Concern for the quality of the environment underlies most of the Council’s planning policies, is reflected in the Greenwich Strategy (2003) and the Council’s Sustainable Development Policy (2003).  The policies within this chapter are concerned with land use and the planning implications of the need to care for the environment and the provision of safe public services. They deal with those aspects of planning which make people’s surroundings safe, comfortable and compatible with the natural environment. They specifically deal with air, water, and land pollution, noise, energy conservation, and the disposal of waste, the reclamation of contaminated land, protection from flooding, the conservation of the water environment, and the protection of the amenities of sensitive residential and working environments. Specific policies on wildlife conservation are in the open space chapter. The general policies on environmental protection are:

The Council’s concern for the environment is reflected in its Sustainable Development Policy (2003), which states that the Council will:

• Promote sustainable development through all Council strategies
• Act and campaign against pollution of land, air and water
• Implement a waste minimisation and recycling strategy to meet and exceed government recycling targets
• Continue to implement energy and water conservation in council properties and promote these issues in the community
• Promote the development and implementation of renewable energy sources and purchase renewable energy for council property when possible
• Reduce emissions that are recognised to contribute to climate change
• Promote sustainable construction practices within the development industry
• Practice environmentally responsible ‘Green’ procurement

The Council Sustainable Development Policy will be addressed, in part, through the application of the UDP Policies.  The Council will encourage developers to use the BREEAM (Building Research Establishment Environmental Assessment Method) independent rating system to demonstrate how their proposals achieve sustainable development objectives. (Policies H7 and D1).

The Greenwich Agenda 21 Strategy seeks to forge direct links into the planning system and local regeneration through the introduction of pilot sustainability indicators. It calls upon developments to address the thirteen themes which embrace social, economic, ecological concerns. The indicators form a useful checklist for developments. The Greenwich Strategy recognises the importance of the environmental well being of Greenwich; it aims to create a clean and well cared for environment and ensures the best use of natural resources.

The Borough is a statutory Waste Disposal Authority (WDA) and forms part of a voluntary grouping of authorities (South East London Waste Disposal Group: SELWDG) which co-ordinates their duties under the Environmental Protection Act 1990, in consultation with the Environment Agency. Government guidance has established a hierarchical approach to waste management, which is addressed within the detailed policies in this chapter. The approach seeks waste minimisation, and views disposal as a last resort.  The Mayor's Municipal Waste Management Strategy: ‘Rethinking Rubbish in London’ was published in September 2003.

The Borough is wholly within the operational area of Thames Water, which is responsible for water supply, sewerage and sewage treatment. The Environment Agency functions of safeguarding the water environment, including water pollution control and flood defence, are exercised over most of the Borough by the Environment Agency Thames Region. A small area within New Eltham and Avery Hill Wards drains into the River Cray system and is in the Environment Agency Southern Region’s area.

Local Environment Agency Plans (LEAP’s), produced by the Environment Agency are a series of 5 year Action Plans for river catchment areas. They seek to protect and enhance the local environment of the area. The Ravensbourne and Marsh Dykes LEAP was published in 1998, the Thames Tideway LEAP in 1999 and the Darent LEAP in 2000.

Many of the environmental issues discussed in this chapter are also the subject of the Building Regulations (1991) and compliance with these is mandatory.

PPS23: Planning and Pollution Control (2004)sets out the Government’s planning policies relating to pollution control. It sets out advice on the relationship between controls over development under planning and pollution control legislation.

To protect the amenities of areas where people live and work the Council will seek to separate them from problem uses. Problem uses are defined as those which would result in the unacceptable emission of noise, odours, fumes, dust, water and soil pollutants, grit or vibration.  Policy E6 deals with air pollution. Policies on the location of commercial and industrial uses which may cause such problems are set out in the Jobs and Local Economy chapter.

Planning applications for major developments may need to be accompanied by an Environmental Impact Assessment subject to Circular 02/99: Environmental Impact Assessment and the Town and Country Planning (EIA) Regulations (England and Wales) 1999. Applicants are advised to approach the Council at an early stage in the development process to determine whether an Environmental Statement is required to be submitted with the application. Assessment of all the environmental impacts in one Environmental Statement will assist the determination of applications.

