London Borough of Richmond Upon Thames - Unitary Development Plan

Unitary Development Plan - Adopted 1 March 2005

Chapter 5 OPEN ENVIRONMENT

ENV 1	Metropolitan open land
ENV 2	Green belt
ENV 2A	Major Developed Site in the Green belt
ENV 3	Other open land of townscape importance
ENV 4	River Crane Area of Opportunity
ENV 5	Protection of views and vistas
ENV 6	Green chains
ENV 7	Contaminated land
ENV 8	Cemeteries and crematoria
ENV 9	Trees in town and landscape
ENV 10	Historic parks, gardens and landscapes
ENV 11	Retention and improvement of public open space
ENV 12	Provision of new public open space
ENV 13	Lighting including floodlighting
ENV 14	Sports stadia/spectator sports
ENV 15	Retention of recreation facilities
ENV 16	Bridleways
ENV 17	Retention and provision of allotments
ENV 18	Sites of special scientific interest and other sites of nature importance
ENV 19	Nature conservation and development proposals
ENV 20	Green corridors
ENV 21	Management for nature conservation
ENV 22	Aims for public information and promotion of nature conservation
ENV 23	Aims for monitoring and liaising with other nature conservation authorities
ENV 24	Species protection
ENV 25	Local nature reserves
ENV 26	Thames Policy Area
ENV 27	Access to the river Thames and the Thames Path national trail
ENV 28	Encouragement of the recreational use of the river Thames, tributaries and riverbanks
ENV 29	Jetties and Pontoons
ENV 30	Passenger and hire boats
ENV 31	Riverside uses
ENV 32	Permanent mooring of houseboats and other craft
ENV 33	Nature conservation on the river
ENV 34	Protection of the floodplain and urban washlands
ENV 35	Surface water run-off
ENV 36	Tidal defences
ENV 37	Culverting of water courses
ENV 38	Riverbank and water pollution
ENV 39	Clean water, foul sewers and sewage treatment
ENV 40	Quality of groundwater

5.1

In its topography and landscape, the Borough is one of the most attractive areas of London. Richmond Hill and the Thames flood plain create a varied and distinctive landscape, and Richmond Hill itself offers views over large parts of the Borough and beyond. In addition some of the Thames' most attractive reaches are within the Borough's boundaries. Kew Gardens and the three Royal Parks, together with many smaller open spaces, contribute to the attractive landscape, as does the abundance of trees in parks, beside roads and in gardens. The open spaces, islands and rivers are also of great importance as wildlife habitats; many of the important natural habitats are owned by the Council or the Crown and are already carefully managed. Functionally, they are essential to a range of both active and passive recreational activities, such as walking, sitting and watching and enjoying wildlife.

5.2

Much of the open space in the Borough has an essential role in providing a break in the urban structure between distinctive communities, and in the case of green belt, between Greater London and neighbouring towns. At the more local level, it creates an open space experience when used, passed or crossed. Open land is also important in providing for both formal and informal recreation (indoor recreation is covered by Chapter 10). Much open land is designated as public open space, some being of nature conservation importance, other areas used as playing fields. Sport and recreation make an important contribution to quality of life, health, lifelong learning and community life. The Borough with all its parks, also provides sports facilities for people living in more densely developed inner London.

5.3

Public open spaces cover a third of the Borough. They range from the Royal Parks, which attract large numbers of visitors, to small parks and playgrounds in residential areas. In considering whether the existing parks adequately meet the needs of Borough residents, the Council has taken into account size, type, location and accessibility using the hierarchy of open space in the London Planning Advisory Committee's (LPAC) Strategic Planning Advice for London (1988) (Table 1 overleaf). A larger park fulfils the functions of any smaller park below it in the table. When considering the provision of additional open spaces regard has to be paid to the density of population to be served. Although the Borough is very well served by both metropolitan and district parks, the lack of accessible local parks is particularly serious for the elderly and children. Those parts of the Borough deficient in open space at the local park level taking into account traffic and other barriers are shown on Map 4.

5.4

Parks and other open space in the Borough provide a wide range of habitats ranging from the semi-natural habitats of common lands, e.g. Sheen Common, through more formal settings such as Richmond Park to formal landscapes such as that at Ham House. There is increased public appreciation of nature study as a recreational activity. Open land provides a valuable nature conservation resource requiring careful management for public enjoyment. In some areas a minimum intervention approach may be appropriate.

TABLE 1: TYPES OF PUBLICLY ACCESSIBLE OPEN SPACE

Type and main Function	Approximate size and distance from home	Characteristics
Regional parks and open spaces (Linked metropolitan open land and green corridors) Weekend and Occasional visits by car or public transport.	400 hectares 3.2-8km	Large areas and corridors of natural heathland, downland, commons, woodlands and parkland also including areas not publicly accessible but which contribute to the overall environmental amenity. Primarily providing for informal recreation with some non-intensive active recreation uses. Car parking at key locations.
Metropolitan parks Weekend and occasional visits by car or public transport.	60 hectares 3.2km or more where the park is appreciably larger	Either (i) natural heathland, downland, commons, woodlands etc. or (ii) formal parks provision for both active and passive recreation. May contain playing fields, but at least 40 hectares for other pursuits. Adequate car parking.
District parks Weekend andOccasional visits onfoot, cycle, car andshort bus trips.	20 hectares 1.2km	Landscape setting with a variety of natural features providing for a wide range of activities, including outdoor sports facilities and playing fields, children's play for different age groups, and informal recreation pursuits. Should provide some car parking.
Local parks For pedestrian visitors	2 hectares 0.4km	Providing for court games, children's play, sitting-out areas, nature conservation, landscaped environment; and playing fields if the parks are large enough.
Small local parks and open spaces Pedestrian visits, especially by old people and children particularly valuable in high density areas.	2 hectares 0.4km	Gardens, sitting out areas, children's playgrounds, or other areas of a specialist nature, including nature conservation areas.
Linear open spaces Pedestrian visits	Variable Wherever feasible	River Thames throughout the Borough, canal towpaths, paths, disused railways and other routes which provide opportunities for informal recreation, including nature conservation. Often characterised by features or attractive areas which are not fully accessible to the public but contribute to the enjoyment of the space.

SOURCE: LPAC: Strategic Planning Advice for London (1988), Table 8.3

SPORTS FACILITIES

5.5

There are many facilities for outdoor sports in the Borough, provided by the Council, the Crown and private clubs. Local needs are met but demands from inner London, where there is a shortage of pitches, are not being met at peak times. Some Council tennis courts are under-used where they are of poor quality, whereas some clubs need extra courts. There are five private golf courses in the Borough, with two public courses at Richmond Park and one at Twickenham. There is also one floodlit public driving range. Horse riding remains a very popular activity and there are riding establishments located in or around the Royal Parks. Horse rides are provided in Ham Lands, Ham Common, and in the Royal Parks and there are also a small number of bridleways. Riding is one of a number of sports which provide pleasure and assist people with disabilities and learning difficulties.

5.6

The areas of concern are the pressure to allow development on private sports grounds, the lack of a floodlit all weather athletics track, and the limited progress in achieving dual use of existing sports facilities. There is a trend towards a variety of artificial surfaces for various sports and an increasing pressure for access to floodlit facilities for a wide range of sports, which has to be considered against the maintenance of the quality of the open environment. There also needs to be an awareness of, and flexible approach to, accommodating emerging sports.

5.7

Restricted finance, land shortage and limited opportunities for development make it essential to ensure private sports grounds and other facilities are not lost and optimum use is made of existing facilities, including the dual use of school sites and public access to private facilities.

FOOTPATHS

5.8

Footpaths allow people to enjoy the Borough's open spaces, riverside and areas of attractive landscape and townscape, generally away from the bustle of vehicles. Most of the longer footpaths are public rights of way. Walking is a very popular recreational activity with people of all ages. Most of the policies for pedestrians and footpaths are located in the Transport Chapter of the Plan.

ALLOTMENTS

5.9

The Council provides 29 ha of allotments on 24 sites, divided into 1863 individual plots of varying size. All statutory sites, which are protected by the Allotment Acts, are owned by the Council. Some of the non-statutory sites were originally purchased by the Council for uses other than allotments and may go out of use in the future, a few are owned by other public bodies. Changes in demand will also determine the future level of provision. Lack of funding has led to maintenance problems. The overall vacancy rate has tended to fall, and has stabilised at 3.5%, whilst there are waiting lists at some sites.

RIVER THAMES, ITS ISLANDS AND ITS TRIBUTARIES

5.10

The River Thames flows through the Borough for 28 km of its length making a unique contribution to the environment. It provides many opportunities for recreation, enjoyment and employment and is valued by residents, visitors and tourists. In its winding course through the Borough it flows past open stretches of woodland and parkland, Victorian industrial waterfront and urban frontages where the life of the town comes down to the water's edge. Some of the earliest settlements, and thus the most important concentrations of historic sites and buildings, are closely associated with the river and its islands, which gives a special character to its immediate environs.

5.11

At its best, the river forms an integrated whole with its banks. Wild stretches enclosed by trees and stretches with buildings whose appearance or purpose is closely tied to the river make up some of the best waterside views in the area, cross river views are particularly important, and co-operation with other Boroughs is essential (e.g. as with the Thames Landscape Strategy).

5.12

The Thames offers opportunities for active recreation too - for anglers, sailors, canoeists, birdwatchers and those who simply like to stroll through some of London's finest open spaces. There is public access to 27 of the 34 km of river bank in the Borough either by towpath or riverside open space. The Thames Path National Trail follows both banks downstream of Teddington Lock. The Thames in the Borough provides the setting for the annual university boat race and other major rowing events.

5.13

The riverside environment has gradually been changing as freight and passenger traffic have declined and the numbers of private launches and sailing boats have increased. Riverside industry has given way to pressure for riverside dwellings and other developments, and defences have been strengthened to protect all of riverside London from the threat of flooding. All these changes can threaten to erode the identity and variety of the reaches, which range from quiet and tranquil, to busy and full of activity, and along with changes in water level, can disturb its wildlife and threaten its ecological balance. River features such as slipways, pontoons, wharves, jetties and steps have regrettably often been lost. Much of the riverside is protected (approx. 80% of its length) by green belt, metropolitan open land, nature conservation and other restrictive policies. If development is permissible, then the opportunity is taken to gain a public riverside walk and sometimes riverside open space, and to enhance the ecology of the riverside.

