• Contents
• Introduction
• Strategic Policies
• Economy, Industry & Commerce
• Housing
• Town Centres, Retailing & Leisure
• General Community Services
• Transport
• Open Environment
• Built & Historic Environment
• Waste, Pollution, Minerals, Water & Energy
• Planning Standards & Controls
• Car Parking Standards
• Cycle Parking Standards
• Proposals Map Schedules
• Glossary of Terms

CHAPTER 9: WASTE, POLLUTION, MINERALS, WATER AND ENERGY

INTRODUCTION /OBJECTIVES

Waste Recycling and Disposal
Pollution Control
Minerals
Water
Energy

WASTE RECYCLING and DISPOSAL
WPM1 Waste Transfer Stations
WPM2 Waste Management Sites and Household Waste and Recycling Centres
WPM3 Reprovision of Household Waste and Recycling Centre
WPM4 Land for Waste Disposal
WPM5 Recycling

POLLUTION CONTROL
WPM6 Development Causing Pollution
WPM7 Development on Contaminated Land
WPM8 Development involving Hazardous Products or Processes
WPM9 Air Quality
WPM10 Noise Pollution and Vibration
WPM11 Light Pollution

MINERALS
WPM12 Minerals
WPM13 Mineral Reserves

WATER
WPM14 Water Quality
WPM15 Protection of Surface Waters
WPM16 Works Affecting Watercourses
WPM17 Water Supply - Demand Management
WPM18 Flood Risk
WPM19 Surface Water Run-Off

ENERGY
WPM20 Energy Efficiency
WPM21 Renewable Energy

BACKGROUND

Waste Recycling and Disposal

9.1 The efficient collection and disposal of refuse is an important factor in maintaining an attractive, clean and healthy environment in all areas of the borough. Since the abolition of the Greater London Council, the North London Waste Authority (NLWA) has been responsible for waste disposal in Waltham Forest, and it deals with disposal of the borough's domestic and commercial as well as some of its industrial wastes.

9.2 Currently, 77% of the borough’s household waste stream is incinerated at the Edmonton Solid Waste Incineration Plant. A further 14%, mainly from civic amenity sites are sent via a waste transfer station to landfills in Cambridgeshire. The remaining 9%, is collected for recycling and composting.

9.3 The Council has developed a number of initiatives to enable it to increase the rate of recycling in the borough. Future waste management will depend upon increasing the level of participation in the current kerbside recycling service and introducing collection services for other materials. It is hoped that these proposed initiatives will enable the Council to meet its statutory targets, as set out in the national waste strategy (Waste Strategy 2000).

9.4 Improvements are proposed to the Council’s Household Waste and Recycling Centres which should also reduce the amount of waste being sent to landfill, this in turn should increase the total amount of waste collected for recycling thereby helping the Council to meet its statutory targets.

9.5 The Council has produced a recycling strategy for the period 2002 – 2006 which provides a more detailed explanation of all its proposed initiatives for the future management of waste.

9.6 In order to conform with the London Plan Municipal Waste the Council will:
Ensure that future waste management targets are met by way of safeguarding all its existing waste management sitesand strongly resisting the loss of privately owned sites, unless appropriate compensatory provision is made;

• Identify new sites in suitable locations for new facilities such as Civic Amenity sites, construction and demolition waste recycling plants and closed vessel composting Seek to reduce the amount of waste sent to landfill by identifying locations for new waste facilities; (currently a new re-use/recycling centre has been agreed upon in the south of the borough);
• Require the provision of suitable waste and recycling storage facilities in all new developments (see Policy BHE3) Ensure all the larger planning proposals include adequate recycling facilities
• Apply the Proximity and Best Practicable Environmental Option (BPEO) principles;
• As part of its recycling strategy, encourage ‘green industry clusters’ whereby provision will be made for small enterprises to process recyclable items (see Policy INB1);
• Adhere to the waste management hierarchy and continue to send residual waste that it has not been able to re-use/recycle to the nearby energy recovery plant.
• The seven north London boroughs within the North London Waste Authority (NLWA) are currently progressing the production of a Joint Waste Development Plan Document (JWDPD), to ensure there are sufficient facilities to deal with municipal and commercial waste – including new and emerging technologies.

