Cheers Peter and Sian!
________________________________
From: cambtrainwash-bounce@xxxxxxxxxxxxx <cambtrainwash-bounce@xxxxxxxxxxxxx>
on behalf of Priyananda Joseph <mail@xxxxxxxxxxxxxx>
Sent: Thursday, November 26, 2020 8:37:16 PM
To: Info Quashthetrainwash <info@xxxxxxxxxxxxxxxxxxxxx>;
cambtrainwash@xxxxxxxxxxxxx <cambtrainwash@xxxxxxxxxxxxx>; celiakenney@xxxxxxxx
<celiakenney@xxxxxxxx>; ediestuart@xxxxxxxxx <ediestuart@xxxxxxxxx>;
giumorse@xxxxxxxxxxx <giumorse@xxxxxxxxxxx>; philip.howell@xxxxxxxxxxxxxx
<philip.howell@xxxxxxxxxxxxxx>; Anne-Sophie Bretonnet <abretonn@xxxxxxxx>; Dave
Baigent <Dave.Baigent@xxxxxxxxxxxxxxxx>; Hannah Fromageau
<hannahfromageau@xxxxxxxxx>; Louis T Koehorst <ted@xxxxxxxxxxxxxx>; Martin
Kulander <martin.kulander@xxxxxxxxx>
Subject: [cambtrainwash] Re: Train wash: Draft response to be submitted morning
of Friday Nov 27
Hi Sean,
Thanks very much for this very clear and comprehensively argued letter.
Sian and I are very happy to add our names:
Dr Sian Stumbles
Peter Joseph
79 Great Eastern Street
Best wishes,
Sian and Peter
From: Info Quashthetrainwash <info@xxxxxxxxxxxxxxxxxxxxx>
Date: Thursday, 26 November 2020 at 18:20
To: "cambtrainwash@xxxxxxxxxxxxx" <cambtrainwash@xxxxxxxxxxxxx>,
"celiakenney@xxxxxxxx" <celiakenney@xxxxxxxx>, "ediestuart@xxxxxxxxx"
<ediestuart@xxxxxxxxx>, "giumorse@xxxxxxxxxxx" <giumorse@xxxxxxxxxxx>,
"philip.howell@xxxxxxxxxxxxxx" <philip.howell@xxxxxxxxxxxxxx>, Anne-Sophie
Bretonnet <abretonn@xxxxxxxx>, Dave Baigent <Dave.Baigent@xxxxxxxxxxxxxxxx>,
Hannah Fromageau <hannahfromageau@xxxxxxxxx>, Louis T Koehorst
<ted@xxxxxxxxxxxxxx>, Martin Kulander <martin.kulander@xxxxxxxxx>, Priyananda
Joseph <mail@xxxxxxxxxxxxxx>
Subject: Train wash: Draft response to be submitted morning of Friday Nov 27
Resent from: <mail@xxxxxxxxxxxxxx>
G'day all,
After the meeting with GTR last week and a final meeting with planners last
night, we've put together a draft response to the train wash planning
application. Please take a look and let me know what you think TONIGHT as I
will be tweaking it before posting it first thing in the morning.
Let me know if you want your name on it, noting that this will become part of a
publically available record. Send your first and last name and street name and
number. If you know others in the community who are not on this list but would
be interested, let them know but don't post it broadly, please.
Until anon, Sean
Response to 20/04395/PRI18A
Quash The Trainwash Community Organisation
Contact: Sean Rintel
(info@xxxxxxxxxxxxxxxxxxxxx<mailto:info@xxxxxxxxxxxxxxxxxxxxx>;
seanrintel@xxxxxxxxx<mailto:seanrintel@xxxxxxxxx>)
Dear Planning Committee members,
This application represents a significant agent of change to the amenity of the
Mill Road community. Quash The Trainwash (https://quashthetrainwash.org) is a
community organisation representing the residents of Great Eastern Street and
surrounding roads on both sides of the Mill Road Bridge. Collectively we wish
to object to the planning application in its current form and propose
conditions for its acceptance.
This document begins with the proposed conditions in summary form, then covers
the background to the community response, the needs for these conditions, and a
comment on the stress of construction.
1.
2. Summary
3. of proposed conditions
1.
1.
2. Visual mitigation:
3.
4.
