THAMES GATEWAY Waste to Energy Limited Proposed energy generation facility at London Sustainable Industries Park, Choats Road, Dagenham, Essex, RM9 6LF Environmental Statement December 2013 Thames Gateway Waste to Energy Ltd 21 Arlington Street, London SW1A 1RN Contents 1 Introduction .................................................................................... 1 1.1 Layout and purpose of this document .................................................... 1 1.2 The applicant ..................................................................................... 1 2 The proposals .................................................................................. 2 2.1 The proposed development .................................................................. 2 2.2 Site location and surroundings .............................................................. 2 2.3 The extant consent ............................................................................. 4 2.4 The Environmental Statement and the environmental impact assessment process.............................................................................................. 4 2.5 The requirement for environmental impact assessment ........................... 6 2.6 Scoping ............................................................................................. 7 2.7 The purpose, content and structure of this report ................................... 8 3 Detailed development description .................................................. 10 3.1 Key elements of the proposed development .......................................... 10 3.2 Site access and circulation .................................................................. 11 3.3 Hours of operation ............................................................................. 12 3.4 Staffing ............................................................................................ 12 3.5 Security ............................................................................................ 12 3.6 Lighting ............................................................................................ 13 3.7 Technology overview .......................................................................... 13 3.8 Operational control and regulation of the proposed development ............. 19 3.9 Construction...................................................................................... 21 4 Policy analysis ............................................................................... 23 4.1 Introduction ...................................................................................... 23 4.2 European policy and legislation ............................................................ 23 4.3 National policy and strategy ................................................................ 26 4.4 Regional and local policy ..................................................................... 34 4.5 Issue-specific policy analysis ............................................................... 59 5 Land use ........................................................................................ 65 5.1 Introduction ...................................................................................... 65 5.2 Context ............................................................................................ 65 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park i 5.3 East London Waste Authority projected arisings and apportionment ......... 66 5.4 Existing and proposed facilities in the ELWA area ................................... 68 5.5 Mayor’s Business Waste Strategy for London ......................................... 71 5.6 Conclusion ........................................................................................ 74 6 Air quality ...................................................................................... 75 6.1 Introduction ...................................................................................... 75 6.2 Assessment criteria ............................................................................ 75 6.3 Existing conditions ............................................................................. 77 6.4 Assessment of impact ......................................................................... 78 6.5 Mitigation measures and residual impacts ............................................. 99 6.6 Conclusion ...................................................................................... 100 7 Noise and vibration ...................................................................... 101 7.1 Introduction .................................................................................... 101 7.2 Existing conditions ........................................................................... 101 7.3 Assessment of impacts ..................................................................... 102 7.4 Mitigation measures ......................................................................... 108 7.5 Conclusion ...................................................................................... 109 8 Visual impact ............................................................................... 110 8.1 Introduction .................................................................................... 110 8.2 Existing conditions ........................................................................... 110 8.3 Assessment of impacts ..................................................................... 116 8.4 Mitigation measures ......................................................................... 121 8.5 Conclusion ...................................................................................... 122 9 Ecology, nature conservation and biodiversity ............................. 124 9.1 Introduction .................................................................................... 124 9.2 Existing conditions ........................................................................... 124 9.3 Assessment of impacts ..................................................................... 125 9.4 Mitigation measures ......................................................................... 126 9.5 Conclusion ...................................................................................... 127 10 Transport and access ................................................................... 128 10.1 Introduction .................................................................................... 128 10.2 Existing conditions ........................................................................... 128 10.3 Assessment of impacts ..................................................................... 129 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park ii 10.4 Mitigation measures ......................................................................... 135 10.5 Conclusion ...................................................................................... 136 11 Geology, ground conditions and land quality ............................... 137 11.1 Introduction .................................................................................... 137 11.2 Existing conditions ........................................................................... 138 11.3 Assessment of impacts ..................................................................... 140 11.4 Mitigation measures ......................................................................... 148 11.5 Conclusion ...................................................................................... 150 12 Water resources .......................................................................... 151 12.1 Introduction .................................................................................... 151 12.2 Existing conditions ........................................................................... 152 12.3 Assessment of impacts ..................................................................... 152 12.4 Mitigation measures ......................................................................... 154 12.5 Conclusion ...................................................................................... 156 13 Energy and sustainability ............................................................. 157 13.1 Introduction .................................................................................... 157 13.2 Existing conditions ........................................................................... 157 13.3 Assessment of impacts ..................................................................... 157 13.4 Mitigation measures ......................................................................... 159 13.5 Conclusion ...................................................................................... 159 14 Socio-economic and health .......................................................... 160 14.1 Introduction .................................................................................... 160 14.2 Existing conditions ........................................................................... 160 14.3 Assessment of impacts ..................................................................... 163 14.4 Mitigation measures ......................................................................... 166 14.5 Conclusion ...................................................................................... 166 15 Conclusion ................................................................................... 167 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park iii Tables Table 1: London Plan projected waste arisings at key milestones ................... 66 Table 2: London Plan apportionment of waste to be managed by ELWA boroughs ........................................................................................................ 66 Table 3: Summary of average capacity surplus/deficit within the ELWA boroughs required to meet the London Plan apportionment ................................... 68 Table 4: Recovery facilities given in Schedule 1 of the joint waste DPD ........... 70 Table 5: Projected commercial and industrial waste infrastructure capacity gap 72 Table 6: IAQM dust risk assessment methodology ........................................ 78 Table 7: Receptor locations ....................................................................... 81 Table 8: Ecological receptors (vegetation and ecosystems) ........................... 83 Table 9: Maximum predicted (process contribution) annual average and 99.8th percentile of hourly average concentrations of nitrogen dioxide (µg m-3) ... 84 Table 10: Predicted annual average concentrations of NO2 at specific receptors (µg m-3) ............................................................................................ 85 Table 11: EPUK Significance Criteria(NO2, µg m-3) ........................................ 86 Table 12: Predicted 99.8th percentile of hourly average concentrations (µg/m3) of NO2 at specific receptors ...................................................................... 88 Table 13: Maximum predicted incremental concentrations due to emissions to atmosphere from the proposed facility (µg m-3) ...................................... 90 Table 14: Predicted increment (process contribution (PC)) of annual average concentrations of oxides of nitrogen (NOx) at ecological receptors ............ 93 Table 15: Predicted environmental concentration (PEC) of annual average concentrations of oxides of nitrogen (NOx) at ecological receptors ............ 94 Table 16: Predicted increment (PC) of annual average concentrations of sulphur dioxide (SO2) at ecological receptors ..................................................... 94 Table 17: Predicted environmental concentration (PEC) of annual average concentrations of oxides of nitrogen (SO2) at ecological receptors ............ 95 Table 18: Site description, habitat and nitrogen deposition critical load range (Kg N ha-1 year-1) ..................................................................................... 96 Table 19: Predicted annual average ground level concentrations and calculated nitrogen deposition rates ..................................................................... 96 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park iv Table 20: Nitrogen deposition rate and critical loads (Kg N ha-1 yr-1) .............. 97 Table 21: Deposition as percentage of critical load function (keg ha-1 year-1) ... 98 Table 22: Noise survey results – Vibrock, 2009 .......................................... 101 Table 23: Predicted noise impacts at nearest sensitive receptors.................. 104 Table 24: BS8233 weekday overnight noise impact assessment ................... 106 Table 25: Cumulative daytime noise levels ................................................ 107 Table 26: Summary of visual impact assessment findings ........................... 120 Table 27: Statutory nature conservation sites within 5 km of the proposed development .................................................................................... 125 Table 28: Operational HGV movements – extant and proposed .................... 131 Table 29: Staff vehicle movements – extant and proposed .......................... 131 Table 30: Predicted traffic flows – staff and HGVs for extant consent and proposed operations ......................................................................... 134 Table 31: Preliminary conceptual model .................................................... 140 Table 32: Locations where reference values exceeded ................................ 144 Table 33: Elevated groundwater concentrations recorded in 2013 study........ 145 Table 34: Revised conceptual model ......................................................... 147 Table 35: Carbon dioxide emissions after each stage of the energy hierarchy 159 Table 36: Regulated carbon dioxide savings from each stage of the hierarchy 159 Table 37: Employment by sector in Barking and Dagenham ........................ 161 Figures Figure 1: Site location ................................................................................ 3 Figure 2: Process schematic ...................................................................... 15 Figure 3: Location of human health receptors and stack ................................ 82 Figure 4: Annual average NOx concentrations .............................................. 89 Figure 5: 99.8th percentile of hourly average NOx concentrations.................... 89 Figure 6: Predicted annual average ground level concentrations of oxides of nitrogen dioxide (NOx) (µg m-3) ............................................................ 98 Figure 7: Predicted annual average ground level concentrations of sulphur dioxide (SO2) (µg m-3) ........................................................................ 98 Figure 8: Current site condition – November 2013 ..................................... 124 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park v Appendices Appendix A: Scoping request Appendix B: Scoping opinion Appendix C: Air quality assessment Appendix D: Noise assessment Appendix E: Visual impact assessment Appendix F: Draft travel plan Appendix G: Phase 1 environmental assessment report Appendix H: Phase 2 environmental assessment report Appendix I: BREEAM pre-assessment Appendix J: Energy assessment Appendix K: Consultation event Appendix L: Landscape plan Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park vi Drawings and plans Drawing 7487-20-001 – Internal building layout Drawing 7487-20-002 – Office internal layout Drawing 7487-20-003 – Facilities plan Drawing 7487-20-010 – Elevations Drawing 7487-20-011 – Office elevations Drawing 7487-70-001 – Topographical survey Drawing 7487-70-002 – Location plan Drawing 7487-70-004 – 3D views Drawing 7487-70-003 – Site layout plan Drawing 7487-70-005 – Sunpath studies Drawing 7487-70-006 – 3D views Drawing 7487-73-001 – Site circulation Drawing 7487-73-002 – Site surfaces Drawing MA9580–200 – Drainage strategy Drawings MA9580–VT101, VT102, VT103 – Vehicle tracking drawings Drawing 30582-60-003 – Utilities Drawing 30582-63-001 – External lighting Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park vii 1 Introduction 1.1 Layout and purpose of this document This document is an environmental statement submitted in support of a full planning application by Thames Gateway Waste to Energy Ltd (TGW2E) for the development of an energy generation facility on a site known as Plot 2 in the London Sustainable Industries Park in Dagenham. This document provides a detailed development description, an analysis of planning policy and assessment of potential environmental issues associated with the proposed development such as noise, air quality, contaminated land, visual impact assessment, transport etc; detailed topic-specific assessments are contained in the accompanying appendices where appropriate and necessary. It is supported by a stand-alone non-technical summary. A design and access statement has also been prepared to accompany the application, which is a separate, stand-alone document. 1.2 The applicant Thames Gateway Waste to Energy Ltd (TGW2E) is a special purpose vehicle formed by Chinook Investment Partners (Chinook Urban Mining) in order to develop and operate the site on the London Sustainable Industries Park. The technology is provided by Chinook Sciences, based in Cranford, New Jersey, with UK headquarters in Nottingham. Chinook Sciences was founded in 1998 and is a leading manufacturer and operator of advanced gasification technology. Its RODECS® gasification system is now in its ninth design generation and is capable of processing a wide range of waste streams. It has been installed in 17 locations throughout the world where it gasifies organic material without using incineration and fully recovers metals in its patented ACTIVE PYRO® process. Chinook Sciences has planning permission for two sites in the UK, one of which is currently under construction. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 1 2 The proposals 2.1 The proposed development The proposed development relates to the generation and export of electricity from 180,000 tonnes of residual commercial and industrial waste that would otherwise be landfilled. Some 19 MW electricity / year will be generated of which 5MW, will be used to power the facility itself with the remaining 14MW exported to the grid; the power exported is sufficient to power approximately 32,000 homes for a year. 2.2 Site location and surroundings The proposed location is shown in Figure 1 and is known as Plot 2 of the London Sustainable Industries Park (LSIP). The LSIP is located off the A13 at Dagenham Dock via the Goresbrook Interchange and Choats Manor Way and Choats Road. Junction 30 of the M25 lies approximately 9 km to the east, whilst the North Circular / A406 lies approximately 5 km to the west. Dagenham Dock Rail Station is approximately 600m to the northeast. The site is largely rectangular in shape, measures approximately 3.35 ha and is relatively flat. It is bounded to the east by Choats Manor Way, which links to the A13. To the immediate south of the site lies vacant land, for which planning permission has recently been granted for a 160,000 tonnes / year anaerobic digestion facility (ref 13/00649/FUL). The site has been cleared and levelled, landscaping implemented around the perimeter and an access road provided by the landowner, the Greater London Authority (GLA). The land benefits from an existing consent for an electricity generation facility granted in March 2011 (ref 10/00287/LBBD). The nearest residential properties to the proposed development are in Shaw Gardens, some 350m to the north and Keel Close some 950m west. The proposed Barking Riverside development is some 500m to the west. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 2 There is one nature conservation site, Goresbrook and Ship and Shovel Sewer SINC, adjacent to the west and northern boundaries of the site. Within a 5 km radius of the site there are eight statutory and important non-statutory sites as well as a number of other SINCs. An on-road cycle route runs along Choats Road although the high numbers of heavy goods and commercial vehicles using this road probably discourage cyclists. A cycle route is proposed to the immediate north of the site running along the southern boundary of the Goresbrook; this route would form part of the National Cycle Network (NCN13) and would provide an alternative route to Choats Road for cyclists and pedestrians. The EL2 bus service between Ilford and Dagenham stops near the site on Choats Road; there are no other bus services within acceptable walking distance. The site records an extremely poor public transport accessibility level (PTAL) of 1a on a scale of 1 – 6. Figure 1: Site location (Image Source: Imagery ©2013 Bluesky, DigitalGlobe GeoEye Getmapping plc. Infoterra Ltd & Bluesky, The Geoinformation Group, Map data ©2013 Google) Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 3 2.3 The extant consent On 31 March 2011, the London Thames Gateway Development Corporation (now London Borough of Barking and Dagenham for planning purposes) granted planning permission to Thames Gateway Power, for an energy generation facility on a site previously known as Abacus Park, Choats Road, Dagenham (ref 10/00287/LBBD); now known as plot 2 of the LSIP. The consent contains 34 conditions, 21 of which need to be discharged precommencement. commencement TGW2E commenced work on discharge of these preconditions, with condition 10 (breeding birds), 23 (archaeology) and part a) of condition 22 (contaminated land) having been discharged by TGW2E. Initially, TGW2E hoped to submit an application under Section 73 of the Town and Country Planning Act 1990 (as amended), which allows amendment of the conditions attached to a planning consent for minor material changes to the development proposals after permission has been granted. The section 73 application would have enabled TGW2E to inter alia replace the approved drawings under the extant consent thereby allowing it to substitute its own technology and layout for that which had been approved. However, as TGW2E progressed with detailed design, it became apparent that the differences between the extant consent and TGW2E’s own design were too great to be approved as a minor amendment to the extant consent and so TGW2E would need to submit a new application. 2.4 The Environmental Statement and the environmental impact assessment process 2.4.1 Legislative background Environmental impact assessment (EIA) is the process by which the positive and negative environmental effects of a proposed development are identified and assessed before development consent is granted. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 4 The process systematically identifies and assesses a project's expected significant environmental effects and culminates in the preparation of an Environmental Statement (ES). The requirement for EIA originates in EU law under EC Directive 85/337 (as amended by Directive 97/11/EC), on the assessment of the effects of certain public and private projects on the environment (the EIA Directive). The EIA Directive has been transposed into English legislation by various regulations, the primary regulations in England being the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (SI 2011/1824) (the ‘EIA Regs’). Formal guidance on the regulations is contained in Department for Communities and Local Government (DCLG) Circular 02/99: Environmental Impact Assessment. Schedule 4 of the EIA Regs, requires the EIA to consider any ‘…direct effects and any indirect, secondary, cumulative, short, medium and longterm, permanent and temporary, positive and negative effects’. The findings of the EIA process are then documented in an Environmental Statement (ES) that is submitted with the planning application to provide the local planning authority (LPA) with appropriate levels of information for decision-making and the determination of the planning application. Statutory and non-statutory consultation takes place throughout the EIA and planning application process. 