PPG24; Planning and Noise introduces the concept of Noise Exposure categories [NEC’s] ranging from A-D. It guides the consideration of planning applications for residential development near transport and mixed sources of noise. These categories will be applied where appropriate.

The London Plan states that Boroughs should reduce noise by promoting sustainable design and construction and well managed, designated locations for noise generating activities.

Minimising the adverse effects of noise and/or vibration of proposed development can be sought by imposing conditions requiring the inclusion of noise and/or vibration attenuation measures in any planning permission where development or a change of use is proposed on sites or in buildings adjacent to a permanent significant noise and/or vibration source.

Conditions imposed will be appropriate to the development and thus may vary from restricting hours of use or operation of machinery to specific periods. Excessive noise and/or vibration can be intrusive to future occupants or users of development. For most developments arrangements can be made to mitigate the effects of noise, such as the position of the buildings on site, internal layout of buildings, window details including insulation and boundary treatment. Encouraging such measures as the use of sound insulation materials on noise sensitive facades facing classified roads can reduce noise from traffic schemes.

To improve the amenities of occupiers and users of adjoining sites adversely affected by existing operations.

The impact of lighting on residential amenity and on the environment are material considerations in the decision making process. Floodlights and outdoor lighting of developments can illuminate an area much wider than the area of immediate activity, causing visual intrusion for neighbouring uses. Residential areas are particularly prone to this, and their amenity should be protected. Lighting can adversely affect species such as bats.  Policy O13 deals with the control of floodlighting of sports facilities.

The Government has displayed a strong commitment towards improving air quality, most recently through the National Air Quality Strategy, in fulfilment of the requirement of the Environment Act 1995. This Act outlines a new system of local air quality management, and Local Authorities are required to carry out periodic reviews of air quality and to assess present and likely future air quality against the air quality standards and objectives prescribed by the Air Quality Regulations. Where the objectives are not likely to be achieved an Air Quality Management Area [AQMA] must be designated. Greenwich designated the whole of the Borough as a AQMA in 2001 and the Air Quality Action Plan was published in 2002.  Greenwich Peninsula has been designated as the first Low Emission Zone (LEZ) in the UK.  The Council will examine the potential to create further LEZs through the use of Section 106 agreements.  The Mayor’s Air Quality Strategy: Cleaning London’s Air, was published in September 2002.  The Council also has responsibility for enforcing Local Authority Air Pollution Controls [LAAPC] introduced under Part l of the Environmental Protection Act 1990, and the smoke, grit and dust controls of the Clean Air Act 1993.

The declaration of the whole Borough as an Air Quality Management Area indicates the seriousness of air pollution in the Borough. Thus when considering development proposals a minimisation in airborne pollutants will be sought. It is important that development proposals do not prejudice the implementation of the Air Quality Action Plan to reduce the specified pollutants. (Particulates, Nitrogen Dioxide and Sulphur Dioxide). Air quality assessments accompanying planning applications should be based on the Technical Guidance Note for developers and consultants issued jointly by London local authorities (ALG 2001) and should indicate impact both with and without minimisation measures.

Areas of poor air quality are identified in the Air Quality Action Plan. Some uses, such as residential, may be particularly susceptible to air pollution.  The impact of air pollution can be reduced through design measures, such as setting dwellings back from the road and the use of ventilation systems.  Proposals for such development should show how ameliorating measures have been taken into account in the design of the scheme.

To contribute to a reduction in air pollution and the emission of ‘greenhouse’ gases, access to and the use of fuels with low sulphur content, unleaded petrol, LPG and CNG and other means of reducing atmospheric and air pollution from vehicles, including new technologies will be encouraged.  Traffic restraint and reduction measures will also seek to develop more sustainable travel patterns, relieving congestion, noise pollution and reducing energy use. Green Transport Plans allow organisations, especially those with many staff, to address their current transport impacts and put in place initiatives to reduce commuter and work related travel and minimise the environmental impacts of necessary transport needs.

