge indicated that the site may have been worked and then landfilled by PT Reid Ltd between 1965 and 1975 adding that the data is not entirely reliable and the area could contain viable deposits. Additionally the Minerals Local Plan shows a large part of the land having been worked in the past.

Redbridge Former minerals extraction areas

So if the site was worked and landfilled then "Policy M9: Priorities for Restoration and After-Use" would apply:
The Council’s priority objective for restoration and aftercare of former minerals land is the promotion of nature conservation as an end in itself, or in tandem with agriculture or open space sport/recreation. Restoration strategies should support national, regional and local biodiversity priorities as expressed in:

• The UK Biodiversity Action Plan.

• The Royal Society for the Protection of Birds (RSPB) Minerals Restoration Potential (MRP) Project. Where sites are identified as capable of supporting priority habitat creation or prove to be capable of achieving RSPB objectives, the aim should be to restore those sites in line with MRP Project habitat priority levels.

• The Mayor of London’s Biodiversity Strategy and London Plan Policy 7.19 Biodiversity and Access to Nature.

• The Redbridge Biodiversity Action Plan.

Some former minerals quarry land in Redbridge has been restored to agricultural use. Although returns from farming urban edge land may be very marginal, the Council would support agriculture at least on those parts of sites with less critical environmental values. 

Much former minerals land in Redbridge has also been restored for wildlife and open space and recreational uses. These include footpaths, bridal ways, reed beds, riding schools, football pitches, sailing and angling clubs and golf courses. There have been some nature conservation initiatives on land previously used for minerals extraction and more are planned. Nature conservation and sport/recreation can go hand in hand as appropriate uses of open space.

As Site 99 Contains a stable, horses grazing, kennels, wildlife, a farm and agricultural use, which all fit the "restoration and aftercare of former mineral sites", exactly why does London Borough of Redbridge plan to build on it?

Billet Road Site 99 was unlicensed landfill - what lies beneath?

Defra show the site London Borough of Redbridge intend to build 800 homes on and a school was an unlicensed landfill site in the 1970's.

Historic Landfill site Defra

A site report by REC Resource & Environmental Consultants Ltd Nov 2014 states:

In case this is hard to read the list is:
As (Arsenic),
Cd (Cadmium),
Cr (Chromium),
Pb (Lead),
Hg (Hydrargyrum),
Se (Selenium),
Ni (Nickel)
Asbestos Fibers in soil
Polycyclic Aromatic Hydrocarbons (PAH)
Total Petroleum Hydrocarbons (TPH) (hexane, benzene, toluene, xylenes, naphthalene)
Ground Gases 
Herbicides and Pesticides
Heavy metals, 

On site potential Sources includes 'Potential harmful ground gasses and contaminants contained within the historic landfill and potential historic agricultural land use.

Off site potential sources include active landfill 138m, off site tank 100m.

Potential Pathways - receptors may be potentially at risk from the identified potential sources of contamination via the following pathways:

• Migration of mobile contaminants on or off site via services, sewers and man made conduits
• Direct contact, ingestion and inhalation of contaminants on site
• Migration of contaminated dusts during easthworks
• Migration of mobile contaminants into groundwater and transport into surface waters
• Migration of mobile contaminants directly into the surface waters
• Migration of hazardous gases and 
• Uptake of toxins/phytotoxins by plants

Potential Receptors - REC has identified the following possible receptors:

• Future users of the site and buildings
• Tertiary River situated approx 65m to the west
• Underlying Secondary (A) aquifer

They add that construction workers are not considered to be a plausible receptor as exposure will be managed through the use of appropriate PPE and that exposure is likely to be for a short duration. BUT what of the residents nearby???

Under Buildings, foundations and services, the reports says that 'breaking ground to develop on site has the potential to disturb and mobilise contaminants in the historic landfill. Elevated sulphate concentrations could effect the integrity of buried concrete structures. Services may be affected by aggressive contaminants and may corride or penetrate services. Water supply pipes can be susceptible to penetration by hydrocarbons which may affect the quality of the water supply.'

Ilford Recorder - Fears 'Orange' water has contaminated land near school and farm' at Billet Road In a recent report, Redbridge Council noted: “The Environment Agency advised that the area… appears to have been an unlicensed tip that received waste between 1970 and 1973.” An Environment Agency spokesman said: ““We are currently investigating a report of a suspicious liquid in Seven Kings Water at Little Heath."