5.14

The tributaries also add interest to the areas through which they flow. The Beverley Brook is a natural drainage channel, partly culverted, and there is only limited access to it outside Richmond Park. The River Crane is a natural drainage channel flowing through some attractive woodland and open space, with a riverside walk for much of its length. The secluded Duke of Northumberland's River was created in the early 16th century to supply water to a convent which stood on the site of Syon House. It flows from the Crane to the Thames, and has a footpath for most of its length in the Borough. The River Crane Walk and the Beverley Brook Walk have been developed with signs, waymarks and accompanying leaflets, and have been validated by the London Walking Forum, as recreational walking routes. The Whitton Brook runs along the northern boundary of the Borough and flows under Ivy Bridge before discharging into the River Crane. The Longford River was cut in the mid 17th century to improve the water supply to Hampton Court Palace, and it now supplies water to the ponds and fountains in Bushy Park. There is almost no public access to it since it flows between back gardens for much of its length. Map 5 shows rivers in the Borough.

FRAMEWORK FOR POLICIES

PROTECTING OPEN LAND

5.15

Strategic Planning Guidance for London (RPG 3 1996), reaffirms the commitment to green belt and states (para 58) that it must be maintained "as far as can be seen ahead". It also emphasises the importance of metropolitan open land and states: "The presumption against development in the green belt applies equally to metropolitan open land". The valuable role of other open land and green chains' is stressed and boroughs are encouraged to consider these in preparing policies on open land. It is recommended that UDPs include land use policies on nature conservation, particularly where sites of Special Scientific Interest (SSSIs) are concerned. The London Planning Advisory Committee (LPAC) supplementary advice on retaining and enhancing open space acknowledges both the local and the strategic structural, amenity, social, cultural and ecological roles of open space as well as the recreational functions.

5.16

Planning Policy Guidance Note 9: Nature Conservation (PPG 9 1994) reaffirms the Government's commitment to the conservation of the natural environment. It emphasises the need not only to protect sites both designated and undesignated but to manage wisely and create new habitats. PPG 9 advises the integration of measures to protect and promote nature across all areas of an authority's work. Subsequently, the UK Biodiversity Group have published species action plans and habitat action plans, to guide the development of local biodiversity action plans and nature conservation decisions of the local authority.

LAND FOR RECREATION

5.17

RPG 3 1996 states that London boroughs should consider Planning Policy Guidance Note 17 (PPG17 1991) Sport and Recreation, when assessing their own requirements for sport and recreation. The Planning Policy Guidance stresses the valuable social and economic role of sport and recreation, the need to enable people to participate in sport and to provide a wide range of opportunities for recreation, with opportunities available to all. Planning authorities are required to ensure that adequate land and water resources are allocated both for organised sport and informal recreation and to take full account of the community's need for recreational space, to have regard to current levels of provision and deficiencies and to resist pressures for the development of open space which conflict with the wider public interest. Local planning authorities should take account of the value of open space not only as an amenity but also as a contribution to the conservation of the natural and built heritage of the area, and should balance very carefully the competing claims of different land uses and the community's long term requirements for open space. Strategic Planning Guidance also states that development to enhance the facilities of sites of national and international importance including the RFU stadium should be encouraged. Boroughs are also asked to consider London Sport's The Sporting Capital: The Regional Recreation Strategy for London (London Sport 1994), which advocates sports equity and sports development towards achieving the National Vision for Sport.

5.18

The former London Council for Sport and Recreation has also published a Playing Fields Strategy for London' (1990). This provides a basis for estimating present and future demands and for assessing playing field requirements for football, rugby, hockey and cricket. The strategy urges the adoption of clear policies in UDPs which recognise the value of playing fields and other recreational open space, and which enable them to be protected against development pressures and promote their use.

5.19

In 1997 the Borough published a revised Sports Strategy for Richmond as a policy framework for the future development of facilities including priorities for provision, participation and standard of sports in the Borough, taking account of the Regional Recreation Strategy (1994). The Council's Sports Strategy advocates the improvement of athletics facilities at Barn Elms, and that the present stock of public and private sports grounds and playing fields should be preserved and their facilities made more available to the public where capacity for greater use of pitches exists.

RIVER THAMES, ITS ISLANDS AND ITS TRIBUTARIES

5.20

Strategic Guidance for the River Thames (RPG 3b/9b) was published in February 1997. It presents a vision for the river and its islands which will provide a land use planning framework for enhancing its status and vitality, and includes objectives for the built and natural environment and the use of the river. The relevant section for this Borough is that from Hampton to Crayford Ness, which guidance designates as the Thames Policy Area' (TPA), requiring local planning authorities to identify detailed boundaries, prepare detailed appraisals and policies. This is intended to enable a more consistent approach to be taken to strategic river issues.

5.21

The Thames between Kew and Hampton flows between a unique landscape of parks, royal palaces and working communities related to the river, and the resulting legacy of architecture, landscape, public access and nature conservation value is unparalleled in the capital. In recognition of the need for its protection by co-ordinated policies and implementation proposals the Council contributed towards the preparation of the Thames Landscape Strategy (June 1994). The implementation of the Thames Landscape Strategy is supported and monitored by a continuing partnership of the four relevant Boroughs, English Heritage, English Nature, the Countryside Agency, the Environment Agency and the Royal Parks Agency. The Council is supporting the employment of a co-ordinator for the implementation of the Strategy and has adopted the policies of the Strategy, as appropriate, into the UDP at review and as supplementary planning guidance. The Strategy integrates with UDP policies by relating them to other boroughs' policies and taking them further, both to more detailed levels and to site specific proposals. It has been supported by Inspector's decisions on appeal, and by RPG 3b/9b. A new strategy covering the area from Kew to Chelsea is being progressed by a steering group comprising the relevant riparian boroughs, the Government Office for London, the London Planning Advisory Committee, English Heritage, the Port of London Authority and local societies under the banner of the West London River Group. The Thames Strategy for Kew to Chelsea will use the approach developed in the Thames Landscape Strategy combined with work required by Thames Guidance RPG 3B/9B to deliver detailed appraisals of the Thames and its environs.

5.22

The overall approach of the UDP is to recognise the distinctive character of individual stretches of the Thames while treating the river and its islands as an integral whole with its banks and hinterland. This involves an interplay and balancing of environmental design, nature conservation, land use and recreational policies.

STRATEGY

5.23

The strategy below forms a framework for the protection and enhancement of the Borough's open environment. The Borough will:-

Open Land and Recreation

protect and enhance the many features including nature conservation interests, of the existing landscape which give the Borough its special character and define the built-up areas;

protect and enhance the ecological systems of the Borough;

encourage more efficient use of existing facilities and resist the loss of existing facilities where there is a demand;

improve access to recreational facilities, including access for people with disabilities and special needs. Many basic facilities, such as playgrounds and local parks, should be within walking distance of all Borough residents and the route to them should be convenient and safe. More specialised facilities should be conveniently accessible by public transport;

improve the environment in other ways where this is required;

River Thames, its Islands and its Tributaries

protect the character and distinctiveness of individual reaches,

protect its the variety of riverside uses;

ensure that for new buildings and other features the likely impact of development proposals has been adequately assessed, that they take account of their riverside setting, enhance the environment, nature conservation and add interest and activity, rather than detract from it;

encourage recreation on the river, its islands and its banks;

protect the Thames viability as a navigable waterway and give encouragement given to the maintenance and extension of these functions. It is particularly important that river related industry such as boat building and repair can continue and that its facilities such as slipways and wet and dry docks are retained and used.

OBJECTIVES FOR THE OPEN ENVIRONMENT

To ensure the protection of open land from development, noise, light and air pollution.
To ensure the preservation and enhancement of areas of open space, and natural environment, including the River Thames, its islands, its banks, flood plain and tributaries.
To identify and protect sites of nature conservation importance, including the River Thames, its islands, its tributaries and banks, to enhance these sites through appropriate management techniques, and to encourage awareness of the importance of these sites.
To ensure that ecologically sensitive sites are protected from the damaging effects of development, and that the ecological potential of every development site is carefully considered and reflected in the form of development proposed.
To protect existing trees and achieve an overall increase in the number of trees in the Borough.
To ensure where practicable that all Borough residents and people working in the Borough should have adequate, convenient and equal opportunities for access to a range of outdoor sports facilities, regardless of age, income level, gender, ethnicity, disability or level of performance.
To ensure that the demand for allotments is catered for as far as possible.
To identify, conserve and complement the variety of uses and the distinctive architectural and landscape qualities of the River Thames, its islands, its banks and tributaries.
To encourage the continuation of a viable boat building and repair industry, and other industry which is dependent on riverside sites, by protecting wherever possible, its sites, facilities, river features such as steps, stairs, wharves, jetties and slipways, and its employment prospects.
To encourage the use of the Thames, its tributaries and riverbanks, for passenger and freight transport and recreation, in so far as this is compatible with the protection and enhancement of the riverside environment.
To ensure that houseboats and other moorings do not have an adverse effect on the riverside environment or hinder public enjoyment of the Thames.
To preserve washlands and floodplains and to safeguard other low-lying parts of the Borough from flooding whilst ensuring that public access to the rivers and their environs is not necessarily diminished.

OPEN LAND, PROTECTION AND IMPROVEMENT

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ENV 1 - METROPOLITAN OPEN LAND

5.24

The Council will protect and conserve metropolitan open land as defined on the proposals map by keeping it in predominantly open use. There will be a presumption against inappropriate development. Building development, including extensions, will generally be unacceptable. Changes of use of existing buildings for purposes not normally acceptable in metropolitan open land will be resisted. In considering development on sites adjoining metropolitan open land the Council will take into account any possible visual impact on the character of the open land.

5.25

Metropolitan open land is open land or water which is of significance to London as a whole or a part of London, either publicly or privately owned, and with or without public access, which either:

contributes to the physical structure of London and helps to separate and/or define London's distinctive communities;

contributes to the establishment of London's special character by providing attractive breaks in what would otherwise be continuous urban development;

creates a significant visual open space experience when used, passed, or crossed;

contains natural features, buildings or landscape of historic, recreational, agricultural, nature conservation or scientific interest, worthy of protection on account of their value nationally or to the whole or a part of London;

includes open air facilities, especially for leisure, recreation and sport, of importance for the whole or a part of London;

or:

forms part of a green chain of related open spaces and linking footpaths, bridleways, riverside and canal walks, and towpaths.

Some open spaces and gardens which themselves might not be of significance to London as a whole, but which combine visually and physically to form a larger significant open area or green wedge, are included.