The Government has established a target that 10% of UK electricity requirements should be met from renewable sources by 2010. Regional studies were commissioned to consider how these targets could be met. The London Regional study recommends the adoption of a target for London of 2.14%, (including energy from waste), of estimated electricity demand by 2010.  However, the sponsors of the regional study (Government Office for London, Greater London Authority and the Association of London Government) are disappointed that the target is so low, and are looking for new and innovative ideas to exceed the target.  The Mayor’s Energy Strategy: ‘Green light to clean power’ was published in 2004. The Council’s Energy Strategy was published in April 2002. 

Increasing the proportion of electricity derived from renewable sources is part of a wider national strategy to reduce consumption of conventional fossil fuels and associated production of greenhouse gas emissions. Achieving these reductions will also require transport emissions to be cut and increased energy efficiency and conservation within the domestic, commercial and industrial sectors.

Land use planning affects transport, design, layout, orientation and energy consumption of the construction and use of buildings. The use and burning of fossil fuels causes air pollution, and their extraction and transport causes further environmental harm. In addition, policies within the Plan’s Movement Chapter aim to promote fuel efficiency and reduce the need to travel. Energy Conservation is also a key principle of design - as detailed in Design and Conservation Policy D1.

To help reduce energy consumption, protect natural sources of material [especially tropical forests], and to aid recycling of waste products in accordance with the Council’s Sustainable Development Policy (2003).  The London Plan states that Boroughs should include policies to improve energy efficiency and increase the proportion of energy generated from renewable sources.  Government Policy is to stimulate the use of renewable energy sources wherever they are economically attractive and environmentally acceptable.

Buildings in use account for a significant proportion of energy use: the planning system can help to reduce energy requirements, by ensuring the provision of renewable energy production equipment in new development or refurbishment / conversion of existing buildings.  Encouraging energy efficiency by promoting improved design, form, layout and orientation of development and use of appropriate materials can lead to reduced consumption of energy and environmental cost of running the building. This could include the use of passive solar design principles and developers are referred to ‘Planning for Passive Solar Design’. (BRESCU 1999). Savings of energy for heating, lighting, cooling and ventilation can all be achieved depending on the building type, although passive solar design principles are best suited to newly built buildings.  This approach will also contribute to national efforts to reverse the damaging effects of energy consumption on climate change.

65% of the electricity used in the Council’s administration buildings, is ‘green electricity’ from low carbon fuels. The Council will introduce measures to improve thermal insulation in its own properties to the standard set by the Building Regulations and wherever possible aims to exceed this standard. Developers will be encouraged to do likewise. Water conservation measures may include where appropriate; water efficient toilet and shower facilities, grey water recycling systems, compostable toilets and/or garden water conservation systems.When assessing applications particular regard will be paid to the existing character of the area and the appropriateness of the design.

Planning Policy Statement 22 (PPS22): Renewable Energy, states that Local Authorities may include policies which require a percentage of the energy used in new residential, commercial or industrial development to come from on-site renewable energy developments. Proposal 12 of the Mayor’s Energy Strategy requests that Local Authorities set targets for renewable energy generation.  Proposal 13 states that applications referable to the Mayor would be expected to generate at least 10% of their energy needs from renewable energy on site where feasible.

There are various types of renewable energy and regard also needs to be paid to technologies which may emerge in the future. Within Greenwich, the most promising sources of renewable energy generation are likely to be solar heated hot water, photovoltaic cells and combined heat and power. The various renewable energy technologies will have different environmental impacts, and it has to be recognised that some technologies may not be suitable in Greenwich. This requirement may be relaxed where the applicant can demonstrate that the installation of renewable energy production equipment is not viable given the location, design and type of development.  Combined Heat and Power (CHP), on it own and in conjunction with Community Heating systems, can provide cost effective, reliable energy and heating at high levels of efficiency and relatively low levels of pollution. CHP engines are already used at a number of Council-sponsored and private sector buildings in the Borough, including the Waterfront Leisure Centre, Woolwich, the Glyndon Road Estate and AmylumUK Ltd, Tunnel Avenue.  Community Heating is in use in the Greenwich Millennium Village.