Pollution Control

9.7 A key component of sustainable development is the health of the biosphere including healthy communities. Minimising the extent and effect of pollutants is a key component of sustainable development.

9.8 Pollution control is not the direct responsibility of the local planning authority. However, the Council conditions planning applications to ensure the new use of land will have minimal impact on the environment, to this extent it does have a responsibility in pollution control. Pollution can take several forms – air borne, land based, water based, noise and vibration, olfactory and light based. Other policies of this UDP will also ensure pollution is discouraged – for example, policies relating to good design and locating appropriate uses in town centres or close to good transport links. The waste section of this chapter in particular addresses pollution control by assisting the recycling of waste.

9.9 The Environment Act (1995) established a new management arrangement for pollution control in England and Wales, with the Environment Agency taking on the responsibilities of the London Waste Regulation Authority, Her Majesty’s Inspectorate of Pollution and the National Rivers Authority. Local authorities also have pollution control responsibilities – for air quality monitoring and control, contaminated land monitoring and control, drinking water quality, rubbish and noise pollution.

Minerals

9.10 There are no current mineral workings in the Borough. As far as is known, the only materials present are gravels laid in shallow deposits across much of Leyton and South Walthamstow. They are mainly built over and their extraction is unlikely to be practical either in environmental or economic terms. Other, deeper, deposits are understood to be located in the Lea Valley, mainly on land owned by the Lee Valley Regional Park Authority and Thames Water plc.

Water, Reservoirs, and other Water Areas

9.11 The Borough has within its boundaries a number of rivers and many other large and small areas of water. The Lea and its associated watercourses is the principal river system in Waltham Forest. Smaller streams, such as the Ching and Dagenham Brook flow into the River Lea. The Lea Valley also contains the Chingford and Walthamstow Reservoirs which together represent one of the largest expanses of open water in London. In addition, there are numerous smaller ponds and water areas, many of which are to be found in Epping Forest.

9.12 The supply of water to new developments is becoming increasingly onerous and further water abstraction could have a detrimental impact on existing abstractions and the environment. In addition sewerage systems and sewage treatment works are in places becoming overloaded. In these circumstances, developers are reminded of the provision of the Water Industry Act 1991 and that the Council will consult the relevant statutory undertakers regarding water and sewerage infrastructure where a proposed development is likely to have significant implications for these services.

9.13 The Borough's rivers are important for drainage purposes and the reservoirs are significant for the region's water supply. Together with other water areas they also provide opportunities for recreational activities and are often attractive features with considerable amenity value. Many water areas also contribute a great deal to nature conservation in the Borough, providing homes for many different plants and animals.

9.14 The Environment Agency Thames Region was created by the Environment Act 1995 and is responsible for the management of water resources and the control of pollution in inland, estuarial and coastal waters. This includes safeguarding and improving the natural water environment of the rivers and lakes in the Borough, as well as the quantity and quality of underground water. It is also responsible for protecting and improving fish stocks, and for promoting water based recreation of all types. The EA is also the flood defence authority for the Borough and has the power to provide flood alleviation works, such as the Lee Flood Relief Channel, on main rivers. For ordinary watercourses the power to provide such works is held by the Council.

Energy

9.15 The majority of energy consumed in the United Kingdom currently comes from fossil fuels, which are not only the principal cause of climate change but are finite. Renewable sources of energy are needed quickly if concerns over climate change and security of future energy supplies are to be tackled.

9.16 There is a national target to generate 10% of the UK’s electricity supply from renewable energy sources by 2010, reduce carbon dioxide emissions by 20% over the same time period and an obligation to reduce 1990 levels of greenhouse gases by 12.5% by 2008-2012.

9.17 Planning has an important role to play in the growth of renewable energy use in the UK. Renewable energy sources will reduce greenhouse gas emissions in the long term and benefit the climate on a global scale. Therefore the Council will seek to ensure that the non-local and long term benefits of renewable energy are given ample consideration in determining planning applications, so that the contribution the locality can make to reducing greenhouse gas emissions is recognised.