5.26

The Council considers the contribution of metropolitan open land is as vital as green belt in defining London's structure. Therefore building development, including the extension of existing uses, will be vigorously resisted. The Borough's metropolitan open land is at present in a variety of uses ranging from the Royal Parks to schools, sports clubs and cemeteries. Envelopes to allow extensions have been provided around major buildings in metropolitan open land. However, the policy also recognises that there may be exceptional cases where it is appropriate to allow modest buildings or extensions, including structures on the river, which are related to the function of metropolitan open land and where this would not have a harmful effect on its character. So that it can be kept in predominantly open use, new uses will only be considered if they conserve and enhance the open nature and character of the metropolitan open land and maintain its nature conservation interest, are by their nature open or depend upon open uses for their enjoyment. Appropriate uses include:

public and private open space and playing fields;

agriculture, woodland and orchards;

golf courses;

allotments, nursery gardens, private gardens;

cemeteries;

nature conservation;

rivers, reservoirs, lakes and other open water.

5.27 The Council will protect metropolitan open land as a habitat for wildlife and take opportunities, where possible, to increase its potential for wildlife. Views across open land are important. The Council will encourage enhancement of metropolitan open land where appropriate, e.g. by landscaping, removal or replacement of inappropriate fencing, screening, and seek to reduce the visual impact of traffic and car parking.

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ENV 2 GREEN BELT

5.28

The Council will protect and enhance the green belt as shown on the proposals map. There will be a general presumption against inappropriate development. New buildings proposed on land adjoining the green belt will be required to have minimum visual impact when viewed from the green belt.

5.29

The green belt within the Borough is shown on Map 2. The main purposes of the green belt are:

To check the unrestricted sprawl of the built up area.
To safeguard the surrounding countryside from further encroachment.
To prevent Greater London from merging with neighbouring towns or urban areas, and to prevent neighbouring towns from merging into one another.
To preserve the setting and special character of historic towns.
To assist in urban regeneration by encouraging the recycling of derelict and other urban land.

5.30

Once green belts have been defined, the use of land in them should fulfil the following objectives:

To provide access to open countryside and outdoor sport and recreational opportunities for the urban population
To retain attractive landscapes, and enhance landscapes, near to where people live
To improve damaged and derelict land around towns
To secure nature conservation interest
To retain land in agricultural, forestry and related uses

In relation to those uses identified above which are considered to be acceptable in the green belt, the Council will, in determining such applications, pay particular regard to ensuring that they protect and enhance the open nature and visual qualities of the green belt.

5.31

The construction of new buildings within the green belt is inappropriate unless it is for the following purposes:

(a)

agriculture, horticulture and forestry

(b)

essential facilities for outdoor sport and outdoor recreation, for cemeteries, and for other uses of land which preserve the openness of the green belt.

5.32

Approximately half of the Borough's green belt comprises operational waterworks, with most of the remainder in various open recreational uses. To ensure the green belt continues to fulfil its intended functions and to preserve its permanence it is essential that its open character and wildlife interest are maintained.

5.33

Degraded landscape quality arising from neglect or misuse of land will not be sufficient justification for allowing development contrary to green belt policy. In these circumstances the Council will endeavour to see the under-used land brought into an appropriate open use.

5.34

The Council will seek the co-operation of other landowners, including Thames Water, to enhance the quality of the green belt, for instance through landscaping schemes. Should waterworks land cease to be operational the Council will endeavour, in conjunction with the water authority, to bring such land into appropriate open recreational use allowing public access, while protecting and enhancing its potential as wildlife habitat.

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ENV 2 (A) - MAJOR DEVELOPED SITE IN THE GREEN BELT

5.35

Part of the Hampton Water Treatment Works is recognised as a major developed site in the green belt and is identified on the proposals map for purposes described in paragraphs C3 and C4 of Annex C to Planning Policy Guidance Note 2: Green Belts. This policy is intended to meet the operational requirements for essential water treatment works at this site, subject to the limitations below and in particular the need to maintain the openness of the green belt.

The filter beds and reservoirs are major contributors to the open character and appearance of the site. The filter beds and other visually open areas are not considered to be part of the developed area for the purposes of this policy. Planning permission will be granted for limited infilling or partial redevelopment for essential water treatment related purposes, provided that:

(a)

It is within the Major Developed Site boundary shown on the proposals map.

(b)

It will have no greater impact than the existing development on the openness of the Green Belt and the purposes for including land within it.

(c)

It will not exceed the height of the existing buildings or lead to a major increase in the developed proportion of the site.

(d)

It will not obstruct the reinstatement to working order of the former light railway serving the works.

MAP 2 - METROPOLITAN OPEN LAND GREEN BELT & GREEN CHAINS

Click map for a larger image

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ENV 3 - OTHER OPEN LAND OF TOWNSCAPE IMPORTANCE

5.36

The Council will protect and seek to enhance other open areas that are of townscape importance. In considering development on sites adjoining these open areas the Council will take into account any possible visual impact on the character of the open land.

5.37

In some parts of the Borough, open areas, which are not extensive enough to be defined as green belt or metropolitan open land, act as pockets of greenery of local rather than London-wide significance. Many of these are of townscape importance, contributing to the local character and are valued by residents as open spaces in the built up area. These areas include public and private sports grounds, some school playing fields, cemeteries, some large private gardens and some allotments, all of which the Secretary of State for the Environment has recognised can be of great importance to the character of a neighbourhood. LPAC through work on urban green space also recognises the importance of such land. The larger areas are shown on the proposals map but there will be other smaller areas which merit protection. The purpose of this policy is to safeguard open land and ensure that it is not lost to other uses without good cause. The policy recognises that there may be exceptional cases where it would be appropriate to allow modest buildings and extensions which are related to the function of Other Open Land of Townscape Importance (OOLTI) and when this would not have a harmful effect on its character.

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ENV 4 - RIVER CRANE AREA OF OPPORTUNITY

5.38

A positive policy of environmental improvement, improved access and sympathetic development will be applied to the River Crane "area of opportunity" as shown on the proposals map.

5.39

The Crane Valley contains large areas of open land, which could benefit from significant environmental improvement. The Council is committed to the overall improvement of the corridor to provide an attractive walk and open wedge between the London Borough of Hounslow and the River Thames.

5.40

The Council is developing a master plan for the main area of potential change, includes the Stoop Memorial Ground, the Craneford Way playing fields, the Council Depot, the Richmond Upon Thames College and the Post Office Sorting Office. It is committed to looking at this area comprehensively with a view to enhancing the open space and the associated linkages, improving sports facilities and providing for possible improvement to the College. Also to be included are improvements to the banks of the River Crane to enhance their ecological interest and provision of a through pedestrian/cycle route along the River Crane. The Council will work with the local community as appropriate in the planning and carrying out of improvements. It is the intention that the existing level of cultivated allotments within the Crane Valley should be retained. It is recognised that there are limited vehicular access points into the area and this would need to be fully taken into account. There will be a need for enabling development and through the master plan process the Council will identify the most appropriate mix and layout of uses.

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ENV 5 - PROTECTION OF VIEWS AND VISTAS

5.41

The Council will seek to protect the quality of views especially those indicated on the proposals map. It will also seek opportunities to create attractive new views and vistas and, where appropriate, improve any that have been obscured.

5.42

This policy will have implications for the quality of design of buildings and the configuration, height and site layout of new development. It may apply even where the viewpoint is a long way from the development, such as in the case of views from Richmond Hill and numerous vantage points in Richmond Park. Trees and general landscaping are particularly important and this policy will be vigorously applied in seeking their protection. The Richmond, Petersham and Ham Open Spaces Act 1902, and various covenants were designed to protect views and prevent building in some areas. In some locations views have been obscured by fencing, buildings or overgrown trees. Appropriate opportunities will be taken to open up or enhance these views for the benefit of the general public. The Council will also seek to protect the quality of views which are identified in Supplementary Planning Guidance, including the Thames Landscape Strategy. Other local views shown on the Proposals Map meet the criteria for designation of "Metropolitan Views" as set out in LPAC report 18/99 "Supplementary advice on High Buildings and Strategic Views in London.

5.43

The view from King Henry VIII's Mound to St Paul's Cathedral is the subject of a Direction made by the Secretary of State as part of strategic guidance (Supplementary Guidance on the Protection of Strategic Views) and is one of eight such strategic views of St Paul's from various viewpoints. The protection and enhancement of the strategic view from King Henry's Mound to St Paul's will be achieved by consultation between boroughs. This will be triggered by any proposal reaching or exceeding the height limitation of 45m AOD (Above Ordnance Datum) within the view cone as defined in the Direction described above, and shown on the proposals map, and 50m AOD within the area of backdrop protection. Protection of the strategic views in an annex to RPG 3 (1991), including the view from King Henry VIII's mound to St Paul's, will also require the co-operation of other authorities.

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ENV 6 - GREEN CHAINS

5.44

The Council, in conjunction with neighbouring Boroughs, will have regard to the importance of interconnected green space (or green chains) as a recreation and nature conservation resource, and as a link to the countryside. Priority will be given to proposals that will provide missing links, and enhance the value of green chains for informal recreation (particularly walking) and nature conservation. Proposals which would breach the green chains with built development will not be permitted.

5.45

There is already a web of interconnected green spaces, (mainly existing open land protected by metropolitan open land, green belt, Area of Special Character, public open space and Other Open Land of Townscape Importance designations), carrying across Borough boundaries. These are referred to as "green chains" in the Strategic Planning Guidance for London (RPG 1996) which advises each Planning Authority to identify and make proposals for such spaces in their UDP. They provide both extended pathways for the public, and wildlife corridors in natural surroundings (these are also covered by policy ENV 20 below) see Map 2.

5.46

To encourage the use of such green chains, the Council will, when finances are available, establish a network of signposted and way marked walks in parts of the areas having public access, including links to town centres, public transport and other attractors. Where appropriate, provision may also be made for cycling and/or horse riding. Where there are missing links or urban sections between open areas, the Council will supplement planting on suitable routes, or acquire land, as resources permit, to complete chains. In liaison with other Boroughs and Authorities, the Council will publish maps and leaflets to explain routes, and publicise their existence.

5.47

The Council already promotes the Thames Path National Trail, the River Crane Walk and the Beverley Brook Walk. It is committed to developing sections of the two orbital walking routes around London, the Capital Ring and the London Loop, in conjunction with adjoining Boroughs and the London Walking Forum. See Map 3 for existing and proposed walking routes. Access to the River Thames is sought where there are new riverside developments. This policy links with policies ENV 28 and TRN 10 which encourage the establishment and use of footpath networks, relating to riverside access, and with the Councils transport strategy which seeks to encourage walking as an alternative to car use.

5.48

Proposed green chains are:-

Hampton - the waterworks area stretching westward towards Kempton Park, eastwards to Bushy Park.

Teddington - Broom Road Recreation Ground, Lensbury Club, Riverside, links to Twickenham riverside; Normansfield links to Bushy Park via Bushy Park Road.