*
* Visual mitigation of the
* enclosures: To align with the surrounding built environment, rather
than a single colour metal or plastic enclosure, both the carriage wash
enclosure and the plant enclosure should be rendered with brick or
brick--effect façades and a dark grey roof colour.
*
*
* Visual mitigation of acoustic
* fencing or other physical noise attenuation materials: Physical noise
attention material colours should be dark green or dark brown, to align with
the colours of gardens and trees.
*
1.
1.
3. Noise mitigation:
1.
5.
*
* Maximum physical noise attenuation
c. of the enclosure:
*
e.
*
* Maximum physical acoustic
iii. attenuation materials to be used throughout the enclosure’s walls and
roof, with special attention paid to areas around active machinery, sprays,
brushes, and water pumps and pipes.
*
*
* Doors to be fitted to the
vii. enclosure entrance and exit to maximise acoustic dampening, or if doors
can not be fitted then the entrance and exit designed to maximise acoustic
attenuation.
*
*
*
* Maximum physical noise attenuation
i. at the entrance and exit of the enclosure
*
k.
*
* Acoustic fencing to be placed
* on both sides of the enclosure’s entrance and exit. Section 53 of
the proposal says that provision will be made for this on the South end if
testing shows it to be necessary and that the plant will provide this on the
north end. We believe that this fencing
iii. should be built pro-actively now rather than waiting for a test, and
should be increased in length to maximise noise attention on all sides.
*
*
*
* Maximum physical noise attenuation
o. along the length of the sidings
*
q.
*
* Acoustic fencing, trees
ii. and other organic landscaping, or other measures to be placed on both sides
of the sidings, extending from the north end of Cavendish Place to the north
end of Rustat Avenue.
*
iv.
*
* If living trees and other
* organic landscaping are to be used, these should be accompanied
by a condition for lifetime maintenance, and if they must be removed for any
reason then they must be replaced by equal or better other physical noise
attenuation
*
*
*
*
* A publicly-available post-construction
u. pre-commissioning independent noise assessment prior to the
start of operations confirming that, from the north end of Cavendish Place to
the north end of Rustat Avenue:
*
w.
*
* noise levels during operation
ii. are contained below a maximum of 44dB (as noted in Section 48)
*
*
* average background noise
vi. levels are contained below a maximum of 40dB
*
*
*
* Publicly-available independent
aa. noise assessment at least once per year, confirming that, from
the north end of Cavendish Place to the north end of Rustat Avenue:
*
cc.
*
* noise levels during operation
ii. do not rise over time over the maximum of 44dB (as noted in Section 48)
*
*
* average background noise
vi. levels are contained below a maximum of 40dB
*
*
1.
1.
2. Vibration monitoring and
5. mitigation:
1.
7.
*
* A publicly-available vibration
c. assessment of the houses on the odd side of Great Eastern
Street as soon as possible to determine current vibration levels
*
*
* A publicly-available post-construction
g. pre-commissioning vibration assessment of the houses on the odd
side of Great Eastern Street to determine if vibration levels are significantly
different and potentially damaging to foundations, walls, and health of
residents
*
1.
1.
5. Hours of operation
1.
7.
*
* Carriage wash operations
c. should be limited to Monday – Friday, with a maximum of 2
trains per hour.
*
*
* Carriage wash operation
g. should be confined to a maximum of 2 trains per hour.
*
1.
2. Background
We draw the attention of the Committee the following background points.
2.1 Timing of and need for this application
That this application has come before the Committee at all is the result of
significant effort and expense of residents in the face of the rail
organizations’ attempt to extend their considerable powers and immunities
beyond what is reasonable for communities and LPAs to bear.
GTR and partners only began holding community meetings about the carriage wash
itself after a small number of residents caught wind of the larger project and
held a meeting with the railway organisations in the Rustat Road construction
blocks on 4th December 2019. This lead to a wider meeting to communicate what
was going on to community on 16 January 2020 (per
https://www.cambridgeraildepotupgrade.co.uk/wp-content/uploads/2020/02/Cambridge-Sidings-Presentation-January-2020.pdf).
Most of the community only learned about the development at this meeting, at
which the carriage wash development was presented as a fait accompli.
This is despite the significant controversy over the Mill Road Bridge closure
in 2018. There were two relevant planning approvals in that year, neither of
which addressed the scale of the industrial facility to be built.
