London’s first cruise terminal: tourism goldmine or dangerous polluter?

A proposal to build London’s first cruise terminal recently received approval, three years after being granted initial planning permission. While supporters hailed its exciting economic potential as a landmark borough development, residents and campaigners slammed the lack of any comprehensive environmental assessment amid fears that the terminal will prove a major source of pollution.


London cruise terminal

After six years on the drawing board, the UK capital's first cruise terminal seems to be floating again, now closer to completion than ever. The highly divisive project aims to redevelop Enderby Wharf in the Greenwich Peninsula into a first-class cruise ship destination, complete with residential housing and leisure facilities. It is hoped the port will firmly place Greenwich on the economic agenda and further afield, on the world's tourist map.

On 21 July, the project received unanimous backing from the Greenwich Planning Board, in spite of strong opposition from the area's residents and campaigners, who, among other aspects of the proposal, decry the lack of a robust environmental study to assess the future level of pollution cruise ships will emit at the heart of a dense residential area.

The project first appeared on the radar in March 2012, when approval was granted to redevelop part of the Peninsula into a cruise liner terminal, a hotel, a skills academy and 770 residential units.

Over time, the application has grown and grown: the current proposal envisions a new "fit for purpose" terminal which is approximately 81% larger than initially planned due to the addition of "turn-around facilities" on its site. Ships are expected to be hotelling at the terminal between 36 and 48 hours at a time.

The site, to be developed by Westcourt Real Estate, now includes over 770 residential units, landscaping and amenity space around Enderby House and a new access road into the site. Architects Ian Simpson and the Manser Practice both list the Enderby Wharf development within their portfolios.

Primed to open in 2017, the port would welcome between 50 and 60 medium-sized cruise ships every season, each up to 240m in length and with a capacity of between 1,200 and 2,000 passengers. As a result, supporters claim it would create up to 600 direct and indirect jobs and bring in between 40,000 and 90,000 tourists each year.

"The Greenwich Borough as a whole has a £1.1bn tourism economy, it supports 16,000 jobs locally and [the terminal] will only add to this and will bring many more people into Greenwich to visit the area," says Greenwich Councillor Miranda Williams. "That will increase our tourism spend and it will only boost the area for the better."



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Barrie Kelly, chief executive of Visit Greenwich says the destination management company has been working closely with the cruise trade for the past two years to ensure the area will absorb a big share of the upcoming tourism profit.

"We're working with our attractions to provide special exclusive access for cruise passengers. We're making the parts of Greenwich which are currently quite difficult to reach for the general tourists become open to the cruise trade, so by providing special access and special prices, at least 50% of spend will be in Greenwich," says Kelly.

"We do accept that the people will want to go to [central London], but they will see the quality of the offer around the Greenwich World Heritage Site, which is a marquee destination, so we are working very closely with the cruise trade and our partners to make sure we offer the kind of access they need for their clients."

But while an estimated construction cost is still lacking and the reported number of jobs created has fluctuated from anywhere between 100 and 600, critics fear that the project might have been sold to the public on false premises. Furthermore, the findings of a number of air quality assessments on predicted pollution levels have been slammed for their lack of hard evidence.

London City Cruise Port released a statement saying: "We welcome the resolution of the Royal Borough of Greenwich Planning Board to approve the Enderby Place planning application. The planning permission will allow us to drive forward our target programme for the development. We will communicate further information in due course."

"There is a general terror that our local council is using this massive brownfield site as a cash cow to score as much money out of developers as possible and turn it into a sky-scraper enclave," says Simon Edge, press officer for Greenwich Green Party. "This project will include nearly 500 homes and in this context, there is this baseline anxiety about congestion, overdevelopment and pollution."

Residential units in breach of density and affordable housing limits

The regeneration of Enderby Wharf will be built in two "distinct phases", according to the project's website. Although the cruise terminal will be constructed and delivered within the first phase, its costs will be covered by the surrounding residential units: "The majority of the new homes proposed are required to fund the new enlarged cruise terminal at Enderby Wharf," the website reads.

The final application states that 75 of these residential units, or 15%, will be provided as affordable housing, faring within the Code for Sustainable Homes (CfSH) Level 4 and BREEAM 'excellent' rating. However, this percentage is in breach of the Greenwich Council's affordable housing target, which is currently set at 35% of any new development.