POLICIES AND PROPOSALS

Waste Recycling and Disposal

9.18 There are currently two Household Waste & Recycling Centres in the Borough. They are at Kings Road E4 and South Access Road E17.

9.19 The importance of recycling in conserving finite energy sources and raw materials is becoming increasingly apparent. Recycling is therefore a vital part of the Council's strategy for waste disposal. Household Waste & Recycling Centres provide important facilities by enabling residents to recycle paper, glass, oil and other materials.

9.20 Waste Transfer Stations are controlled not only by planning legislation but also by waste management licensing and environmental health regulations. However, they do not make good neighbours in residential areas, or in commercial areas where the quality of the environment is important to firms' operations. Suitable access to the sites is also important because of the size, type and contents of vehicles visiting the stations (skips, large container lorries etc).

9.21 The problems associated with waste transfer stations can be minimised by enclosure of the sites to prevent the escape of waste away from the site (including atmospheric pollution by dust) and to improve the visual aspect of sites. All sites will be expected to be suitably landscaped or screened. Hours of operation will be controlled to minimise disturbance to surrounding areas.

9.22 There are no sites in Waltham Forest which would be suitable for handling toxic or liquid wastes because of the built-up nature of the Borough.

Waste Management Sites and Household Waste and Recycling Centres

9.23 Household Waste and Recycling Centres need to be located within a reasonable distance of the residential areas they serve in order to discourage fly-tipping. They should nonetheless, be located where harm to the environment of the surrounding area is minimised. However, because of the nature of the operation with regard to Household Waste and Recycling Centres (delivery of waste by the public), it would not be practicable to have the sites entirely enclosed.

Reprovision of Household Waste and Recycling Centres

9.24 The Council in association with the six other north London boroughs is currently preparing a Joint Waste Development Plan Document (JWDPD), which will set out the amount of waste management facilities required in Waltham Forest as part of this sub-regional approach to waste planning. The JWDPD will assist the borough in meeting the requirement set out in the London Plan that most waste should be treated or disposed of within the region it is produced. PPS10 Planning for Sustainable Waste Management 2005, provides further guidance to local authorities on key planning objectives for the sustainable management of waste.

Land for Waste Disposal

Recycling

9.26 The Council currently recycles waste materials such as paper, rags, metal and used oil. Bottlebanks and can banks are an important part of the recycling process and the Council seeks to encourage their use. Bottlebanks are now widely used by the Borough's residents and more containers should be provided to allow greater recycling of glass. The Council has also provided can banks for the collection of recyclables.

9.27 Bottlebanks, can banks and other such containers should be sited in prominent locations where they will be convenient and easily accessible to members of the public. Locations outside public buildings and in shopping areas, with convenient access to public transport, may well be appropriate. However, the precise location of recycling facilities should follow the principles on location of street furniture which are outlined in the Council's "Access For All Design Guidelines". Where possible recycling facilities should be located close to a safe stopping point for cars (with a dropped kerb where applicable). The Council will also investigate the possibility of providing recycling facilities that are accessible to people with disabilities. Care also needs to be taken to ensure that containers do not obstruct cyclists, or road traffic or cause undue visual intrusion in the street scene. The proper management of containers to ensure that they are well maintained and do not exceed capacity is also important. Planning applications for the development of new large residential and retail developments will be required to provide appropriate recycling infrastructure.

9.28 Recycling initiatives by private organisations and voluntary groups will be encouraged and given support.

Development Causing Pollution

9.29 Pollution takes many forms including noise (and vibration), light, smell as well as land, water and air based.

9.30 Pollution can be discouraged by ensuring polluting activities are not located in proximity to sensitive land uses i.e. housing. Conversely new developments consisting of sensitive land uses such as childcare centres/ housing, should be positioned in very low risk areas of potential contamination. It is suggested that the precautionary principle should be used, due to the fact that contaminants can affect nearby land from contamination that may have occurred from former land uses.