18/1372/CAP18: 18/1372/CAP18 confines itself to the alterations to the Mill
Road Bridge – enlarging the arches and adding a set of steps. It notes in the
title that one of the reasons is “to facilitate new sidings”. The application
does not provide a comprehensive plan for the industrial scale carriage wash
facility. In the letter dated 15 August 2018 from Steve Taylor to Planning
Services at the Cambridge City Council, the proposed carriage wash is mentioned
twice in Schedule 1 as the reason for the need for the alterations, but no
further details are provided in writing or in the drawings and photographs in
Schedule 2. This detail would have provided context for that application which
might have impacted the LPA’s decision based on injury to the amenity of the
neighbourhood, a critical part of the GDPO 2015.
18/5161PREAPP: 18/5161PREAPP is a notice of the development, with much the same
planning material — or lack thereof — included in 18/1372/CAP18. 18/5161PREAPP
proposes that the carriage wash falls under Schedule 2 Part 8 Class A of the
GDPO 2015.This application relies entirely on the first class about permitted
development, which we excerpt below:
“A. Development by railway undertakers on their operational land, required in
connection with the movement of traffic by rail.”
This application does not address the section immediately after the above,
development not permitted, which we excerpt below:
“A.1 (c)(i) “the construction or erection otherwise than wholly within a
railway station of – (i) …a building used for an industrial process…”.
The GDPO defines an industrial process as “a process for or incidental to any
of the following purposes … (b) the altering, repairing, maintaining,
ornamenting, finishing, cleaning, washing, packing, canning, adapting for sale,
breaking up or demolition of any article or vessel….”
On 06 March 2020, Chris Penn forwarded Network Rail’s response to the issues
above. This included: “As the proposed carriage wash is for the cleaning of
trains within a railway depot, it is not considered that this represents an
‘industrial process’ and therefore does not meet the definition.“
Network Rail’s own description would appear to meet the definition of an
industrial process. To argue otherwise defies logic.
Further, in the current application (20/)4395/PRI18A, which purports to be an
application only for enclosures for carriage wash machinery and plant
machinery, we draw the Committee’s attention to Section 20 and 21, which
establish the interdependence of the enclosures and the industrial operations:
20. Of the CWM works, only the enclosure/covering of the CWM requires prior
approval as comprising a “building” namely, a structure. The CWM Plant Room
works amount to plant or machinery, namely, the CWM Plant and its housing. The
housing is not designed to accommodate operations or occupation carried on by
persons. The CWM to be mounted either side of the new north/south connection
road is also plant and/or machinery.
21. The requirement for the CWM is for a covered installation which is common
industry practice and is selected for the Cambridge Depot site for reasons that
include:
a. The CWM employs a water reclaim system which will recycle circa 60% of the
water used on each wash. Run-off from the trains within the CWM is captured on
the wash apron and directed into a series of underground valve chambers and
settling tanks. This
system is designed to discharge the minimal amount possible to the foul sewer
in order to comply with the existing trade effluent discharge consent. There is
an overflow as part of the system, where if the storage tanks fill, any
additional water will be routed to the foul discharge. Without an enclosure,
rainwater will be captured by the wash aprons and fill the system. This will
then be directed into the overflow and potentially exceed the Depot's discharge
consent;
b. An enclosure will protect the plant and machinery equipment (comprising the
CWM) within, improving its longevity, and reducing maintenance requirements;
c. An enclosure will also provide noise attenuation from the CWM and the
physical contact from the brushes on the train;
d. An enclosure will naturally provide additional protection from any overspray
associated with train washing.
The community understands the complexity of the planning law in this area, but
our position is that the trainwash planning application should have included
both the plant and the enclosure.
2.2 Location of the facility
Given the above, an industrial facility should not be built in a residential
area that is itself in the middle of a conservation area. More appropriate land
at Cambridge North was previously available, but was sold and no explanation
for this apparent error has ever been provided to the community. The closest
that community has come to an explanation is that, on 22 July 2020, Daniel
Zeichner, MP for Cambridge, passed along a letter from Ellie Burrows, Network
Rail’s Route Director for the Anglia Region (full letter available at
https://quashthetrainwash.org/who-is-a-key-stakeholder/).
We call the Committee’s attention to the following two paragraphs:
“I understand that residents would have liked this facility to be located at
Cambridge North (also referred to as Chesterton Sidings). We highlighted this
land for potential commercial development in early 2010, and while some of this
land was used for the construction of the new station, the remainder was sold
to raise funds for enhancements elsewhere on our network in early 2016.