Ham - Thames Path, Ham Lands, riverside playing fields, Ham House Avenues, Greycourt School, Ham Common, Cassell Hospital north west boundary, links to Thames Path via path through housing estate (formerly British Aerospace, R.B. Kingston).

Richmond/Barnes - Richmond Park, Palewell Common, Barnes Common to River Thames, following Beverley Brook Walk, linking to Thames Path.

Richmond - Richmond Park to Wimbledon Common at Robin Hood Gate, Beverley Brook Walk and Capital Ring.

Richmond/Kew/Mortlake - Old Deer Park, Kew Gardens, Kew and Mortlake riverside Mortlake Cemetery.

Barnes - Lonsdale reservoir, Harrodian school, St Pauls School, Barn Elms Wildfowl and Wetland centre and sports grounds, Barnes Common.

River Crane -

" Crane Park, Kneller Park " Craneford Way playing fields to London Road. " Moormead Park to A316 and open land further north.

River Thames.

MAP 3 - EXISTING & PROPOSED WALKING ROUTES

Click map for a larger image

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ENV 7- CONTAMINATED LAND

5.49

The Council will seek to identify contaminated land, whether in public or private ownership, and will take necessary measures to ensure that the contamination is treated appropriately in order to protect public health and the natural environment and bring sites into beneficial use. Before considering applications for the development of sites which are possibly contaminated, the council will require developers to undertake an assessment of the types and concentration of contaminants present and provide a statement of the method and scope of the assessment and remedial measures proposed.

5.50

Ground and water pollution may result from activities such as gas manufacture, industrial processes, land-fill and sewage disposal. The extent of contamination in the Borough is at present unknown but land used for industrial purposes has been relatively insignificant and the amount of contamination is therefore likely to be limited. Nevertheless it will be important to identify the extent of the problem and ensure that remedial action is taken to protect public health and the environment, including wildlife and groundwater. The Council will publish a list of sites where contamination is identified and remedial action is considered necessary. This information will be available for public inspection. Developers will be expected to assess levels of contamination and undertake remedial action prior to development, ensuring safety both during and after development. The level of remediation required will be that sufficient to render sites harmless, taking account of the views of the Environment Agency and in accordance with government and other appropriate guidelines, but will also be at a level appropriate to the use proposed.

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ENV 8 - CEMETERIES AND CREMATORIA

5.51

The Council will safeguard existing cemeteries, land reserved for future burials and existing crematoria.

5.52

Three of the six cemeteries in the Borough owned by the Council are full. At present rates of interment there is sufficient land available, including reserves, at East Sheen & Richmond, Teddington and Twickenham cemeteries for approximately eighteen years of burials. London Borough of Hammersmith & Fulham operates Mortlake and North Sheen cemeteries and London Borough of Hounslow operates Hounslow and Powder Mill Lane cemeteries in the Borough. A proportion of the space in these cemeteries is likely to be taken by Borough residents, thereby contributing an additional two years to the Borough's burial capacity. There are crematoria at Mortlake and at Hounslow cemeteries.

5.53

The adequacy of cemetery provision in the long term will depend on future rates of interment and cremation, although the life of existing cemeteries might be extended through the re-use of graves, should legislation for this be forthcoming. The Council will continue to monitor interment and cremation rates and keep the requirements for future burial space under review.

5.54

Cemeteries should also be safeguarded because of their important environmental qualities. Besides providing visual amenity as open breaks in the urban fabric they are valuable as areas for quiet contemplation. They have especial value in providing green lungs that serve as wildlife habitats, many being designated as other sites of nature importance such as Barnes, East Sheen and Richmond cemeteries, as well as being the setting for many quality trees.

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ENV 9 - TREES IN TOWN AND LANDSCAPE

5.55

The Council will:

continue to protect trees and make tree preservation orders (TPOs) where appropriate;

encourage tree planting where appropriate, and give priority to native trees where these are suitable. The Council will continue its own programme of planting, especially in the areas shown on the proposals map;

continue its programme of maintaining trees in streets and public open spaces and of selectively clearing and replanting trees;

seek to retain the existing character of areas of forest tree planting, and generally favour forest trees over others where opportunities arise;

promote planting of clumps and thickets in appropriate locations.

5.56

The abundance of trees in the Borough is a great asset to its environment, softening the hardness of buildings and streets, adding life and colour to the urban landscape and enhancing open spaces. Trees along the Thames are important for riverside landscape character. Trees also provide an important habitat for wildlife, and reduce levels of lead and other forms of airborne pollution, and increase the supply of oxygen. It takes many years for a replacement tree to reach maturity. The areas shown on the proposals map are those in which the Council considers further planting is most needed, but planting will also be encouraged throughout the Borough. In some woodland areas periodic thinning and clearing may be necessary to ensure the overall health of the wood. In streets it is important that species are chosen that are appropriate to the scale of their surroundings and planting will be in consultation with statutory undertakers to safeguard underground apparatus. The distinctive character of many parts of the Borough is reinforced by the forest type of tree planting, and it is important that this is maintained where space allows. The Council will endeavour to keep the diversity of indigenous species by encouraging, in appropriate cases, planting of native trees when implementing tree planting policies and considering other landscape schemes for trees in relation to development sites.

5.57

Many trees are already protected by TPOs, but the Council will continue to make TPOs where trees of environmental importance are threatened. Trees in conservation areas are, with some exceptions, automatically protected, as six weeks notice must be given in writing to the Council before any proposed works are carried out. Where unauthorised works to any protected trees are undertaken the Council will seek to initiate legal proceedings which can result in substantial fines. Where trees are felled, the Council will normally require that an appropriate replacement be planted. Planning guidance advising owners on the selection and care of trees is available. Considerable care is required when carrying out work to underground services to avoid damage to trees. The Council will continue to monitor such work, BLT 24 refers to the arrangements for cable television. The Council has produced a Tree Strategy for the Borough, covering detailed guidance on the implementation of this policy, through planting and management on Council owned land, and through the Council's influence on owners of other trees by means of planning controls, advice, joint projects and consultations. (See also ENV 20 Green Corridors).

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ENV 10 - HISTORIC PARKS, GARDENS AND LANDSCAPES

5.58

The Council will seek to protect and enhance the parks and gardens of special historic interest included in the Register compiled by English Heritage under the Planning (Listed Buildings and Conservation Areas) Act 1990, and other historic parks, gardens and landscapes where appropriate. Proposals which have an adverse effect on the settings, views, and vistas to and from historic parks and gardens, will not be permitted.

5.59

The Register carries no statutory provisions as does the List of Buildings of Special Architectural or Historic Interest. The Council therefore needs to take care in carrying out its development control functions so that historic gardens are not affected by encroaching or adjacent new development. The Council will investigate opportunities for reinstating historic landscape settings and links between them, including avenue planting and vistas, the water gardens in Bushy Park are to be restored as part of proposals in the area. In appropriate cases, including circumstances where land is defined in the Plan as public open space, the Council will seek absorption of parts of the Royal Parks currently in private enclosures into public use. Many of these parks and gardens have management plans to enhance their value which the Council supports, and may form the basis of supplementary planning guidance (e.g. for the Old Deer Park). (See Map 6).

The following are included in the Register, together with plans defining the relevant areas, and on the proposals map:

Bushy Park	Grade I
Hampton Court Park	Grade I
Richmond Park	Grade I
Royal Botanic Gardens, Kew (including Old Deer Park)	Grade I
Ham House	Grade II*
Marble Hill House	Grade II*
Strawberry Hill	Grade II*
Hampton Court House	Grade II*
Richmond Terrace Walk	Grade II*
Pope's Garden	Grade II
Garrick's Villa	Grade II
York House Gardens	Grade II
Terrace Gardens & Buccleugh Gardens, Richmond Hill	Grade II
Teddington Cemetery	Grade II

The Council will also seek to protect and enhance other historic parks and gardens not Included in the Register, including in particular the following:

Orleans House Gardens
Radnor Gardens
Richmond Green
Thames Landscape throughout the Borough

POLICIES FOR RECREATION

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ENV 11 - RETENTION AND IMPROVEMENT OF PUBLIC OPEN SPACE

5.60

(A)

The Council will resist the loss of any land shown as public open space on the proposals map. It will endeavour to increase the enjoyment of public open space through site management of parks and open spaces under Council control, having regard to the needs of nature conservation as well as providing for both active and passive recreation, and improving public access and facilities for all residents, including people with disabilities, where possible.

(B)

The Council will seek to protect and enhance the visual quality of areas of public open space through the maintenance of a high standard of design in landscaping, boundary treatment, fencing materials, play equipment and other items of furniture and by ensuring a high quality of design in new development within or adjacent to it.

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ENV 12 - PROVISION OF PUBLIC OPEN SPACE

5.61

The Council will seek, where opportunities arise and finance permits, to provide new public open space with safe, convenient access for all residents, including people with disabilities, especially small local parks, to serve residents in the areas poorly provided with open space as identified on the proposals map.

5.62

The intention of these policies is to maintain and increase the public open space in the Borough which contributes so greatly to its recreational and environmental character and to secure additional open spaces with safe access in those areas that are relatively less well served. Opportunities for improvements may occur when changing needs and more intensive use of school pitches mean that some land laid out as sports pitches can be released and planted as parkland.

5.63

Management plans will be prepared and practices adopted which take greater account of the need to protect habitats and wildlife, for example, by minimising the use of pesticides, herbicides and chemical fertilisers and which balance the needs of recreational use with nature conservation. Where appropriate, local participation in management will be encouraged. In addition it is intended that the enjoyment of existing public open spaces should be enhanced, particularly through providing opportunities to enjoy nature, and opportunities will be taken to provide new, more convenient entrances and gates to the Royal Parks for non-vehicular traffic. The Department of the Environment, Transport and the Regions has already indicated that they are prepared to consider extra entrances for example, at Palewell Common as part of the Beverley Brook riverside scheme proposal B6, however any proposal would need to be subject to full public consultation. The Council recognises the important role that the Royal Parks have in providing for the recreation of residents and visitors, habitats for wildlife, areas of beauty, calm and darkness to escape from the pressure of urban living and in contributing to the Borough's special character by virtue of their mature historic landscapes. It will therefore oppose changes to the administration and management of the Parks if they threaten these functions, remove their present status as public open space with free access during daylight hours or threaten public rights of way. Small local parks are particularly valuable to the less mobile such as the elderly and carers with young children. The enjoyment of open spaces for these groups will also be enhanced through the provision of dog free areas and adoption of Poop-Scoop byelaws to counter dog fouling.