9.31 The Strategic Employment Areas are considered the most appropriate locations for pollution generating activities, subject to their presence not creating any adverse affect upon surrounding uses.

9.32 The Council’s initiatives to encourage waste recycling will also have the effect of reducing the level of pollution in the borough.

9.33 Applications for a polluting or potentially polluting use will be assessed against the following criteria:
a) Impact on neighbouring uses including loss of amenity.
b) The design and appearance of the development.
c) The hours of operation of the proposed development and its transport requirements including the scope for transport by rail or water.
d) The proposed after-use of the site.
e) Any environmental benefits arising from the development, for example, the regeneration of derelict land.
f) The possibilities for a time limited permission in order to assess the impact of the development.

9.34 An Environmental Impact Assessment (EIA) enables the environmental effects of developments to be systematically assessed and for certain types of development is a statutory requirement. All proposals listed in Schedule 1 of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999, require an EIA. In addition, the Regulations state that proposals in Schedule 2 which meet certain criteria or thresholds and which the local authority considers likely to give rise to significant effects on the environment would also require an EIA.

9.35 Developers may request a 'screening opinion' from the planning authority on whether an EIA is needed prior to submitting a planning application. Further guidance is set out in Circular 2/99 Environmental Impact Assessment.

9.36 There may be concern regarding the impact of proposals which while they might not require an EIA, due to their nature, scale and local circumstances, would require the local planning authority to be provided with information on the nature of such impacts in order to determine whether a proposal is acceptable. Such impacts might relate to air, land and water quality, flood risk, transport and ecological impact or other matters. The new contaminated land regime/production of contaminated land legislation (see below), introduces the legislative framework to remediate, re-use contaminated land ‘with appropriate remedial measure sites can be made suitable for re-use’.

Development on Contaminated Land

9.37 The need for contaminated land to be brought back into beneficial use has become particularly acute in light of increased Government interest to re-use previously developed ("brownfield") land in urban areas (e.g. for building new homes). The Contaminated Land (England) Regulations 2000, requires site investigations to be undertaken to confirm the presence of contaminants on-site. Site investigation procedures and sites of potential contamination in the borough, are outlined in the Council’s Contaminated Land Strategy 2000. Much brownfield land in the borough is potentially contaminated due to former industrial use. With proper remediation many sites can be made safe for reuse so reducing the pressure to develop greenfield sites.

9.38 On contaminated or potentially contaminated sites developers will be required to carry out detailed site investigations – all proposals listed in Schedule 1 of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999, require an EIA. Circular 2/99 (Environmental Impact Assessment) gives policy guidance on the implementation of the amendments made to the original E.C. Directive on environmental impact assessment.

9.39 Once land has been defined as contaminated and the appropriate persons and liability groups are identified for the particular pollutant linkage, a remediation notice can be served by the Council. The Council at its discretion, can allow a three month consultation period specifying remediation required before a notice is served, however in urgent cases the Council will undertake the necessary remedial action. In most cases the Council will seek to reach voluntary co-operation in preference to using regulatory action.

9.40 Where contamination is identified, an assessment of the remediation work necessary to enable the development to take place safely will be carried out. The remediation work may be carried out by the developer, or others (i.e. previous owner, government agency). Whilst the Council may not insist on the developer carrying out the remediation work, it has the power to prevent the development taking place should remediation work not be carried out.

Development involving Hazardous Products or Processes

9.41 In considering any planning applications for development which may involve hazardous substances the Council will need to be completely satisfied that the proposal will not constitute a hazard. In assessing these planning implications the Council will consult and liaise with the Health and Safety Executive.

9.42 The Planning (Hazardous Substances) Act 1990 provides for the control of the presence or use of hazardous substances by local authorities. Under this legislation the local authority must take a view on any element of risk to the environment (to people, plants or animals). Even after all health and safety controls have been complied with, there remains a residual risk to the surrounding area and these planning controls allow for the risk to be assessed.