2.4.2 Content of an ES Schedule 4 of the Regulations specifies information to be included in an ES viz.: A description of the development. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 5 An outline of the main alternatives studied and an indication of the main reasons for the choice. A description of the aspects of the environment likely to be significantly affected including in particular: population, fauna, flora, soil, water, air, climatic factors, material assets, including the architectural and archaeological heritage, landscape, and the interrelationship between the above factors. A description of the likely significant effects of the development on the environment, to include direct, indirect, short, medium and long term, permanent and temporary, positive and negative effects etc. 2.5 Mitigation measures to prevent or reduce any significant adverse effects. A non-technical summary of the information contained in the ES. The requirement for environmental impact assessment Certain types of development (projects listed in Schedule 1 of the EIA Regs) always require EIA by virtue of their size, type and potential environmental effects. The proposed development falls into the following category: Schedule 1 part 10 - Waste disposal installations for the incineration or chemical treatment (as defined in Annex IIA to Council Directive 75/442/EEC under heading D9) of non-hazardous waste with a capacity exceeding 100 tonnes / day. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 6 2.6 Scoping Part 4 of the Regulations provides for an applicant to ask the relevant planning authority to state its opinion on the proposed EIA content (‘scoping’). A detailed request for a scoping opinion was submitted to the London Borough of Barking and Dagenham (LBBD) as planning authority on 30 September 2013 (Appendix A). In identifying topics proposed to be addressed in the EIA, a detailed review was undertaken of the application for the extant planning consent (10/00287/LBBD) and in particular its accompanying EIA, the scope of which was agreed with the LPA with comments also received from the Greater London Authority (GLA). The scoping opinion issued by the LPA1 in respect of the EIA undertaken in support of the extant consent application required that the following topics be addressed: Land use Landscape and visual Ecology, nature conservation and biodiversity Transport and access Geology, ground conditions and land quality Hydrology and hydro-geological Drainage Archaeology Flood risk Noise and vibration Air quality 1 Letter from LTGDC dated 8 October 2009 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 7 Construction environmental management Energy and sustainability Socio-economic and health The Officer’s report on the planning application2 noted that in terms of environmental considerations (flood risk / contamination / air quality / noise / visual impact / biodiversity), the Environmental Statement concluded that impacts are either negligible or minor beneficial; a position supported by consultees subject to appropriate conditions. Given the findings of the previous EIA and the work already undertaken by TGW2E in discharging planning conditions, it was possible to scope some topics out of detailed consideration in the EIA. LBBD issued a formal scoping opinion on 8 November 2013 (Appendix B), which required that the following topics be addressed in the EIA: 2.7 Land use Air quality Noise and vibration Ecology, nature conservation and biodiversity Visual impact Transport and access Geology, ground conditions and land quality Hydrology and hydrogeology Energy and sustainability Socio-economic and health The purpose, content and structure of this report This document is the Environmental Statement (ES), which accompanies the application for planning permission. 2 London Thames Gateway Development Corporation Planning Committee Meeting 8 July 2010. No: LTGDC/10/PC34. Application number 10/00287/LBBD Report Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 8 This document addresses all pertinent environmental issues related to the construction and operation of the proposed development. Potentially significant impacts relating to the development have been identified and addressed and where possible, potentially adverse impacts have been designed out. If this is not possible then mitigation measures are proposed to minimise and ideally eliminate the effects. Beneficial impacts of the proposed development are also identified and maximised wherever possible. This document and accompanying technical appendices and the free-standing non-technical summary comprise the Environmental Statement for the proposed development. All relevant issues listed in Schedule 4 of the Regulations have been addressed. The EIA has been undertaken by Amberley Consulting Ltd with input from a number of specialist consultants whose technical reports are included in the appendices to this ES. The remainder of this document is structured as follows: Section 3: Detailed development description Section 4: Policy analysis Section 5: Land use Section 6: Air quality Section 7: Noise and vibration Section 8: Visual impact Section 9: Ecology, nature conservation and biodiversity Section 10: Transport and access Section 11: Geology, ground conditions and land quality Section 12: Water resources Section 13: Energy and sustainability Section 14: Socio-economic and health Section 15: Conclusion Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 9 3 Detailed development description 3.1 Key elements of the proposed development The proposed development is shown in a series of drawings and plans, which accompany this application as follows: Drawing 7487-20-001 – Internal building layout Drawing 7487-20-002 – Office internal layout Drawing 7487-20-003 – Facilities plan Drawing 7487-20-010 – Elevations Drawing 7487-20-011 – Office elevations Drawing 7487-70-001 – Topographical survey Drawing 7487-70-002 – Location plan Drawing 7487-70-004 – 3D views Drawing 7487-70-003 – Site layout plan Drawing 7487-70-005 – Sunpaths Drawing 7487-70-006 – 3D views Drawing 7487-73-001 – Site circulation Drawing 7487-73-002 – Site surfaces Drawing MA9580–200 – Drainage strategy Drawings MA9580–VT101, VT102, VT103 – Vehicle tracking drawings Drawing 30582-60-003 – Utilities Drawing 30582-63-001 – External lighting Key elements of the proposed development include: Erection of a building comprising a waste reception, post-processing and materials storage hall (89.8m x 65.6m x 17m) Erection of a RODECS® process building (26.9m x 58.5m x 20.5m) Erection of a two storey office building (34.3m x 11.25m x 8.5m) Installation of a 55m stack Installation of a dedicated electricity substation with associated fencing and export connection Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 10 Installation of a weighbridge and erection of associated office Installation of external energy conversion, emissions treatment and control equipment 3.2 Erection of perimeter fencing around the external boundary of the site Drainage infrastructure including underground water storage tanks Hardstanding, roadways, vehicle and bicycle parking areas Soft landscaping. Site access and circulation There are two accesses to the site as shown on Drawing 7487-70-003. Vehicle movements associated with the proposed development will include HGVs and staff / visitor vehicles; site circulation is shown on Drawing 748773-001. Material for processing will be brought onto site by HGVs from a number of locations in the London area. All HGVs will enter the site through the western gate. HGVs bringing material for processing will pass over the incoming weighbridge, and proceed to the lorry waiting / parking area, where they will be held until the reception area in side the building is clear. They will then drive into the building to deposit the waste before retracing their route and passing over the outgoing weighbridge before exiting the site. Fast-acting roller shutter doors will open to allow access / egress by HGVs; tipping will only take place when the doors are closed. Air from the waste reception area will be extracted and passed through carbon filters prior to discharge to remove any odours. HGVs collecting recovered materials for further processing will pass over the incoming weighbridge and proceed to the southern end of the building, where metals and aggregates will be stored. They will reverse into the building for loading and then retrace their route passing over the exit weighbridge prior to leaving the site. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 11 HGVs delivering materials / fuel will pass over the incoming weighbridge before being directed to the appropriate area of the site. Staff / visitor vehicles will enter / exit the site through the eastern access and proceed to the relevant parking areas. 3.3 Hours of operation The development will operate 24 hours / day, seven days / week. HGV deliveries to the site will be between the hours of 07:00 – 22:00 Monday – Friday and 07:00 – 17:00 on Saturdays, over the equivalent of 304 days / year (six days / week excluding bank holidays). Electricity will be generated 24 hours / day, seven days / week. 3.4 Staffing The development is expected to employ 55 staff in total. Of these 55, 45 staff will be employed in production across two or four shifts, dependent on the specific job function, the remaining 10 non-production staff would work general office hours. 3.5 Security The entire site will be securely fenced with 2.4 – 3.0m high weldmesh fencing (the 3.0 m fencing to be installed on the northern boundary where there is considered to be a greater security risk). Access will only be possible through the two entrances, which will be gated with security barriers controlled remotely from the weighbridge / gatehouse. The facility will be in operation 24 hours / day, seven days / week so there will always be personnel present on site. A CCTV system will be installed, maintained and operated in accordance with BS7958:2009 – Closed circuit television (CCTV) management and operation (code of practice). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 12 3.6 Lighting Operational activities would be undertaken internally in buildings and so external lighting would be restricted to areas of hardstanding and roadways, to enable safe movement of traffic around the site, and to areas of external equipment. Hours of working on site mean that lighting would be required after dusk throughout the year; lighting would be directional to prevent spill and limit any potential adverse effects on neighbouring landuses and users. Security and utility lighting will comprise pole or building mounted lights at approximately 6m high, downwards oriented and inward facing. Downward pointing lighting will also be positioned above vehicle entrances into buildings and low-level lighting will be provided along walkways / cycle routes within the site to allow for the safe movement of staff around the facility. Proposed external lighting is shown on drawing 30582-63-001. Internal lighting would be fully controlled by a combination of movement detectors, passive infra red (PIR) detectors and daylight sensors to ensure energy use is minimised. As far as possible, the roofs of buildings would be perforated by an array of translucent panels that would transmit daylight into the buildings. Artificial lighting would be required to supplement day-lighting under certain conditions in these buildings and would be provided in the administrative areas and externally. Emergency lighting would be provided in line with the emergency lighting code of practice BS 5266-1. 3.7 Technology overview 3.7.1 Gasification Gasification is the thermal decomposition of material in an atmosphere, which does not contain enough oxygen to allow full combustion. It is a well- established process dating from the early 1800s, when it was first used to produce town gas from coal. The process results in the production of a combustible gas, ‘syngas’, which typically contains a mix of predominantly carbon monoxide, carbon dioxide, hydrogen, methane, and nitrogen. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park The 13 syngas can be combusted and the hot exhaust gases sent to a waste heat boiler to generate steam, which can be used in a steam turbine or used directly to produce electricity and heat. 3.7.2 The Chinook Sciences technology The Chinook Sciences gasification technology is called RODECS®, which forms the core of the ‘ACTIVE PYRO®’ system. The RODECS® system consists of a process chamber controlled by a natural gas–fired thermal reactor. It has been operating at commercial scale for thirteen years in the UK, Europe, the Americas and the Middle East on a range of input materials. A schematic of the process is shown in Figure 2 and described below. 3.7.3 RODECS® The gasification system will consist of two RODECS® batch Gasifiers, each capable of processing the total design throughput of 90,000 tonnes per year (7,500 hours per year). The RODECS® system will have a natural gas fired thermal reactor to supply the primary heat for the gasification process. Front end loaders will push the un-processed material against a wall ready for transfer to the RODECS®. This material will then be fed, using a grabber system, into a RODECS® bin with a volume of 100 m3. The RODECS® bin will be positioned in the filling area using an automated trolley car system combined with bin location stands; each movable trolley car is designed to hold two bins. The waste will be loaded into the bin and be compressed regularly while it is in the bin to allow more waste to be added into the bin. This process will continue until the bin reaches the target weight of 24 tonnes (the stand is equipped with a weigh scale system). Once the bin reaches the target weight, loading will stop and the trolley will then move the freshly filled feed bin towards the RODECS® immediately next to the position in which the processed bin is removed. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 14 Figure 2: Process schematic First zone Second zone Third zone Fourth zone Fuel Preparation: The waste is Combustion chamber: The syngas is Waste heat boiler: The hot exhaust Air pollution control system: The processed under tight Oxygen & combusted and the exhaust gases held gases from the combustion chamber are exhaust gases from the boiler pass temperature control to ensure the o at a temperature of >850 C for >2s in passed through a waste heat boiler to through a bag filters to remove any complete gasification of the organics to accordance with the requirements of the generate steam which is passed to a particulate that is suspended in the produce a synthetic gas fuel (syngas) and Waste Incineration Directive (now Steam Turbine Generator (STG) set to gases before allowing them to exit via thermally clean all of the valuables in incorporated in to the Industrial generate electricity. the stack. Sorbent/PAC injection the waste for further recycling. Emissions Directive). The hot gases leave the boiler at a removes acid gases and Dioxins. o Temperature Range: 550 - 600 C o Temperature Range: 850 – 1,400 C o reduced temperature (≈200 C) Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 15 The processed bin will then be unlatched from the RODECS®, and the trolley moved into a position such that the fresh feed bin is in place to be latched to the RODECS®. After the fresh bin has been attached, the RODECS® will then rotate 180 degrees so that the bin will be at the top of the RODECS® and inverted, starting the process cycle. Changing bins will be accomplished in approximately three minutes. The RODECS® Gasifier uses a patented process by the name of ACTIVE PYROLYSIS® to control both the atmospheric conditions within the RODECS® and the conversion rate of the energy-containing materials in the feed into a syngas consisting primarily of carbon monoxide (CO), hydrogen (H2), carbon dioxide (CO2), methane (CH4), water (H2O) and nitrogen (N2) from the air fed to the process. The temperature inside the Gasifier (550 – 600°C) is maintained below the melting temperatures of metals enabling them to be recovered. The syngas is generated in the RODECS® processing chamber through a combined action of pyrolysis and gasification. The rate of reaction is controlled by an array of controlled parameters (among which are flow, temperature, Oxygen-level, etc.). The rate at which the batch is heated is determined by the process chamber movement, volume of gases and temperature of the recycled hot gases sent to the RODECS® from the Thermal Reactor chamber. The preheated gases provide sensible heat required for heating. The gases are also used to fluidise the feed to enhance the rate of production of the syngas in the RODECS®. The remaining material, metal, glass, dirt and sand, is mechanically retained inside the RODECS® processing chamber. At the end of the batch processing, the RODECS® will be rotated such that the bin is back at the bottom with the inert materials falling back into the bin for removal. The bin will be unlatched and the contents taken to the process material separation area, after which the separated materials will be taken to the process material storage area. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 16 The total cycle time will be approximately 120 minutes for a 24 tonne batch. The time required reaching threshold syngas production is expected to be in the region of 25 minutes. The cool down time before unlatching the bin where the average syngas production rate has declined below the threshold value to the complete depletion of syngas is expected to take 10 to 15 minutes. The bin will only un-latched after full depletion of the syngas. The syngas produced in the gasifier passes to a dedicated natural gas fired combustion chamber where it is combusted and the exhaust gases held at a temperature of 900oC for >2s in accordance with the requirements of the Waste Incineration Directive (now incorporated into the Industrial Emissions Directive) which stipulates that ‘the gas resulting from the process is raised, after the last injection of combustion air, in a controlled and homogeneous fashion and even under the most unfavourable conditions, to a temperature of 850°C, as measured near the inner wall or at another representative point of the combustion chamber as authorised by the competent authority, for two seconds’. 3.7.4 Air pollution control system For NOx control, a Selective Non-Catalytic Reduction (SNCR) system is employed utilising ammonia solution (NH3aq) injection in to the combustion chamber. The amount of NH3aq injected is adjusted according to the NOx measurement at the stack inlet by the CEM (Continuous Emissions Monitoring) system and this is done on a continual basis. Exhaust gases exiting the waste heat boiler, exit at 200oC and are drawn through an Air Pollution Control (APC) system aided by an induced draft fan and are then discharged to atmosphere via a stack. The APC consists of a ‘barrier type’ particulate filter that utilises bag filters. Besides filtering the exhaust gases for particulate, acid gases (e.g. HCl, HF and SOx) will also be removed from the flue gas at the APC. Here, sodium bicarbonate sorbent will be injected using a dry system which will form a fully Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 17 reactive coating on the ceramic filter candles in order to neutralise the acid gases. Powdered Activated Carbon (PAC) is also injected in order to adsorb dioxins / furans. The sodium bicarbonate and reaction products are powders and are discharged from the ceramic filter along with filtered particulate and spent PAC for removal and disposal. The flue gas cleaning equipment has been designed based on the waste feedstock characteristics. 3.7.5 Turbine / generator The exhaust gases from the combustion chamber are passed through a waste heat boiler to generate steam which is passed to a Steam Turbine Generator (STG) set to generate electricity. On discharge from the STG, the steam is condensed in an Air Cooled Condenser (ACC). Condensate is returned to the de-aeration system via condensate extraction pumps. Water make up is via a water treatment plant; as the system will be running on demineralised water, the blow-down / make-up water is a negligible amount. The STG can be by-passed through a Pressure Reducing De-Superheating valve (PRDS) to provide steam pressure control. A substation will be constructed on site to enable export to the grid. 3.7.6 Reclamation of inert recyclable materials Any metals, glass and aggregates in the incoming waste will be recovered from the inert solid residues arising from the RODECS® system and sent for further reprocessing / recycling; it should be noted that the incoming waste will have already been subject to recycling / reprocessing, so the quantities of metals etc remaining in the incoming waste in particular are not expected to be significant. It is expected that the remaining inert residue material will be sent to landfill initially although TGW2E has committed to working with the University of East London to find and develop markets for this material (section 14.3). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 18 3.7.7 Potential for heat export The technology to be employed in the proposed development has been designed to maximise the amount of electricity that is generated from the infeed material. It is therefore extremely efficient in recovering heat to increase the efficiency of the energy conversion process as heat is recovered from the combustion gases through the use of waste heat boilers and steam turbines. The efficiency of the heat recovery process means that there is less available for potential export to a heat transmission network than would normally be the case for an energy from waste facility. However, given the Mayor’s commitment to decentralised energy and the proposed district heating transmission line along Choats Road, TGW2E will provide a CHPReady facility (section 3.8) and regularly review the potential for heat export. 3.8 Operational control and regulation of the proposed development The proposed development requires an Environmental Permit (EP), issued by the Environment Agency, before it can operate. The Environmental Permitting regime seeks to ensure that regulated facilities do not cause harm to the environment or human health; it is the Environment Agency’s responsibility to ensure that this is the case. Operators have to manage and operate activities in accordance with a written management system that identifies and minimises risks of pollution, including those arising from operations, maintenance, accidents, incidents, nonconformances, closure and those drawn to the attention of the operator as a result of complaints. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 19 Environmental Permits have a series of conditions attached addressing specific outcomes e.g. emissions and monitoring requirements, maintenance of records, requirements for staff competence etc., which must be complied with. The Agency conducts regular inspection visits to ensure that facilities are operating in accordance with the permit conditions. The Agency requires that all applications for Environmental Permits for new installations regulated under the Environmental Permitting (England and Wales) Regulations 2010 demonstrate the use of Best Available Techniques (BAT) for a number of criteria, including energy efficiency. The Agency recognises that one of the principal ways in which energy efficiency can be improved is through the use of CHP. With respect to the use of CHP, there are three applicable BAT tests. 