• Appendix 9: Consultation response from Environment Agency 07/08/13

Proposal: The proposed construction of a barge house large enough to

house the barge, store equipment and provide display and

education opportunities including a replacement café ;

wetdock with a guillotine sluice gate to hold water at mean

high water so that the barge can be displayed to the public and

a dredged channel to enable access when river is at the

retained level of 1.7m AOD

• Location: Orleans Road, Twickenham, TW1 3BL.

Thank you for consulting us at the pre-application stage. We welcome proposals

which “make space for water” and restore more natural environmental processes

which can deliver multiple environmental, social and economic benefits.

Having reviewed the proposal we would like to highlight the following issues and

opportunities for this key riverside park. These are related to: Flood risk management,

Flood defences and climate change; and Biodiversity and fisheries

• Flood risk management

The site is located in the highest risk zone called Flood Zone 3 in front of the

Thames Tidal Defences. As such it could be considered to be functional flood

plain (FZ3b). The proposal is classified and water compatible (barge house) and

less vulnerable (cafe) in Table 2: Flood risk vulnerability classification of the

Technical Guidance to the National Planning Policy Framework.

Table 1: Flood zones sets out the suitability of certain type of development within

areas of flood risk. Water compatible development is classed as appropriate

development in flood zone 3B, however less vulnerably development is classified

as unsuitable at this location. In this case the less vulnerable element will be a

replacement café on a like for like footprint and so would not be

increasing/introducing new risk into the functional flood plain so we would have no

objection. In order for the proposal to be acceptable in its current form you should

discuss the issue of functional flood plain with Richmond Local Planning authority.

If the proposal were to progress to a planning application then you would need to

produce a Flood Risk Assessment (FRA). The FRA should be prepared in

accordance with the Technical Guidance to the NPPF. Much of the information

required to inform the assessment may be obtained from the London Borough of

Richmond‟s Strategic Flood Risk Assessment (SFRA), which shows local flood

risk at a strategic level.

Your FRA should include the following:

– Identification of the Flood Zone and vulnerability classification in accordance

with Table 2 of the Technical Guidance to the NPPF.

– Confirmation of the flood defences and standard of protection provided, to

confirm the level of residual risk in accordance with the SFRA for the borough.

– Estimation of flood depths at the site for a range of flood events, to calculate

internal flood depths in the event of a flood event.

– Suitable flood mitigation measures based on flood characteristics at site.

We recommend that you use flood resistance and resilience measures and

construction techniques to help reduce the impact of flooding should it occur.

Please refer to “Improving the Flood Performance of New Buildings: Flood

Resilient Construction” (CLG, 2007).

You may also wish to consider whether a Flood Warning and Evacuation Plan

would assist in reducing the impact of flooding on the future users of the

development. We do not normally comment on or approve the adequacy of flood

emergency procedures accompanying development proposals, as we do not

carry out these roles during a flood. Our involvement with this development during

an emergency will be limited to delivering flood warnings to occupants/users

covered by our flood warning network.

Paragraph 9 of the Technical Guidance to the NPPF states that those proposing

developments should take advice from the emergency services when producing

an evacuation plan for the development as part of the flood risk assessment. In all

circumstances where warning and emergency rs is fundamental to managing

flood risk, we advise local planning authorities to formally consider the emergency

planning and rescue implications of new development in making their decisions.

Our Customers and Engagement Team can provide any relevant flooding

information that we have available. Please be aware that there may be a charge

for this information. Please contact 01707 632 511 or email:

NETenquiries@environment-agency.gov.uk.

• Climate change and Thames Estuary 2100 (TE2100)

As the development is within the floodplain you will need to consider TE2100

advice. An assessment should be made on the implications that rising water

levels due to climate change would have on the development and how the flood

defences can be raised if required. We recommend discussing the proposed

works to the flood defences in this area with London Borough of Richmond upon

Thames and how it fits with the wider long term management of flood defence

structures in Richmond and Twickenham.