Air Quality

9.43 The Environment Act 1995, Part IV requires local authorities to review and assess air quality in their area. Where it is apparent from this review and assessment that the air quality standards or targets are not being achieved, or are not likely to be achieved within the relevant time period, the local authority must designate an Air Quality Management Area (AQMA). The Council has completed a detailed 3 stage review and assessment and has subsequently identified and designated an Air Quality Management Area covering the whole borough. The detailed 3 stage review and assessment identified road traffic as the main source of pollutants of nitrous oxides Nox and particulates PM10. A more detailed Stage 4 assessment has confirmed the earlier findings and details the measures proposed to improve air quality in the area. The review and assessment process will continue until 2010.

9.44 Air quality is a material planning consideration in the determination of planning applications. The planning system has an important role in controlling certain types of development in close proximity to existing sources of pollution. The Council has now published its Air Quality Action Plan 2004 which encompasses the whole borough. The levels of air pollution are never constant, the dynamics of it are dependant to a large extent on traffic levels along certain corridors.

9.45 The Council has assessed the main road network in the borough for levels of nitrogen dioxide (NO2) and respirable particles (PM10). Development proposals where levels of pollutants exceed the Government’s air quality objectives will be required to address the issue of air quality and how the development is affected by pollution, or the development may affect the air quality. This should take the form of a detailed impact assessment and include any mitigating measures that are considered necessary.

9.46 The Council will produce supplementary planning guidance which will specify the types of significant development that will require detailed air quality impact assessments to provide examples of design features to alleviate air pollution and identify the areas of the borough most likely to be affected. Policies in Chapter 6 (see TSP7 & TSP9) cover issues such as car-free housing (reduction of car ownership and usage) and the submission of environmental statements including air quality impact assessments where any major development or any development which has significant transport implications is proposed in the borough.

9.47 It is hoped that the procedures set out in the plan will lead to a diminution of air pollution over time.

Noise Pollution and Vibration

9.48 The impact of noise and vibration can be a material consideration in determining a planning application. Noise sensitive development such as housing and hospitals should not be located close to major sources of noise or vibration unless the effects can be adequately mitigated. Conversely noisy new development should be located away from noise sensitive uses if its disturbance effect cannot be adequately reduced.

9.49 In some cases it may be possible to allow noise generating uses if the noise or vibrations can be controlled via planning conditions.

9.50 Wherever there is a concern over the potential for noise pollution the Council will require a noise impact survey outlining effects and possible attenuation measures. Should measures be required to deal with noise, a failure to carryout such measures would be grounds for a refusal of permission.

Light Pollution

9.51 The impact of light can also be a material consideration in determining planning applications, too much light is particularly detrimental to wildlife, it can also ruin the character of an area and disrupt people’s sense of place. On the other hand good lighting is a vital tool for community safety initiatives. As such lighting will be required which is adequate for the development, but no more than that. Should adequate lighting be detrimental to wildlife or local amenity the Council may have no alternative but to refuse the development.

Minerals

9.52 The Council recognises a continuing high demand in London for aggregates, particularly sand and gravel. It accepts that where there are no overriding objections on environmental, public safety and amenity, or traffic grounds, reserves within London should be permitted for working so that a contribution is made towards meeting the capital's own demands for construction aggregates.

9.53 Working in partnership with industry the Council will aim to achieve the reuse of 80% of construction and demolition waste. By 2011, 60% of that 80% should be reused as waste aggregate within London.

9.54 This Borough Council is the minerals planning authority for Waltham Forest. SERPLAN’s latest sub-regional position on minerals will go forward as part of the London Plan.

9.55 Mineral working can have significant and widespread effects on public safety and amenity. It can also have a major effect on the environment, particularly in areas which are important for nature conservation. One of the most noticeable effects on the amenity and safety of local residents is the effect of the heavy lorry movements associated not only with the mineral extraction but also subsequent filling. In some circumstances it may be feasible for minerals to be transported away from a site by barge and this may be an acceptable alternative to the use of heavy lorries. Noise from mineral working and associated activities is an additional environmental nuisance.