1. Use of CHP in circumstances where there are technically and economically viable opportunities for the supply of heat from the outset. 2. In cases where there are no immediate opportunities for the supply of heat from the outset, the Environment Agency considers that BAT is to build the plant to be CHPReady (CHP-R) to a degree which is dictated by the likely future opportunities which are technically viable and which may, in time, also become economically viable. The term ‘CHP-R’ in this context represents a plant which is initially configured to generate electrical power only but which is designed to be ready, with minimum modification, to supply heat in the future. The term 'minimum modification' represents an ability to supply heat in the future without significant modification of the original plant / equipment. Given the uncertainty of future heat loads, the initial electrical efficiency of a CHPR plant (before any opportunities for the supply of heat are realised) should be no less than that of the equivalent non-CHP-R plant. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 20 3. Once an Environmental Permit has been issued for a new CHP-R plant, the applicant / operator should carry out periodic reviews of opportunities for the supply of heat to realise CHP. Such opportunities may be created both by new heat loads being built in the vicinity of the plant, and / or be due to changes in policy and financial incentives which improve the economic viability of a heat distribution network for the plant being CHP. The Agency has produced a CHP-R Guidance document to help satisfy the requirements of the second BAT test. As part of the Environmental Permit application process, TGW2E will undertake a CHP-R study in accordance with the Agency guidance to satisfy the requirements of the second BAT test. 3.9 Construction The construction period is expected to take twelve – fifteen months with a further six – nine months for equipment installation. During construction, the workforce is anticipated to range from 50 – 130 staff dependent on the activities on site, with a maximum workforce of 50 on site during equipment installation. To ensure that any mitigation measures contained in this ES are implemented, the contractor will be required to produce a construction environmental management plan (CEMP), which will incorporate measures for inter alia, monitoring construction noise and vibration, protecting air quality (dust, smoke and odour control), protecting existing services, control of water pollution, management and control of site waste, ensuring any biodiversity features are protected, implementation and monitoring and hours of operation, etc. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 21 A separate construction logistics plan will also be prepared and submitted to LBBD before construction commences; this plan will address traffic management and will also investigate the feasibility of transport of construction materials by river. It is expected that the commitment to produce a CEMP and construction logistics plan will be secured by way of planning condition. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 22 4 Policy analysis 4.1 Introduction A detailed policy analysis is included in this section to demonstrate the extent to which the proposed development contributes to, and is in conformance with, prevailing policies, aims and guidance. Both energy and waste management policies are relevant to the proposed development given that it will utilise waste materials to produce electricity for export to the national grid. It is important to note that the principle of the development has clearly already been established through the granting of the extant planning consent. 4.2 European policy and legislation 4.2.1 Waste Framework Directive The revised Waste Framework Directive (2008/98/EC) (WFD) came into force on 12 December 2008. Member States were required to implement the WFD by 12 December 2010. The objective of the WFD is to provide a comprehensive and consolidated approach to the definition and management of waste. The aims of the WFD are: To provide a comprehensive and consolidated approach to the definition and management of waste. To shift from thinking of waste as an unwanted burden to a valued resource and make Europe a recycling society. To ensure waste prevention is the first priority of waste management. To provide environmental criteria for certain waste streams, to establish when a waste ceases to be a waste (rather than significantly amending the definition of waste). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 23 Article 3 sets out the key WFD definitions (with the exception of the definition of "by-product", which is set out in detail in Article 5). In particular, the WFD clarifies the definitions of recovery and disposal to make a clear distinction between them: Recovery means any operation, the principal result of which is waste serving a useful purpose by replacing other materials, which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy. Annex II to the WFD sets out a non-exhaustive list of recovery operations. Disposal means any operation, which is not recovery, even where the operation has as a secondary consequence the reclamation of substances or energy. Annex I to the WFD sets out a non-exhaustive list of disposal operations. The list of recovery operations provided in Annex II includes ‘R1 – Use principally as a fuel to generate energy’. The proposed development is defined as a recovery operation by the WFD and is in accordance with its aims. 4.2.2 Industrial Emissions Directive The recast Directive on Industrial Emissions (2010/75/EU) came into force on 7 January 2011. It combines seven directives, listed below, into one: the Large Combustion Plant directive (LCPD); the Integrated Pollution Prevention and Control directive ( IPPCD); the Waste Incineration directive (WID); the Solvent Emissions directive (SED); and the three existing directives on Titanium dioxide on (i) disposal (78/176/EEC), (ii) monitoring and surveillance (82/883/EEC) and (iii) programs for the reduction of pollution (92/112/EEC). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 24 Member states have two years to transpose the directive into national law i.e. by 6 January 2013; draft regulations, amending the Environmental Permitting (England and Wales) Regulations 2010, were laid before parliament in December 2012. The purpose of the Directive is ‘to achieve a high level of protection for the environment taken as a whole’ from harmful effects of industrial activities (Article 1). It does so for many activities by requiring each of the industrial installations concerned to have a permit from the competent authority. Permit conditions and pollutant emission limit values therein have to be set on the basis of the application of best available techniques (BAT). 4.2.3 Renewable Energy Directive Directive 2009/28/EC on the promotion of the use of energy from renewable sources requires the UK to source at least 15% of its total energy from renewables by 2020. To meet this target, the Government has estimated that renewable sources will need to contribute: At least 32% of the UK’s electricity, with one-third of this coming from biomass, of which waste forms a part. At least 12% of UK heat requirements. At present this is less than 1%. The proposed development will contribute to the renewable energy target by generating electricity from waste. 4.2.4 Landfill Directive The landfill directive (99/31/EC) requires Member States to draw up strategies for a reduction in the quantity of biodegradable waste disposed of to landfill. The landfill directive was introduced in order to prevent, or reduce Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 25 as far as possible, the negative effects of landfilling waste on the environment and on human health. The proposed development would divert a significant amount of waste from landfill. 4.3 National policy and strategy 4.3.1 Introduction National planning policy in England changed last year with the publication of the National Planning Policy Framework (NPPF) on 27 March 2012 and the consequent revocation of planning policy guidance and planning policy statements (PPG and PPS). The only PPS still in place is PPS 10: Planning for sustainable waste management; an updated national waste planning policy document was out for consultation this summer although PPS10 and the supporting guidance will remain in effect until it is replaced by the updated policy and practice guidance respectively3. 4.3.2 The National Planning Policy Framework The NPPF states that the purpose of planning is to ‘help achieve sustainable development’ and that ‘development that is sustainable should go ahead, without delay – a presumption in favour of sustainable development that is the basis for every plan, and every decision’. Para. 14 states that at the heart of the NPPF is a ‘presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking.’ For decision-taking this means, (unless material considerations indicate otherwise): 3 para 11: Updated national waste planning policy: Planning for sustainable waste management. Consultation July 2013 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 26 Approving development proposals that accord with the development plan without delay Where the development plan is absent, silent or relevant policies are out of date, granting permission unless: Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in the NPPF taken as a whole or Specific policies in the NPPF indicate development should be restricted. The NPPF sets out 12 core planning principles that should underpin both planmaking and decision-taking. Those relevant to the proposed development include requirements for planning to: Proactively drive and support sustainable economic development Always seek to secure high quality design Support the transition to a low carbon future in a changing climate and encourage the use of renewable resources Contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value Encourage the effective use of land by re-using brownfield land. Annex 1 sets out how the NPPF will be implemented. It explains that policies in the Local Plan should not be considered out of date, simply because they pre-date the NPPF (para. 211), but that policies contained within the NPPF are material considerations which need to be taken into account immediately (para. 212). Decision makers may also give weight to relevant policies in emerging plans according to (para. 216): The stage of preparation of the emerging plan with a greater weight given to later stages The extent to which there are unresolved objections to relevant policies (greater weight given, the less significant the objections) Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 27 The degree of consistency of the relevant policies in the emerging plan to the policies in the NPPF (increased weight for greater consistency) Under the heading ‘Delivering sustainable development’, the NPPF sets outs the policies under 13 sections. Those relevant to the proposed development are as follows: Policy 1: Building a strong, competitive economy ‘The government is committed to securing economic growth in order to create jobs and prosperity, building on the country’s inherent strengths, and to meet the twin challenges of global competition and of a low carbon future (para. 18)’. Government is committed to ensuring that the planning system does everything it can to support sustainable economic growth. Planning should encourage and not act as an impediment to sustainable growth, with significant weight placed on the need to support economic growth through the planning system (para. 19). The proposed development directly supports this policy through the creation of employment (section 14.3.1) and the active reduction of emissions of CO2 (section 13). CO2 savings are due to the displacement of electricity generation from fossil fuels, the recycling of metals which avoids them being replaced through energy intensive primary metal smelting processes as well as the avoidance of landfill gases. Policy 4: Promoting sustainable transport All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment (para. 32) and required to provide a Travel Plan (para. 36). Where practical, developments should be located and designed to: accommodate efficient delivery of goods and supplies, Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 28 give priority to pedestrians and cyclists, create safe and secure layouts, incorporate facilities for charging plugin and other ultra-low emission vehicles, consider the needs of people with disabilities (para. 35). An assessment of the transport implications of the development has been undertaken and is contained in section 10. A draft travel plan has also been prepared and is included in Appendix F. The design also includes provision for charging points for electric vehicles. The needs of people with disabilities have been considered and inclusive access provision is discussed in the accompanying Design and Access Statement. Policy 7: Requiring good design Good design is a key aspect of sustainable development, indivisible from good planning and should contribute positively to making places better for people (para. 56). Planning policies and decisions should aim to ensure that developments inter alia, function well and add to overall quality of the area, optimise the potential of the site to accommodate development, create and sustain an appropriate mix of uses, respond to local character and history and reflect the identity of local surroundings and materials, are visually attractive as a result of good architecture and appropriate landscaping (para. 58). The layout of the proposed development has been dictated by the operational requirements of the technology, constraints imposed by pylons and by the location of the vehicular accesses into the site, which are already fixed. The appearance of the development is described in detail in the accompanying Design and Access Statement and a detailed visual impact assessment has also been undertaken (section 8). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 29 Policy 10: Meeting the challenge of climate change, flooding and coastal change LPAs should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon energy sources. LPAs should inter alia have a positive strategy to promote energy from renewable / low carbon sources, design policies to maximise renewable / low carbon energy development while ensuring adverse impacts are satisfactorily addressed (para. 97). When determining planning applications, LPAs should not require applicants for energy development to demonstrate the overall need for renewable or low carbon energy and recognise that even small-scale projects provide a valuable contribution to cutting greenhouse gas emissions and approve the application, unless material considerations indicate otherwise, if its impacts are (or can be made) acceptable. Once suitable areas for such development are identified in plans, LPAS should expect subsequent applications for commercial scale projects outside these areas to demonstrate that the location meets site selection criteria (para. 98). New development should be planned to avoid increased vulnerability to the range of impacts arising from climate change (para. 99). Development should be directed away from areas at highest risk of flooding but where development is necessary, it should be made safe without increasing the risk elsewhere (para. 100). Flood risk assessments will be required for developments of 1 hectare or greater in Flood Zone 1 and for all proposals for new development, including minor development and change of use, in Flood Zones 2 and 3 or for an area in Flood Zone 1 which has a critical drainage problems and where the proposed development may be subject to other sources of flooding (para. 103). The proposed development directly supports this policy through the considerable reduction of CO2 emissions, which will result from its implementation; an energy statement has been prepared which Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 30 demonstrates the significant savings from the proposed development (section 13). A flood risk assessment (FRA) was undertaken to support the application for the extant consent. TGW2E has incorporated the mitigation measures described in the FRA into its design and confirms that the proposed changes in terms of the new technology and site layout will not affect the findings of the FRA. LBBD confirmed in its scoping opinion (Appendix B) that flood risk did not need to be addressed in this application. Policy 11: Conserving and enhancing the natural environment The planning system should contribute to and enhance the natural and local environment by: protecting and enhancing valued landscapes, recognising the wider benefits of ecosystem services, minimising impacts on biodiversity and providing net gains where possible, preventing both new and existing development from contributing to, or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air water or noise pollution or land instability remediating and mitigation despoiled, degraded, derelict, contaminated and unstable land, where appropriate (para. 109). Planning policies and decisions should encourage effective land use by reusing previously developed land provided that it is not of high environmental value (para. 111). Planning policies and decisions should ensure that: a site is suitable for its new use taking account of ground conditions and land instability, including that from natural hazards and former activities such as mining and pollution from previous uses and any Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 31 proposals for mitigation, including impacts on the natural environment arising from any remediation after remediation, as a minimum, the land should not be capable of being determined as contamination land under Part IIA of the Environmental Protection Act 1990 adequate site investigation prepared by a competent person is presented (para. 121). Planning decisions should aim to avoid noise that gives rise to significant adverse impacts on health and quality of life as a result of new development (para. 123). The proposed development complies with the aims of this policy: It reuses a former industrial site, which is allocated for a use such as the proposed development. A landscape plan has been prepared, which increases the number and range of habitats present in the immediate area (section 9.4) A phase 2 site investigation has been undertaken (section 11) which demonstrates that there are no significant risks to human health for the site’s end users once the development is completed. A noise assessment has been undertaken which demonstrates that there will not be any adverse impacts on health and quality of life (section 7). Policy 12: Conserving and enhancing the historic environment Applicants are required to describe the significance of any heritage assets affected by the proposed development, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance. Where a site includes, or has the potential to include, assets of archaeological interest, developers will be required to submit an appropriate desk-based assessment and where necessary a field evaluation. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 32 A programme of archaeological investigation was undertaken by TGW2E in summer 2013 in order to discharge condition 23 of the extant consent (section 2.3), which found no archaeological remains and concluded that the site was of limited archaeological potential. LBBD confirmed in its scoping opinion (Appendix B) that archaeology / heritage did not need to be addressed in this application. 4.3.3 Planning Policy Statement 10: Planning for sustainable waste management PPS10 identifies that ‘positive planning’ has an important role to play in delivering sustainable waste management by inter alia ‘providing sufficient opportunities for new waste management facilities of the right type, in the right place and at the right time’. Moving waste management up the waste hierarchy remains a key objective of Government waste policy in order to reduce the environmental impact of waste and is therefore included as a key planning objective in PPS10. Other key objectives include: Providing a framework for self-sufficiency at the community level; Helping implement the national waste strategy and supporting targets; Helping secure the recovery / disposal of waste without endangering human health or harming the environment and in accordance with the proximity principle; Reflecting the concerns and interest of communities. PPS10 also notes that in determining planning applications, planning authorities should adhere to the principle that controls under the planning and pollution control regimes should complement rather than duplicate each other. The proposed development complies with the aims of this policy statement; it would move waste management up the waste hierarchy and would treat waste without endangering human health or harming the environment. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 33 4.4 Regional and local policy 4.4.1 Context At a regional level, the London Plan, published in July 20114, is the overall strategic plan for London, and sets out a fully integrated economic, environmental, transport and social framework for the development of the capital to 2031. The London Plan forms part of the development plan for Greater London. Boroughs’ local plans need to be in general conformity with the London Plan, and its policies guide decisions on planning applications by councils and the Mayor. The Barking and Dagenham Local Plan consists of a series of documents. The Core Strategy, which was adopted in July 2010, sets out the spatial vision for Barking and Dagenham and a strategy for how this vision will be achieved. The Development Management Policies Document, the Site Specific Allocations Document, the Barking Town Centre Area Action Plan and the Joint Waste Plan support the strategic objectives set out in the Core Strategy. 4.4.2 The London Plan The vision for London set out in the London Plan is that ‘over the years to 2031 – and beyond, London should: excel among global cities – expanding opportunities for all its people and enterprises, achieving the highest environmental standards and quality of life and leading the world in its approach to tackling the urban challenges of the 21st century, particularly that of climate change’. 4 On 11 October 2013, the Mayor published Revised Early Minor Alterations to the London Plan (REMA). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 34 This vision is supported by six detailed objectives, which link the vision to detailed policies. Policies are set out in topic specific chapters as follows: London’s places London’s people London’s economy London’s response to climate change London’s transport London’s living places and spaces Policies relevant to the proposed development are set out below. Chapter two – London’s places Policy 2.17 – Strategic industrial locations (SIL) identifies areas, which will be promoted and managed as London’s principal reservoirs of industrial and related capacity. Suitable uses include ‘waste management and environmental industries (such as renewable energy generation)’. Development proposals in SILs should only be approved if they inter alia are for an appropriate industrial use and comply with an opportunity area planning framework or borough development plan document as appropriate. The proposed development lies in the London Sustainable Industries Park (LSIP), which is part of the Dagenham Dock Preferred Industrial Location (PIL). PILs are a class of strategic industrial location, which are particularly suitable for general industrial, light industrial, storage and distribution, waste management, recycling, some transport related functions, utilities, wholesale markets and other industrial related activities. Chapter four – London’s economy Policy 4.1 – developing London’s economy states that the Mayor will work with partners to inter alia drive London’s transition to a low carbon Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 35 economy and to secure the range of benefits this will bring and support and promote outer London as an attractive location for businesses. The proposed development directly supports the aims of this policy; it is a low (negative) carbon development, which will be located in outer London. Policy 4.10 – new and emerging economic sectors requires that the Mayor, boroughs, statutory agencies and other stakeholders support the development of green enterprise districts such as that proposed in the Thames Gateway. The proposed development is an emerging sector, located in an area that will be supported. Policy 4.12 – improving opportunities for all states that strategic development proposals should support local employment, skills development and training opportunities. The proposed development will create 55 new jobs. TGW2E is committed to maximising the number of jobs provided from within the local community and providing appropriate training opportunities and has had discussions with LBBD to explore ways in which the opportunities can be maximised (section 14.3). Chapter five – London’s response to climate change Policy 5.1 – climate change mitigation sets out a target for an overall reduction in London’s carbon dioxide emissions of 60% (below 1990 levels) by 2025. The proposed development results in significant carbon dioxide savings (section 13) and therefore directly supports the target in this policy. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 36 Policy 5.2 – minimising carbon dioxide emissions requires that development proposals make the fullest contribution to minimising carbon dioxide emissions in accordance with an energy hierarchy: 1. Be lean: use less energy 2. Be clean: supply energy efficiently 3. Be green: use renewable energy Major developments will have to meet specific targets for carbon dioxide emissions reduction in buildings5. It also specifies the required content of energy assessments needed to accompany major development proposals. An energy assessment has been undertaken in accordance with GLA guidance (Appendix J), which demonstrates that the development easily meets the required target of a 40% improvement on 2010 Building Regulations. Policy 5.3 – sustainable design and construction requires development proposals to demonstrate that sustainable design standards are integral to the proposal, including its construction and operation, and ensure that they are considered at the beginning of the design process. Major development proposals should meet the minimum standards outlined in the Mayor’s supplementary planning guidance and this should be clearly demonstrated within a design and access statement. The standards include the following sustainable design principles: minimising carbon dioxide emissions across the site, including the building and services (such as heating and cooling systems) avoiding internal overheating and contributing to the urban heat island effect 5 expressed as minimum improvements over the Target Emission Rate (TER) outlined in the national Building Regulations leading to zero carbon non-domestic buildings from 2019 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 37 efficient use of natural resources (including water), including making the most of natural systems both within and around buildings minimising pollution (including noise, air and urban runoff) minimising the generation of waste and maximising reuse or recycling avoiding impacts from natural hazards (including flooding) ensuring developments are comfortable and secure for users, including avoiding the creation of adverse local climatic conditions securing sustainable procurement of materials, using local supplies where feasible, and promoting and protecting biodiversity and green infrastructure. The BREEAM assessment (Appendix I) and energy assessment (Appendix J) demonstrate how the proposed development minimises CO2 emissions, avoids overheating and minimises use of natural resources. Topic-specific assessments in this Environmental Statement explain how pollution has been minimised, natural hazards avoided and biodiversity enhanced. Policy 5.5 – decentralised energy networks contains an expectation for 25% of the heat and power used in London to be generated through the use of localised decentralised energy systems by 2025. Although the proposed development will be connected to the grid to export electricity, there is the potential for power and heat to be supplied to endusers more locally within the LSIP. Initial discussions have already taken place with one of the other occupiers on the LSIP who is interested in taking power from TGW2E through a private wire network. Policy 5.6 – decentralised energy in development proposals requires that development proposals evaluate the feasibility of Combined Heat and Power (CHP) systems, and where a new CHP system is appropriate also examine opportunities to extend the system beyond the site boundary to adjacent sites. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 38 The proposed development has been designed to maximise the conversion of input energy into electricity and to this end, produces very little waste heat that can be exported. However, there is a requirement for consideration of the potential for CHP as part of the Environmental Permit application (section 3.8) and it is recognised that there is a proposed heat transmission network along Choats Road and so the potential for export of heat will be evaluated in detail. Policy 5.7 – renewable energy includes an aim to increase the proportion of energy generated from renewable sources, thereby enabling projections for installed renewable energy capacity outlined in the Climate Change Mitigation and Energy Strategy and in supplementary planning guidance to be achieved in London. Within the framework of the energy hierarchy (Policy 5.2), major development proposals should provide a reduction in expected carbon dioxide emissions through the use of on-site renewable energy generation, where feasible. The purpose of the proposed development is to generate energy from waste. Policy 5.8 – innovative energy technologies encourages the more widespread use of innovative energy technologies to reduce use of fossil fuels and carbon dioxide emissions, which includes ‘the uptake of advanced conversion technologies such as … gasification … for the treatment of waste’. The proposed development utilises gasification, which is specifically referred to in this policy. Policy 5.10 – urban greening requires that development integrate green infrastructure into the design, which may include tree planting, green roofs and walls and soft landscaping. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 39 A landscape plan has been developed which includes tree planting and soft landscaping (section 9.4). Policy 5.11 – green roofs and development site environs requires that major development proposals should be designed to include roof, wall and site planting, especially green roofs and walls where feasible, to deliver as many of the following objectives as possible: adaptation to climate change (i.e. aiding cooling) sustainable urban drainage mitigation of climate change (i.e. aiding energy efficiency) enhancement of biodiversity accessible roof space improvements to appearance and resilience of the building growing food. The proposed development utilises sustainable urban drainage techniques and is highly energy efficient. A landscape plan has been designed which enhances biodiversity and improves the appearance of the development. Policy 5.12 – flood risk management requires that developments comply with the flood risk assessment and management requirements set out in the NPPF and have regard to measures proposed in Thames Estuary 2100 (TE2100 – see paragraph 5.55) and Catchment Flood Management Plans. The development complies with the flood risk assessment requirements set out in the NPPF as described in section 4.3.2 above. In the event of a flood, a safe haven can be provided for all personnel / visitors on site on the first floor of the office building. Policy 5.13 – sustainable drainage requires that developments utilise sustainable urban drainage systems (SUDS) wherever practicable, and should aim to achieve greenfield run-off rates and ensure that surface water run-off is managed in accordance with a specified drainage hierarchy. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 40 The proposed development includes surface water storage on site with run-off rates restricted in accordance with the measures set out in the flood risk assessment (section 12). Policy 5.16 – waste self-sufficiency aims to manage as much of London’s waste within London as practicable, working towards the equivalent of 100% of London’s waste within London by 2031 whilst also creating positive environmental and economic impacts from waste processing and working towards zero biodegradable or recyclable waste to landfill by 2031. The proposed development will take waste from London (section 5), thereby contributing to the target of set out in this policy and also creating positive environmental and economic impacts from waste processing. Policy 5.17 – waste capacity states that the Mayor supports the need to increase waste processing capacity in London and sets out criteria against which development proposals should be evaluated as follows: locational suitability proximity to the source of waste the nature of activity proposed and its scale a positive carbon outcome of waste treatment methods and technologies (including the transportation of waste, recyclates and waste derived products) resulting in greenhouse gas savings, particularly from treatment of waste derived products to generate energy the environmental impact on surrounding areas, particularly noise emissions, odour and visual impact and impact on water resources the full transport and environmental impact of all collection, transfer and disposal movements and, in particular, the scope to maximise the use of rail and water transport using the Blue Ribbon Network. The policy also lists developments that will be supported and includes: developments that contribute towards renewable energy generation, in particular the use of technologies that produce a renewable gas Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 41 developments for producing renewable energy from organic/biomass waste. Wherever possible, opportunities should be taken to provide combined heat and power and combined cooling heat and power. Boroughs are required to allocate sufficient land and identify waste management facilities to provide capacity to manage the tonnages of waste apportioned in this Plan. Land to manage borough waste apportionments should be brought forward through ‘…identifying sites in strategic industrial locations’. Waste is deemed to be managed in London if it is used for energy recovery in London, or it is compost or recyclate sorted or bulked in London material recycling facilities for reprocessing either in London or elsewhere. In terms of the criteria listed in this policy, the proposed development is in a suitable location, will treat London’s waste within London, has a positive carbon outcome and does not have any significant adverse effects on surrounding areas. The development is also of a type that is supported by this policy and is to be located on land specifically identified for waste management which has an extant planning consent for an identical use. Policy 5.21 – contaminated land supports the remediation of contaminated sites. The site and surrounding area has been the subject of extensive desk-based and intrusive investigations. The site has been remediated and mitigation measures recommended to address any remaining contamination (section 11) and therefore the proposed development complies with this policy. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 42 Chapter six – London’s transport Policy 6.3 – assessing effects of development on transport capacity requires that development proposals ensure that impacts on transport capacity and the transport network, at both a corridor and local level, are fully assessed with transport assessments undertaken in accordance with TfL Guidance for major planning applications. Travel plans, construction logistics plans and delivery and servicing plans should be secured in line with the London Freight Plan. The transport implications of the development have been assessed in section 10 and a draft travel plan prepared (Appendix F). It is assumed that a construction logistics and deliveries and servicing plan will be secured by way of condition. Policy 6.9 – cycling requires that developments should inter alia provide secure, integrated and accessible cycle parking facilities in line with specified minimum standards, and on-site changing facilities and showers for cyclists with the aim of encouraging and promoting cycling in London. The development will provide secure cycle parking facilities for twenty cycles. Changing facilities and showers for staff are provided. Policy 6.13 – parking standards sets out the maximum number of car parking spaces and minimum numbers of spaces for cycles, disabled places and electric vehicle charging points to be provided in developments. The number of parking spaces proposed at eighteen is in line with this policy, whilst the number of cycle places provided (twenty) slightly exceeds the minimum requirement of one space / 500m2 floorspace (eighteen spaces required). Disabled places and electric vehicle parking points comply with the requirement set out in the policy, with two disabled spaces and six for electric vehicles (four active and two passive) respectively. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 43 Chapter seven - London’s living places and spaces Policy 7.6 – architecture requires that architecture make a positive contribution to a coherent public realm, streetscape and wider cityscape, incorporating the highest quality materials and design appropriate to its context. Buildings and structures should: be of the highest architectural quality be of a proportion, composition, scale and orientation that enhances, activates and appropriately defines the public realm comprise details and materials that complement, not necessarily replicate, the local architectural character not cause unacceptable harm to the amenity of surrounding land and buildings, particularly residential buildings, in relation to privacy, overshadowing, wind and microclimate. This is particularly important for tall buildings incorporate best practice in resource management and climate change mitigation and adaptation provide high quality indoor and outdoor spaces and integrate well with the surrounding streets and open spaces be adaptable to different activities and land uses, particularly at ground level meet the principles of inclusive design optimise the potential of sites The accompanying design and access statement explains how the proposed development meets the requirements of this policy. Policy 7.8 heritage assets and archaeology requires development proposals to identify, value, conserve, restore, re-use and incorporate heritage assets, where appropriate and make provision for the protection of archaeological resources, landscapes and significant memorials. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 44 A programme of archaeological investigation has been undertaken, which found no archaeological remains and concluded that the site was of limited archaeological potential. LBBD confirmed in its scoping opinion (Appendix B) that archaeology / heritage did not need to be addressed in this application. Policy 7.14 improving air quality requires development proposals to: promote sustainable design and construction to reduce emissions from the demolition and construction of buildings following best practice guidance be at least ‘air quality neutral’ and not lead to further deterioration of existing poor air quality (such as areas designated as Air Quality Management Areas (AQMAs)). ensure that where provision needs to be made to reduce emissions from a development, this is usually made on-site. provide a detailed air quality assessment and forecast pollutant concentrations where required. A detailed air quality assessment has been undertaken (section 6), which demonstrates that the maximum predicted concentrations of all substances comply with relevant air quality objectives at nearby sensitive locations and the impact of the proposed development is considered to be insignificant. A Construction and Environmental Management Plan (CEMP) will be produced, which will detail measures to control air quality during the construction period (section 3.9). Policy 7.15 – reducing noise and enhancing soundscapes seeks to reduce the potential adverse impacts of noise from development proposals through design, location, screening and promotion of new technologies and improved practices to reduce noise at source. A noise assessment has been undertaken (section 7) which demonstrates that the proposed development will not have any adverse impacts on the nearest residential receptors. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 45 Policy 7.19 – biodiversity and access to nature requires that wherever possible, developments should not adversely affect protected sites / species and should make a positive contribution to the protection, enhancement, creation and management of biodiversity with a focus on assisting the achievement of targets in biodiversity action plans (BAPs). Section 9 demonstrates that the proposed development will not adversely affect protected species or sites. The proposed landscape plan will create new habitats on the site, with a focus on selecting species in the wildflower mixes to support identified priority invertebrate species (section 9.4). Policy 7.26 - increasing the use of the Blue Ribbon Network for freight transport requires that development proposals close to navigable waterways should maximise water transport for bulk materials, particularly during demolition and construction phases. Waste for processing at the proposed development will be delivered from a number of sources in the London area, including from a facility within 5 km of the proposed development, and it is therefore not practicable to use the water network during operation. Detailed consideration will be given to the potential use of the water network for delivery of certain bulk construction materials or key items of plant during the detailed design phase. 4.4.3 The Barking and Dagenham Core Strategy The Core Strategy contains thirteen strategic objectives and a spatial strategy built around five themes: Managing Growth; Sustainable Resources and the Environment; Creating a Sense of Community; Ensuring a Vibrant Economy and Attractive Town Centres; and Creating a Sense of Place. Policies relevant to the proposed development are set out below. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 46 Managing growth Policy CM1 – general principles for development notes that employment growth will be focussed on Dagenham Dock. The proposed development lies within the Dagenham Dock area. Sustainable resources and the environment Policy CR1 – climate change and environmental management sets out measures to contribute towards global, national, regional and local sustainability, and in particular to address the causes and potential impacts of climate change. These measures include: Requiring all new development to meet high environmental building standards and encourage low and zero carbon developments. Promoting sustainable waste management. Protecting water and air quality. Promoting the remediation of contaminated land. The proposed development complies with this policy as follows: It is a low carbon development, which meets BREEAM excellent (section 13) It promotes sustainable waste management by recovering energy from waste generated in the local area The enclosed nature of the process (section 3.7) and emissions control systems ensure that there are no significant adverse impacts on air / water quality (section 6 and section 12 respectively). The remaining pollutant linkages resulting from in-ground contamination will be removed (section 11). Policy CR3 – sustainable waste management states that the Borough will seek to manage waste in a sustainable way and to help achieve national targets through prioritising waste reduction, re-use, recycling Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park and 47 composting, new and emerging recovery technologies and conventional incineration over landfill, which will only be considered acceptable as a last resort. Appropriate existing waste management capacity will be safeguarded and preferred sites identified for new facilities as set out in the Joint Waste DPD. The proposed development complies with the aims of this policy and is to be located on a safeguarded site as identified in the Joint Waste DPD. Policy CR4 - flood management contains a presumption against development that places people and property at risk from flooding, or which would have an adverse impact on watercourses. A Flood Risk Assessment will be required for all proposals for new development in flood zones 2 (medium probability) and 3 (high probability). The development lies in flood zone 3 but an FRA has already been undertaken in relation to the extant consent, and LBBD has confirmed that no further consideration of flood risk is required; the proposed development complies with the mitigation measures set out in the FRA (section 12). Ensuring a vibrant economy and attractive town centres Policy CE3 – safeguarding and release of employment land states that the Council will safeguard, promote and manage the Strategic Industrial Locations at … Dagenham Dock. Land within these locations will not be released for other purposes. The proposed development is specifically identified as a suitable enduse for SIL land in Dagenham Dock. Policy CE4 – mix and balance of uses within designated employment areas states that proposals to establish recycling and reprocessing activities and other industries in the environmental business sector are particularly Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 48 encouraged within the Dagenham Dock area which will be developed and promoted as a Sustainable Industries Park. The proposed development is within the environmental business sector and will enable the recovery of high quality metals from the process. Creating a sense of place Policy CP3 – high quality built environment sets out requirements for high quality standards in relation to the design and layout of new buildings and spaces. Requirements relevant to the proposed development are as follows: New developments should achieve a high standard of inclusive design. It should be legible, usable and permeable, and accessible to all those who may need to use them. The safety of occupants, visitors and passers-by should be considered in the design of all development, and all reasonable efforts taken in the design and planning processes to prevent crime and minimise fear of crime. This should be undertaken in liaison with the Council’s crime prevention design officer. All new development should conform to the highest standards of sustainable design. Development should respect and strengthen local character and history and provide a sense of place. Buildings and spaces should be functional, durable, flexible and adaptable. Inclusive design and sustainability are discussed in the accompanying design and access statement. Safety of all people visiting and working at the site has been a key consideration in the development of the layout. Crime prevention has been considered in the specification of the fencing (a taller fence on the northern boundary for example) and in requirements for CCTV Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 49 and lighting. The site will be operational and manned 24 hours / day, which will reduce opportunities for crime. 