MAP 4 - ACCESS TO LOCAL PUBLIC OPEN SPACE

Click map for a larger image

5.64

Where opportunities arise the Council will enter into Section 106 agreements with developers to secure the provision of public open space, and will seek its provision as planning advantage. In areas of public open space deficiency, the local planning authority may require a contribution from developers towards the provision of additional public open space. Contributions will be on a scale related to the size and type of development. Other ways of increasing opportunities include providing access to other open land in public ownership such as redundant cemeteries and school playing fields, e.g. Barn Elms, or through the creation of new parks following redevelopment of sites in either public or private ownership e.g Alpha Road pocket park and Hampton village green. The areas shown on the proposals map are generally those parts of the Borough which are more than 400m from a local park or are separated from one by a busy road.

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ENV 13 LIGHTING INCLUDING FLOOD LIGHTING

5.65

When considering proposals for lighting or floodlighting of buildings, sport, leisure or other facilities, the Council will take account of the benefits of the facilities and the effect they will have on the character and amenities of the surrounding area, including open land and in the wider context it will also take account of the impact on views from Richmond Hill, Richmond Park and across the River Thames. Favourable consideration will be given to the replacement of existing lighting to minimise impact.

5.65

Many forms of lighting can be beneficial, to enhance the safety and security of highways, railway land, pedestrian access routes and buildings, to extend the hours of use of outdoor sporting facilities especially in the Winter or to enhance particular buildings, landscapes or features.

5.66

In some designated open areas (metropolitan open land, green belt or other open land of townscape importance), which are also either designated as important for wildlife; are registered as Historic Parks, Gardens or Landscapes; or within the Thames Policy Area, any form of lighting could be intrusive. In such locations new installations may not be permitted . However proposals for sports facilities will be encouraged wherever possible and, in foregoing designated areas, where floodlighting is proposed, in particular at existing facilities, information and measures for reducing the impact of the floodlighting will be invited and fully considered in determining an application. Efforts will be made to improve existing installations.

5.67

Where lighting or floodlighting is permissible in principle, factors such as: the appearance of the installation when switched off; the effect of the lighting on residents when lit in terms of sky glow, glare, and light trespass, as well as the effects on wildlife, including on adjoining land; and the potential noise and disturbance from the associated use of the facilities being lit, will be taken into account. If permission is granted, conditions or an agreement may be imposed to restrict the lighting levels and times of use, or to implement other measures to minimise possible adverse effects, both within the site and on adjoining land.

5.68

Outside the designated areas, lighting may be acceptable in principle, but the considerations detailed above then apply. It is important that the columns themselves should be designed to be as unobtrusive as possible when unlit, in terms of number, height, width, design, colour and siting. Light pollution should be minimised to protect residents and passers by, using cowls or purpose built downward illuminating lighting, as well as to conserve energy. Applicants are referred to the Institute of Lighting Engineers Guidance Notes for the Reduction of Light Pollution.

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ENV 14 - SPORTS STADIA/SPECTATOR SPORTS

5.69

Proposals for sports stadia and other spectator sports facilities will be considered in relation to the following criteria:

(a)

they should be well located in relation to the road and public transport network or show that adequate improvements could be secured and should not result in serious problems of road access, traffic congestion or road safety;

(b)

spectator capacity should not exceed a level compatible with the potential capacity of the local area;

(c)

car parking should be minimised to reduce use of cars as far as practicable;

(d)

they do not detract from the open function, character and quality of land designated as green belt, metropolitan open land , or other open land of townscape importance; or in the English Heritage Register of Historic Parks and Gardens.

(e)

they would not have an unacceptable adverse effect on the environment of the surrounding area, in particular residential amenity.

5.70

The Borough is the home of the RFU and a number of rugby clubs at the Stoop Memorial Ground, Richmond Athletic Ground and the Old Deer Park. The annual Boat Race and the Hampton Court Flower Show are other major attractors. They provide pleasure to those who attend matches and local residents, including many school children participate at an amateur level. The development of professional rugby has changed the nature of the clubs. Although there are beneficial effects on the local economy through the spending of both the clubs, including employment, and the spectators, there have been adverse impacts on the character of the grounds, traffic congestion and residential amenity. The development of professional sport has increased spectator numbers, and brought pressures for more modern stands, hospitality suites, and more car parking which are difficult to accommodate without conflicting with policies to protect open space.

5.71

The Council will seek to reach agreements with the RFU and the clubs (and the organisers of other spectator events where relevant) in relation to

(a)

longer term development strategies (both on-site and off-site);

(b)

operational matters (number of events and timing, noise monitoring, use of ancillary facilities;

(c)

floodlighting, stewarding, off-site catering, parking and hospitality, financial support for services);

(d)

employment and the local economy including purchasing policies and training and recruitment and equality of opportunity;

(e)

means of travel including managing demand for travel and ensuring it is by means that cause the minimum nuisance, accident or environmental harm;

(f)

community and environmental initiatives, consultative arrangements and monitoring and enforcement.

5.72 The Plan proposes improvements to Twickenham Station and a new purpose built walk for spectators to serve both the Stoop Memorial Ground and the RFU will be investigated, other improvements to transport provision and arrangements could be investigated by prospective developers of sport facilities. The Council will seek improvements to public transport infrastructure and improved access between existing or proposed public transport services and development sites

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ENV 15 - RETENTION OF RECREATION FACILITIES

5.73

The Council will resist the loss of public and private sports grounds and playing fields and private open space in recreational use and will encourage owners of private facilities to make them available for public access and use.

5.74

Sports grounds and playing fields, games pitches, courts and outdoor swimming pools etc. including the many private facilities, provide facilities for Borough needs and assist towards meeting the wider sports needs of other Boroughs. They also, by their openness, make a significant contribution to the townscape and natural environment. There is evidence that a shortfall exists in the number of pitches available for some sports at peak times. It is therefore important that the recreational opportunities afforded by both public and private open sports facilities and their open character are not lost without good reason. The fact that playing fields have become disused is not sufficient reason to allow the use to be lost permanently or be a justification for building on them. If reasonable attempts to market a site for a sports user have failed, the Council will endeavour, subject to the availability of resources, to ensure continued open recreational use, especially in areas of open space deficiency. The Council will seek the advice of the English Sports Council and Local Sports Councils when considering the future of open recreational facilities. Gaining more public access to private facilities and school/ educational establishments will allow higher levels of participation in recreation and ease pressures on public facilities at times of peak demand.

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ENV 16 - BRIDLEWAYS

5.75

The Council will seek to improve existing bridleways and encourage the construction of new bridleways where this is feasible.

5.76

Horse riding is popular in the Borough, but there is a conflict between horse riders and pedestrians, and horse riders and vehicles, and it may have an ecological impact. The Council is anxious to improve the situation by encouraging the provision of separate bridleways where opportunities arise. Bridleways may become unusable in wet weather, leading to unauthorised detours resulting in ecological damage, and drainage improvements and suitably designed barriers are necessary to prevent this. The Council also seeks to reduce conflicts through signing, patrolling and publicising recognised routes and supporting the users' groups. Substantial investment is needed to improve and extend the existing network. Horse riding associations, clubs and other interested bodies will need to make finance available. The Council has produced a voluntary Horse Riding Code of Practice on the use of bridleways.

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ENV 17 - RETENTION AND PROVISION OF ALLOTMENTS

5.77

The Council will promote the cultivation of allotments by retaining existing statutory allotments, and generally resisting the loss of non-statutory allotments so long as there is a demand. The Council will seek to provide new allotments where a demand becomes apparent. The Council will ensure the most effective use of allotments in the Borough and secure improvements to sites where appropriate.

5.78

The Council is committed to promoting allotments as part of its Environmental Policy Statement and it is the intention of these policies to ensure that suitable land is available. In assessing demand, regard will be had to the number of applicants on the waiting list for sites. The use of smaller size plots can stimulate demand and allows some flexibility in matching available allotment land with cultivators. Generally, future demand is unlikely to be sufficient to necessitate further overall provision. If a demand becomes apparent in a particular part of the Borough, the Council will seek to provide new allotments.

5.79

The Council will continue to liaise with interested groups regarding the management of sites and will seek to transfer management to tenant associations whenever possible to improve amenity standards. Where practicable the Council will seek to improve the appearance of allotments by ensuring that they are fully used and by raising standards of cultivation through improvements in site amenity and control of vandalism. The Council is also investigating ways of encouraging and supporting organic horticulture, for example, by encouraging allotment holders undertaking organic cultivation to locate on adjoining plots. Consideration may be given to the conversion of some allotments to leisure gardens, to be used for recreational gardening without restriction to the cultivation of vegetables, where this will improve their visual appearance. Where sites have become under-used and neglected over a long period, plots will be consolidated and the surplus land removed from allotment use on a temporary basis. Only where long term demand for allotments appears likely to remain low will suitable alternative uses be considered. Since many allotment sites lie within areas of metropolitan open land, and open land of townscape importance, open uses will normally be the most appropriate alternatives.

POLICIES FOR NATURE CONSERVATION

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ENV 18 - SITES OF SPECIAL SCIENTIFIC INTEREST AND OTHER SITES OF NATURE IMPORTANCE

5.80

Proposals which may have an adverse effect on a Site of Special Scientific Interest, Local Nature Reserve or Other Site of Nature Importance shown on the proposals map, or which may be identified from time to time, will not be permitted. Developers may be required to show that their proposals will not affect these areas by way of built form, noise, air pollution, light pollution, surface run-off of water, water quality, changes in level, landscaping and other factors, including those raised in the Local Biodiversity Action Plan.

5.81

The Borough is fortunate in having a large number of sites of nature conservation importance. Richmond Park and Barn Elms reservoirs (now the Wildfowl and Wetland Centre) have been designated Sites of Special Scientific Interest, (SSSIs). The Council is required to consult with English Nature before giving permission for development in or near SSSIs. English Nature notify the Local Authority of the consultation areas and types of development about which they wish to be consulted.

5.82

Other Sites of Nature Importance, (OSNIs) have been identified in consultation with the London Ecology Unit and local groups, including important habitats and species identified in the Borough's LA 21 Biodiversity Group's Biodiversity Action Plan. It is important to ensure that as well as protecting these from development and/or the construction process which is incompatible with their nature conservation interest, development in locations nearby will not cause harm. In those exceptional cases where there is a specific proposal involving development on either an SSSI or an OSNI, policy ENV 19 will apply.

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ENV 19 - NATURE CONSERVATION AND DEVELOPMENT PROPOSALS

5.83

All new development will be expected to preserve and where possible enhance existing habitats and wildlife features. The opportunity should be taken in new and existing development to create appropriate new habitats, in the design of buildings themselves and in appropriate design and species in landscaping schemes and to incorporate features to attract wildlife. Supplementary planning guidance will be issued and site briefs will incorporate specific requirements. Conditions or agreements will be used where appropriate to protect features, secure mitigating measures or ensure appropriate management, and subsequent monitoring.