9.56 Although the future demand for aggregates is difficult to forecast accurately, the Council, in assessing the need for the release of sand and gravel reserves, will take into account both the supply policy for the South East region set down by SERPLAN which assumes an annual average production level for London up to 2006 of 1 million tonnes, and the existing level of permitted reserves within London. The Council will not grant permission for extraction unless it is satisfied that the reserve is of sufficient quantity and quality to justify the extraction.

9.57 The Council will expect all applications for the extraction of minerals to include a detailed scheme for the progressive restoration of the land and the after-use of the site. In appropriate cases, the Council will use legal agreements to secure the satisfactory restoration and management of mineral sites.

9.58 There is no history of gravel extraction in Waltham Forest in the recent past. At present, the Council is not aware of any sites in the Borough where the extraction of gravel or other mineral working could take place without an unacceptable adverse impact on the local environment.

Mineral Reserves

9.59 In 1987 the Association of London Borough Planning Officers prepared a report on Sand and Gravel Resources in London. One of the purposes of the report was to assist in the preparation of Unitary Development Plans. The report identified 25ha of sand and gravel deposits in Waltham Forest which may be possibly workable. However, the 1994 boundary changes between Waltham Forest and Enfield have resulted in a redistribution of possible workable resources. The only area left in Waltham Forest, which was included in the 25ha, is Banbury Reservoir. There is considerable uncertainty over whether deep dredging of reservoirs will produce marketable gravel, and even if it were practically and economically viable, there may be strong environmental reasons for not allowing gravel extraction. Furthermore, there is no realistic prospect of Banbury Reservoir being used for other purposes which would sterilise any mineral resources in the foreseeable future.

Water Quality

9.60 The Council will support initiatives by the Environment Agency to prevent groundwater pollution and improve surface water quality. Without these initiatives future supply of adequate quality water will be inhibited. Surface water run-off and leakage from contaminated sites is a potential source of such pollution which the Council may influence by the use of statutory powers granted under the Contaminated Land (England) Regulations 2000 (see also Policy WPM7). There are significant areas of possible contamination in the south-western portion of the Borough which are also located within the 1 in 100 year floodplain identified by the Environment Agency. This includes parts of industrial estates such as Argall Avenue and Blackhorse Lane.

Protection of Surface Waters

9.61 The water environment is sensitive to change and can easily be damaged by development. Watercourses should be protected and retained in their natural state, where possible, culverting and canalisation should be avoided. The Environment Agency is responsible for the protection and enhancement of water courses, the prosecution of polluters and the promotion of nature conservation and water recreation.

9.62 As well as being important for functional considerations such as drainage and water supply, the Borough's water areas are significant for recreation, amenity, and nature conservation reasons. Generally, the Council will encourage the use of water areas for recreational activities provided there is no conflict with nature conservation and environmental considerations (see policy ENV 21).

9.63 This policy seeks to prevent inappropriate developments which would adversely affect the amenity and nature conservation value of the Borough's water areas. The larger expanses, such as the King George V and William Girling Reservoirs, are particularly important locations as feeding, roosting, and moulting areas for birds. Many of the smaller water areas, such as the ponds in Epping Forest, are attractive features and provide valuable water habitats.

Works Affecting Watercourses

9.64 All works which affect watercourses need to be properly evaluated and receive any necessary statutory consents. Uncontrolled works may lead to effects such as an increased risk of flooding, erosion of the watercourse, increased danger to the public, restricted access for maintenance purposes, and damage to the water environment. The Council will therefore consult the Environment Agency on any development proposal which affects a watercourse in accordance with agreed consultation procedures.

9.65 When the EA or the Council carries out any works affecting a water course, such as widening, or straightening, it must do so in accordance with the Environmental Impact Assessment (Land Drainage Improvement Works) Regulations 1999. Where works are proposed by an applicant which is neither the EA nor the Council, the Council will consider the likely impact in accordance with the same environmental assessment regulations.