4.4.4 Supplementary planning guidance Green infrastructure and open environments: The all London green grid The All London Green Grid (ALGG) SPG aims to promote green infrastructure in the form of a ‘green grid’ – an integrated network of linked green and open spaces together with the Blue Ribbon Network of rivers and waterways across London. The Epping Forest and Roding Valley Green Grid Area (GGA) includes two strategic links in the vicinity of the proposed development; the Goresbrook Link and the London Riverside Link. 4.4.5 Barking and Dagenham borough-wide development policies DPD The borough-wide development policies development plan document (DPD) was adopted in March 2011 and contains detailed policies that build on the content of the Core Strategy (section 4.4.3) and London Plan (section 4.4.2) above. Policies are set out in chapters under the same headings as the core strategy; those directly relevant to the proposed development are summarised below. Sustainable resources and the environment BR1 – environmental building standards states that all developments are expected to meet high standards of sustainable design and construction. Applicants for all major and strategic developments must produce an environmental assessment such as the Building Research Establishment’s Environmental Assessment Method (BREEAM). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 50 Minimum standards for non-housing development under BREEAM are very good – excellent for major development. The policy notes that there may be exceptional circumstances, for example due to economic viability, where achieving targets in this policy is not appropriate. A BREEAM assessment has been undertaken (section 13), which demonstrates that the proposed development achieves a rating of excellent. BR2 – energy and on-site renewables sets out requirements for major and strategic development to demonstrate in an energy assessment that heating, cooling and power systems have been selected to minimise CO2 emissions. An energy assessment has been undertaken (Appendix J), which demonstrates that CO2 emissions are minimised in accordance with this policy. BR3 – greening the urban environment states that where there are no existing features of nature conservation on a site, development should seek to create nature conservation enhancements to help ‘green the urban environment’. Examples of enhancements include the provision of green walls, bio-diverse green roofs, wildlife gardens, buffer strips, nesting, and roosting boxes and commitment to the implementation of a Habitat Management Plan. The landscape plan prepared for the proposed development creates a number of new habitats on the site, with a focus on selecting species to support identified priority invertebrate species. It includes wildlife gardens, nesting and roosting boxes and a five-year ecological mitigation and maintenance plan (EMMP) will be produced (section 9.4). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 51 BR4 – water resource management requires development to ensure that greenfield surface water run-off rates are achieved, where possible, through the use of SUDS. New development will be expected to achieve a high standard of water efficiency, by incorporating appropriate measures to minimise water use. The drainage strategy for the proposed development has been designed to comply with the overall site drainage strategy for the LSIP. The surface water discharge rate from the site has been limited to a greenfield rate as agreed with the Environment Agency. The SUDS strategy is based upon attenuated surface water to final discharge into public sewer incorporating rainwater harvesting for use on site where possible (section 12). BR5 - contaminated land states that development on or near land that is known to be contaminated or which may be affected by contamination will only be permitted where an appropriate site investigation and risk assessment (agreed by the local planning authority) has been carried out. If contamination is found which would pose an unacceptable risk, the Council will impose a condition to ensure the applicant undertakes appropriate remedial measures to ensure that the site is suitable for the proposed end use and the development can safely proceed. A site investigation has been undertaken (section 11), which demonstrates that small number of pollutant linkages that exist will be removed by the development and that there are no significant risks to human health for the site’s end users once the development is completed BR9 – parking states that the car and cycle parking standards set out in the London Plan and TfL guidance will be used. Parking has been provided in accordance with the relevant standards. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 52 BR10 – sustainable transport requires developers to submit a transport statement where there are any identifiable transport impacts or a transport assessment and a travel plan where there are significant transport implications (in accordance with the London Plan). The transport impacts of the proposed development have been assessed (section 10) and a draft travel plan prepared. BR11 – walking and cycling requires that the design and layout of new development take account of the needs of cyclists and walkers by providing inter alia: Safe, secure, convenient, accessible and direct access for pedestrians and cyclists to, from and within development. Sufficient, convenient, safe, secure and where possible integrated, cycle parking facilities. Provision of safe walkways and cycleways, segregated from HGV traffic has been a key consideration in the development of the layout. Cycle storage is in two locations in the proposed development; adjacent to the office entrance for office-based staff and adjacent to the materials reception building for operational employees. BR13 – noise mitigation states that if it is not possible to fully separate noise sensitive and noise generating land uses, planning permission will only be granted if there will be no exposure to noise above an acceptable level. Measures should be taken to minimise noise and mitigate its impact in accordance with the London Plan. A noise assessment has been undertaken which demonstrates that the proposed development will have no adverse impact on the nearest offsite sensitive receptors. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 53 BR14 - air quality requires the submission of an air quality impact assessment if a development is likely to have a significant negative impact on air quality. Permission will only be granted where mitigation measures are introduced which bring the levels of air pollution to an acceptable level. An air quality assessment has been undertaken (section 6), which demonstrates that the development will not have a significant negative impact on air quality. BR15 - sustainable waste management sets out a series of measures by which sustainable waste management will be achieved, which includes: Using waste as a resource, including for the generation of energy, wherever possible. Prioritising waste management according to the waste hierarchy Ensuring all waste is handled in the most sustainable manner, without endangering human health or harming the natural environment. Ensuring sufficient and timely provision of waste management facilities in appropriate locations, including for waste disposal, to meet the needs of communities and accommodate waste management capacity requirements for at least the next 10 years. Ensuring new waste management facilities do not detract from the quality or character of distinct areas. The proposed development uses waste as a resource for the generation of energy. The topic-specific assessments in this EIA demonstrate that there will be no harm to human health or the natural environment as a result of the development. The visual impact assessment demonstrates that it will not detract from the quality of character of the area. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 54 Creating a sense of place BP8 – protecting residential amenity requires that developments have regard to the local character of an area and ensure that existing and proposed occupiers are not exposed to unacceptable levels of pollution, disturbance or significant overshadowing. The design of the proposed development is described in the accompanying Design and Access Statement; key features such as the concealment of pitched roofs behind a parapet reflects the design on previously consented developments in the LSIP. Detailed topic-specific assessments in subsequent chapters demonstrate that the proposed development would not lead to significant offsite impacts on air quality, noise, shadowing etc BP11 – urban design sets out a series of principles that new developments need to address in both layout and design. These principles include requirements for high quality architecture and landscaping, accessible and inclusive features, safe environments, sustainable design and construction features, and integration of renewable energy features. The accompanying design and access statement, visual impact assessment, landscape scheme and energy assessment all show that the development addresses the required principles. 4.4.6 Statement of community involvement LBBD’s Statement of Community Involvement (SCI) sets out the Council’s policy for involving communities in the planning process, both in the preparation of planning documents and in considering applications for planning permission. Minimum standards for consultation for applications accompanied by an Environmental Statement comprise advertisement in the local newspaper and a site notice or neighbour notification. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 55 The Council encourages developers to engage in pre-application discussions on proposals before submitting a planning application. Applicants are also encouraged to engage in pre-application consultation with the community, particularly for applications, which may have an impact on the local community. Developers should ensure the Council is aware that consultation is being undertaken, and should disseminate the results including details of what involvement was carried out and who was involved. Detailed discussions have taken place with LBBD and the GLA throughout the preparation of the planning application. A community exhibition was held on 10 December at Barking Learning Centre. A notice was placed in the Barking and Dagenham Post and fliers advertising the event sent to some 765 properties. A summary of the event is given in Appendix K. 4.4.7 The East London Joint Waste DPD The joint waste development plan document (DPD) for the four East London Waste Authority (ELWA) boroughs (Barking and Dagenham, Havering, Newham and Redbridge) was adopted by LBBD in February 2012. The Joint Waste DPD is part of each borough’s Local Plan / Local Development Framework, however it differs from other borough DPDs as it sets waste management targets and allocates sites suitable for waste development for implementation across all of the four boroughs. Each of the four ELWA borough core strategies contains a strategic policy, which sets the framework for the joint waste DPD. The vision for the East London Joint Waste DPD is that it ‘aims to manage waste produced in the boroughs of Barking and Dagenham, Havering, Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 56 Newham and Redbridge in line with the growth set out in the boroughs’ adopted and emerging Local Development Framework Core Strategies … and identifies required levels of waste management capacity, which can be delivered by 2021 … Boroughs will work with the Mayor of London to deliver his aspiration that no untreated waste will go directly to landfill, as set out in London’s emerging Waste Strategy. The Joint Waste Plan will deliver sustainable development by addressing waste as a resource without endangering health or harming the environment. In dealing with waste, boroughs will ensure that well designed, high quality waste facilities are developed, including the promotion of green industries, which integrate with and complement opportunities for regeneration across East London’. The Joint Waste DPD has eight objectives, as follows: A. Deliver sustainable development by driving waste management up the waste hierarchy, addressing waste as a resource and looking to disposal as the last option, while recognising that disposal must be adequately catered for. B. Work towards meeting targets set out in the Waste Strategy for England 2007, and the London Plan. C. Enable the provision of a range of waste technologies. D. Enable the provision of facilities to allow for net self-sufficiency in the ELWA boroughs in accordance with the London Plan. E. Enable waste to be managed in one of the nearest appropriate installations without endangering health or harming the environment. F. Integrate waste planning with other spatial concerns, including regeneration plans. G. Reverse the historical trend of the ELWA area being the dumping ground for London’s waste. H. Encourage our communities to take more responsibility for their waste. The proposed development is in accordance with these objectives. It drives waste management up the hierarchy by enabling energy to be recovered from waste, which would otherwise be landfilled, and for valuable recyclables Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 57 to be recovered from that waste. It will help to meet policy targets for recovery, enable waste to be managed in a local installation and will bring a new waste technology to the ELWA area. Policy W2 - waste management capacity, apportionment and site allocation sets out the two measures by which the ELWA boroughs will meet their London Plan apportionment: Safeguarding the capacity of existing waste management facilities listed in Schedule 1 and encouraging increased processing of waste at these facilities Approving strategic waste management facilities where it will contribute to the ELWA boroughs meeting the London Plan apportionment on sites within the locations listed in Schedule 2. In all cases applications will be required to meet the relevant borough design guidance and Policy W5. The LSIP is specifically identified as a safeguarded site suitable for waste management uses in Schedule 2 of the Waste DPD. Furthermore, the extant consent application is specifically referred to in Schedule 2. The development is a strategic waste management facility, which will significantly contribute to London Plan apportionment. Policy W3 - energy recovery facilities states that applications for advanced treatment technologies will only be considered where the waste cannot practicably and reasonably be reused, recycled or processed and where there is provision for energy recovery and co-location with complementary facilities. Facilities will be required to meet relevant design guidance and requirements of Policy W5. The residual waste to be treated by the proposed development is currently landfilled; there are no suitable processing facilities for this residual waste and energy recovery is the most appropriate treatment option. The proposed development will further enable recovery of recyclable materials from the Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 58 waste after processing. The LSIP has been developed to encourage and promote green economy businesses to the area and it will therefore be colocated with complementary facilities. Policy W5 - General considerations with regard to waste proposals states that planning permission will only be granted where it can be demonstrated that there are no significant adverse impacts on people, land, infrastructure and resources. The policy also sets out information that may be required to accompany a planning application dependent on the proposals and its location. The topic-specific assessments in this ES demonstrate that there are no significant adverse impacts that would result from the proposed development. 4.5 Issue-specific policy analysis The policy analysis above has considered the extent to which the proposals comply with relevant policies assessed on a plan-by-plan basis. This section groups the analysis under a series of key issue headings. 4.5.1 Land use The site is specifically allocated for industrial development as a strategic industrial location (Policy 2.17 London Plan and Policy CE3 LBBD Core Strategy) and a suitable use of the site is further defined as ‘waste management and environmental industries (such as renewable energy generation)’. Policy CE4 of the LBBD Core Strategy specifically encourages environmental sector businesses in the Dagenham Dock area whilst Policy W2 of the Joint Waste DPD specifically identifies the LSIP as a safeguarded site with specific reference to the extant consent in Schedule 2. The proposed development is therefore an appropriate use of the site that is fully in accordance with policy. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 59 4.5.2 Economy Policy 1 NPPF commits to ensuring the planning system does everything possible to support sustainable economic growth and to meet the challenges of inter alia a low carbon future. The proposed development directly supports this policy; not only does it create a significant number of new jobs but these jobs will themselves directly contribute to a low carbon future. At a local level, London Plan Policies 4.1 and 4.12 and LBBD Core strategy SO.5 encourage local employment opportunities whilst LBBD Core Strategy Policy CM1 states that employment opportunities in the borough will be focussed on Dagenham Dock and London Plan policy 4.10 requires that green enterprise districts such as Thames Gateway are supported. TGW2E has committed to working with LBBD and Dagenham college to maximise local employment and training opportunities. 4.5.3 Climate change, renewable energy and decentralised energy Various policies state a presumption in favour of, or at the very least encourage, renewable energy schemes (Policies 1 and 10 NPPF, London Plan policies 5.7 and 5.8, policy CR1 LBBD core strategy) and require developments to minimise carbon dioxide emissions (Policies 5.1 and 5.2 London Plan, policy BR2 LBBD DPD) whilst London Plan policies 5.5 and 5.6 set targets for decentralised energy and require the consideration of combined heat and power (CHP) in development proposals. The proposed development will generate renewable energy from waste which would otherwise be landfilled and is therefore directly supported by these policies. The energy statement (Appendix J) demonstrates the significant carbon dioxide (CO2) savings that result from the development. The proposed development has been designed to maximise electricity production but the potential for heat export will be kept under review. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 60 4.5.4 Waste management London Plan policy 5.16 seeks to manage as much of London’s waste within London as practicable. London Plan policy 5.17, LBBD Core Strategy Policy CR3, LBBD DPD Policy BR15 and Joint Waste DPD Policies W2, W3 and W5 relate to sustainable management of waste in accordance with the proximity principle and the waste hierarchy, support the need for new waste management infrastructure and set out measures against which waste development proposals will be assessed. Under London Plan policy 5.17, boroughs are required to identify and safeguard sufficient land to manage their waste apportionment under the London Plan. The proposed development will help to reduce the amount of London’s waste that is sent outside the capital for final treatment (section 5). It will treat residual waste, which would otherwise be landfilled, and will enable the recovery of valuable recyclables and is therefore in accordance with the waste hierarchy. The location is on a site safeguarded for such as use in the Joint Waste DPD. 4.5.5 Design and appearance Policy 7 NPPF, Policies 5.3 and 7.6 in the London Plan, Policy CP3 LBBD Core Strategy and Policy BR1 and BP8 LBBD DPD all relate to design and require developments to accord with principles of sustainability in design as well as set out general design criteria against which applications will be assessed. The design philosophy of the development is addressed in the accompanying Design and Access Statement. The overall layout of the development has been driven by the need to maximise utilisation of the site for the range of uses proposed and to ensure appropriate segregation of HGV traffic on site and the safety of all working / visiting. Within these constraints, careful thought has been given to maximising the amount of landscaping that can be provided and ensuring Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 61 that the landscaping enhances biodiversity through the creation of new habitats. Given the size of the proposed development it has not been possible to completely eliminate its visual impact (section 8) although the use of landscaping and surface treatments goes someway to ameliorating the impact. A BREEAM pre-assessment has been undertaken which confirms that the development should achieve an ‘excellent rating (section 13). 4.5.6 Ecology and nature conservation There is a raft of policies which seek to ensure that new development provides appropriate landscaping and new biodiversity features and protects or enhances existing features and designated sites where appropriate (e.g. Policy 11 NPPF, policies 5.10, 5.11 and 7.19 London Plan, policy BR3 LBBD DPD). A detailed scheme has been prepared which adds new biodiversity features and complements and enhances the existing landscaping on the wider LSIP (section 9). An ecological mitigation and management plan will be prepared and it is assumed that long-term management of the landscaped areas on site will be secured by an appropriate planning condition. The air quality assessment has included consideration of designated sites around the proposed development and has demonstrated that there is no impact on any of the sites from emissions from the stack (section 6). 4.5.7 Traffic and transport Policy 4 NPPF, policies 6.3, 6.9 and 6.13 in the London Plan, policies BR9, BR10 and BR11 in the Barking and Dagenham DPD require the transport implications of developments to be appropriately considered and addressed Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 62 with an emphasis on reducing the need to travel where possible. London Plan policy 7.26 requires water transport is considered for proposals close to navigable waterways; given the origin of the infeed material, use of nearby wharves is not appropriate for the operational phase but will be investigated for construction. An assessment has been undertaken which has demonstrated that the network can accommodate the demand from the development (section 10). The nature of the proposed development is such that it is not practical for travel to be reduced by measures such as e.g. working from home. A draft travel plan has been prepared (Appendix F) however, which focuses on encouraging travel by more sustainable means; it is expected that implementation and on-going monitoring of the travel plan would be secured by way of condition. 