More information can be found at:

http://www.environment-agency.gov.uk/homeandleisure/floods/125045.aspx

• Flood defences

Its essential the level of flood defence protection is maintained for this area of

high risk and regular flooding at high tides. We have concerns on the potential

negative impacts of reinstating the subway from Orleans House Gallery to the

barge house. We recommend that an alternative form of access is considered or

we agree ways to maintain flood defences

Under the terms of the Water Resources Act 1991, and the Thames Land

Drainage Byelaws 1981, the prior consent of the Environment Agency is required

for any proposed works or structures, in, under, over or within 16 metres of the

landward edge of the tidal defence of the River Thames, designated a „main

river‟.

• Water Framework Directive

The Water Framework Directive (WFD) came into force in 2000 and is the most

substantial piece of EU water quality legislation to date. The Thames River Basin

Management Plan was produced in 2009 to provide an initial guide on how the

targets for water quality improvements as set out in the WFD could be met for this

catchement. All new activities in the water environment will need to take the

Directive and the river basin management plan into account.

A fundamental requirement of the Water Framework Directive is to attain good

ecological water quality status and that deterioration in the status of waters is

prevented. Any new development must ensure that these two fundamental

requirements of the Directive are not compromised.

As your development involves bank and in channel works you should investigate

if a WFD assessment is required. WFD assessments aim to determine the effects

of proposed schemes on ecological quality, identifying any potential impacts that

could cause deterioration in the status of a water body or could hinder the water

body from meeting its WFD objectives. More information can be found at

http://www.environment-agency.gov.uk/research/planning/125035.aspx

• Biodiversity and fisheries

Please refer to “Rivers by Design” which provides a useful guide for planners,

designers and developers, providing practical advice and information on restoring

and protecting rivers and sharing good practice case study examples of projects

that have been successfully implemented across Europe. This available from:

http://www.restorerivers.eu/ Due to the developments location and the potential for

work in the River Thames you should produce an environmental assessment to ensure

there is no risk to wildlife and look at ways to improve the riverside environment for people

and wildlife. We will also require a method statement setting detailing any in channel

works and how the impact on fish and aquatic biodiversity will be mitigated.

• Advice for developers

We have updated our advice for developers and it is now a joint agency

document with advice from Environment Agency, Natural England and Forestry

Commission, it‟s available to view on our website

http://www.environment-agency.gov.uk/business/sectors/136252.aspx

I trust hope our response is helpful and we look forward to working with you on

this exciting project. We are happy to review any draft reports prior to formal

submission. If you require any additional information please contact me . .

Yours sincerely

Sustainable Places – Planning Advisor

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• Appendix 8: Advice from Beckett Rankine Marine Consulting Engineers . .

. . following a site visit at Orleans Gardens 10.07.13

It was good to meet with you and on the Riverside at Orleans House  Gardens yesterday. This would certainly be an excellent location for Gloriana’s  bargehouse.  Clearly there are several issues that will have to be resolved but I do think these can  all be worked out and, from a technical point of view, I believe the development of  this project would be achievable. My summary thoughts at this stage are:

  • It would be good to in some way reinstate the use of the former boathouse,  but we will have to find out by site investigation what if anything remains  underground from that structure.

  • Some dredging could be needed adjacent to the existing river wall which  might require some strengthening or underpinning, depending on the  extent of deepening.

  • Access to the site will require agreement with Hammerton’s to modify their  pontoon berths and then approvals from the authorities. As we discussed I  think this could provide a beneficial opportunity for all concerned.

  • There is some linkage between the desired level of Gloriana while on  display, the depth of excavation for the dock, access time requirements for  transferring her between the river and bargehouse and how this  manoeuvre is to be done. These all need to be considered jointly and in  some detail.