5.84

Although the principal use of a site may be for housing or other development, schemes should be designed to retain natural features on site, e.g. trees or other vegetation, water courses, banks, old field boundaries including hedges. Where no such features exist, or where the Council is satisfied that retention would be impracticable, new habitats or features to encourage wildlife should be created on the site, where possible. Account will also be taken of the site's potential as part of a green corridor. The Council will endeavour to keep the diversity of indigenous species by requiring, in appropriate cases, the planting of native trees when implementing tree planting policies and considering other landscaping schemes. The Council may also, in appropriate cases, refer to the Local Biodiversity Action Plan and require site management agreements to support indigenous species and habitats considered seriously at risk. The Council will issue design guidelines to ensure that nature conservation is integrated at the planning stage into all development. (See ENV 9 - Trees in Town and Landscape and ENV13 - Floodlighting).

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ENV 20 GREEN CORRIDORS

5.85

The Council will protect and enhance green corridors as shown on the proposals map for nature conservation. Developments which threaten the integrity of these corridors will not be permitted, and opportunities will be taken to strengthen, enhance or create new wildlife corridors when new development takes place.

5.86

Green corridors are relatively continuous areas of open space leading through the built environment and which may link sites together and to the Green Belt. They often consist of railway embankments and cuttings, roadside verges, canals, parks, playing fields and rivers. They may allow plants and animals to penetrate further into the built up area than would otherwise be the case, and provide an extension to the habitats of the sites they link. It is important that such green corridors are not narrowed or breached by development and that if possible they are widened, or improved if opportunities arise. The creation of new green corridors and the joining of missing links will be encouraged. Lack of public access to green corridors may sometimes be a positive advantage and green corridors may include elements of private land, and transport routes such as railway embankments and road verges which are not easily accessible, or suitable for the public to walk along. The Council will consult with Railtrack and the train operating companies to ensure proposals for green corridors do not affect the operational and technical requirements of the railway. The needs of the railway shall be seen as a priority where conflicts may arise. Green corridors may be part of green chains. Further information is available in the London Ecology Unit's Advisory Note 6, "Green Corridors in London" 1991.

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ENV 21 - MANAGEMENT FOR NATURE CONSERVATION

5.87

The Council will promote nature conservation where appropriate in the management of its own land. The Council will encourage and advise other landowners to manage land in accordance with nature conservation principles and will seek to secure management agreements where appropriate. Management plans will be prepared for all nature conservation sites controlled by the Council, in consultation with expert bodies and other individuals or groups with an interest in the land. When resources are available, appropriate sites will be designated as Local Nature Reserves (see policy ENV 25).

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ENV 22 - AIMS FOR PUBLIC INFORMATION AND PROMOTION OF NATURE CONSERVATION

5.88

The Council will maintain and enhance the value of sites for nature conservation purposes by promoting a greater awareness of nature conservation, through publicity, references to appropriate parts of the Local Biodiversity Action Plan and interpretive material, by encouraging the involvement of local groups in nature conservation activity, by encouraging the development of nature conservation areas within schools, and by the use of sites of nature conservation interest for educational purposes. Due regard will be paid to the need to balance these aims with the protection of the ecology and environment from over-use.

5.89

In order to maintain and enhance the value of sites for nature conservation purposes it is essential that sites are managed to accord with nature conservation principles. The Council has the opportunity to manage its own land appropriately and is empowered under the Wildlife and Countryside Act 1981, Section 39, to enter into management agreements with other landowners. It can also promote good practice by example and information, e.g. by reducing the use of herbicides on its own sites. The Council recognises the value of working towards these ends through its involvement with the Agenda 21 process and the Biodiversity Group in particular, the process of producing the Local Biodiversity Action Plan involves public consultation and promotion throughout. The Environmental Policy Statement has an objective to provide information and education on environmental issues and the Council will ensure that the public is informed of the reason for management practices which affect their local environment.

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ENV 23 - AIMS FOR MONITORING AND LIAISON WITH OTHER NATURE CONSERVATION ORGANISATIONS

5.90

The Council will seek expert advice on environmental and conservation matters, including the identification, protection, enhancement and management of sites for nature conservation. The Council will, with the assistance of the GLA Biodiversity Strategy Team, Environment Group, monitor the distribution and quality of habitats within the Borough, and will maintain an up to date schedule of sites with information on their nature conservation interest.

5.91

The Council is committed to liaison with national and local organisations involved in nature conservation. These groups provide specialist knowledge and expertise. The Council supports cooperation with local residents and specialist groups in the creation and management of nature conservation areas, and will continue to support the work of the GLA Biodiversity Strategy Team, Environment Group. The Borough's Local Agenda 21 Biodiversity Group is to prepare a Biodiversity Action Plan, which will include biodiversity indicators for monitoring.

5.92

It is important that the wildlife resource is continually assessed and that data is kept up to date. For example, a decline in a particular species may point to a need for a change in management practices.

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ENV 24 - SPECIES PROTECTION

5.93

Planning permission will not be granted for development or land use changes which would have an adverse impact on badgers or species protected by schedules 1, 5 or 8 of the Wildlife and Countryside Act 1981. In addition, the Council will take into account the presence of local or national biodiversity priority species when assessing applications. Where development is permitted that may affect those species, the council will impose conditions where appropriate, and seek to use its powers to enter into planning agreements to facilitate the survival of individual members of the species; reduce disturbance to a minimum; and provide adequate alternative habitats to sustain at least the current levels of population.

5.94

Part 1 of the Wildlife and Countryside Act 1981, sets out the protection which is afforded to wild animals and plants, the schedules of species protected are reviewed every 5 years, and Local Authorities are bound by the Act to bring these to the attention of the public and school children. Some animals are protected under their own legislation, e.g. the Protection of Badgers Act 1992. The presence of a protected species is a material consideration when the Local Planning Authority is considering a development proposal, which if carried out, would be likely to result in harm to the species or its habitat. The Council will consult English Nature before granting planning permission, and will consider the use of appropriate planning conditions or agreements to ensure that the developer takes steps to secure the protection of the species. Developers should satisfy both Planning and Wildlife legislation with regard to protected species. When a development may affect a badger sett, developers must secure a licence issued by English Nature under Section 10(1)(d) of the Protection of Badgers Act 1992, in addition to applying for planning permission. Developers of other sensitive sites and habitats should also be aware of the details set out in the LBAP for the Borough, EU directives and other international conventions and the general requirements of the area of the proposed development.

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ENV 25 - LOCAL NATURE RESERVES

5.95

The Council will review its existing land holdings and will, in consultation with English Nature, declare appropriate sites as statutory Local Nature Reserves (LNRs). The Council may also, where appropriate, purchase or enter into management agreements over privately owned sites with the intention of declaring them as Local Nature Reserves.

5.96

The Council has already designated five Local Nature Reserves in the Borough, Crane Park Island, Oak Avenue, Ham Lands, Lonsdale Reservoir, and Barnes Common. Opportunities exist to create more, as resources allow.

POLICIES FOR THE RIVER THAMES

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ENV 26 - THAMES POLICY AREA

5.97

The Council will seek to protect and enhance the special character of the Thames Policy Area [TPA], whose boundaries are indicated on the Proposals Map, by:

(a)

protecting and enhancing views and vistas of and from the River Thames and its riverside landmarks as identified in RPG 3B/9B, and on the Proposals Map;

(b)

identifying and protecting the special character of individual reaches;

(c)

ensuring a high quality of design for buildings and spaces, appropriate to the identity of the context, so that the individuality of the reaches is protected;

(d)

ensuring that development establishes a relationship with the River and takes full advantage of its riverside location, addressing the River as a frontage and opening up views and access to it, taking account of the changed perspective with tides (see ENV 35);

(e)

identifying sites where, exceptionally, landmark buildings may be appropriate;

(f)

encouraging development which includes a mixture of uses, including uses which enable the public to enjoy the riverside, especially at ground level in buildings fronting the river;

(g)

preparing design briefs, as appropriate, in consultation with the local community and requiring design statements from developers for all significant developments in the TPA, and all riverside sites;

(h)

identifying and protecting landscape features, important structures and archaeological resources associated with the River and its history and heritage and ensuring that new riverside development incorporates existing river features (as described in detail in policy ENV 30);

(i)

discouraging land infill and development which encroaches into the river and its foreshore other than in exceptional circumstances, which may include where necessary for the construction of new bridges, tunnels, jetties, piers, slipways etc.;

(j)

requiring a statement of the effect of the proposal on any existing river-dependent uses on the site and their associated facilities (both on and off the site); and an assessment of the potential of the site for river-dependent uses and facilities if there are none existing.

5.98

The Thames is a unique resource and the preservation of its special character is essential to London as a whole. Strategic Guidance for the River Thames (RPG 3b/9b) indicates that policies to protect the character of the River, following its Thames Policy Area designation, should be included in UDPs. Design statements required from developers, should contain the following information:

(a)

an assessment of scale, mass, height, silhouette, density, layout, materials and colour in relation to:

(a)

an assessment of scale, mass, height, silhouette, density, layout, materials and colour in relation to:

the local context, including the River frontage

impacts on local and strategic views, including views across, along and from the River

the skyline; and

local landmarks and historic buildings and structures

(b)

proposals for:

river edge treatment

visual and physical permeability and links with the River's hinterland;

protecting and enhancing public access to and along the river

landscaping, open spaces and street furniture; and

lighting

and should take account of UDP policies, and of any design briefs or guidelines prepared by the local authority. They should also consult Local Authorities and other relevant bodies, including the local community, before submitting an application. The Thames Landscape Strategy has also been adopted as supplementary planning guidance. In the application of this policy the Council will take account of the provisions of the Thames Landscape Strategy, and any other supplementary planning guidance which the Council may from time to time adopt, as a material consideration.

MAP 5 - LOCAL NATURE RESERVES

Click map for a larger image

5.99

Strategic Guidance for the Thames also indicates that local authorities should prepare detailed appraisals of their stretches of the River and its environs within the TPA. For the stretch from Hampton to Kew, the Thames Landscape Strategy fulfils this function and, which together with other similar initiatives, will be supported by the Council. The Council will liaise with relevant London Boroughs to consider the preparation of appraisals for reaches downstream of Kew and upstream of Hampton.

5.100

The character of the River Thames within the Borough varies according to the individual reaches. The contrast between the reaches and between opposite banks within the reaches makes a major contribution to the character of the River -there are changes from built-up to rural areas, from urban townscape to suburban gardens, from formal vistas to woodland, within quite short distances. Development proposals, if acceptable in principle, must always take account of the character of the reach that provides their context. Forms appropriate for one reach may be quite unsuitable for another. Decisions will be based on analysis of the special character of each reach, as set out in the Thames Landscape Strategy, the Study of River Related Industry Sites by Roger Tym and Partners, the Council's conservation area statements and studies, and future detailed appraisals to be carried out as appropriate.

