Since its submission at the start of March, the planning application for Project Exodus at Thorpe Park Resort has been progressing through the usual post-submission phase which includes statutory and non-statutory consultations, in order to help inform Runnymede Borough Council’s (RBC) decision on whether or not to approve the proposals. Following inaccurate recent reports that the application has been rejected, Attraction Source News takes a look at the application’s current status.
Often, as was the case for Project Exodus, the applicant (Thorpe Park) and its planning advisors (Lichfields) will hold preliminary discussions with key consultees in order to flag any key issues that should be addressed within the main application. Formal post-application consultation is then required of a number of different parties at local borough, county and national level. We have grouped together the consultations that have occurred to date by common theme.
In respect of the impact on noise levels, Cahill Design Consultants responded on behalf of Thorpe Park to technical queries raised by the RBC Environmental Health Manager, noting that Project Exodus will have an unlikely negative effect on the noise levels being emitted from the Resort, and that the noise levels from the PA system will not increase the overall noise coming from the area of the Resort where the rollercoaster is planned to be located. Furthermore, the RBC Conservation Officer noted that, after taking into account the regional importance of Thorpe Park and that recent developments at the former CEMEX site have taken account of existing noise levels from the theme park, they do not consider that the proposals would further harm the setting of the Thorpe conservation area or the nearby heritage assets. It therefore seems as though any potential concerns here have been satisfactorily addressed.
In connection with the potential transport impact of both the construction and operation of the rollercoaster, National Highways gave no objection, subject to the inclusion of a standard condition requiring a Construction Environment Management Plan (CEMP) to be submitted prior to the commencement of construction. The purpose of this is to outline arrangements such as construction traffic routes to the Resort, the areas for loading/unloading and storage, and the hours of construction and the associated traffic. SCC County Highway Authority also provided a consultation response to state that they were satisfied that the application would not have a material impact on the safety and operation of the adjoining public highway, and therefore had no highway requirements.
The requested CEMP was submitted at the end of April, and was the source of the plan which indicated that the Resort intend to facilitate access to the Logger’s Leap station building between August and November, seemingly to enable Creek Freak Massacre to open during this year’s Fright Nights. The CEMP was revised in May to include additional details requested by Surrey Wildlife Trust (see below), and to confirm that the contractors’ parking does not form any part of the existing staff car parking area, following a concern raised by the Surrey County Council (SCC) Transport Development Planning Officer. National Highways subsequently confirmed that the revised CEMP was satisfactory.
Due to the Resort’s close proximity to Heathrow Airport, Safeguard Heathrow Airport were another party consulted. They gave no safeguarding objections to the proposals, but highlighted that where a crane is required for construction, the operator may need to consult the aerodrome.
The Surrey Police Crime Prevention Design team were another party consulted. They noted that the proposed location has previously been identified as a weak point in the overall security of the Resort. Therefore, they recommended that:
- An appropriate boundary treatment needs to be considered to effectively deter trespass and potential antisocial and criminal behaviour often associated with unauthorised access from Monk’s Walk.
- CCTV and lighting need to be considered as integral to the overall scheme.
- The rollercoaster and associated buildings should have the ability to be reasonably secured against the risk of ‘urban explorers’.
Ensuring the boundary along Monk’s Walk was sufficiently secure was something which was acknowledged by the Resort during the public consultation phase, and therefore it already seems as though these recommendations have been incorporated into the development
Since the proposed development is within an area that has previously been subject to gravel extraction, the SCC Archaeology team responded to note that the probability that significant archaeological remains survive on the site is remote. Therefore, they deemed it very unlikely that significant archaeological remains will be present on the site and so confirmed that they have no archaeological concerns. Similarly, Historic England responded to say that, on the basis of the information provided, they do not consider it necessary for them to be notified any further.
In their initial response, the RBC Arboricultural Officer raised no objection, subject to the inclusion of standard conditions, namely the submission of a arboricultural method statement (AMS) and tree protection plan. They noted that the loss of the trees outlined in the plans will require substantial mitigation, but that this is provided for in the plans, with the planting of more than 50 individual heavy standard trees and the use of whip planting to create areas of native woodland and scrub. Following this response, Lichfields subsequently liaised with the council and Arboricultural Officer to highlight that a tree protection plan was included amongst the application documents, and pro-actively submitted an AMS at the end of April in order to reduce the number of conditions required. The Arboricultural Officer confirmed that this was acceptable, removing the need for the associated planning conditions.
Furthermore, the RBC Contaminated Land Officer gave no objection subject to the inclusion of standard conditions, namely the submission of an assessment of the nature and extent of any contamination, and then, if required, the submission and implementation of remediation scheme to remove any unacceptable contamination. Also, SCC Minerals and Waste responded with no objection subject to the standard condition that a Waste Management Plan is submitted prior to the commencement of construction.
In order to confirm compliance with all relevant policies, there was consultation by the council of their internal RBC Planning Policy team. Their response was that they only had limited comments to make, but noted that (i) Thorpe Park is located in the Green Belt but is a previously developed site, (ii) comments on the noise impacts should be sought from the council’s consultancy service (see above), and (iii) the council should confirm with Surrey Wildlife Trust that the Biodiversity Net Gain proposals are acceptable.
