Representation by The Peabody Trust and Tilfen Land Limited (The Peabody Trust and Tilfen Land Limited)
- Date submitted
- 13 June 2024
- Submitted by
- Members of the public/businesses
Cory Decarbonisation Project Interested Party submission on behalf of Peabody Trust and Tilfen Land Limited Introduction 1. This submission is made by CBRE on behalf of Tilfen Land Limited (UK company registration number 3685753, referred to below as “Tilfen”), as owner of the relevant land (referred to in this submission, as the “Peabody Land”), and also by its parent entity, Peabody Trust (a registered society, UK registered number RS007741), which owns Tilfen. Together, Tilfen and the Peabody Trust will be referred to as “Peabody” in this submission, and the relevant land as the “Peabody Land”. 2. At this stage Peabody has not considered in any detail the content of the DCO application documents and its position is therefore reserved. The Peabody Interest 3. It is useful to set out the nature of Peabody’s interest in the land proposed to be included in the proposed DCO. Peabody, one of the oldest housing associations in the UK, is responsible for more than 107,000 homes and around 220,000 residents across London and the Home Counties. Their purpose is to help people flourish. 4. Peabody became part of the Thamesmead story in 2014 when they took over from the previous owners, Gallions Housing Association, Trust Thamesmead and Tilfen Land. This meant much of the housing, community activities and more than 760 hectares of land became owned by a single body, for the first time in a generation. 5. Peabody is leading the regeneration of Thamesmead, working with people and partners to create new opportunities and improve neighbourhoods. Their mission is to improve, grow and look after the town for the long-term (see para 8 for further details). 6. Peabody owns 65% of the land in Thamesmead. The assets they own and manage include: • 240ha of green space • 5 public parks • 5 lakes • 7km of canal and waterways • 2.5km of river frontage • 53,000 trees • 5,600 homes • 15 community buildings. 7. Peabody’s work is guided by its Plan for Thamesmead, described below as “the Thamesmead Plan”). The Thamesmead Plan is revised every five years. Peabody’s latest version covers 2023-28 and is accessible via the following link: Maintaining Momentum - Peabody (peabodygroup.org.uk). 8. The Plan for Thamesmead 2023-28 sets out five goals for Peabody. They are to: • improve people’s day to day experience of living in Thamesmead • build new homes, leisure and community spaces • improve the quality of the landscape and create more chance for people to use it • make culture a part of everyday life • support communities to be happier, healthier and wealthier 9. Peabody’s commitment to improving the quality of the landscape for Thamesmead is underpinned by Peabody’s green infrastructure framework, Living In the Landscape (accessible via the following link: living-in-the-landscape-full-report - david.dean Flip PDF | AnyFlip. This is supported by their local Biodiversity Action Plan (accessible via the following link: thamesmead-biodiveristy-action-plan-2020.pdf (peabodygroup.org.uk). Issues of Concern to be addressed at Examination. Design Principles 10. Peabody notes the themes which will influence the design principles of the Project. Peabody is particularly concerned in respect of people and place, for the reasons set out in Cory’s consultation document. However, Peabody will want to be assured that the design of the Project, and the proposed mitigation, will fit in with their general environmental aspirations, and considers that ongoing discussion in this regard during the preparation of the application to the Planning Inspectorate, for the DCO, will be worthwhile. Land-based Infrastructure 11. In respect of the planning of the construction process, Peabody is concerned to limit the noise impacts and lorry movement impacts, on local people. We would like to input in relation to the proposed content of the Code of Construction Practice for the Project. Environmental Mitigation and Enhancement Opportunities 12. It is apparent that it is intended, as part of the Project, to use land owned by Peabody to deliver environmental mitigation for the Project. The land is in two blocks, one known as Norman Road Fields, which is being considered to provide replacement for the parts of Crossness Local Nature Reserve that will be taken (and lost to the Nature Reserve), and the other known as the Former Thamesmead Golf Course (“Golf Course”). 13. Norman Road Fields is let on grazing licences, to members of the local community. It is important that the graziers are consulted and considered by the Project. Peabody is concerned to ensure that the future of this use is maintained and will need to consider any Cory proposals in this regard. 14. The former Golf Course forms part of an ongoing project with the community to deliver the wider aspirations of Peabody to deliver ecological and social improvements for the area. It follows that the Golf Course is of particular value to Peabody and the local community. Any intervention that would prejudice the ability for the established goals for this project to be realised, will not be welcomed. Considerable further engagement will be necessary in this regard so that Cory is properly aware of this project and can accommodate it. Improving connectivity 15. Peabody would also wish for Cory to consider further measures to improve public access to the River Thames, as part of their overall proposals. 16. As a general principle, Peabody is supportive of the objectives advanced by Cory to improve local area connectivity by enhancing public rights of way. As noted, this forms a critical component of the Thamesmead Plan and Peabody will wish to consider Cory’s proposals in this regard. Other 17. Peabody notes the Preliminary Environmental Information Report (“PEIR”) provided within the consultation materials and as part of earlier consultation has already provided more detailed comments to be addressed by Cory. 18. Peabody has previously indicated its view to Cory, without prejudice to any potential agreement, that all land over which Cory may or may wish to exercise DCO powers including the former Golf Course, should be included in the red line boundary of the DCO and assessed within the project’s Environmental Statement. However, it is noted that Cory has not included the former Golf Course in the draft DCO red line boundary and that the outline Landscape Biodiversity Access and Delivery Strategy within the DCO application considers the former Golf Course area for off site BNG provision, presumably for Cory to get agreement with Peabody to carry out the required environmental mitigation on the Golf Course. 19. Without prejudice to any potential agreement, Peabody’s position is that any proposals in respect of the Peabody Land must be achieved without cost or loss to Peabody. This cost or loss will need to be based on an assessment in perpetuity, to protect Peabody from possible legacy liabilities in the long-term future. 20. Any proposed use of compulsory acquisition powers to secure rights over the Peabody Land, which is designated Metropolitan Open Land will be resisted. 21. The programme and timing for delivery of the works will be key and should address reprovision and relocation of existing uses and habitats prior to taking, or carrying out works to, land that may be required. Conclusion 22. Peabody considers itself a key stakeholder, as both a landowner and for the community, in this process, and expects to have an active and influencing role in the future stages of the application for the DCO, and in relation to the development proposed by the Project.