Applications should include an energy assessment which sets out the predicted energy requirements of the development, and how it is proposed to supply at least 10% of this requirement from renewable resources.  Alternatively, a full and complete explanation would be required of the reasons why this target could not be met.  London Renewables publication Integrating renewable energy into new developments; Toolkit for planners, developers, and consultants provides guidance on assessing energy requirements and the cost and feasibility of different technologies. 

Proposals of a scale or nature likely to have a significant environmental impact should be supported by an environmental assessment, as required by Circular 02/99: Environmental Impact Assessment and the Town and Country Planning (EIA) Regulations (England and Wales) 1999. 

Hazardous materials can compromise the fragility of the natural environment and present a risk to public health and safety. Proposals involving such materials on development sites will be subject to conditions including a safety audit and survey for hazardous materials and the advice contained in Circular 04/00: Planning Controls for Hazardous Substances.

To avoid the health and safety hazards associated with polluted land and to protect the community and to comply with PPS23: Planning and Pollution Control (2004).   Contaminated land and potentially contaminated land is defined as: “land that has substances in or under it, thereby posing a real or possible risk to humans and their environment, or causing or likely to cause pollution of controlled waters”.  Contaminated land is often found on sites which have a history of landfill, or which have previously accommodated a polluting industrial use. Once these sites, or sites adjacent to these areas become available for redevelopment it is essential that a full technical investigation is carried out. Guidelines, as published by the former Department for the Environment, Transport and the Regions concerning contaminated land and the Borough’s Land Use Registry of Contaminated Sites place a requirement upon Local Planning Authorities to prepare a strategy detailing how the sites identified in the registry will be dealt with. The Council’s Contaminated Land Strategy was published in 2002. The strategy  also provides advice on investigation and remediation measures, including defining levels of pollutants that constitute land as being contaminated and what levels could result in significant harm.  Contaminated sites may have archaeological value; this should be taken into consideration when conducting investigation / remediation works, in accordance with Policies D30 and D31 and PPG16 (Archaeology and Planning).

To ensure that community need for up-to-date services is met. While in general development, sites can be adequately serviced there may be cases where development should be phased or developers should contribute to service provision.  Prospective developers should ascertain the adequacy of services at an early date, in particular the electricity suppliers should be contacted about development in Thamesmead, and in the area between the Woolwich Road and the Thames.

The Council and the public are concerned that there may be a risk to the health of residents in close proximity to electromagnetic fields.  The National Radiological Protection Board has a statutory duty to advise on such risks. Telecommunications Development is covered by Policy D11 and Satellite Antennae by Policy D12.

PPS10: Planning for Sustainable Waste Management (2005) and the Government’s national waste strategy ‘Waste Strategy for England and Wales 2000' set out the Government’s planning policies relating to waste management. They set out a policy framework for sustainable waste management within which stakeholders can plan and take waste management decisions, which reduces the amount of waste we produce, and, where waste is produced, deals with it in a way that contributes to the economic, social and environmental goals of sustainable development. The ‘Waste Hierarchy’ outlined within the Waste Strategy for England and Wales 2000 is a step towards tackling waste disposal within the principles of sustainable development. Policies regarding waste should place an emphasis on those options at the top of the hierarchy. The waste management options are:

• Reduction
• Re-use
• Recovery, including recycling, composting and energy recovery
• Disposal.

The Council will apply the principle of The Best Practicable Environmental Option (BPEO) when considering waste management options. This procedure establishes the option that provides the most benefits or least damage to the environment, in both the long and short terms.

The Mayor's Municipal Waste Management Strategy: Rethinking Rubbish in London was published in September 2003, and will also be a consideration when making planning decisions on Waste Management facilities. The Mayor published ‘Recycling and recovery facilities: sites investigation in London’ in July 2005 as part of a London-wide review of waste sites.  It is expected that this will inform the proposed Sub Regional Development Framework for East London, to be published in 2006.  The Borough is part of the South East London Waste Disposal Group (SELWDG). SELWDG maintains close liaison with other WDAs.

