EH RESPONSE TO CONSULTATION
REFERRAL FROM PLANNING:
DEVELOPMENT CONTROL
Planning Reference:
Planning Officer:
PP/13/04728
Steven Roberts
Environment Officer:
Telephone:
Email:
9 October 2013
Kyri Eleftheriou-Vaus
020 7341 5686
[email protected]
EH Acolaid Number
SRENE/: 13/139382
Application site address: Land South of Carlyle Building, Hortensia Road, London,
SW10 0QS
Pre-Application
Full Application
Informal Advice



Appeal
Notification

Planning brief
Policy


Date received
Date returned to planning officer :
Consultation deadline from
planning website:
Date(s) of discussion(s) with Planning officers
Environmental issue covered in this response :
Air Quality
X
Noise
Other (describe) such as
Licensed premises issues
Notification has also been
forwarded to (EH officer name)
Notification has also been
forwarded to (EH officer name)
Contaminated land
Date
Date
Other
For comments on:
(subject area)
For comments on:
(subject area)
Summary of application proposal
Construction of part 3, part 5 and part 7 storey residential building comprising 31
dwellings with commercial unit (Flexible A1,A2,B1 & D1 uses) at ground and basement
(435 sqm) with ancillary landscaping (Major Application)
Comments
The Proposed Development will comprise the following:
Basement housing plant space and commercial space (135 m2 GIA) Ground floor retail
unit for A1/A2/B1/D1 unit of 256 m2 GIA; and 31 residential units arranged over six
floors. The site is located on the corner of Hortensia Road and King’s Road. The site
comprises existing hard standing with no buildings currently on site. Therefore the
new development should seek to reduce emissions as currently there are none
associated with the site.
An air quality assessment has been provided; I have also made comments on the
energy statement in relation to its impact on air quality.
Energy Statement
It is proposed that the development will include a centralised energy centre to provide
heating and hot water to all residential units. This will house a 10 kWe (17kWth)
combined heat and power (CHP) unit to provide base load heating and electricity,
which will be supplemented by 3 x 250 kW low NOx boilers to provide additional
heating and hot water. In addition approximately 25m² of PV panels which will reduce
emissions by approximately 6%.
The Energy statement in calculating the CO2 savings from CHP provides the following
emission factors:
Carbon Factors (kgCO2/kWh)
Natural Gas
0.198
Electricity
0.517
Displaced Electricity 0.529
The carbon saving has been calculated as 8%. However more up to date reports e.g.
2012 Guidelines to Defra / DECC’s GHG Conversion Factors for Company Reporting)
gives the 2010 carbon dioxide rolling emissions (5 year average) as 0.491kg CO2/kWh
from grid electricity. This is considerably lower than the figure used for the displaced
electricity and will therefore result in a higher carbon saving figure being calculated.
Alternatively CO2 emissions reductions could be achieved by deploying greater
proportion of photo voltaic panels for electricity generation this would reduced both
CO2 and NOX emissions.
Boiler /Energy emissions
The NOx emissions of the boiler/plant provided in the air quality report is given as 39.7
mg/kWh (0% O2) for the low NOx Boilers and 45.5 mg/kWh (0% O2) for the Micro
Turbine CHP. However no annual emissions calculations are provided in the
document. This information was requested and the estimated emissions were
subsequently provided by Environ. Annual emissions were calculated as 118 kg of
NOx from the boilers and 101 kg of NOx from the CHP.
This was based on the assumption that two of the three boilers would operate for 12
hours per day and the CHP for 10 hours per day. This shows that the single CHP, whilst
operating for less time produces, almost the same emissions as the two much larger
boilers. Further supporting the use of more non combustion renewable technology
such as PV panels.
Transport
No parking is proposed and the site will be permit free, therefore the main source of
additional traffic will result from the servicing requirements of the commercial and
residential uses of the buildings. Overall this should not generate a significant number
of trips.
Conclusions
Ideally more of the energy provision should be made through low polluting options
such as PV panels rather than CHP, however as a minimum the AQ report should be
amended to include the updated emissions factors for the boiler and CHP plant and the
calculated annual emissions are included. In addition the following condition should
be set to ensure that the emissions are no higher than those stated in the assessment.
Prior to the occupation of the building and installation of the
boiler and plant, a certificate of the emissions for the equipment
being installed shall be submitted for approval and should not
exceed the emissions stated in the air quality assessment.
Requested
condition(s)
S.106
opportunities
Officer(s)
initials
KEV
Times spent (to nearest half hour)
Download

Consultee Responses