"This project will include nearly 500 homes and in this context, there is this baseline anxiety about congestion, overdevelopment and pollution."

According to council's policy, developers will have to submit a viability report detailing why the target has not been met, which can be kept confidential. The revised application does mention however, that "a unit breakdown for the affordable element has not been provided and therefore officers are unable to determine the level of affordable housing at this stage".

Another issue is the density of the provided housing. The application admits the proposed density of units, of 818 habitable rooms per hectare (hrha), "significantly exceeds" the density range of 200 to 450 hrha recommended in the London Plan Density Matrix. (7.4.9)

Their justification is that the land represents "an identified opportunity area ... where densities should be optimised." Additionally, the document acknowledged that "the residential intensification of this part of the site is required to enable the delivery of the enlarged, fit for purpose terminal facility which has strategic policy support."

Fears of pollution spark heated debate

The Greenwich Society, East Greenwich Residents Association and Tower Hamlets residents have brought these issues forward, as well as highlighting mounting fears of air pollution. The threat spurred 117 letters of opposition and petitions from local residents, while only three letters signed by locals expressed support for the project.

"Amongst the people who have been following [the terminal's development] there is fury and disbelief, just shock at how contemptuously the council have just backed it anyway," says Edge.

The environmental assessments meant to assuage these fears are steeped in murky waters and have only fuelled the debate further.
The terminal's revised application, dated 21 July - the same day the project was granted approval at a lengthy Planning Board meeting - references a currently unavailable environmental statement from March 2015.

The document specifies that the environmental study failed to assess the air quality impact of the cruise terminal itself in its calculations, thus brushing past the largest source of pollution at the heart of the project.

"The assessment concludes that the development will be air quality neutral from a transport perspective. However, the assessment does not include the D1 use (skills academy) [nor] the cruise terminal use in the calculations." (7.4.21)



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The document also goes on to advise that "the applicant should include these uses in the air quality neutral calculations and resubmit these to the [Greater London Authority] GLA for further assessment." Pollution from the construction and operation phases of the project is classed as "negligible and therefore not significant".

"The applicant has assessed the potential air quality impact of the development which has been verified by independent experts on behalf of the GLA and it concluded that with mitigation, the air quality impacts from transport for the construction and operational phases of the development will be minor adverse to negligible and therefore not significant." (7.4.20)

A second air quality assessment undertaken by Royal HaskoningDHV for the Royal Borough of Greenwich published on 14 July looked at detailed air dispersion modelling to measure emissions from cruise liners hotelling at Enderby Wharf. According to a member of the Planning Board, himself and fellow members were simply given "a 'technical' briefing a week or so before the Planning Board meeting, which covered air quality and noise issues", while the Haskoning assessment was not made available to them prior to their decision.

Royal HaskoningDHV appears to have replaced the project's previous environmental consultant Aecom, who while listed as an environmental consultant on the Architects' Journal website, has not released any reports concerning the Enderby Wharf redevelopment.

Just how much do cruise ships emit?

Ralph Hardwick, campaigner against the cruise terminal, claims that the figures used in the assessment report are deeply flawed and based on outdated statistics. For its modelling, Haskoning considered emissions created by ships of 3.5MW electrical load, while cruise ships expected to moor into the terminal far exceed that figure, according to Hardwick.

"From my point of view, they definitely appear to have used an inadequate electrical load of the ships to conduct a proper assessment," he explains.

"If you look at 250m-long ships, they require 8MW of power. And something like the Queen Mary II requires 14MW of electrical power. So ships of the dimension that are supposedly going to moor up, based on the capacity of the terminal being built to take 2,000 passengers, we are certainly way beyond the figure of 3.5MW which Greenwich seems to have advised the consultants to use."
Furthermore, the report falls back on the Department for Environment, Food and Rural Affairs (DEFRA) statistics from 2001 in calculating its sulphur dioxide background concentration levels.

"Findings by a King's College report recently showed that almost 9,500 Londoners die prematurely each year from the combined effects of NO2 and PM2.5"

"The numbers they used in this report for this modelling may be completely inaccurate," Hardwick says. "At this point in time, most of the assessments have been made using DEFRA's Local Air Quality Management produced in 2009, which suggests that if a fuel of less than 1% sulphur content is used, then there is no need to carry out further tests. But this doesn't include nitrogen oxides, nitrogen dioxide or any particulates."