The development of South East London Combined Heat and Power (SELCHP), at Deptford, as part of the Borough’s association with the SELWDG has provided the Borough with a facility that both processes non-hazardous waste and reduces reliance upon landfill sites. This is a preferable option to landfill disposal, as the waste hierarchy in the Government’s Waste Strategy for England and Wales 2000 indicates. In addition, SELCHP contributes towards energy recovery, with energy generated through incineration, being sold onto the National Grid, and some materials are also recycled. The Council is contractually committed to using the SELCHP Waste Disposal Facility until 2024, which has sufficient capacity for the predicted level of non-recycled waste in the Borough.  No further incineration capacity or landfill capacity is required during the Plan period; other sites for waste disposal either within, or outside of the Borough, will not be sought. 

The Council have contractual arrangements to process 105,000 mt of waste a year at SELCHP until 2024, and to process up to 30,000 mt of mixed dry recyclate a year at the Materials Recycling Facility (MRF). The Council are allocated permits to consign waste to landfill under the Landfill Allowance Trading System (LATS); the annual LATS allocation varies over the Plan period from 35,000 mt to 53,000 mt.  The proportion of the Borough’s municipal waste sent to landfill is about 30% compared with the London-wide rate of 73% (London Plan Table 4A.).

The forecasted yearly municipal waste arisings for 2003/4 are 124,000 mt, rising to 159,000 in 2010/11.  The Council have sufficient capacity for the forecasted yearly municipal waste arisings for the Plan period and will have unused LATS permits which can be sold to other Boroughs.  The Council are investigating the possibility of developing an anaerobic digestion facility in the Borough, which will enable a greater proportion of green and kitchen waste to be processed.  The existing and proposed waste facilities have sufficient capacity for the Plan period.  It is therefore not considered necessary to identify new sites in the UDP.

However the Council will also, through the review of itsWaste Disposal Plan and Recycling Plan, seek to increase the use of the more sustainable options of waste reduction, reuse and recycling. The land use policies in this Plan seek to ensure that the Borough’s land resources are managed so that the Waste Disposal and Recycling Plans can be implemented.

The Mayor's Municipal Waste Management Strategy proposes that waste authorities should apply the proximity principle and the hierarchy of waste management. 

An increased emphasis is now placed upon the minimisation of waste production, the reuse and recycling of waste materials, and that waste disposal is environmentally responsible. The Environmental Protection Act 1990 sets out a framework and targets for waste management policies and planning policies. The Government aims to have 30% of household waste recycled or composted by 2010 (Waste Strategy for England and Wales 2000). Statutory Borough targets are to recycle 10% of household waste by 2003/4 and 18% by 2005/6 (Guidance on Municipal Waste Management 2001). The London Plan targets are to exceed 25% by 2005, 30% by 2010 and 33% by 2025.  The Public Service Agreement target is to recycle 19% of household waste by 2004/5. The Council is on course to achieve these targets; in June 2004, the proportion of household waste recycled was 16%

There is an existing Licensed Waste Transfer Station at Nathan Way, Thamesmead.   A Materials Recycling Facility (MRF) opened on the adjacent site in November 2004. The Mayor's Municipal Waste Management Strategy proposes that waste authorities should make household recycling collections of at least three materials; the MRF will enable the kerb-side collection of 5 mixed dry recyclables (glass, cans, plastic, paper and cardboard) from every property in the Borough.  The MRF will also serve neighbouring Boroughs and will enable residents of this Borough and the sub-region to recycle more materials more easily. A re-use and recycling centre, which will enable the processing and re-use of discarded electrical goods and furniture, is due to open in August 2006.  This will assist manufacturers and retailers to comply with the Waste Electrical and Electronic Equipment Directive.

The provision of handling plants close to the source of waste (‘the proximity principle’) is desirable.  However this needs to be balanced against the need to ensure compatibility with surrounding land uses and that the proposal does not have a detrimental effect on the environment from processes producing noise, dust or fumes.  Major developers on riparian sites should first consider the use of river transportation for the removal of demolition spoil and import of materials. Alternatively, sites should have good access to rail or river transport.