Upon being subsequently consulted, Surrey Wildlife Trust requested further details to substantiate the Biodiversity Net Gain proposals, in order to address the technical issues that they raised, as well as further information on the potential impacts, and proposed mitigation, on protected species (i.e. birds and bats) and habitats. Baker Consultants (ecology consultants) responded to the points raised at the end of May, either seeking to fully address them with the responses given, or outlining updates that would be made to other documents, such as the CEMP (see above). Based on the publicly available information, Surrey Wildlife Trust are yet to follow-up on this to clarify whether their responses have been adequately cleared.
However, Natural England objected on the basis that the application could have, what they saw as, potential significant effects on the South-West London Waterbodies SPA during the construction phase, and therefore required a Habitats Regulations Assessment (HRA) to be completed to address these concerns. They also requested clarity on the impacts of the temporary infilling of Abbey Lake. In their response at the end of May, Baker Consultants noted that it is Runnymede Borough Council that need to provide the HRA to Natural England. However, they would aid the council in doing this by preparing a ‘shadow HRA’ compiling relevant information from documents already prepared as part of the Project Exodus application. It appears as though this is ongoing.
The SCC Drainage team were satisfied that the proposed drainage scheme included with the application meets the requirements. They proposed standard conditions for detailed drainage design documents to be submitted ahead of the commencement of construction, as well as a verification report that the surface water drainage system has been constructed in line with this, prior to use. After originally recommending a condition to confirm a 1m unsaturated zone from the base of any proposed infiltration device to the seasonal high groundwater level, this was removed at the request of Lichfields and HBL Associates (the drainage consultants), since it was deemed unlikely to be achievable because the development site is in the flood plain.
The RBC Drainage Engineer advised that the Environment Agency should be consulted in respect of fluvial flood risk, but that they otherwise have no objections to the proposed drainage strategy.
It is the Environment Agency who have made what seems to be the most significant objection. In a letter from March, they outlined that they had no option but to object ‘in principle’ to the development in line with national planning policy, due to it being located within ‘Flood Zone 3b’. They also highlighted some concerns with the Flood Risk Assessment (FRA) submitted as part of the application.
Atkins, an environmental specialist engaged by Thorpe Park, responded to this letter on behalf of the Resort at the end of April. It was firstly noted that the design of the rollercoaster has followed a sequential approach by ensuring that the less vulnerable elements of the scheme are located outside of Flood Zone 3b, and that the rollercoaster’s support columns (which can be considered water compatible) are the only elements located within Flood Zone 3b.
Atkins also noted that it is their understanding that the Environment Agency cannot object on the grounds of the ‘sequential test’, only advise the Local Authority that they are not satisfied the test has been met, and therefore further investigation by them may be required. Reference was made to the prior agreement with Runnymede Borough Council that:
“I still consider that a degree of flexibility ought to be applied when considering new development at Thorpe Park. In my opinion it would be nonsensical for the Planning Authority to rigidly adopt PPS25’s parameters and preclude all future development at the theme park on the premise that as the development is not Essential Infrastructure or Water Compatible no development should therefore be permitted in Zone 3b. Such an approach would fail to take into account the site history and local circumstances and all other material planning considerations.” (Jonathan Partington in 2010).
This agreement is said to have been consistently applied for multiple applications that have been submitted since, given the site’s (i.e. Thorpe Park) history and unique nature.
Atkins did acknowledge that the Environment Agency can object in relation to Part 2 of the ‘Exception Test’, and so they sought clarification that the FRA submitted demonstrates that there will be no net increase in flood risk in comparison to the existing scenario, which is said to have been already acknowledged by the Environment Agency during a meeting in March 2022.
At the start of June, the Environment Agency responded with another letter, outlining three objections to the application. The first, and principle objection, is that the proposed development falls within a flood risk vulnerability category that is inappropriate to the Flood Zone in which the application site is located. It is noted that the only way Thorpe Park can overcome this principle objection is to demonstrate that the development is not within Flood Zone 3b. If this can be demonstrated there are then two further objections to be addressed. The first is that the submitted FRA does not comply with the requirements for site-specific flood risk, and therefore doesn’t adequately assess the flood risks posed. It is suggested that this can be overcome through the submission of a revised FRA that includes details of the floodplain compensation already provided for as part of the Medium Term Development Plan 2010-2016. The final objection is on the basis that the development would encroach on a watercourse and lake that has significant nature conservation value. This can potentially be overcome by the submission of an additional detailed assessment of the associated impacts.
Nonetheless, the Environment Agency conclude by noting that if Runnymede Borough Council are minded to approve the application contrary to their objection, the council should contact them to explain why material considerations outweigh their objection. This is to allow the Environment Agency to make further representations, and recommend the inclusion of condition(s) on any subsequent approval. It remains to be seen whether there will be any further dialogue with the Environment Agency to mitigate their concerns, or whether RBC will move forward with the application on the basis of the precedent set at the local level to show a degree of flexibility, as referred to above.
With the application not on the agenda for discussion at the next Planning Committee meeting on 22nd June 2022, it seems it will be at least another month before a decision is issued, with the next meeting scheduled for 13th July 2022. The timeline shared at the public consultation phase anticipated that a planning decision would be issued in late spring or summer 2022. Therefore, a more drawn out planning process was factored into the timeline, and there is nothing at this stage to suggest that a 2024 opening has become unachievable.
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