  • The proposal is for a wet dock accessible at higher tidal levels, although it  has been mentioned that access at maintained water level would be  preferable. Technically both would be feasible but for access at the lower,  maintained, water level it would obviously be necessary to excavate more  soil on land and in the river. This would be more costly not just because of  the increased volume but it would also make the construction work slightly  more difficult as it would be below the minimum water level, unless it is  possible to carry out this construction during a period of drawdown.  Maintenance costs including dredging and silt removal would also be  greater for the deeper excavation.

  • To facilitate Gloriana’s maintenance it would be desirable to dewater the  dock, making it become a dry dock. When studying options for doing this,  the relative merits of constructing a slipway rather than a dock, or even  inside the dock, should also be considered.

  • Some dredging will be required in the river and the creation of a new wet  dock will cause river water to flow into the newly excavated space. Siltation  will inevitably occur to some extent in both places. Mitigation measures  can be put in place to minimise this effect.

  • A guillotine gate can provide a simple and effective entrance to the dock  and a walkway could be connected as an integral part so that gate and  walkway lift out together. It can also be useful to help flush accumulated  silt from the dock as in various examples we discussed. However this will  have to be agreed and approved by the relevant authorities.  Navigation in and out of the dock will inevitably require Gloriana to be  aligned perpendicular to the river flow. At times the flow can be strong and  this might require some delay until slacker water near to the turn of the  tide. The entrance should be designed to allow some flexibility for this  manoeuvre.

  • I understand that Depressed River Mussels may be present in the area.  These and other environmental issues will have to be taken into account and  mitigation measures put in place if required.  Obtaining consents from authorities for marine projects can take several months even for projects such as this that appear to have only limited impact. This needs to be taken into account in the programme.

I hope this is useful at this stage and I very much look forward to working with you to further develop this project towards its successful implementation.

Kind regards

Beckett Rankine Marine Consulting Engineers

• Appendix 7: Note of meeting at Orleans Gardens on Monday 8th July 2013

Present: Lord Sterling LS Gloriana; MK Gloriana; Lord True LT Leader, LBRuT; IM LBRuT; DS LBRuT; MA Adams Infrastructure Planning Ltd.

York House

The meeting started at York House where LS said that he supported the recommendation in the draft feasibility study for a bargehouse at Orleans Gardens. LS asked how long would it take to deliver the project? DS indicated a period of 6 – 8 months to progress to RIBA Stage D design and to submit a planning application. LS said that this is too long and the timescale needs to be shortened. LT indicated that the timescale could be reduced. DS said that there would be a need for public consultation before the planning application is submitted. York House Gardens LT guided LS through the York House grounds to the Twickenham waterfront to view Eel Pie Island and then along to Riverside to show Orleans House and Orleans Gardens.

Bargehouse at Orleans Gardens

MA indicated the preferred site for the bargehouse. The water was at the retained (half-tide) level. Lord S said that Simon Thurley, (the Chief Executive of English Heritage) is keen on a bargehouse in this location. MA showed the remaining wall of the C19th dry dock and explained that the land formerly extended further into the river. LBRuT has title to land that is now in the river. This is not shown on Land Registry plans and LBRuT solicitors are seeking to resolve this discrepancy.

MA showed evidence of the former wet dock in the river wall and said that the rest of the structure is now filled in and is located beneath the children’s play area. LS said that there should be plans of this and that these should be obtained. LS and MK asked at what states of the tide access could be obtained? MA said that the plan in the draft report shows a toe pile wall at the entrance to the wet dock and this would allow for Gloriana to moor prior to accessing the wet dock / bargehouse on the high tide. An alternative would be for Gloriana to be moored on a pontoon prior to entering the bargehouse. MA said that the PLA engineer has commented that a dredged berth is likely to fill with silt quite quickly here when the river is in flood.