The London Plan states that Boroughs should work to minimise the level of waste generated and should apply the principles of the Best Practical Environmental Option, which requires that waste be treated as close to source as possible.

Proposals which include provision for the reduction of waste, or the separation at source for recycling in terms of storage spaces and access for specialised vehicles will help to reduce damage to the environment. Greenwich Environmental Management Services [GEMS] operates a Waste Exchange database for businesses wishing to trade rather than dispose of waste arisings.  Residential schemes should incorporate measures for community recycling that minimises waste disposal. All new residential developments should provide refuse bins and recycling boxes.

Such facilities will allow material suitable for recycling to be separated and leachate and methane producing material to be deposited in less environmentally sensitive land fill sites.        

To avoid the risk of flooding, pollution and other detrimental impacts on the environment, to protect public health and to safeguard sources of extractable water.

The Government through PPG25' Development and Flood Risk’, the Environment Agency and the London Plan promote the use of “soft” sustainable drainage systems (SuDS) as the most sustainable form of surface water drainage for new developments. This involves moving away from traditional piped drainage systems to engineering solutions that mimic natural drainage processes.  SuDS control surface water run-off as close to its origin as possible before it is discharged to a watercourse or to the ground. There are a wide range of techniques; including water butts, permeable / porous surfaces, grassed swales and balancing ponds, that aim to reduce problems of river pollution and flooding caused by conventional urban drainage systems. To implement these techniques effectively developers need to consider their use at the earliest possible stage. The Environment Agency can advise on site specific requirements for developments on sites larger than 0.5 hectares.

This is particularly important in catchment areas (Map 7) and on riverside sites.Without careful consideration the siting and design of development can increase the likelihood of flooding in areas downstream.

Development within an area at risk from fluvial flooding can have two adverse effects. Not only can the development itself be put at direct risk but through a reduction in the storage capacity of the flood plain and an impeding of the flow of water, other areas can be subjected to an increased risk of flooding. The areas at risk from fluvial flooding are shown on the Proposals Map and the areas at risk from tidal flooding are shown on Map 7.  This information is taken from the Flood Zones Map produced by the Environment Agency.   In Flood Zone 2, flooding is predicted to occur at least once every 1000 years but not more than once every 100 years (i.e. 0.1-1% probability).  In Flood Zone 3, flooding is predicted to occur at least once every 100 years (i.e. >1% probability).  The tidal flood risk areas are protected by existing defences to a 1:1000 level (i.e. 0.1% probability of flooding). It should be noted that as flood alleviation works are carried out the areas at risk will change. The Council will consult the Environment Agency on planning applications for development in flood risk areas.

Government Advice is contained in PPG25: Development and Flood Risk (2001).  This sets out the responsibilities of all parties.  Where development is proposed in a flood risk area, the guidance requires a flood risk assessment appropriate to the scale and nature of the development, the level of flood risk, and the protection afforded by the existing defences to be carried out.   A sequential test should be carried out where development is proposed on an unallocated site within a flood risk area.  This must demonstrate that there are no reasonable options available in lower flood risk areas. 

The tidal and fluvial defences are an essential means of protecting low-lying areas from flooding.  Where development relating to the tidal defences is permitted the Council may use this opportunity to extend the public access to the waterside in support of its policy to promote opportunities for leisure, tourism, riverside walks and cycle ways along the Thames.   In light of anticipated sea level rise and climate change the Council will encourage riverside development proposals to examine the opportunity to retreat flood defences to increase flood storage, biodiversity and visual connections with the river (See Policy W2).

The relevant flood defence levels are:-

Bugsby’s Reach (upstream of the Thames Barrier):  5.18m ODN

These flood defence levels are likely to increase in the light of anticipated sea level rise.  Existing tidal flood defences are designed to protect London at a 1:1000 flood risk level until 2030; the Environment Agency is working to ensure protection until 2100. 

Adequate access to flood defence facilities such as embankments, tidal sluices and pumping stations, must be retained, and where appropriate improved, for operational, maintenance and emergency purposes.