The decision to construct a carriage wash at Cambridge depot was made after
this land was sold. For land to be sold, we have to apply for and be granted
land disposal consent from the Office of Rail and Road (ORR). As part of this
process key stakeholders including GTR, GA and the DfT were consulted and no
objections were raised to this sale.”
Network Rail’s definition of key stakeholders here includes only railway
organisations, not the community and not the LPA. This is an appalling
oversight. “No objections were raised” because no-one who would be materially
affected was asked. This demonstrates the lack of interest that the rail
organisations have for the well-being of communities, the belief that their
power is absolute, and a material intention to side-step genuine planning
processes.
Sections 23-25 make an argument that various other locations would not be
suitable for various reasons. Cambridge North, in particular, is claimed to not
be suitable because it “lacks the resilience required, is less efficient and
risks an ability to meet timetabling requirements due to the additional
distance to be travelled at the end of service and the number of additional
movements required to accommodate the maintenance and cleaning requirements for
such rolling stock. Cambridge North also currently lacks sufficient platform
space and would necessitate significant Network Rail infrastructure
improvements that are not included in the 5-year rolling plan.”
These objections are failures of planning. Cambridge North was a brand new
development that could easily have accommodated this facility without the level
of train movements required to overcome the ‘pinch point’ problem created by
the Mill Road bridge at Cambridge.
Further arguments about the impossibility of other locations are based on the
fact that trains would have to move. This seems disingenuous given that this is
the function of trains and, indeed, that trains from around the region will
have to move to this station to be cleaned. If they can move to Cambridge, they
could move somewhere else that is more suitable.
The community’s position is that it should have been formally consulted from at
least 2018, although more properly from before the development of Cambridge
North to understand its place in the larger Anglia rail network, to determine
whether and how this facility should be situated at the Cambridge depot.
2.3 Setting a precedent for formal community consultation and fairness in
railway planning
The community began organised action after 16 January 2020, when it became
clear that we were being told to accept the development, not asked about, not
explained how it fit or did not fit into this area or other sites that had been
considered. This action cost the community significant time and money
organizing offline and online action, including rallies, media attention, a
website, twitter feeds etc. (all of which can be seen at
https://quashthetrainwash.org).
The community has also raised and spent £7353 in legal fees to establish our
democratic right to a formal consultative process
(https://www.crowdjustice.com/case/quashthetrainwash/). We are fortunate to
have had the means and reach to do so, but many other communities -- including
many within the LPA’s area of influence -- may not have been able to do so. As
such, our objection in this case is not merely that of local resident NIMBY’s
(“Not In Our BackYard”) but rather a community seeking to establish a precedent
that we should have a say in the effective planning of our neighbourhoods.
The railway organisations are opposed to such a precedent being established.
Again, per the email of 06 March 2020, in which Chris Penn forwarded Network
Rail’s response:
“The precedent of applying for a Certificate of Lawful Development
If Network Rail were to apply for a CLD for all work that is permitted
development, or even a small proportion of work, it would result in significant
additional cost, delay to projects and need for significant additional
resource. Furthermore, it also sets a precedent whereby CLD applications may be
requested by other Local Authorities. This is not something that Network Rail
can commit to.”
The community believes that the LPA, and the UK public as a whole, should want
such a precedent set when an industrial facility is being situated in a
residential area. It is very clear that the law has not moved with the times.
We believe that the burden should be on developers to demonstrate the
decision-making process and the effect of the development on the community. The
community should not have to wait until a facility is developed to find out its
effects.
As things stand now, we are being asked, two years later and after considerable
effort (see below) to respond only to the development of two enclosures,
without regard to a significant step change in railway activity that this
development will have.
This reflects a deeper problem of serious inequities in the UK’s train planning
system, which leaves already embattled communities struggling with development
decisions taken without their consent, consultation, or recourse to appeal.
Taking away people’s rights to be involved in decisions that fundamentally
affect their lives undermines local communities and the sense of place and
identity that bind people together.
We are not alone in this kind of action. Residents in Scarborough and
Wednesbury/Bescot have also had to take action (see links to media reports at
https://quashthetrainwash.org/fairness/).