LS said that it is essential that the proposed bargehouse can be accessed at all states of the tide. LS does not want Gloriana to be restricted in the same way as at St. Katharine’s Dock. MA said that restricted access would be less of a problem in this location because trips down river would normally start and end at high tide. LS said that he would wish to have an assurance from a marine engineer that it would be possible to access the bargehouse at all states of the tide before confirming his support for this location. If it cannot be made to work then he would have to look at sites that are upriver.

Post meeting note

MA has arranged for a director of Beckett Rankine to attend a site visit on 10th July and to advise on the engineering aspects of securing access to the proposed wet dock when the river is at the retained (half tide) level. The meeting will be attended by DS and MA.

9.7.13

• Appendix 6: Note of meeting at Hammertons Ferry on Thursday 27th June 2013

Present:; FS Hammertons Ferry; AS Hammertons Ferry; DS LBRuT; MA Adams Infrastructure Planning Ltd.

MA introduced DS from Richmond Council and his commission from

Richmond Council to find a suitable location for a permanent home for the Royal

Row Barge, ‘Gloriana’. MA said that the Leader of Richmond Council is keen that

the barge should be based in the Borough.

FS said that Gloriana is a beautiful boat and had generated a lot of interest from the

public when she was moored at Hammertons for the Great River Race in 2012. FS

indicated that Gloriana is programmed to return for the 2013 Great River Race and

that he had offered to provide a mooring for the event.

MA outlined the three locations that the Council had asked him to evaluate. These

were Buccleuch Gardens, the Gothic House site that is next to Steins restaurant in

Richmond and Marble Hill Park / Orleans Gardens. Town planning constraints apply

to all three locations and it would not be practical to crane out Gloriana onto the

Gothic House site or into Marble Hill Park. He said that he is recommending a site in

Orleans Gardens that was used for a boathouse in the nineteenth century. The

boathouse was subsequently demolished and the site is currently occupied by part of

the children’s play area and the café.

MA said the proposed bargehouse would provide another visitor attraction that could

potentially fit well with Orleans House Gallery, Marble Hill House etc.

FS said that, in his view, tourist trade had dropped off in the locality since the London

bombings.

MA showed FS and AS sketch drawings of the plan of the wet dock and bargehouse

together with some indicative elevations. MA stressed that the proposals are only at

a very draft stage at the moment. It was necessary to show some detail in order to

establish if the location could work and to obtain indicative cost estimates but these

details could change.

MA also said that it would be necessary to reduce the length of the Hammertons

Ferry pontoon at the upstream end.

AS said that it is possible to move quite large vessels through the gap to the

moorings between the pontoon and the river bank but he appreciated that a wider

gap would be necessary to manoeuvre Gloriana, particularly when the tide is

running.

FS indicated that he would be happy to reduce the length of the pontoon. MA said

that it may be possible to extend the pontoon at the downstream end by agreement

with the PLA. MA said that there may be merits in revising the layout of the brow to

the pontoon by keeping the existing brow but adding a second one outside the

proposed bargehouse to provide a more direct route for visitors to the ferry and to the

hire boats. FS indicated that he thought that there may be some merit in this.

MA said that there would be a meeting on site shortly to give Lord True, Leader of

Richmond Council and Lord Sterling an opportunity to see the site and make a

decision as to whether proposals should be advanced to the next stage. If they

decide to go ahead with the Orleans Gardens site then it would be necessary to

engage FS/AS in the development of more detailed proposals.

MA asked whether FS/AS had any initial comments on the draft proposals.

FS made the following comments:

1. There is congestion in Orleans Road at the weekend and it would be

necessary to consider the provision of a one way access route to the

bargehouse;

2. It would be necessary to consider the provision of a car park as this will be a

massive attraction; and,

3. There is a need to survey the condition of the riverside trees and prune them

where necessary. FS said that there is a PLA responsibility for trees growing

out of the bank and a Richmond responsibility for the trees landward of the

bank. He said that he has had problems with unstable trees threatening his

property but the PLA is reluctant to act and he has had to take action himself.

28.6.13

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