Water Supply – Demand Management

9.66 The prudent use of natural resources is one of the Government’s key objectives as part of a commitment to sustainable development. The combination of greater water usage and increased demand as a consequence of new development in the south-east, especially housing, will require prudent use of water resources if future supplies are to be adequate in the region. The planning system can play an important role in this approach by encouraging demand measures in new development. These may include the recycling of rainwater and grey-water (water that can be safely reused within the dwelling, such as from washing), low-flush WCs and metering.

Flood Risk

9.67 Rivers, drain groundwater and surface water run-off from land. The flood plain is generally the area of low lying land adjacent to a watercourse channel which is liable to flood when the capacity of the channel is exceeded. Floodplain storage is a natural and sustainable response to flood flows in rivers and has the effect of reducing flood water levels and the risk of flooding elsewhere. Developing in floodplain or raising ground levels in floodplains reduces the flood storage capacity and may impede flood flows. This will have the effect of increasing the flood water level elsewhere in the catchment. Records of areas known to have flooded are kept by the Environment Agency who also advise on the general risk of flooding in all areas adjacent to watercourses. One of the Environment Agency functions is to advise local authorities on flood risk and the Environment Agency is a statutory consultee in the planning process. The Environment Agency has produced Flood Zones which include the Waltham Forest area. These Flood Zones derive from modelling and records of flood events and will specify the degrees of flood risk associated with locations in Waltham Forest. Up to date Flood Zone information can be obtained from the Environment Agency’s website www.environment-agency.gov.uk. In Waltham Forest large parts of the Lea Valley and smaller areas close to the Ching Brook are known to have flooded.

9.68 A considerable amount of development has already taken place on the flood plains and people and property in these areas are at an increased risk from flooding. These developments are not only at direct risk, but have also reduced the capacity of the available flood plain and impede the flow of water, thereby increasing the risk of flooding elsewhere in the catchment. This issue is considered in more detail under Policy WPM19 below.

9.69 The risk from flooding needs to be discouraged and safely managed so that inappropriate development is avoided in areas of flood risk. In terms of minimising future risk, the Council will take a risk based approach, in accordance with PPS25, to avoid development that might be exposed to an unacceptable risk of flooding in terms of the scale and potential consequences. It is the responsibility of the prospective developer to provide evidence of whether a development is affected by flooding and whether it will increase the flood risk elsewhere. The Council will consider this information in consultation with the Environment Agency in order to decide the degree of flood risk and whether this risk can be adequately managed by a requirement for appropriate flood protection works. This will be carried out in accordance with procedures set out in the latest Town and Country Planning Liaison Procedures published by EA Thames Region. As a means of illustration, development of strategic importance, such as hospitals will not be permitted in areas at risk from flooding whereas housing could be permitted in areas of moderate risk if the development can be defended to an appropriate standard. Each application will be considered on its merits.

Surface Water Run-Off

9.70 Planning applications will be expected to incorporate Sustainable Urban Drainage Systems (SuDS) in both new development and redevelopment schemes. The implementation of SuDS is an integral part of PPS25, as development through the river catchment can have a significant impact on flooding simply by increasing surface water run-off. SuDS provide a way of controlling surface water run-off so that it does not increase flood risk elsewhere. They can also significantly improve water quality, amenity and biodiversity.

9.71 The Environment Agency Thames Region has prepared Catchment Zoning Maps indicating areas where development causing additional run-off would result in increased risk of flooding downstream. These show that in Waltham Forest, developments where surface water run-off drains to the Ching Brook or Dagenham Brook may require appropriate attenuation measures. Any such measures will be determined by the Council in consultation with the Environment Agency in accordance with agreed consultation procedures.

Energy Efficiency

9.72 A building constructed now will consume substantial quantities of heat and power during its lifetime, where such factors are subject to planning control the Council will ensure that the interests of energy conservation and renewable energy systems are taken into account. In all major developments the Council will expect the submission of an assessment of energy demand as set out at Policy 4A.8 in the London Plan. The Council will also encourage in all aspects of commercial development, methods of production and practices which are environmentally sustainable, such as the recycling of building materials, green purchasing and reducing vehicular trips. The growth of ‘Green Industries’ in Waltham Forest, will be an integral part of the Council’s sustainable development objectives over the coming years.