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ENV 27 - ACCESS TO THE RIVER THAMES (INCLUDING FORESHORE) AND THE THAMES PATH NATIONAL TRAIL

5.101

The Council will seek to maintain and improve access to the River Thames and its foreshore, and implement the Thames Path National Trail. To that end, the Council will, on either side of the River Thames:

(a)

Protect existing rights of way and public rights of access to the Thames-side, and resist any proposals that would remove, narrow or materially impair such rights.

(b)

Seek to provide public rights of access to Thames-side pedestrian facilities where such rights do not exist.

(c)

Require any development of Thames-side sites to provide a permanent, continuous, high quality public right of way, adjacent to the river, with links to the surrounding network, and without restricted access hours. (Subject to the exceptions below.)

(d)

Ensure that the following features are incorporated into new sections of riverside paths:

Full accessibility, including for people with disabilities.
High quality design, layout and materials
Way marking and other signposting and street furniture in accordance with design guidelines, signs to indicate links to other walking routes, stations, bus stops etc.

(e)

Take opportunities to maintain and, where appropriate, enhance access to the foreshore, in conjunction with the PLA.

5.102

Exceptions to (a) and (b) will only be considered if it is necessary

to protect a listed building or its setting;
to enable any industrial or commercial activity that uses the Thames, to continue to operate;
to preserve or conserve any natural or man-made features that contribute to the character of the Thames-side;
to protect natural habitats, to preserve the natural ecology of the Thames and Thames-side; to ensure public safety.

In such circumstances, locating the route back from the bank edge will be investigated as an alternative option, and only if varying the route would not overcome potential problems will an exception to the policy be made.

5.103

Probably the most effective way of improving access to the river and of increasing its recreational role, with minimum impact on the natural environment, lies in improving and extending riverside footpaths wherever this is practical, (see also policy ENV 6). The Thames Path Long Distance Trail is continuous on the south bank in the Borough. It is possible to walk from one end of the Borough to the other along the Thames by crossing the river at Hampton Wick and Hampton Court and using paths in Kingston and East Molesey. Along the north bank the Thames Path at present follows roads from Teddington Lock to Twickenham as there is no continuous public access to about 7 km of the north bank in the Borough. At present, access to the riverside is limited to short stretches, some of which has been achieved through redevelopment of riverside sites. The Council will continue to seek such access, and ensure that it is available without restriction and that paths are appropriately designed and laid out, and properly signed. See the Countryside Commission's "A Good Practice Guide for the Thames Path (Nov' 98). Access to the foreshore, primarily in the ownership of the PLA, can have both recreational and educational value. There is a right of access for fishing, navigational and other customary purposes. Public access must be considered in the context of the environmental and archaeological importance of the foreshore and also safety considerations. The PLA have undertaken a recent access survey, which they wish to review with the Council to determine the extent of appropriate public access.

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ENV 28 - ENCOURAGEMENT OF THE RECREATIONAL USE OF THE RIVER THAMES TRIBUTARIES AND RIVERBANKS

5.104

The Council will encourage the recreational use of the Thames, tributaries and their riverbanks by

(a)

resisting the loss of facilities that contribute to their enjoyment

(b)

encouraging new facilities and extensions to existing ones, where the physical capacity of the river and environmental considerations including the ecological implications and the amenities of riverside residents allow, subject to consultation where appropriate, with the PLA.

(c)

seeking to conserve, restore and enhance the natural elements of the river environment.

5.105

Recreational use of the River Thames and sites adjoining is encouraged to maximise opportunities for residents and visitors to enjoy what is one of the Borough's greatest assets. The water and bank side activities include sailing, fishing, walking, cycling and passive pursuits.

5.106

Responsibility for maintaining the Thames towpath rests with the owner of the bank, with the exception of the path adjacent to Kew Gardens which is owned and maintained by the Property Services Agency, although responsibility for maintaining the towpath surface, where there is a public right of way, rests with the Council as highway authority. When considering improvements to the towpath the Council will take into account the need to retain the contrast between the urban and more isolated rural stretches which adds so much to its character and the need to retain secluded feeding areas for birds.

5.107

Some parts of the Thames towpath are already officially available for cyclists, and for shared use, and some are not, although there is some unofficial use. SUSTRANS have made proposals for shared use of the remaining riverside towpath. However, although the principle of the Thames Cycle Route is supported not all the towpath is at present suitable for cycling because of possible conflict with pedestrians, although it is being shown elsewhere that these conflicts are capable of being resolved. Any change in status of the path would be subject to legal procedures and public consultation. There is a need for resurfacing of the most neglected sections of the towpath in sympathetic materials to make the towpath suitable for pedestrians and those with human powered wheeled transport such as wheelchairs, pushchairs and possibly cycles. At present the stretch from Teddington Lock to Kew Gardens is not officially available for cyclists so SUSTRANS are attempting to develop an alternative route away from the Thames, along roads, for the section of the Thames Cycle Route running through the Borough of Richmond upon Thames. There is a need for resurfacing of parts of the towpath in sympathetic materials to make it suitable for the needs of permitted users.

5.108

The main recreational use that can be accommodated on the tributaries is walking and cycling. Cycling is permitted along many parts of the River Crane in this Borough. The west London Boroughs of Brent, Ealing, Hillingdon, Hounslow and Richmond upon Thames, working in conjunction with the Countryside Commission, Sports Council, Environment Agency, London Canals Committee, British Waterways and Thames Water Utilities, supported the West London Waterways Walk Project which ran for six years ending in 1996, and aimed to develop the River Crane, Beverley Brook and River Brent, the Thames and the Grand Union Canal. The work of this project will be continued by the London Walking Forum, West Sector. The River Crane Walk and the Beverley Brook Walk have now been validated by the London Walking Forum as recreational walking routes. The Council will continue to make representations to the London Borough of Hounslow on its section of the River Crane when consulted on development on Feltham Marshalling Yards. Illegal incursion by motor bikes into Crane Park at Butts Farm will be subject to appropriate action. The Longford River has no footpath.

MAP 6 - RIVERS IN THE BOROUGH

Click map for a larger image

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ENV 29 - JETTIES AND PONTOONS

5.109

Proposals for jetties, pontoons and similar structures on the river will be assessed against the following criteria. They should:

(a)

Be functionally related to the river and be of an appropriate design for their immediate surroundings;

(b)

cause no impediment to navigation or interference with the river regime;

(c)

incorporate appropriate design measures to ensure that vessels are safely and securely moored;

(d)

be a minimum height, scale and bulk to serve their intended purpose;

(e)

not prejudice public enjoyment of the river or compromise nature conservation interests;

(f)

be located so as not to adversely affect local views.

Recreation enjoyment of the river can be enhanced through the provision of moorings and associated facilities. However, it is essential that proposals for permanent river structures are assessed against reasoned criteria, to ensure that they do not cause detriment to navigational, environmental or conservation interests along the river. (See also policies ENV 1, ENV 2, ENV 5 and ENV 26).

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ENV 30 - PASSENGER AND HIRE BOATS

5.110

The Council will encourage the provision, maintenance and improvement of passenger and boat hire services and ferries and will encourage integration of these with existing transport networks. The Council will also seek to provide piers and short stay visitor moorings where appropriate should opportunities arise, subject to safety considerations.

5.111

Passenger boats not only add to the visual interest of the river but also attract and give pleasure to tourists. Priority will be given to locations near public transport facilities for preference or close to riverside car parks or tourist attractions. The provision of more boat piers on the Thames will encourage further use of the River in accordance with the Plan's policies and assist in achieving a wider spread of visitors in the Borough in accordance with tourism policy. Piers will only be provided where they will not cause a serious obstruction and congestion or cause severe problems for small boats. The most feasible passenger service would be from Twickenham to Richmond. This would require a passenger pier at Twickenham. Tourist services already run from Kingston to Hampton Court, and Kingston to Richmond. However, due to their nature, these trips are infrequent and slow. The Council recognises that the Thames in its tidal reaches has a fast flowing tideway. The Council will consult with the Port of London Authority on safety matters and navigation prior to the granting of consent on any proposal relating to works or services on the river.

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ENV 31 - RIVERSIDE USES

5.112

In considering development sites, the Council will seek uses that are functionally related to the River, add to its character, and enable the public to enjoy it. Permission will not normally be granted for change of use or redevelopment for other purposes of such sites. Sites in use for river-related industry will be expected to remain in industrial use (B2). Riverside facilities including boat building sheds, slipways, docks, wharves and piers should be retained, and where possible new facilities should be provided. Any new development or infill should not encroach on the river or its foreshore other than in exceptional circumstances which may include structures which improve accessibility to and from the river, such as piers, jetties, moorings, slipways, steps and stairs and landing places.

5.113

River-related business uses, especially those involving the construction, repair and servicing of river craft make a vital contribution to the continuation of the historic tradition and function of the Thames "highway" for transportation, communication and recreation. They also have a significant role in the local economy. Following a survey of boatyards (co-ordinated by PLA, 1999) LPAC have recommended to government a list of boatyard sites for safeguarding. The Council supports in principle the safeguarding of these sites which would be a material consideration in implementing this policy. It is essential that these surviving facilities essential to the industry's future, such as boatyards and sheds, public and private wharves, slipways, wet and dry docks and cranes, as well as boathouses, piers, pontoons and stairs, are not lost to other uses. Although the main pressure is for the redevelopment of sites as residential, there has been some demand for redevelopment for non river-related business use and the Council will resist such proposals. In addition to their functional roles, river-related uses make an irreplaceable contribution to the character and contrasts of the individual reaches through the activity, distinctive building forms, varied visual interest and historical link they provide. The Council will seek agreements under the Town and Country Planning Act 1990, Section 106, in order to retain appropriate river uses.

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ENV 32 - PERMANENT MOORING OF HOUSEBOATS AND OTHER CRAFT

5.114

The permanent mooring of all kinds of crafts, including houseboats will only be permitted where:

(a)

the site is an urban stretch of the river where such craft would add interest to the river scene and not have an adverse effect on views or the character of the area;

(b)

the presence of the boats would not interfere with recreational use of the river, or with navigation;

(c)

provision of access, servicing and car parking can be made in a form which would not adversely affect amenity, particularly that of the river;

(d)

the site has adequate on-shore sanitary facilities or another acceptable system for the disposal of sewage and waste.

The loss of pleasure craft moorings will normally be resisted where they meet these criteria.