The lack of any definitive answer on the levels of NO2, and particulates PM2.5 and PM10 released into the atmosphere has proved particularly worrisome after findings by a King's College report recently showed that almost 9,500 Londoners die prematurely each year from the combined effects of NO2 and PM2.5. The study's breakdown by boroughs shows that in Greenwich, 7.6% of deaths were attributable to PM2.5 in 2010 and 12.7% attributable to NO2.

Will emissions be monitored?

The Evening Standard reported that the council will commit "£500k towards monitoring and improving air quality" in the area. Furthermore, under its sustainability proposal, the London City Cruise Port's website mentions the site will also include photovoltaic solar panels on the brow of the terminal and rain water harvesting facilities. Regarding NOx prevention, the website says that "by connecting to the district heating network, there will be little to no NOx emissions on site."

"The impact on air quality of any new development will be fully monitored and the approval at the Planning Board meeting last month will be committed to monitoring and improving air quality in the borough," says Councillor Williams.

"I am a resident of the borough, I'm a local councillor and I have to consider my residents' wellbeing. I would not have spoken at the Planning Board meeting in favour of this application if I did not believe the council had taken every step to look at the concerns in regards to air quality," she says.



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The borough certainly has a stake in ensuring emissions are kept within legislative boundaries. As Hardwick points out, under the Localism Act, boroughs can be held directly liable for fines imposed by the European Union if found to be in excess of recommended emission levels.

A letter from the GLA's air quality manager Elliot Treharne quotes the original environmental statement to say that "the potential effects on local air quality and the proposed land use are likely to be insignificant" and "no further assessment to SO2 emissions from cruise liners is considered to be required".

But a follow-up Enderby Wharf Cruise Terminal Assessment from 15 June by Royal HaskoningDHV concluded that "there needs to be a review of the accumulative effect from the vessel fume stack with the localised region around the terminal, particularly if the vessels are going to remain on the berth from early in the morning to the following day which could be up to 36 or 48 hours".

Shore-side Energy dismissed by consultants citing high costs

To alleviate pollution created by idling berthed ships, the use of shoreside energy (SSE) was taken into consideration. Shore-to-ship power, or cold ironing, is a cleaner energy system which enables ships to shut down their engines while berthed and plug into an onshore power source, considerably cutting down on emissions.

According to the 2015 'Potential for Shore Side Electricity in Europe' report by energy consultancy ECOFYS, "SSE offers the potential to mitigate 800,000 tons of CO2 emissions" and "the business case for SSE is most attractive for ships that have a high electricity demand per berthing" - namely cruise ships, the biggest power consumers amongst all vessel types.

The use of SSE, particularly for newly built terminals in residential areas, was made obligatory under 2014 EU legislation which supports the deployment of alternative fuel infrastructure. Article 4 of Directive 2014/94/EU "obliges member states to implement alternative infrastructure networks such as shoreside power technology by December 2025".

"SSE offers the potential to mitigate 800,000 tons of CO2 emissions."

Nevertheless, Haskoning dismissed the case for SSE at London's terminal, describing it as "not appropriate for this site", while reasoning that "it is unlikely that the huge investment in shore side power equipment can be justified," even as an overall cost of the project has not yet been released.

Additionally, the Haskoning study fails to mention that under the European Commission's TEN-T programme, the EU covers up to 50% of the costs of research and 20% of the costs of implementation whenever a member state opts for shore-side electricity supply at its inland ports.

Awaiting a decision

"I would like to be satisfied that we are not going to have something pumping massive amounts of diesel emissions very close to where people live," says Edge.

Various party members, local residents and members of the Greater London Assembly have written to the Mayor of London, urging him to either reconsider the terms of the project, or flatly refuse its construction. The Mayor's stage II decision is expected to arrive in early autumn.

Although another environmental assessment has not yet been announced, the project's application will soon be reviewed by the GLA, where Hardwick says the project could potentially be stopped and rejected.

In the meantime, Greenwich is also awaiting a new set of DEFRA guidelines on air quality management in the area which would require the borough to further comply with European legislation.

Given the city's worldwide status as a top tourist destination, the cruise terminal undoubtedly holds great potential for London. Once completed, a quick return on investment can almost be taken for granted, making it all the more surprising that developers should cut corners when building one of the future legacy sites adorning the capital.