Everyone else in the UK has to apply for more planning permission than the
railways. The railways rely on two laws:
The Railways Clauses Consolidation Act 1845 (RCC Act 1845), Section 16 of which
enables railway companies “erect and construct such houses, warehouses,
offices, and other buildings, yards, stations, wharfs, engines, machinery,
apparatus and other works and conveniences as they think proper” without
requiring planning.
The Town and Country Planning (General Permitted Development) Order 2015, which
specifies development that allowed with or without planning permission. Part 8
(Transport Related Development) and Part 18 (Miscellaneous Development; Class A
– development under local or private Acts or Order) relates to “A. Development
by railway undertakers on their operational land, required in connection with
the movement of traffic by rail.”
The set of things for which development is not permitted is the problem. It
fails to provide clarity on where it is and is not appropriate to build
facilities with respect to residential areas. It does not place a burden on the
railways to demonstrate their choice of siting facilities to Local Planning
Authorities.
The railways do have sites that propose to make long-term planning (LTPP) more
transparent, such as the Network Rail Long-Term Planning site, but this
development is startlingly opaque. The planning page for the Eastern region
Anglia route does not mention the current development
(https://www.networkrail.co.uk/running-the-railway/our-routes/anglia). The
Anglia Route Strategic Plan document from 18 January 2018 does not mention this
proposed carriage wash facility, or any other, or even the words “wash” or
“clean”
(https://quashthetrainwash.org/wp-content/uploads/2020/03/Anglia-Route-Strategic-Plan.pdf).
Given that permitted development submissions were being made just months after
these documents, and that we are only now in a consultative process, the
railway organisations appear to want to claim a blanket right for all
development instead of exploring when it would and would not be a reasonable
burden. Residential areas should require this burden from the railways.
2.4 A step change in railway activity
At the heart of Network Rail’s proposal is the notion that this area has always
been a railway depot, with activities very similar to those that the proposed
enclosures will be part of. However, the proposal also states, in Section 9,
that “The depot and stabling upgrade works at Cambridge is a strategic
component of the wider Thameslink programme, and will support timetabled
services and new fleets for both GTR and GA.”
The community asserts that this is not a minor change in the normal life of the
railway and of surrounding streets. It will necessarily bring with it a new
level of continuous noise, as 12-carriage trains are intended to arrive on a
continuous basis from across the region. In a 18 November 2020 meeting with GTR
and partners, the following slide shows the significant amount of industrial
operations that will be occurring 24/7/365, with most operations occurring in
anti-social hours.
[https://lh5.googleusercontent.com/65RAITwN19KkCVXA2TD1dOpcottybHk0GCwIzN8RSuuCtgIPi3vjKVfPbpCiVMnQ6AP6xTn9rnGTZZxuqongisq8BsttyK-W3lwqCy9iwRSL5fvTv5CTIntUDOmPq70eQyXSG2zA]
Residents who live near the railway accept that train movements make noise. We
have always lived with that reality. The trainwash represents a major, planned
increase in continuous noise and this is not acceptable without significant
mitigation.
2.5 A potential blight on the area
The carriage wash enclosure and plant, car park, and other elements of this
facility will be extremely obvious to anyone on the Mill Road bridge, and
residents on either side. The carriage wash machine enclosure will be 8.5
meters high and 34 meters long (Section 41), which is as high or higher than
some houses on Great Eastern Street, and as wide as some terrace sections. It
is clear that it will become a landmark in the area, and unlikely to be a
positive one unless it is visually appealing or at least in keeping with the
surrounding built environment.
The community notes that Section 43 and 44 of the proposal relate community
consultation on height and shade lead to a change from a mono-pitched to gable
roof design, and that the CWM ENCLOSURE DESIGN COMPARISON & SHADE MODELLING
document shows a reduction in height to 8.5 meters. We acknowledge that this
was a positive step by the railway companies, although we also note that it was
only achieved after considerable effort and outside of a formal planning
process which would have considered the facility more holistically.
Even with this change, such an obvious set of structures and their consistent
use will clearly mark the area as industrial. While the area has historically
been industrial, like many areas in Cambridge it is undergoing a revival. Areas
and communities change. Indeed, the Ironworks development opposite the sidings
is a positive upgrade from the prior industrial facility on that site. This
carriage wash facility has the potential to retard this revival, both in terms
of property values and home ownership. There are already reports by residents
selling houses in the area that concerns about the carriage wash facility are
increasing the number of showings necessary to find a buyer, and decreasing the
sale value of properties.