9.73 The Council will encourage specific improvements in energy efficiency for new developments and refurbishment schemes, using advice and guidance from the Department of the Environment’s Energy Efficiency Best Practice Programme and Design Advice, these schemes are operated by the Building Research Establishment (BRE). Renewable forms of energy can also contribute to meeting the Council’s targets for the Home Energy Conservation Act (HECA) 1995, which requires local authorities to reduce household energy consumption. Part L of the Building Regulations also sets down minimum energy efficiency targets.

9.74 The use of energy has a bearing on many aspects of transportation and land use planning. This is recognised by the Council's Local Agenda 21 Action Plan and in the Government's Planning Policy Guidance Note 13, Transport. It is desirable to protect the environment and to reduce pollution by conserving energy. This can be achieved by the co-ordination of transportation and land use planning, through efficient transport systems, in building construction and industrial processes. The Council's transport policies in Chapter 6 have the objective of reducing unsustainable modes of travel and thereby assisting energy conservation.

9.75 With regard to energy conservation in buildings the Council has a policy of improving the efficiency of its own buildings in terms of construction, insulation and use of energy.

Renewable Energy

9.76 The Mayor’s Energy Strategy (Feb 2004) sets out the Mayor’s strategy to bring about a shift in the way London supplies and uses its energy in order to minimise the effects on climate change and promote a green economy. The Mayor expects all boroughs to implement the proposals contained in the strategy: Proposal 13 requests the inclusion in development plans of a renewable energy policy, specifying the 10% requirement in order to meet London’s targets for the generation of renewable energy. At the national level, the Government’s Climate Change Programme (November 2000), sets a target of 10% of the UK’s electricity requirements to be met from renewables by 2010.

9.77 Developing renewable energy schemes helps to minimise the use of fossil fuels and therefore reduces emissions of greenhouse gases. The Council’s Green Charter sets out in its Local Agenda 21 objectives, how the Council will develop and review a comprehensive energy strategy for the borough, basing this strategy on the principles of energy efficiency and energy conservation (see also Policy WPM20).

9.78 It is appreciated that the requirement will place additional costs upon developments in terms of plant and equipment and the space to accommodate it. However, the costs will only affect new development and these will effectively be transferred to the value of the development land and possibly be reflected in a reduced land cost. It should also be noted that business and residential premises incorporating renewable energy generating infrastructure would be in a position to command higher market value and as such will be able to counteract any loss in land value. Where these measures would result in the development being unviable, an applicant will be asked to demonstrate this fully to the Local Planning Authority.

9.79 It is intended that by combining economic incentives and prescriptive development policy for renewable energy systems, the Council will assist the “demand push” which will reduce the costs of such systems through economies of scale.

9.80 The policy proposal is reinforced by a national financial instrument which will further strengthen the viability of developments which incorporate independent renewable energy systems. The Government’s Climate Change Levy adds about 8% to the electricity and gas bills of businesses from April 2001. The Government has introduced enhanced 100% first year capital allowances for approved energy saving investments by businesses, who will be able to take this investment into account in calculating corporation tax.

9.81 Examples of suitable technologies are as follows:

• Biomass heat or Combined Heat Power (CHP) plants serving the whole development;
• Solar water heating;
• Solar electricity (PV) photovoltaic and active solar heating systems: both could be incorporated into south facing roofs or units;
• Ground source heat pumps;
• Passive solar design – designing a building to take maximum advantage of sunlight which reduces overall energy consumption, making 10% an easier target to meet;
• Borehole cooling – where a suitable ground water source exists.

9.82 The Council recognizes the importance of renewable energy technology in helping achieve medium / long-term Government objectives to reduce national energy consumption. With all new development proposals the Council intends to seek active involvement of developers in the promotion and use of this technology. Limited measures – e.g. the introduction of lower tariff energy metering will not normally be considered a sufficient measure in this respect. It is of paramount importance that all renewable energy schemes most of which will involve design issues, be agreed at the pre-application stage – retrofit (installation after building is started) is expensive and very difficult to implement.

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