GUIDANCE ON RESPONSES TO CAMDEN COUNCIL PLANNING DEPARTMENT

As well as signing the 38 degrees petition - see previous post - you can write to Camden to urge them to object to the plans.

The planning application by the City of London to carry out dam works on Hampstead Heath has been received by Camden Council and there is a deadline of 29 July 2014 for objections to be lodged.

The Planning Application number is 2014/4332/P and details are available on Camden’s website here. You can respond by:

1.     The on-line form on the Camden Council webpage for this planning application

2.     E-mail to planning@camden.gov.uk

3.     Writing to Jonathan Markwell, Regeneration & Planning, Development Management, 6th Floor, Camden Town Hall Extension, Argyle Street, London WC1H 8EQ

The points below are intended to help with details for individual responses, but please do personalise this and explain how you feel about the proposed dam works.

Nature and Wellbeing

·       The City of London is required under the Hampstead Heath Act of 1871 to preserve it in its “natural state and aspect”.

·       The City of London has been custodian of Hampstead Heath since 1989

·       Hampstead Heath is world famous, freely available to all Londoners and visitors. 

·       Used daily by wide variety of people; walkers, runners, swimmers, families with children. 

·       Benefits to physical and mental health, in turn a wider economic benefit.

·       Works would take at least 2 years, massive disruption to the Heath.

·       Permanent disfigurement.  Large areas inaccessible during works. 

·       Wildlife will be disrupted, sensitive environment damaged by traffic and heavy machinery.

Scale of Works

·       Heath a natural space, subject to gradual human intervention over hundreds of years.  Proposed works would be sudden and dramatic. 

·       Spillways proposed as a “soft engineering” option will still have significant impact.

·       Proposing to fell at least 160 mature trees as part of these works, to keep spillways clear.

·       Model Boating Pond to be enlarged, island created and 2.5m dam to south.

·       Men’s Bathing Pond 1m dam

·       Highgate No1 Pond 1.25m dam and wall

·       Catchpit Valley earth embankment, 5.6m high, up to 40m deep at base and 100m long

·       Mixed Bathing Pond 1m dam

·       Works over 2 year period, requiring use of heavy plant on the Heath.  Likely to worsen the soil compaction and increase flood risks.

·       Works would cost £17million, which is money which could be better spent elsewhere.

Risk model/Flooding

·       Failing to consider alternatives e.g. Stephen Myers’ proposals reported in the Camden New Journal on 4 July 2014 (greater use of the Heath’s natural capacity to absorb flood water requiring much smaller modifications to the existing dams).

·       Based proposal on risk model of the 1 in 400,000 year “probable maximum flood” and seek to “virtually eliminate” the risk of dam failure.  Unrealistic.

·       Illogical approach and this work is not a requirement of the 1975 Reservoirs Act.

·       Based this flood model on the number of additional people (300) who might be killed by the Probable Maximum Flood if the dams fail. 

·       Takes no account of the responsibilities of other bodies like Camden Council and Thames Water to reduce the impact of flooding.

·       No consideration of civil contingencies measures e.g. early warning systems or evacuation procedures that Camden Council is required to have in place. 

·       Does not allow for other infrastructure which would fail earlier than the proposed dams, and still lead to flooding and deaths e.g. drains and sewers south of the Heath. 

·       Assumes the 300 additional people who might die in floods due to dam failure remain in their homes and take no action to leave.

·       In over 300 years’ existence the ponds on Heath have not collapsed or caused any major flooding.  Have just had wettest winter on record with no ill-effects to the ponds.

·       Money would be better used advising local residents of potential flooding risks and supporting access to suitable insurance.

Consultation

·       City of London has ignored the results of its own limited consultation exercise (November 2013 – February 2014) where two thirds of respondents were very dissatisfied with all of the dam proposals. Given limited options to comment on in first place.

Proposed works at Ladies’ Pond

·       Full Amenity Assessment (Appendix 10.1) states Ladies’ Pond will be closed for 7.5 months and there will be no alternative swimming facility for most of this period (October 2015-March 2016) as the Mixed Pond is closed for most of this time too.  Needs to be clarified as assurances previously given about access to female only swimming facilities throughout the works i.e. access to the Mixed Pond as a substitute.

·       Furthermore, the builders (BAM Nuttall) indicated at Development Management Forum on 5 June 2014 that swimming would be restricted for a much shorter period, due to use of aqua-dam during work on Ladies’ Pond. Indicated they would only need to restrict swimming during de-silting works and when changing rooms being rebuilt.

·       Proposed single narrow entrance to deck area and changing rooms will be much more congested than at present. Potential risk in emergency situation.

·       Single point of exit from proposed lifeguard facilities makes no provision for alternative emergency exit from long/narrow building.  Also a “blind spot” from the back of the office area, no view of the south meadow.  An emergency exit door here facing south meadow, with suitable glazed panel, would resolve both issues (instead of proposed window to side/gate).