3. Conditions to mitigate the significant agent of change
We object to the trainwash application because we believe that it is an
industrial process that had it been on city rather than railway land, would
likely have been rejected on the grounds of loss of amenity, unsightliness and
unacceptable noise impacts, day and night, on residents. As such, we propose
the following mitigation measures such that the community does not bear the
undue burden of significantly scaled up railway operations.
3.1 Visual appearance
This facility is being built in the centre of the Mill Road Conservation area.
It will be in the direct line of sight of all residents on the odd side of Mill
Road, Ironworks residents, and anyone crossing the Mill Road Bridge, as well as
others. As such, the enclosures and other physical structures should align with
the look of the surrounding built and natural environment. As such, we propose:
Visual mitigation of the enclosures
1.
2. To align with the surrounding
3. built environment, rather than a single colour metal or plastic
enclosure, both the carriage wash enclosure and the plant enclosure should be
rendered with brick or brick--effect façades and a dark grey roof colour.
4.
Visual mitigation of acoustic fencing or other physical noise attenuation
materials
1.
2. Physical noise attention
3. material colours should be dark green or dark brown, to align with the
colours of gardens and trees.
4.
3.2 Noise mitigation
Continuous noise and vibration are the biggest community concerns, and these
were not sufficiently addressed through the railway organisation’s consultation
processes until residents pushed for planning approval and the public release
of an independent noise assessment.
We draw the Committee’s attention to the PDFs of presentations from the railway
organisations on 16 January 2020, 24 February 2020, and 13 May 2020, all of
which report noise of circa 40dB. The community requested evidence for this
figure throughout the year. However, even when this proposal was submitted, the
proposal originally only included a summary of the report
(F535-GTR-ERP-MD-000010_01). The F535-GTR-ERP-MD-000010_01 report itself was
only made available on 10 November 2020, but is dated 08 January 2020. The
community even asked repeated for this report but it was never made available.
The report is based on limited modelling of a different form of facility in a
very different area. No identical carriage wash facility was available for
empirical verification, and no evidence was provided that the surrounding area
was similar to the residential area around the Cambridge sidings. The use of
hypothetical modelling in this case is contentious, to say the least.
Turning to the modelling, Section 48 claims that there is a background noise
level of 38dB and that the carriage wash facility in operation would raise the
noise level to around 44dB , above the 5dB threshold that requires significant
effort to attenuate. The modelling does not specify anything about the
cumulative effect of 24/7/365 noise or the perceptual difference of noises at
night compared to day.
The community is concerned that the proposal downplays the effect of noise (the
measure is considered “conservative”) and the; proposes notes that acoustic
fencing next to the entrance of the carriage wash and other areas will only be
erected if a noise assessment after construction shows it to be absolutely
necessary (Section 53). However, residents are already experiencing significant
similar noise from construction and interior train cleaning, causing
sleeplessness, stress, and anxiety.
As such, the community believes the precautionary principle should apply and
urges that maximum pro-active physical noise mitigation measures be pursued
during this construction rather than having to restart noisy construction
post-completion. As such, we propose:
Maximum physical noise attenuation of the enclosure:
1.
2. Maximum physical acoustic
3. attenuation materials to be used throughout the enclosure’s walls and
roof, with special attention paid to areas around active machinery, sprays,
brushes, and water pumps and pipes.
4.
5.
6. Doors to be fitted to the
7. enclosure entrance and exit to maximise acoustic dampening, or if doors
can not be fitted then the entrance and exit designed to maximise acoustic
attenuation.
8.
Maximum physical noise attenuation at the entrance and exit of the enclosure
1.
2. Acoustic fencing to be
3. placed on both sides of the enclosure’s entrance and exit. Section 53 of
the proposal says that provision will be made for this on the South end if
testing shows it to be necessary and that the plant will provide this on the
north end. We believe that this
4. fencing should be built pro-actively now rather than waiting for a test,
and should be increased in length to maximise noise attention on all sides.
5.
Maximum physical noise attenuation along the length of the sidings.
1.
2. Acoustic fencing, trees
4. and other organic landscaping, or other measures to be placed on
both sides of the sidings, extending from the north end of Cavendish Place to
the north end of Rustat Avenue.
1.
6.
*
* If living trees and other
c. organic landscaping are to be used, these should be accompanied
by a condition for lifetime maintenance, and if they must be removed for any
reason then they must be replaced by equal or better other physical noise
attenuation
*
1.