5.115

LPAC has published 'Guidelines on Moored Vessels and Structures' which includes reference to houseboats (para 3.3: Residential Moorings), which states: "Residential moorings may be appropriate in some limited areas, and their location should be considered in the context of the draft regulations proposed by the Residential Boat Owners Association."

5.116

Some provision for new houseboat moorings may be appropriate to make provision for the relocation of craft displaced from other moorings. However, suitable sites for residential moorings are very difficult to find. Houseboats also make a minor addition to the housing stock. On the other hand they can cause problems because they have to be serviced like normal dwellings, can obstruct navigation and public access to the river and are all too often unsightly. There has been considerable interest in the mooring of craft for use as floating restaurants, but these are generally inappropriate. Moorings, rather than houseboats, are controlled by planning legislation. A short study of the provision of improved public short stay mooring facilities will be undertaken in conjunction with the Port of London Authority and the relevant organisations.

5.117

Planning permission is required for new moorings and change of use of the bank and riverbed for permanent mooring. Planning control can limit the number of moorings, but does not extend to the appearance of boats. The Environment Agency and the Port of London Authority require houseboats to be licensed and can object to them on navigational grounds.

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ENV 33 - NATURE CONSERVATION ON THE RIVER

5.118

The Council will ensure that new development does not encroach into the river or damage valuable wildlife habitats and will seek to protect the flora and fauna along the Thames, banks, margins, islands and tributaries and take opportunities to restore wildlife value where it has been lost.

5.119

The variety of wild life in and beside the Thames and its tributaries adds to the enjoyment of the rivers, and several of the islands are managed as informal nature reserves. The River Thames forms part of a green corridor' described in policy ENV 20, and as such is an important route for wildlife migration.

5.120

The Thames and its tributaries have been subject to a number of surveys, by the London Wildlife Trust on behalf of the Council in 1986, and more recently by the Environment Agency as part of its Local Environment Agency Plan (LEAP) process. Such studies have confirmed the significant ecological values of rivers and their corridors. Policy ENV 19 seeks to protect the ecological value of all sites. Of unique importance in relation to the rivers are water areas, beaches and natural banks, green margins and tidal areas. Care will be taken that these are not destroyed or put at risk by development, increased public access or changes in maintenance regimes.

5.121

The water surface is significant for wintering wildfowl, and linkages between adjoining water areas are particularly important. Some of the islands have valuable semi-natural woodland reaching right down to the water. River margins have often been destroyed or urbanised in the past, but where natural, provide a unique environment for flora and fauna. The tidal Thames below Teddington, provides a rare habitat for fish, invertebrates and birds, and the adjacent land, where undisturbed, is critical to the life cycle of many species, especially birds.

5.122

Where characteristic riverside vegetation has been destroyed, opportunities should be taken to re create such habitats, to add to biodiversity and improve the rivers value as a wildlife corridors.

POLICIES TO PROTECT WATER QUALITY

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ENV 34 - PROTECTION OF THE FLOODPLAIN AND URBAN WASHLANDS

5.123

Within the area liable to flood, as shown on the proposals map, development, including land raising, will not be permitted unless it can be demonstrated to the satisfaction of the Council that the proposal would not of itself, or cumulatively in conjunction with other development:

(i)

increase impedance to the flow of floodwater;

(ii)

reduce the site's contribution to the capacity of the floodplain to store water (ideally a scheme should enhance its capacity); or

(iii)

increase the number of people or properties at risk from significant adverse effects of flooding;

(iv)

obstruct land adjacent to water courses required for access and or maintenance purposes;

(v)

adversely affect flood defence structures or other features with the same role.

5.124

A considerable amount of development has taken place on the floodplains of London's rivers and consequently people and property in these areas are at an increased risk from flooding. These developments are not only at direct risk, but also reduce the capacity of the available floodplain and impede the flow of water, thereby increasing the risk of flooding elsewhere. If redevelopment takes place, it should allow as much water as possible to flow over the land - i.e. stilts' should be used.

5.125

PPG 25 (Development and Flood Risk) requires developers to take into account the 1:1000 floodline, as areas within this line may be at risk in the longer term. Flood risk assessments will be required as appropriate, and the Council will be producing further supplementary planning guidance on this issue.

5.126

An Environment Agency licence is required for any works or development within 8m of non-tidal main river and 16m of tidal main river. The Council's emergency plan will be maintained and updated to protect residents and property from the risk of flooding (see ENV 36).

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ENV 35 - SURFACE WATER RUN-OFF

5.127 Planning permission will not normally be granted for new development or redevelopment if such development would result in an increased flood risk in areas downstream due to additional surface water run-off. Where development is permitted which is likely to increase the risk of flooding, it must include appropriate attenuation measures for the disposal of surface water, defined by the Council in consultation with the Environment Agency.

5.128

New development can increase the rate and volume which run-off reaches water courses in times of heavy or prolonged rainfall, leading to an increased risk of flooding and damage to watercourses and habitats. Wherever possible, permeable surfaces should be used (e.g. car parks) and development should incorporate features to reduce run-off from impermeable surfaces. Suitable surface water drainage methods include water butts, soakaways, porous pavements, storm water wetlands and balancing ponds. The methods adopted will need to have regard to the hydrological setting of individual sites and the use of appropriate pollution prevention methods. The Environment Agency can advise on site specific requirements.

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ENV 36 - TIDAL DEFENCES

5.129

There will be a general presumption against development which would adversely affect the integrity of the tidal defences and flood defences above Teddington Lock. Where development relating to the tidal defences and flood defences is permitted, the Council will, in consultation with appropriate bodies including the Environment Agency, require appropriate measures to be incorporated to protect the integrity of the defences.

5.130

A breach in the tidal defences of the River Thames could lead to significant flooding in areas of low lying land often well away from the location of the breach. In order to protect people and property from the effects of tidal inundation, it is essential that the integrity of the tidal defences is maintained. For redevelopment proposals the nature of the proposed and past site uses will be a key consideration to a proposal's acceptability, for example the continuation of an existing use in an area of flood risk may be acceptable, whereas a proposed change to residential use may be unacceptable. In association with redevelopment proposals the Council will seek opportunities, particularly in undefended or poorly defended flood plain areas for improvements to flood flow and flood storage capabilities. The prior written consent of the Environment Agency is required for any works:

(i)

in, under or over the River Thames (or other main river);

(ii)

within 16 metres of a tidal flood defence structure or within 8m of the brink of a non tidal main river; and

(iii)

of repair, alteration or rebuilding of any flood defence.

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ENV 37 - CULVERTING OF WATER COURSES

5.131

The Council will resist the culverting of water courses, both main and non-main, and will encourage alternative schemes which utilise the water course as a feature and nature conservation resource and enhance the setting of the area.

5.132

Under the Public Health Act 1936, Land Drainage Act 1991 and Water Act 1989, environmental aspects have to be considered when determining consent applications under the Acts. There should be a presumption against culverting in order to protect the river and consider its environment. The Council will liaise with the Environment Agency, which supports a presumption against culverting in dealing with applications for culverting. This policy reflects the effect of culverting on the continuity of the river corridor in addition to the adverse effects on flooding, nature conservation and safety.

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ENV 38 - RIVERBANK AND WATER POLLUTION

5.133

The Council will continue to liaise with the relevant statutory bodies to encourage cleanliness and the removal of driftwood and debris from the tidal Thames foreshore and banks, to achieve containment, and where possible reduction, in pollution of the Thames and tributaries and to promote improvement of water quality generally. The Council will continue to encourage voluntary groups who assist in the removal of riverside debris. There will be a presumption against developments which the Council considers likely to affect adversely the water quality of rivers, lakes and other areas of water, as a result of their surface or waste water discharge or the disturbance of contaminated land.

5.134

The cleanliness of the rivers has improved, but further pollution control to improve water quality is desirable. Maintaining or enhancing the water quality of rivers, canals, lakes, ponds and other water bodies is important for a wide range of uses. Deteriorating water quality can affect the supply of water for domestic, industrial and agricultural uses, general amenity, the provision of water based recreation, fisheries and nature conservation. The Council, in conjunction with the Environment Agency, will seek to restrict development which threatens surface water quality and will generally encourage initiatives that result in an improvement in surface water quality. Driftwood and floating debris are both unsightly and potentially dangerous to craft especially in the tidal areas. While the Port of London Authority and the Environment Agency have the responsibility for the collection of driftwood from the river it also strongly supports voluntary activities to remove riverside debris. Co-operation between the organisations responsible is essential if healthy public enjoyment of the river and riverside is to continue.

5.135

The Council has continued to liaise with statutory bodies and to an increasing extent with voluntary bodies in clean-ups of the towpaths and foreshore. It has also commissioned London Scientific Services to monitor regularly pollution levels in the Thames and has received reports upon them.

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ENV 39 - CLEAN WATER, FOUL SEWERS AND SEWAGE TREATMENT

5.136

In considering proposals for development, the Council will take account of the capacity of existing water and sewerage services and the impact of development proposals on them. Where necessary the Council will seek improvements to utility infrastructure related and appropriate to the development.

Development proposals for the provision of infrastructure or for utilities and related services will generally be considered favourably where:

there would not be an unacceptable impact on amenity including visual impact and the environment of the surrounding area generally or an adverse effect on public safety;

there are adequate access and servicing arrangements; and

there would not be an unacceptable impact on traffic conditions.

5.137

Many existing water mains, sewage systems and treatment works are becoming overloaded. Unless additional infrastructure is provided, further demands placed on existing facilities may result in poor pressure for clean water and in the pollution of water courses. Consequently, development should only take place where the new demand upon existing infrastructure is taken into account. Richmond is well served by a well maintained system of sewers. These sewers will need to be protected from new construction and tree planting. The sewerage built for the new development should separate foul and surface water to at least the boundary of the development site. In accordance with advice from DETR, Thames Water encourages, wherever possible, disposal 'on site' without recourse to the public sewerage system, for example in the form of soakaways or infiltration areas on free draining soils. If town centres are to be pedestrianised, vehicular access will be required to the public sewerage at all times.

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ENV 40 - QUALITY OF GROUNDWATER

5.138

Developments will not be permitted which, in the opinion of the Council, after consultation with the Environment Agency, pose an unacceptable risk to the quality of groundwater.

3.139

Groundwater resources are an invaluable source of water for public supply and industry, as well as sustaining the base flows of rivers. Some activities, such as the disposal of effluent in soakaways, landfilling of unsealed sites over permeable bedrock, or inappropriate storage of chemicals can result in the pollution of groundwater. Since the clean up of contaminated groundwater is difficult and very expensive, the Council will seek to prevent or reduce the risk of groundwater pollution by refusing planning permission for developments which it considers pose an unacceptable risk to groundwater.

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