A publicly-available post-construction pre-commissioning independent noise and
vibration assessment prior to the start of operations confirming that, from the
north end of Cavendish Place to the north end of Rustat Avenue:
1.
2. noise levels during operation
3. are contained below a maximum of 44dB
4.
5.
6. average background noise
7. levels are contained below a maximum of 40dB
8.
Publicly-available independent noise assessment at least once per year,
confirming that, from the north end of Cavendish Place to the north end of
Rustat Avenue:
1.
2. noise levels during operation
3. are contained below a maximum of 44dB
4.
5.
6. average background noise
7. levels are contained below a maximum of 40dB
8.
3.3 Vibration monitoring and mitigation
Section 39 on the proposal makes the claim that vibration will not affect
residents, but this has not been verified against current conditions. The
Victorian terrace houses on Great Eastern Street have very shallow foundations
and old brick walls. As such, we propose:
Vibration monitoring and mitigation:
1.
2. A publicly-available vibration
3. assessment of the houses on the odd side of Great Eastern Street as soon
as possible to determine current vibration levels.
4.
5.
6. A publicly-available post-construction
7. pre-commissioning vibration assessment of the houses on the odd side of
Great Eastern Street to determine if vibration levels are significantly
different and potentially damaging to foundations, walls, and health of
residents.
8.
3.4 Hours of operation
As noted above in Section 2.5, and repeated here, the community asserts that
this is not a minor change in the normal life of the railway and of surrounding
streets. It will necessarily bring with it a new level of continuous noise, as
12-carriage trains are intended to arrive on a continuous basis from across the
region. In a 18 November 2020 meeting with GTR and partners, the following
slide shows the significant amount of industrial operations that will be
occurring 24/7/365, with most operations occurring in anti-social hours.
[https://lh5.googleusercontent.com/65RAITwN19KkCVXA2TD1dOpcottybHk0GCwIzN8RSuuCtgIPi3vjKVfPbpCiVMnQ6AP6xTn9rnGTZZxuqongisq8BsttyK-W3lwqCy9iwRSL5fvTv5CTIntUDOmPq70eQyXSG2zA]
The railway organisations have put considerable effort into detailing the
reasons why they believe that this is the only viable manner in which to
operate the facility to take advantage of train downtime. However, nights and
weekends are also residents’ downtime. This proposal implies that there is
simply no other way to operate the facility, when that is clearly not the case.
This is a matter of choice for the railway organisations. The community
deserves at least some time free of noise and vibration, even if it will never
escape the visual appearance of the facility. As such, we propose:
Hours of operation
1.
2. Carriage wash operations
3. should be limited to Monday – Friday.
4.
5.
6. Carriage wash operation
7. should be confined to a maximum of 2 trains per hour.
8.
4. Stress of construction
While recognising that construction is not itself part of the planning process,
the community wishes to draw the Committee’s attention to the fact that the
community has been suffering through frequent 7 day a week construction from
both the depot upgrade and the Ironworks facilities for the last year. This has
been exacerbated by the requirement to work from home due to the COVID-19
pandemic.
The community has had no respite from noise and vibration for months, causing
significant stress and anxiety, and in some claims, damage to houses from
vibration. There have been several extreme indicidents, such as the overnight
piling work on 12 July 2020 and similar work on 19 July 2020. These can all be
seen on the community Twitter feed at https://twitter.com/quashtrainwash.
It is difficult for the community to judge how different the noise and
vibration of the carriage wash operations will be from the noise of
construction, but given the 24/7/365 operations proposed by the railway
organisations, our concern is that this is in fact a taste of life to come for
the future of Great Eastern Street and surrounding community.
5. Conclusion
The community and the LPA have been placed in a bind by this proposal. An
industrial facility does not belong in a residential area that is itself in the
middle of a conservation area. Ideally such a development should occur in a
more suitable location along the line in a clearly industrial area. But we are
advised that this is impossible to accommodate. If we argue against the
enclosures as being out of place in a residential area, we lose noise attention
and visual mitigation, which are clearly in our interest if we must accept this
development. No community and no LPA should be placed in this situation, and
hard questions must be raised for the railway organisations as to why the
Anglia Region rail planning did not plan for a more suitable option.
Signed
The Quash The Trainwash community organisation.
{SIGNATORIES}