4.5.8 Pollution Various policies (e.g. policy 11 NPPF, London Plan policies 5.21, 7.14 and 7.15, Policies BR5, BR13, BR14, BP8 in the LBBD DPD) relate to pollution in the widest sense i.e. encompassing air quality, noise, soil, water etc. and the desire to prevent new development from contributing to unacceptable levels of pollution. A range of detailed assessments have been undertaken and are described in subsequent sections and demonstrate that the development will not have a significant adverse impact on any off-site receptors e.g. potentially sensitive land uses such as nature conservation sites, ground and surface waters, residential receptors etc. 4.5.9 Water resources Policies 10 NPPF, 5.12 London Plan, and CR4 LBBD core strategy and all relate to development in areas at risk of flooding or development that would increase the risk of flooding elsewhere. Policy 5.13 London Plan and BR4 LBBD DPD require that developments use sustainable drainage systems (SUDS) where possible and reduce runoff to greenfield rates. A strategic Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 63 level FRA was undertaken for the whole of the LSIP and mitigation measures defined; the proposed development is in accordance with the strategic FRA and the drainage strategy incorporates SUDS measures and restricts runoff to agree rates (section 12). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 64 5 Land use 5.1 Introduction This section considers the need for the proposed development in terms of the amount of waste generated in London, current and proposed treatment options and capacity in London and, more specifically, the east London area and policy aims and targets for the management of London’s waste going forward to 2031. 5.2 Context The proposed development will generate some 19 MW of electricity from up to 180,000 tonnes of residual commercial and industrial (C&I) waste, which would otherwise be landfilled. Residual waste is that portion of the waste stream that is not reused, recycled or composted and remains to be treated through the recovery of energy and / or materials or through disposal to landfill. Residual waste will have undergone some form of segregation, recycling and processing to remove recyclable materials. Policy 5.16 of the London Plan relates to waste self-sufficiency and sets out strategic aims to inter alia manage as much of London’s waste within London as practicable, work towards managing the equivalent of 100% of London’s waste within London by 2031 and work towards zero biodegradable or recyclable waste to landfill by 2031. However, London currently exports a significant amount of waste generated within its boundaries. The Environment Agency estimates that of the 6.6 million tonnes of London’s waste that was landfilled in 20086, some 5.6 6 This figure includes commercial and industrial, construction, demolition and excavation and municipal waste Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 65 million tonnes (85%) was transported outside of the region to the south east and east of England. Of the total landfilled, around 48% is unsegregated, mixed waste. 5.3 East London Waste Authority projected arisings and apportionment Table 5.2 in the London Plan gives municipal and C&I waste projections at Borough level at key milestones through to 2031 as shown in the excerpt for the four ELWA Boroughs contained in Table 1 below. Table 1: London Plan projected waste arisings at key milestones 2011 Borough 2016 2021 2026 2031 MSW C&I MSW C&I MSW C&I MSW C&I MSW C&I Barking & Dagenham 103 74 113 72 123 75 133 79 141 81 Havering 135 132 143 130 152 126 160 126 168 125 Newham 154 123 170 123 186 124 202 124 215 127 Redbridge 123 114 128 109 134 104 139 98 143 95 Total 958 988 1024 1061 1095 Table 5.3 in the London Plan then apportions waste to be managed in London across all the boroughs. The amounts to be managed by the ELWA boroughs are as shown in Table 2 below. Table 2: London Plan apportionment of waste to be managed by ELWA boroughs 2011 Apportion- Borough 1 2016 2021 2026 2031 ment MSW C&I MSW C&I MSW C&I MSW C&I MSW C&I 6.1 159 283 194 309 230 336 270 366 309 399 Havering 4.0 105 187 128 204 152 222 178 241 204 263 Newham 4.9 129 229 156 249 186 272 218 296 250 323 Redbridge 1.9 87 60 95 71 104 83 113 95 123 Barking & Dagenham 49 Total 1,228 1,395 1,573 1,765 1,966 1: % share of waste to be managed in London London Plan Policy 5.17 requires the Joint Waste DPD to identify sufficient land to provide capacity to manage the apportioned tonnages of municipal solid waste (MSW) and commercial and industrial (C&I) waste. Waste is Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 66 deemed to be managed in London if it is used for energy recovery in London, or it is compost or recyclate sorted or bulked in London material recycling facilities for reprocessing either in London or elsewhere. Taking into account the reduced apportionment in the London Plan (2011), Policy W2 of the joint waste DPD sets out that the ELWA boroughs will need to provide sufficient waste management capacity for municipal and commercial and industrial waste as follows: 1.228 million tonnes in 2011 1.395 million tonnes in 2016 1.573 millions tonnes in 2021 Table 2 of the Joint Waste DPD lists existing waste management capacity in the ELWA area7. There is one facility listed under incineration taking clinical waste with an annual permitted tonnage of 7,000 tonnes, which translates as a throughput of 5,250 tonnes8. The number and mix of facilities that will be required within the ELWA area is dependent not only on the amount of waste that will require treatment but also how it is treated. Targets for recycling, composting, recovery etc are set in Waste Strategy 2000 and the London Plan. Additionally, the ELWA boroughs have planned on the basis that waste which is not recycled or composted is recovered and therefore no waste will go to landfill. Based on this approach for the management of waste in the ELWA area, and the existing waste management capacity, the ELWA boroughs need to provide capacity as summarised in 7 Date is not given but assumed to be 2011 It is generally accepted that most facilities are licensed for a throughput in excess of what they achieve in practice. As there is considerable uncertainty surrounding actual throughput and little available data, the Joint Waste DPD Technical Report uses an estimate for actual throughput of 75% of maximum available capacity to maintain consistency with data used in the London Plan. 8 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 67 Table 3 below in order to manage the apportionment of MSW and C&I waste in the London Plan (2011). The figures in Table 3 are based on an assumption of 75% utilisation of existing facilities. Table 3: Summary of average capacity surplus/deficit within the ELWA boroughs required to meet the London Plan apportionment Waste management route Recycling (MSW and C&I) Composting (MSW and C&I) Recovery (all facilities) Capacity required 2011 786,203 -47,440 -262,710 2016 674,313 -109,170 -256,090 2021 415,428 -320,255 -269,370 Bold text is deficit in capacity Italic is surplus ‘Recovery’ is defined in the waste DPD as obtaining value from waste through one of the following means: Recycling Composting Other forms of material recovery (such as anaerobic digestion) Energy recovery (combustion with direct or indirect use of the energy produced, manufacture of refuse derived fuel, gasification, pyrolysis, or other technologies). Table 3 clearly shows that there is a projected deficit in recovery facilities within the ELWA boroughs and therefore that without additional capacity the London Plan apportionment for recovery will not be met. 5.4 Existing and proposed facilities in the ELWA area Since the figures in Table 3 were derived, three recovery facilities, all in the LSIP, have received planning consent TEG Environmental composting and anaerobic digestion facility Cyclamax energy generation facility Refood UK Ltd anaerobic digestion facility Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 68 In the Officer’s report for the Refood application (application ref 13/00649/FUL, para 6.1.10) it was noted that this proposal (i.e. Refood) ‘would result in a total of 330,000 tpa of consented recovery capacity which is over the 270,000 tpa recovery capacity gap identified in the JWDPD. It is important to stress though that PPS10 regards apportionments as a benchmark for the preparation of local development documents and the focus of the JWDPD is on identifying a suitable range of sites with sufficient flexibility to meet the apportionment…Therefore whilst this proposal surpasses the capacity gap by 60,000 tpa it is not considered reasonable to assess this element as non-apportioned waste under policy W5 of the JWDPD as this would be treating the apportionment as a maximum target rather than a benchmark contrary to PPS10’. However, given that the figures for capacity used in the London Plan and the JWDPD assume an actual throughput of 75% of maximum available capacity to maintain consistency with data used in the London Plan, the three facilities with planning consent actually represent a recovery capacity of 247,500 tonnes / year (assuming throughput is 75% of maximum available (consented) capacity of 330,000 tonnes / year as above). The Cyclamax consent has obviously not been implemented and will be superseded by the proposed development, with a maximum throughput of 180,000 tonnes / year i.e. an increase of 45,000 tonnes capacity over the total of 247,500 tonnes / year given above, which is 22,500 tonnes above the capacity gap. The proposed development would therefore result in an overprovision of capacity in the ELWA area. However, as the extract from the Officer’s report cited above clearly states, it is not considered reasonable to assess this additional tonnage as non-apportioned waste as that would be treating apportionment as a maximum target. Given the support for energy recovery schemes, particularly in the LSIP, it would also conflict with a range of policies in the London Plan and LBBD core strategy and borough-wide DPD. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 69 A further factor that needs consideration is that the London Plan and JWDPD combine MSW and C&I waste streams to enable assessment of capacity required. Schedule 1 of the JWDPD lists existing waste management facilities. Five facilities are listed under the ‘recovery’ heading in Schedule 1 as shown in Table 4 below. Table 4: Recovery facilities given in Schedule 1 of the joint waste DPD Facility name Borough Facility type Hunts Wharf Barking & Dagenham Redbridge A16 – Physical Treatment Facility Annual permitted tonnage (tonnes) 150,000 A18 – Incinerator (Clinical Waste) 7,000 Havering 90,000 Havering A17 - Physico-chemical Treatment Facility (gasification) A23 – Biological Treatment Facility Newham A23 – Biological Treatment Facility 99,840 Clinical Waste Ltd (Goodmayes Hospital) Novera Gasification (Frog Island) Frog Island Bio-MRF Jenkins Lane Bio-MRF 93,600 The Frog Island and Jenkins Lane Bio-MRF facilities treat municipal waste as part of Shanks’ long-term contract with ELWA whilst the ‘Novera’ (now Biossence) gasification facility is not yet built; revised planning consent was received March 2013. It is understood that it will use the refused derived fuel produced by the ELWA facilities at Frog Island and Jenkins Lane. Therefore, even though the throughput at these facilities is used to derive the overall capacity requirements for MSW and C&I waste, in practice, these facilities are not available for the commercial and industrial residual waste arisings, which would be treated at the proposed TGW2E facility. Although the projected figures given in the above analysis indicate that the ELWA area is providing slightly in excess of its apportionment, these figures just relate to broad categories of treatment e.g. recycling, recovery etc. All wastes are not equal and different treatment options are needed for different waste streams. For example, whilst both AD and gasification are classed as Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 70 recovery, the AD processes operated by TEG Environmental and Refood, will take food / wet organic wastes, whereas the proposed TGW2E development will take much drier mixed residual wastes and RDF type wastes. The waste to be treated by TGW2E would not be suitable for AD nor would TGW2E seek to take the wet organic waste streams targeted by TEG or Refood. 5.5 Mayor’s Business Waste Strategy for London Making Business Sense of Waste – The Mayor’s Business Waste Strategy (MBWS) for London was published in November 2011. There is no statutory requirement for a Business Waste Strategy but given that business waste accounts for around 80% of solid waste generated in London, in order to ‘fully realise the economic and environmental value of waste as a resource, London requires a truly holistic approach to managing all of the waste that it generates’ and not just waste from local authority collected sources, which is addressed in the statutory Mayor’s Municipal Waste Management Strategy. The MBWS sets out the Mayor’s vision for the management of London’s business waste and contains three overriding aims: Focus on waste reduction and more efficient management of resources to reduce the financial and environmental impact of waste Manage as much of London’s waste within its boundaries as practicable by taking a strategic approach to developing new capacity Boost recycling performance and energy generation to deliver environmental and economic benefits to London. The strategy contains four policies to help deliver the aims as follows: 1: Promoting the commercial value of a resource efficient business 2: Boosting reuse, recycling and composting participation in the commercial and industrial sector Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 71 3: Supporting the waste infrastructure market in London to grow and deliver for businesses 4: Drive improvements in resource efficiency in the construction and demolition sector while continuing to maintain the good levels of reuse and recycling performance already achieved. In 2010, London generated 6,496,000 tonnes of C&I waste. Some 17% of C&I waste is known to be landfilled but there is a further 17% whose destination is unknown, which equates to some 1.1 million tonnes landfilled and a further 1.1 million tonnes whose destination is unknown. Some 74% of the industrial waste element and 37% of the commercial waste element respectively was in the form of mixed general waste; the MBWS considers it likely that a proportion of this waste could be segregated for reuse, recycling, composting or other recovery; this mixed general waste is precisely the waste stream that will be targeted by the proposed TGW2E development. The proposed TGW2E technology also means that metals, glass and aggregates present in this general mixed waste can be recovered. Policy 3 is directly relevant to the proposed development. The policy vision is to ‘…assist the development of new waste infrastructure, which will help to manage London’s business waste within the capital, so that there is less reliance on landfill…’ The MBWS sets out the projected commercial and industrial waste infrastructure gap for the whole of London. Table 5: Projected commercial and industrial waste infrastructure capacity gap Infrastructure capacity gap (tonnes) Facility type 2015 2020 2031 Materials reclamation facility (MRF) 1,835,000 2,259,000 2,282,000 Composting and anaerobic digestion 648,000 819,000 880,000 Mechanical biological treatment 542,000 505,000 1,904,000 338,000 238,000 1,175,000 New energy generation 1 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 72 Infrastructure capacity gap (tonnes) Facility type Thermal treatment 2 Total 2015 2020 2031 361,000 302,000 479,000 3,724,000 4,123,000 6,720,000 1: New energy generation is back-end thermal treatment capacity required for refuse-derived fuel produced following mechanical biological treatment of waste. 2: Thermal treatment exclude treatment capacity required for refuse-derived fuel produced following mechanical biological treatment of waste Table 5 clearly shows a need for energy generation infrastructure in London; the proposed development would make a significant contribution to closing this gap. The MBWS identifies two related key impediments in the development and delivery of infrastructure for the C&I waste sector: The lack of contracts available for significant amounts of C&I waste; businesses contract individually with waste management collection operators requiring a significant number of contracts to accrue sufficient waste for treatment. The short duration of feedstock supply contracts: businesses generally only enter into contracts for two - three years. Developments such as that proposed by TGW2E typically have a lifespan of twenty – thirty years and the sophisticated nature of the technology means very high capital costs. The proposed development will treat C&I waste and so the challenges identified in the MBWS are directly relevant. Discussions with local and national waste management companies (who have an extensive local presence) are agreements. at an advanced stage with respect to waste supply However, for precisely the reasons identified in the MBWS, specifically the short term nature of contracts, as well as commercial confidentiality, TGW2E is not in a position to publicly state which operator(s) will be providing the waste for the proposed development, given that it will Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 73 not be operational until 2015. Additional issues that make obtaining forward supply agreements exceedingly challenging are the time taken to obtain the necessary consents that can cause considerable delays to projects and the number of energy from waste schemes that have successful passed the planning and permitting hurdles but have not been implemented. TGW2E does have agreement in principle with a national waste operator to supply residual waste to the proposed development. Approximately one third of the throughput is C&I waste from the ELWA area; further waste is available from the same operator, which would come from north London. TGW2E is also keen to explore possibilities of taking residual waste from other operators and businesses on the LSIP. 5.6 Conclusion The analysis of projected waste arisings and treatment options in east London and the wider London area has demonstrated that there is a capacity gap. New infrastructure is needed in London required to meet the targets for selfsufficiency and recovery set in the London Plan. The proposed development will make a significant contribution to the targets and would not compete with existing and planned (consented) infrastructure in the east London area. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 74 6 Air quality 6.1 Introduction This section provides an overview of the existing legislation and assessment criteria in relation to air quality. The Local Air Quality Management (LAQM) review and assessment process is outlined together with a summary of the assessment findings and monitoring data for the Dagenham area. The impact of the proposed development on air quality is assessed and mitigation measures recommended as appropriate. The full air quality modelling and assessment report is included within Appendix C and the results summarised in this section. 6.2 Assessment criteria 6.2.1 Air quality limit values and objectives Air quality limit values and objectives in the UK can be split into four groups, each of which have different legal status and are handled in a different way within UK air quality policy: UK air quality objectives set down in regulations for the purpose of local air quality management (Air Quality (England) Regulations) UK air quality objectives not included in regulations EU Limit Values transcribed into UK legislation (Air Quality Limit Value Regulations) Air quality guidelines with no legal basis (e.g. World Health Organisation). The most recent version of the Air Quality Strategy (AQS) for England, Scotland, Wales and Northern Ireland was published in July 20079 and sets objectives for 10 pollutants10 to be achieved between 2003 and 2010. 9 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland (July, 2007) Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 75 The standards set out in the AQS are aimed primarily at the protection of human health. However, it also provides for standards for the protection of vegetation and ecosystems in respect of two of the pollutants (nitrogen dioxide and sulphur dioxide). The air quality standards in the UK are derived from the European Commission (EC) Directives, and adopted into English law via the Air Quality (England) Regulations 2000 and Air Quality (England) Amendment Regulations 2002. The European Union’s (EU) Framework Directive 96/62/EC on ambient air quality assessment and management was formally adopted on 27 September 1996 and had to be implemented by Member States by 21 May 1998. The Directive aims to protect human health and the environment by avoiding, reducing, or preventing harmful concentrations of air pollutants. As a Framework Directive it requires the Commission to propose “Daughter” Directives setting air quality objectives, limit values, alert thresholds and guidance on monitoring, siting and measurement for individual pollutants. To date there have been four “Daughter” Directives. In April 2008, the EU agreed and adopted a new European Air Quality Directive (2008/5O/EC). The Directive merges four Directives and one Council decision into a single directive on air quality. It sets standards and target dates for reducing concentrations of fine particulate matter (PM2.5), together with coarser particles known as PM10, which is already subject to legislation. The Air Quality Standards Regulations 200711 implement Council Directive 96/62/EC on ambient air quality assessment and management and all related Daughter Directives. Legislation is pending to implement the requirements of 10 Benzene, 1,3-butadiene, carbon monoxide, lead, oxides of nitrogen, ozone, particulate matter PM10 and PM2.5, polyaromatic hydrocarbons (PAH), sulphur dioxide 11 SI No. 2007/64 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 76 the new EU Air Quality Directive. The Environment Act 1995 places statutory duties on Local Authorities for Local Air Quality Management (LAQM) and requires Local Authorities to contribute to the achievement of AQS objectives and conduct periodic reviews and assessments of air quality. 6.2.2 Pollutants relevant to the proposed development The principal pollutants that will be released to atmosphere from the proposed development are: Oxides of nitrogen (NOx) Sulphur dioxide (SO2) Fine particulate matter (PM10) In addition to these pollutants, consideration is given to: Carbon monoxide (CO) Hydrogen chloride (HCl) Hydrogen fluoride (HF) Polychlorinated dibenzodioxins (dioxins, PCDD) Polychlorinated dibenzofurans (furans, PCDF) Metals Descriptions of these pollutants, including their effects on human health and relevant standard and guidelines values are given in Appendix C. 6.3 Existing conditions 6.3.1 LBBD air quality assessment and review The London Borough of Barking and Dagenham declared an Air Quality Management Area (AQMA) across the whole borough for nitrogen dioxide and particulates. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 77 6.4 Assessment of impact 6.4.1 Construction No demolition or site clearance is required for the proposed development. The closest residential properties to the proposed development are those off Shaw Gardens which are about 150 m to the north of the development. The Institute of Air Quality Management (IAQM) has published guidance on how to assess impacts of emissions of dust from demolition and constructions sites. This guidance has been followed in Table 6, which shows the steps undertaken to determine the risk of dust from construction giving rise to annoyance. Table 6: IAQM dust risk assessment methodology Step Step 1: Need for detailed assessment Outcome Assessment required due to proximity of sensitive receptors within 350 m Step 2: Assess the risk of dust effect Low risk site due to receptors at a distance of 150 m Step 3: Identify the need for site-specific Mitigation measures detailed in the GLA best mitigation practice guidance for Low Risk will be followed Step 4: Define effects and their Negligible impact (following mitigation) significance Given the distance to the closest sensitive receptors, the risk of dust annoyance occurring during construction is considered to be low. Following the implementation of appropriate mitigation measures the significance of the impacts is considered to be negligible. The effect on air quality of emissions to atmosphere from construction vehicles will be negligible. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 78 6.4.2 Operation The principal types of emissions to air that may result from operation of the proposed development are: Emissions associated with vehicle movements. Process emissions vented through the proposed facility’s stack. The potential impacts of these types of emissions are considered in turn below. 6.4.3 Vehicle movements The EPUK guidance for development control12 includes criteria for when an air quality assessment is required and states that an assessment is required when there is a change in AADT of more than 10% (or 5% in an AQMA). An assessment is also required if there is an increase in HGV movements of more than 200 per day. During operation there will be a maximum of ten deliveries per hour. Emissions to atmosphere from ten heavy duty vehicles (HDVs) per hour will not have a significant effect on air quality and will not be considered further. 6.4.4 Atmospheric dispersion modelling In order to quantify the potential impact of emissions from the process, and to determine the optimum stack height for dispersion, detailed atmospheric dispersion modelling using the industry standard atmospheric dispersion model ADMS version 5.0 has been undertaken. The full dispersion modelling report is included in Appendix C and results are summarised below. A detailed analysis was undertaken to assess the sensitivity of the predicted 12 EPUK (2010) Development Control for Air Quality (2010 Update). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 79 concentrations to inter alia variations in meteorological data, grid spacing, stack height and dispersion model used; the sensitivity analysis is included in Appendix C. Short term versus long term impacts Defra technical guidance13 states that for elevated point sources the focus of the assessment should be on short term impacts. However, for urban areas where the prevailing annual average concentration of nitrogen dioxide (NO2) are close to, or exceed, the Air Quality Strategy objectives, even for point sources, it is often the case that the increment to the annual average is of more significance that the short term impact. This is also because the effect on the 99.8th percentile can be negligible as peak ground level concentrations from point sources do not necessarily coincide with the peak background concentrations; the meteorological conditions that give rise to maximum ambient pollutant levels, e.g. still conditions, are not those that give rise to maximum impacts from point sources e.g. high wind speeds or unstable conditions. For this assessment equal weight is given to both long and short term impacts although it is considered that the increment to the annual average concentration is of greater significance than the short term impact. The assessment is undertaken for continuous full load normal emissions at the emissions limits. Receptor locations To determine the maximum ground level concentrations occurring due to emissions to atmosphere from the proposed facility and the distribution of impacts, predictions are made of ground level concentrations for a grid of receptors; making predictions for a grid of receptors also allows the predicted ground level concentrations to be presented as contour plots. 13 Defra (2009). Local Air Quality Management Technical Guidance LAQM TG(09) Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 80 The specific receptors used in the assessment can be divided into three groups: Monitoring locations, which allows for predicted impacts to be directly compared and added to measured concentrations Locations where there is relevant exposure such as residential properties. Statutory and non-statutory sites of ecological importance within 5 km of the site. For the purpose of Local Air Quality Management (LAQM) the Air Quality Strategy Objectives (AQS) only apply where there is relevant exposure. This is defined as being where members of the public are regularly present and are likely to be exposed for a period of time, appropriate to the averaging period of the objective. For the annual average objective, locations of relevant exposure include residential properties, schools and hospitals. Receptor locations used in the assessment are given in Table 7 below. Table 7: Receptor locations No. Description Distance (km) R1 Warehouse 1 0.1 R2 Dagenham Dock Station 0.4 R3 Allotment Gardens (NW) 0.5 R4 Residential Property on New Road (1) 1.0 R5 Residential Property on New Road (2) 1.2 R6 Beam Valley Country Park 2.0 R7 School - Leys Avenue 2.3 R8 School - School Road 1.5 R9 Allotment Gardens (N) 1.6 R10 School - New Road 1.0 R11 Schools - Lowen Road 2.2 R12 School - Gores Bridge 0.8 R13 Playground - Goresbrook Park 1.0 R14 Goresbrook Leisure Centre 1.1 R15 School - Goresbrook Road 1.3 R16 Shaw Gardens 0.6 R17 Castle Green 1.6 R18 School - Burnham Road 2.0 R19 School - Dawson Avenue 3.1 R20 Hospital 3.2 R21 Schools - Sandringham Road 3.2 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 81 No. Description Distance (km) R22 Mayesbrook Park 2.8 R23 School - Cannington Road 2.4 R24 Parsloes Park 2.1 R25 Recreation Ground - Reede Road 2.6 R26 Playing Fields - Tom Thumb Lake 3.3 R27 Allotment Gardens - Tom Thumb Lake 3.6 R28 Allotment Gardens - Rainham Road 4.2 R29 School - Tangmere Crescent 4.8 R30 School Heron Flight Avenue 4.3 R31 Albyns Farm 4.5 R33 Allotments - Ingreborne Road 4.1 54 Diffusion Tube No 109 0.6 55 Diffusion Tube No 110 0.8 56 Diffusion Tube No 117 1.0 57 Diffusion Tube No 125 0.5 58 Diffusion Tube No 126 0.1 59 Diffusion Tube No 127 0.8 60 Diffusion Tube No 128 0.6 61 Diffusion Tube No 129 0.9 62 Scrattons Monitor 0.7 Figure 3 shows the locations of the receptors, as well as the location of the stack. Figure 3: Location of human health receptors and stack Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 82 Table 8 lists the ecological receptors used in the assessment. The Environment Agency (EA) has confirmed that Table 8 includes the statutory and 'important non-statutory sites' that need assessment following the EA AQTAG06 guidance for nutrient nitrogen and acid deposition (14) (15) . Table 8: Ecological receptors (vegetation and ecosystems) No. Distance Description Designation E1 Ingreborne Marshes SSSI 3.8 E2 Inner Thames Marshes SSSI 3.5 E3 Crossness LNR 2.2 E4 Ripple Site of metropolitan importance 1.7 E5 Scrattons Park Site of borough importance 0.6 E6 St Peter and St Paul Church Yard LNR 2.1 E7 Thames Important bird area 1.0 E8 Abbey Wood SSSI 4.2 (km) In addition to the sites shown in Table 8, there are a number of other sites that have received a local designation of importance for nature conservation (SINC), including Goresbrook and the Ship & Shovel SINC and Scratton’s Farm Ecopark SINC. Modelling has also been undertaken to assess the impacts on these sites. Nitrogen dioxide modelling and assessment results Oxides of nitrogen (NOx), which all progressively becomes nitrogen dioxide (NO2) in the atmosphere, is the principal pollutant released to atmosphere from the proposed development. Table 9 shows the maximum predicted ground level concentration of nitrogen dioxide (NO2) occurring as a consequence of emissions to atmosphere from the development for each of the five years of meteorological data used in the assessment. (14) Email from Nick Bettinson (EA) to David Harvey (ADMs Ltd) 9 October 2012. (15) Environment Agency (20 April 2010) AQTAG 06; Technical Guidance on detailed modelling approach for an appropriate assessment for emissions to air. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 83 Table 9: Maximum predicted (process contribution) annual average and 99.8th percentile of hourly average concentrations of nitrogen dioxide (µg m-3) Annual average Year 2008 2009 2010 2011 2012 Background Concentration Background + Maximum Impact (PEC) Assessment Criteria (a) 99.8th percentile of (a) hourly averages 2.6 2.1 1.5 2.5 2.2 8.9 9.3 9.7 9.1 9.3 33.3(b) 35.9 76.3(d) 40 200 (a) Assumes 70% oxidation for annual average and 35% for 99.8th percentile. (b) Measured ambient concentration assumed as a little higher that estimated values. (c) Predicted Environmental Concentration (d) Defra (TG4(00)) and Environment Agency (H1) guidance; 99.8 th + 2 x annual average background. (c) Table 9 shows that shows that 2008 meteorological data gives rise to the highest predicted increment to annual average ground level concentrations and 2010 for the 99.8th percentile of hourly averages. For 2008 meteorological data, at the point of maximum predicted impact, the incremental increase in annual average ground level concentration is 2.6µg m-3 which can be compared to the air quality strategy objective of 40 µg m-3. When added to the prevailing background concentration of 33.3µg m-3, the resulting total concentration of 35.9 µg m-3 is less than the objective. The maximum predicted 99.8th percentile of 9.7µg m-3 is small compared to the air quality strategy objective of 200 µg m-3. To determine the incremental increase to background occurring due to the proposed facility, the Defra TG04(00)/H1 guidance is used. The resulting total 99.8th percentile is 86µg m-3. Table 10 shows the predicted annual average concentration at the specific receptors for human exposure using 2008 meteorological data. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 84 Table 10: Predicted annual average concentrations of NO2 at specific receptors (µg m-3) Location Description Predicted increment (PC)(a) Prevailing conc. (b) Predicted increment + prevailing (PEC) Increment (PC) as % of objective 1 Warehouse 1 0.1 33.3 33.4 0.2% 2 Dagenham Dock 1.8 33.3 35.1 4.4% 3 Allotment Gardens 0.2 33.3 33.5 0.4% 4 Property on New Road 1.3 33.3 34.6 3.2% 5 Property on New Road 1.1 33.3 34.4 2.9% 6 Beam Valley Country 0.7 33.3 34.0 1.6% 7 School - Leys Avenue 0.5 33.3 33.8 1.3% 8 School - School Road 0.7 33.3 34.0 1.7% 9 Allotment Gardens (N) 0.4 33.3 33.7 1.1% 10 School - New Road 1.3 33.3 34.6 3.4% 11 Schools - Lowen Road 0.3 33.3 33.6 0.8% 12 School - Gores Bridge 1.0 33.3 34.3 2.5% 13 PlaygroundGoresbrook 0.3 33.3 33.6 0.7% 14 Goresbrook Leisure 0.1 33.3 33.4 0.3% 15 School - Goresbrook 0.1 33.3 33.4 0.2% 16 Shaw Gardens 0.2 33.3 33.5 0.4% 17 Castle Green 0.1 33.3 33.4 0.2% 18 School - Burnham Rd 0.0 33.3 33.3 0.1% 19 School - Dawson Ave 0.0 33.3 33.3 0.1% 20 Hospital 0.0 33.3 33.3 0.1% 21 School - Sandringham 0.0 33.3 33.3 0.1% 22 Mayesbrook Park 0.0 33.3 33.3 0.1% 23 School - Cannington 0.0 33.3 33.3 0.1% 24 Parsloes Park 0.1 33.3 33.4 0.2% 25 Recreation Ground 0.3 33.3 33.6 0.8% 26 Playing Fields 0.2 33.3 33.5 0.6% 27 Allotment Gardens 0.2 33.3 33.5 0.5% 28 Allotment Gardens 0.2 33.3 33.5 0.5% 29 School - Tangmere 0.2 33.3 33.5 0.5% 30 School Heron Flight 0.2 33.3 33.5 0.5% 31 0.1 33.3 33.4 0.4% 0.1 33.3 33.4 0.2% 54 Albyns Farm Allotments Ingreborne Diffusion Tube No 109 0.2 36.3 36.5 0.4% 55 Diffusion Tube No 110 0.2 75.6 75.8 0.4% 56 Diffusion Tube No 117 0.1 42.2 42.3 0.3% 57 Diffusion Tube No 125 2.0 39.7 41.7 5.0% 58 Diffusion Tube No 126 0.0 48.6 48.6 0.0% 59 Diffusion Tube No 127 0.2 38.9 39.1 0.5% 60 Diffusion Tube No 128 0.5 45.9 46.4 1.3% 61 Diffusion Tube No 129 0.2 46.2 46.4 0.6% 62 Scrattons Monitor 0.2 33.3 33.5 0.4% 33 Assessment Criteria 40 (a) Assumes 70% oxidation. (b) Either measured values or Defra estimated background values. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 85 The EPUK significance criteria are applicable to locations where there is relevant exposure and are only applicable to annual average concentration. Defra TG(09) guidance gives the following examples of where there is relevant exposure to annual average objectives: Building facades of residential properties School Hospital Care homes Examples given of where there is not relevant exposure to annual average objectives include; gardens of residential properties, hotels and kerbside sites. The receptors where measured concentrations are at their highest tend to be road side locations where there is no relevant exposure and where the EPUK significance criteria are not relevant. For example the maximum annual average increase in concentration of nitrogen dioxide (NO2) of 2.0µgm-3 occurs at receptor number 57. This receptor is some distance from any location where there is relevant exposure and therefore it is not appropriate to determine the significance of the impact at this location using EPUK significance criteria. Table 11 shows the EPUK significance criteria applied to the nineteen locations where there is relevant exposure to annual average objectives. Table 11: EPUK Significance Criteria(NO2, µg m-3) Predicted Location Description increment (PC) Increase (%) Magnitude of PEC (a) Change Impact Descriptor 4 Property on New Rd 1.3 3.2% Small 34.6 Negligible 5 Property on New Rd 1.1 2.9% Small 34.4 Negligible 7 School - Leys Ave 0.5 1.3% Small 33.8 Negligible 8 School - School Rd 0.7 1.7% Small 34.0 Negligible 10 School - New Rd 1.3 3.4% Small 34.6 Negligible 11 Schools - Lowen Rd 0.3 0.8% Imperceptible 33.6 Negligible Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 86 Predicted Location Description increment Increase (PC) (%) Magnitude of PEC (a) Change Impact Descriptor 12 School - Gores 1.0 2.5% Small 34.3 Negligible 13 PlaygroundGoresbrook 0.3 0.7% Imperceptible 33.6 Negligible 14 Goresbrook Leisure 0.1 0.3% Imperceptible 33.4 Negligible 15 School Goresbrook Rd 0.1 0.2% Imperceptible 33.4 Negligible 17 Castle Green 0.1 0.2% Imperceptible 33.4 Negligible 18 School - Burnham Rd 0.0 0.1% Imperceptible 33.3 Negligible 19 School - Dawson Ave 0.0 0.1% Imperceptible 33.3 Negligible 20 Hospital 0.0 0.1% Imperceptible 33.3 Negligible 21 School Sandringham 0.0 0.1% Imperceptible 33.3 Negligible 23 School Cannington Rd 0.0 0.1% Imperceptible 33.3 Negligible 26 Playing Fields 0.2 0.6% Imperceptible 33.5 Negligible 29 School Tangmere 0.2 0.5% Imperceptible 33.5 Negligible 30 School Heron Flight 0.2 0.5% Imperceptible 33.5 Negligible 31 Albyns Farm 0.1 0.4% Imperceptible 33.4 Negligible -3 -3 (a) Predicted Environmental Concentration (µg m ), includes background of 33.3 µg m . Table 11 shows that the proposed development is predicted to have an impact of negligible significance on annual average concentrations of nitrogen dioxide (NO2) according to the EPUK significance criteria. The conclusion of an impact of negligible significance does in part depend on the assumed background concentration. With a 'small' magnitude of change the significance of the impact would be no worse than 'slight adverse' if background concentrations were higher than assumed. It is however considered that the background concentration of 33.3µg m-3 for this determination of significance is conservative as it is higher than the 2010 Defra background of 25.5µg m-3, which is expect to fall in the future. It is therefore considered that the assessment of significance presented in this assessment is robust. Table 12 shows the predicted 99.8th percentile concentration at the specific receptors using 2010 meteorological data. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 87 Table 12: Predicted 99.8th percentile of hourly average concentrations (µg/m3) of NO2 at specific receptors Predicted Location Description Predicted Increment + Increment (PC) Prevailing (PEC)(b) Increment as %age of objective (%) 1 Warehouse 1 2.7 69.3 1.4% 2 Dagenham Dock Station 8.5 75.1 4.2% 3 Allotment Gardens (NW) 7.7 74.3 3.8% 4 Property on New Road 4.7 71.3 2.3% 5 Property on New Road 3.9 70.5 2.0% 6 Beam Valley Country 2.5 69.1 1.3% 7 School - Leys Avenue 2.3 68.9 1.1% 8 School - School Road 3.1 69.7 1.6% 9 Allotment Gardens (N) 3.0 69.6 1.5% 10 School - New Road 4.7 71.3 2.3% 11 Schools - Lowen Road 2.0 68.6 1.0% 12 School - Gores Bridge 6.0 72.6 3.0% 13 Playground -Goresbrook 4.4 71.0 2.2% 14 Goresbrook Leisure 4.7 71.3 2.3% 15 School - Goresbrook Rd 3.6 70.2 1.8% 16 Shaw Gardens 7.5 74.1 3.8% 17 Castle Green 2.8 69.4 1.4% 18 School - Burnham Road 2.3 68.9 1.1% 19 School - Dawson Ave 1.6 68.2 0.8% 20 Hospital 1.4 68.0 0.7% 21 School - Sandringham 1.3 67.9 0.7% 22 Mayesbrook Park 1.6 68.2 0.8% 23 School - Cannington Rd 1.8 68.4 0.9% 24 Parsloes Park 2.0 68.6 1.0% 25 Recreation Ground 2.2 68.8 1.1% 26 Playing Fields 1.8 68.4 0.9% 27 Allotment Gardens 1.6 68.2 0.8% 28 Allotment Gardens 1.5 68.1 0.7% 29 School - Tangmere 1.2 67.8 0.6% 30 School Heron Flight Ave 1.3 67.9 0.7% 31 Albyns Farm 1.1 67.7 0.6% 33 Allotments - Ingreborne 1.3 67.9 0.7% 54 Diffusion Tube No 109 7.3 79.9 3.7% 55 Diffusion Tube No 110 6.0 157.2 3.0% 56 Diffusion Tube No 117 5.2 89.6 2.6% 57 Diffusion Tube No 125 8.1 87.5 4.1% 58 Diffusion Tube No 126 1.2 98.4 0.6% 59 Diffusion Tube No 127 5.6 83.4 2.8% 60 Diffusion Tube No 128 6.9 98.7 3.5% 61 Diffusion Tube No 129 5.1 97.5 2.6% 62 Scrattons Farm Monitor 7.0 73.6 200 3.5% Assessment Criteria (a) Assumes 35% oxidation. (b) Defra guidance (TG4(00)); NO2 99.8th + 2 x annual average NO2 background. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 88 Table 12 shows that the maximum predicted 99.8th percentile of hourly average nitrogen dioxide (NO2) concentrations is 8.5µg m-3 at any of the specific receptors which is only 4.2% of the objective. The results reported above (Table 9 - Table 12) show that at the specific receptors, the predicted incremental increase in concentrations of nitrogen dioxide (NO2) occurring due to emissions from the proposed facility are small compared to the assessment criteria and are not of concern to human health. Figure 4 and Figure 5 below illustrate the distribution of oxides of nitrogen (NOx) emissions (process contributions) from the proposed facility, using 2008 meteorological data for annual average and 2010 data for 99.8th percentile of hourly averages. The figures show that peak predicted increments to ground level concentrations occur within about 500 m of the facility. Figure 4: Annual average NOx Figure 5: 99.8th percentile of hourly concentrations average NOx concentrations Other pollutants Table 13 below shows the results for all pollutants considered in this assessment, assuming full load continuous operation at the IES limits and Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 89 2008 meteorological data because this gives rise to the largest increment to annual average concentrations. Table 13: Maximum predicted incremental concentrations due to emissions to atmosphere from the proposed facility (µg m-3) Averaging Pollutant period Predicted concentration (µg m-3) Assessment criteria (µg m-3) Percentage of assessment criteria (%) Nitrogen 1 hour 8.9 200 4.5% dioxide (NO2) Annual 2.56 40 6.4% Particulate 24 hour 0.51 50 1.0% matter (PM10) Annual 0.18 40 0.5% 15 minutes 7.4 266 2.8% 1 hour 6.3 350 1.8% 24 hour 4.2 125 3.4% 8 Hour 6.4 10,000 0.1% Sulphur dioxide (SO2) Carbon Hydrogen monoxide 1 Hour 2.0 750 0.3% Hydrogen chloride Annual 0.018 16 0.1% fluoride (HF) 1 Hour 0.20 160 0.1% Antimony Annual 0.0010 5 0.02% (a) (Sb) 1 Hour 0.011 150 0.0% Arsenic (As) Annual 0.00001 0.003 0.4% Cadmium (Cd) Annual 0.00046 0.005 9.1% Chromium Annual 0.0010 5 0.0% 1 Hour 0.011 150 0.0% Annual 0.00000009 0.0002 0.0% Annual 0.0010 0.2 0.5% Annual 0.0010 10 0.0% 1 Hour 0.011 200 0.0% Annual 0.0010 0.25 0.4% Annual 0.0010 150 0.0% 1 Hour 0.011 1,500 0.0% Annual 0.0009 0.25 0.4% 1 Hour 0.010 7.5 0.1% Annual 0.0010 0.02 5.1% Annual 0.0010 5 0.0% 1 Hour 0.011 1 1.1% - - (Cr) (b) Chromium (Cr, Cobalt VI) (c) (Co) Copper (Cu) Lead (Pb) Manganese (Mn) Mercury (Hg) Nickel (Ni) Vanadium (Vn) Dioxins Annual -3 1.8 (fg m ) (a) antimony and compounds (as Sb) except antimony trisulphide and antimony trioxide. (b) Chromium, chromium (II) compounds and chromium (III) compounds (as Cr). (c) Chromium (VI) oxidation state in PM10 fraction. Table 13 shows that as a percentage of the short term assessment criteria, it is the 99.8th percentile of hourly average concentration of nitrogen dioxide (NO2) which is 4.5% of the assessment criteria that has the largest impact. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 90 When combined with the background concentration the PEC (Predicted Environmental Concentration) of 75.5µg m-3 is 38% of the assessment criteria and not considered to be of concern to human health. For annual average impacts the increment to annual average concentration of cadmium (Cd) is predicted to give rise to the largest percentage of the assessment criteria of 9.1%. It should be noted that the assessment criteria of 0.005 µg m-3 is from the World Health Organisation Air Quality guidelines (2000) which state that the guideline is set to 'prevent any further increase of cadmium in agricultural soils'. Given that the maximum predicted concentration is substantially less than the assessment criteria and that the area is predominantly urban, it is considered that there is no concern to human health. Dioxins and furans are a group of organic compounds that are formed as a result of incomplete combustion in the presence of chlorine. Sources include vehicles, domestic and industrial coal burning, power generation and incinerators. There are no regulatory air quality standards set for dioxins and furans and there are only limited data available on airborne dioxins and furans in the urban environment in the UK; these show concentrations in the range of 146 – 188 fg I-TEQ /m3. The maximum predicted ground level concentration of dioxin of 1.8fg I-TEQ/m3 is small compared to the reported range of urban dioxin concentrations. As part of the 2010 permit application, a health risk assessment was submitted (16). The 2010 Heath Risk Assessment was undertaken assuming a maximum annual average dioxin concentration of 8 fg m-3 and concluded 'The assessment indicates that the risk to health of the local population due to exposure to dioxins in emissions from the proposed Thames Gateway Energy Facility is likely to be very low.' For the current design, the maximum (16) GF Environmental Ltd (April 2010) Thames Gateway Power Ltd; Dioxin Health Risk Assessment for Proposed Thames Gateway Energy Facility. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 91 predicted annual dioxin concentration has reduced from 8 fg m-3 to 1.8 fg m3. Given that the facility is in the same location and therefore surrounded by the same land use and subject to the same rainfall as assumed in the 2010 assessment, the recalculated dioxin intake for the re-submitted development is 23% of that calculated for the previous scheme, which was determined to have a 'very low' impact. When considering the significance of the impacts on air quality of emissions from the facility and their relevance to human health one needs to consider both the maximum impact, the receptors exposed to the maximum impacts and the geographic extent of the impact. Figure 4 and Figure 5 show that the area of maximum impact is limited to an industrial area to the south east of the facility. This reduces the significance of the impacts compared to, for example, a larger facility where the magnitude of the impacts may be similar but the area of impact larger and includes sensitive receptors such a residential properties, school and hospitals. It is also of relevance to compare the predicted impacts for this updated proposal for the facility with those presented in the 2010 assessment report for the original application. Table 4.4 of the 2010 report shows that the maximum predicted increment to annual average ground level concentrations of nitrogen dioxide (NO2) was 10.2 µg m-3, this can be compared to 2.6 µg m3 for the revised development. For the maximum 99.8th percentile of hourly averages, the previous process contribution was 82 µg m-3 compared to 9.7 µg m-3 for the current proposal. The reduction in concentration is principally a consequence of the increase in stack height from 42 m to 55 m. Potential impact on vegetation and ecosystems This air quality assessment has also considered the potential impact on statutory nature conservation sites within 5 km and non-statutory sites within 2 km. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 92 The atmospheric pollutant of most concern for sensitive vegetation and best understood is Oxides of Nitrogen (NOx). Both the EU and WHO have set limit and guidelines for the annual average concentration of NOx for the protection of vegetation. For the protection of vegetation and ecosystems there is an Air Quality Objective (AQS) and an EU target of 30 µg m-3 for NOx. This objective does not apply to locations within 5 km of built up areas of more than 5,000 people, or industrial sources regulated under Part A of the 1990 Environment Act. However for the purpose of the assessment, this objective was used. Table 14 shows that the predicted increments to annual average concentrations of the oxides of nitrogen (NOx) are close to the 1% level of insignificance with a maximum of 2.0% at receptor which is a Local Nature Reserve (LNR). Table 14: Predicted increment (process contribution (PC)) of annual average concentrations of oxides of nitrogen (NOx) at ecological receptors No. Description Designation PC (NOx, µg m-3) PC as % of Critical Level (% of 30 µg m-3) E1 Ingreborne Marshes SSSI 0.11 0.4% E2 Inner Thames Marshes SSSI 0.13 0.4% E3 Crossness LNR 0.11 0.4% E4 Ripple Site of metropolitan importance 0.45 1.5% E5 Scrattons Park Site of borough importance 0.26 0.9% E6 St Peter and St Paul Church Yard LNR 0.59 2.0% E7 Thames Important bird area 0.31 1.0% E8 Abbey Wood SSSI 0.05 0.2% Table 15 shows the Predicted Environmental Concentration (i.e. predicted increment + background concentration, PEC) of annual average concentration of the oxides of nitrogen (NOx) at the eight receptors of ecological importance and the percentage of the critical level which for the oxides of Nitrogen (NOx) is 30 µg m-3. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 93 Table 15: Predicted environmental concentration (PEC) of annual average concentrations of oxides of nitrogen (NOx) at ecological receptors No. Description Designation PEC (NOx, µg m-3) PEC as % of Critical Level (% of 30 µg m-3) E1 Ingreborne Marshes SSSI 41.3 138% E2 Inner Thames Marshes SSSI 41.3 138% E3 Crossness LNR 41.3 138% E4 Ripple Site of metropolitan importance 41.7 139% E5 Scrattons Park Site of borough importance 41.5 138% E6 St Peter and St Paul Church Yard LNR 41.8 139% E7 Thames Important bird area 41.5 138% E8 Abbey Wood SSSI 41.3 138% Table 15 shows that the PEC exceeds the critical level at all the receptors as a direct consequence of the prevailing background concentration. For the protection of vegetation and ecosystems there is also an Air Quality Objective and an EU target of 20 µg m-3 for sulphur dioxide (SO2) (annual and winter average). This objective does not apply to locations within 5 km of built up areas of more than 5,000 people or industrial sources regulated under Part A of the 1990 Environment Act. However for the purpose of this assessment the objective is used. Table 16: Predicted increment (PC) of annual average concentrations of sulphur dioxide (SO2) at ecological receptors No. Description Designation PC (SO2, µg m-3) PC as % of Critical Level (% of 20 µg m-3) E1 Ingreborne Marshes SSSI 0.03 0.1% E2 Inner Thames Marshes SSSI 0.03 0.2% E3 Crossness LNR 0.03 0.1% E4 Ripple Site of metropolitan importance 0.11 0.6% E5 Scrattons Park Site of borough importance 0.07 0.3% E6 St Peter and St Paul Church Yard LNR 0.15 0.7% E7 Thames Important bird area 0.08 0.4% E8 Abbey Wood SSSI 0.01 0.1% Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 94 Table 16 shows that the predicted increments to annual average concentrations of sulphur dioxide (SO2) are less than the Environment Agency's test for insignificance of 1% and therefore is insignificant. There would therefore be justification not to consider the impact of sulphur dioxide (SO2) further. However, for completeness, the deposition rates and contribution to acidification are assessed. Table 17 shows the Predicted Environmental Concentration (i.e. predicted increment + background concentration) of annual average concentration of sulphur dioxide (SO2) at the eight receptors of ecological importance and the percentage of the critical level which for sulphur dioxide (SO2) is 20 µgm-3. Table 17: Predicted environmental concentration (PEC) of annual average concentrations of oxides of nitrogen (SO2) at ecological receptors Designation PEC (SO2, µg m-3) PEC as %age of Critical Level (% of 20 µg m3 ) No. Description E1 Ingreborne Marshes SSSI 6.8 34% E2 Inner Thames Marshes SSSI 6.8 34% E3 Crossness LNR 6.8 34% E4 Ripple Site of metropolitan importance 6.9 35% E5 Scrattons Park Site of borough importance 6.9 34% E6 St Peter and St Paul Church Yard LNR 6.9 35% E7 Thames Important bird area 6.9 34% E8 Abbey Wood SSSI 6.8 34% Table 17 shows that the critical level for sulphur dioxide (SO2) is not predicted to be exceeded. The deposition of nitrogen (N) from the atmosphere acts as a fertiliser which affects the natural balance of vegetation. The critical load for the deposition of nitrogen, normally expressed as Kg N ha-1 year-1, is the exposure below which there should be no harmful effects on sensitive elements of the ecosystem. The critical loads vary for the type of ecosystem from as low as 5-10 Kg N ha-1 year-1 for sensitive lichen found on mountain tops to 20-30 Kg Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 95 N ha-1 year-1 for some type of meadows. A full analysis was undertaken using the specific critical load applicable to each receptor. Table 18 shows the habitat descriptions that are relevant to atmospheric deposition and the critical load range for nitrogen deposition (Kg N ha-1 year1 ) which were obtained from the APIS web site (17) . Table 18: Site description, habitat and nitrogen deposition critical load range (Kg N ha-1 year-1) No. Description Critical Range Habitat Load Min Max E1 Ingreborne Marshes Fen, Marsh & Swamp 10.0 15.0 E2 Inner Thames Marshes Fen, Marsh & Swamp 10.0 15.0 E3 Crossness Grazing marsh/scrub and rough grassland 20.0 30.0 E4 Ripple Semi-improved neutral grassland 20.0 30.0 E5 Scrattons Park Neutral grassland 20.0 30.0 E6 St Peter and St Paul Church Yard Neutral grassland 20.0 30.0 E7 Thames Mud Flats 10.0 20.0 E8 Abbey Wood Woodland 10.0 20.0 Table 19 shows the calculated nitrogen deposition rates, the calculations are made assuming a dry deposition velocity for nitrogen dioxide (NO2) of 0.003 m s-1 and assuming that the contribution from wet deposition is negligible. Table 19: Predicted annual average ground level concentrations and calculated nitrogen deposition rates No. Description Annual average NO2 Nitrogen deposition rate concentration (µg m-3) (µg m-2 s-1) (Kg N ha-1 y-1) E1 Ingreborne Marshes 0.080 0.0002 0.02 E2 Inner Thames Marshes 0.093 0.0003 0.03 E3 Crossness 0.075 0.0002 0.02 E4 Ripple 0.316 0.0009 0.09 E5 Scrattons Park 0.184 0.0006 0.05 E6 St Peter and St Paul Church 0.416 0.0012 0.12 E7 Thames 0.216 0.0006 0.06 E8 Abbey Wood 0.035 0.0001 0.01 (17) Air Pollution Information System (APIS) www.apis.ac.uk. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 96 Table 20 shows the calculated nitrogen deposition rates (Process Contribution/additional load) as a percentage of the critical load range and the total load (i.e. baseline + additional load). Table 20: Nitrogen deposition rate and critical loads (Kg N ha-1 yr-1) No. Description Critical load Additional range load (PC) Min Max % of critical load Existing Deposition Range Total (PEC) E1 Ingreborne Marshes 10 15 0.02 0.15% 0.23% 15.7 15.7 E2 Inner Thames Marshes 10 15 0.03 0.18% 0.27% 15.7 15.7 E3 Crossness 20 30 0.02 0.07% 0.11% 16.1 16.1 E4 Ripple 20 30 0.09 0.30% 0.46% 16.1 16.2 E5 Scrattons Park 20 30 0.05 0.18% 0.26% 16.1 16.2 E6 St Peter and St Paul Church 20 30 0.12 0.40% 0.60% 15.7 15.8 E7 Thames 10 20 0.06 0.31% 0.62% 16.1 16.2 E8 Abbey Wood 10 20 0.01 0.05% 0.10% 34.3 34.3 Table 20 shows that the Process Contribution / additional load are less than 1% of the critical load and therefore insignificant at all the receptors. The total nitrogen deposition (PEC) falls within the range of critical loads, except Abbey Woods where the existing deposition rate is the cause of the exceedence. The predicted increments to the nitrogen deposition rates occurring due to emissions from the proposed facility are therefore insignificant. Deposition of sulphur and nitrogen compounds can cause acidification and both must be taken into account when assessing potential for emissions from the facility to cause acidification. For acidification, the nitrogen (N) and sulphur (S) deposition rates are expressed as 'equivalents' which is a measure of how acidifying a substance can be. The units for N and S deposition are Keq ha-1 year-1. Table 21 below shows that for the ecological receptors where the habitat is sensitive to acid deposition the predicted contribution to the acid deposition is less than 1% and therefore insignificant. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 97 Table 21: Deposition as percentage of critical load function (keg ha-1 year-1) Process No. Contribution (PC) Description S PEC PC (%age of PEC (%age of CL Function, CL Function, %) %) N E1 Ingreborne Marshes 0.0034 0.0016 Not calculated E2 Inner Thames Marshes 0.0039 0.0019 119.4 E3 Crossness 0.0031 E4 Ripple E5 E6 (a) (a) 0.0015 Not calculated 1.71 0.2% 30.3% 0.0134 0.0065 1.73 0.2% 30.3% Scrattons Park 0.0078 0.0038 1.72 0.4% 30.5% St Peter and St Paul Church 0.0176 0.0086 29.8% E7 Thames 0.0091 0.0044 1.74 0.4% (a) Not calculated E8 Abbey Wood 0.0015 0.0007 2.70 260% 40.8 0.0% (a) Not calculated as habitat is not sensitive to acid deposition. For the non-statutory sites, Figure 6 and Figure 7 below show the predicted distribution of the increment (process contribution) to ground level concentration of oxides of nitrogen (NOx) and sulphur dioixide (SO2) for emissions from facility together with the location on non statutory ecological sites and the stack. Figure 6: Predicted annual average ground level concentrations of oxides of nitrogen dioxide (NOx) (µg m-3) Figure 6 shows that the Figure 7: Predicted annual average ground level concentrations of sulphur dioxide (SO2) (µg m-3) predicted increment to annual average concentrations of oxides of nitrogen (NOx) at the non statutory sites of ecological importance are in the range of ~0.5 µg m-3 to a peak of ~2 µg m-3 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 98 over a small area at close to the point of maximum impact. The increments are small compared to the assessment criteria of 30 µg m-3. Figure 7 shows that the predicted increment to annual average concentrations of sulphur dioxide (SO2) at the non statutory sites of ecological importance are in the range of ~0.2 µg m-3 to a peak of ~0.6 µg m-3 over a small area at the point of maximum impact. The increments are small compared to the assessment criteria of 20 µg m-3. 6.5 Mitigation measures and residual impacts 6.5.1 Construction Emissions of dust generated during construction can be almost entirely abated by appropriate mitigation measures. Mitigation measures to be employed during construction will be drawn from the GLA’s best practice guidance18 and will be discussed and agreed with LBBD as appropriate prior to commencement of construction. 6.5.2 Operation No significant adverse impacts have been identified and therefore no mitigation measures are proposed. The assessment has shown that the dispersion provided by the 55 m stack is sufficient to render the emissions harmless at ground level to both human health and ecological receptors and therefore no further mitigation measures are required. 18 The control of dust and emissions from construction and demolition: Best Practice Guidance. GLA November 2006. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 99 6.6 Conclusion The results of the atmospheric dispersion modelling and assessment clearly demonstrate that the maximum predicted concentrations of all substances comply with relevant air quality objectives at nearby sensitive locations and that a stack height of 55 m would provide adequate dispersion of pollutants such that emissions from the stack will not significantly affect air quality at ground level and the impact is considered to be insignificant. The overall impact on air quality of emissions to atmosphere from the proposed facility can be described as of minor significance. This conclusion is based on all the impacts presented in the assessment and takes account of the localised nature of the area of maximum impact. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 100 7 Noise and vibration 7.1 Introduction This section considers the potential noise impact from construction and operation of the proposed development on nearby receptors. Enzygo Ltd was commissioned to undertake the noise assessment of the proposed development; the full assessment report is included in Appendix D and summarised below. 7.2 Existing conditions Noise levels at the three nearest sensitive receptors and at a fourth location immediately adjacent to the boundary were measured in 2009 and formed the basis of the noise assessment undertaken by Vibrock Ltd in support of the extant consent application. The locations are summarised below and the results of the survey given in Table 22 below. Loc 1: Shaw Gardens (to the north of the proposed development) Loc 2: Keel Close (to the west of the proposed development) Loc 3: Proposed cycle route (to the immediate north of the proposed development) Loc 4: North-eastern extent of the Barking Riverside Development (to the south west of the proposed development) Table 22: Noise survey results – Vibrock, 2009 Location Survey period Measured LAeq,T Measured LA90,T Loc 1 – Shaw Daytime 07:00 – 23:00 52 48 Gardens Nighttime 23:00 – 07:00 47 43 Loc 2 – Keel Daytime 07:00 – 23:00 49 44 Close Nighttime 23:00 – 07:00 47 39 Loc 3 – proposed Daytime 07:00 – 23:00 53 49 cycle route Nighttime 23:00 – 07:00 50 46 Loc 4 – Barking Daytime 07:00 – 23:00 53 50 riverside Nighttime 23:00 – 07:00 48 46 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 101 Vibrock noted that the noise climate of the area was ‘dominated by road traffic noise from the A13 and surrounding road network. Aircraft arriving and departing London City Airport also influence the noise climate as does residential activity, train movements and bird song’. 7.3 7.3.1 Assessment of impacts Introduction The assessment of noise impacts arising from the proposed development has comprised a number of key stages as follows: A review of the noise assessment undertaken in support of the previous application on the site (report complied by Stratus Environmental dated March 2010 reference CY1052/ES). Assessment of the potential impacts of the proposed development on the adjacent sensitive receptor locations, as well as the wider environment. Consideration of cumulative effects of the proposed development with other significant development in the area including the adjacent ReFood AD plant. Quantification of suitable acoustic mitigation measures and strategies that could be employed within the design of the site to control noise as appropriate. 7.3.2 Construction Construction traffic, site establishment activities and building construction have the potential to cause short term disturbance to the amenity of nearby sensitive receptors. Traffic flows due to construction activities are estimated to be no more than those during operation (section 10.3.1) and therefore construction traffic noise is not expected to be a significant issue. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 102 A construction noise and vibration management plan (CNVMP) has been prepared and is included as an appendix to the noise assessment (Appendix D). The limitation of a predictive noise assessment of construction is that there are a myriad of potential locations, elevations, acoustic reflections and refractions, screening parameters and equipment specifications and combinations that could occur during the normal execution of the required works. As such it is considered that acoustic control at source and the implementation of Best Available Technique (BAT) is considered the best method of control; this approach forms part of the RISK based assessment contained within the CNVMP. The assessment seeks to identify the potential main activities at the site which have the potential to generate noise (and vibration) and provides details of appropriate control measures that could be implemented where appropriate. 7.3.3 Operation Noise emission levels for the key sources were provided by Chinook Sciences (the technology provider) and are shown on the site plan contained in Appendix D. A three-dimensional model of the proposed development was constructed using the commercial noise mapping software SoundPLAN 7.2. The model included all sources of noise on the site (both internal and external plant and equipment and vehicles). Noise levels were then predicted and assessed at nearby locations considered to be noise sensitive (i.e. the residential receptors summarised in section 7.2 above). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 103 The likely impact of the proposed development on residential amenity at the receptors has been assessed using BS414219 and results are presented in Table 23 below. A specific, external noise levels at each receptor location is calculated and then converted to a ‘rating level’ in order to take account of any tonal or noticeable characteristics of the noise under consideration. The difference between the noise from the new development (expressed in terms of the rating level) and the existing background noise level of the area is indicative of the likelihood of complaint as follows: A difference of around +10 dB or more indicates that complaints are likely A difference of around +5 dB is of marginal significance A difference of -10dB is a positive indication that complaints are unlikely Table 23: Predicted noise impacts at nearest sensitive receptors Location Period Average measured L90 ‘background noise level’ dB Shaw Gardens Daytime 48 Predicted BS4142 rating level, dB (unrounded value) LAeq 42 (41.6) Night-time 43 41 (41.4) -2 Daytime 44 34 (34.0) -10 Night-time 39 34 (33.6) -5 Daytime 50 40 (39.7) -10 Night-time 46 39 (38.6) -7 Keel Close Barking Riverside Difference Significance -6 Less than ‘marginal significance’ Less than ‘marginal significance’ ‘positive indication that complaints would be unlikely’ Less than ‘marginal significance’ ‘positive indication that complaints would be unlikely’ Less than ‘marginal significance’ It can be seen from Table 23 that noise as a result of operations associated with the proposed development would be at a level considered by the BS4142 19 BS4142: 1997 Method for rating industrial noise affecting mixed residential and industrial areas Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 104 Standard to be of less than ‘marginal significance’ towards a ‘positive indication that complaints would be unlikely’. Furthermore, the levels predicted are also below the acceptable criteria of L90 +0dB imposed by LBBD on planning consents for other developments within the LSIP. It is reasonable to assume that during the nighttime period (2300 - 0700), residents of the nearby dwellings would typically be within their properties rather than outside. Therefore, noise impacts occurring within the nearest dwellings as a result of the proposed development have also been assessed. This assessment has been undertaken in line with BS823320, assuming a bedroom on the façade overlooking the site. In order to calculate the potential ingress of noise, it was necessary to make an assumption as to the level of attenuation afforded by the façade of these buildings. In the absence of information on the construction of the houses dwellings or their glazing, attenuation for an open window for ventilation has been assumed which could be expected to be in the order of 10 – 15dB. This is considered to be a worstcase assumption with regard to façade attenuation as closed windows would give significantly better performance (up to -33 dB(A) potentially). The results of the assessment are presented in Table 24 below and demonstrate that that overnight noise as a result of operation of the proposed development are at a level which would be acceptable with regard to the internal design criteria of BS8233. 20 BS8233: 1999 ‘Sound insulation and noise reduction for buildings - Code of practice Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 105 Table 24: BS8233 weekday overnight noise impact assessment 7.3.4 Predicted façade Corrected noise levels (+3dB internal BS8233 Criteria on non-façade levels (- achieved Receptor Period values) 13dB) Shaw Gardens Nighttime 44.4 31.4 <35dB(A) Reasonable Keel Close Nighttime 36.6 23.6 <30dB(A) Good Barking Riverside Nighttime 41.6 28.6 <30dB(A) Good Cumulative effects As planning consent has very recently been granted for the ReFood anaerobic digestion facility on plot 5, immediately to the south of the proposed development, a cumulative assessment has been undertaken although it should be noted that no cumulative assessment was undertaken by ReFood, despite the existence of the extant consent on plot 2. Data have been used from the ReFood study undertaken by Noise.co.uk in this cumulative assessment but it is important to note that no validation of the information or calculations therein have been made. The Noise.co.uk study only considered one receptor, located at the southern end of Shaw Gardens and also only considered 06:00 – 22:00 hours. It is assumed therefore that the ReFood facility is only operational during the daytime period, and so the cumulative consideration is restricted to these hours. The Noise.co.uk study predicted a level of 42.9dB(A) at the properties on Shaw Gardens, with a resulting BS4142 assessment result of +2dB(A) above the prevailing background noise climate noted to be of Marginal Significance. An approximation of the noise associated with the ReFood AD facility has been made based upon the 1min LAeq Sound Pressure Level quoted in the Noise.co.uk report; this enables levels at Keel Close and the Barking Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 106 Riverside Development to be estimated utilising Noise.co.uk’s own methodology. It is noted that the noise levels presented within the Noise.co.uk report are in breach of the planning consent condition limit21 granted for the AD facility and therefore additional noise mitigation will be necessary. In order to cumulatively consider the resulting noise levels at each of the three receptors from noise associated with both the proposed development and the ReFood facility the predicted noise levels of both have been logarithmically combined to provide a single expected noise level as shown in Table 25 below. Table 25: Cumulative daytime noise levels Predicted noise level LAeq, 1hr Proposed development 41.6 Estimated noise level LAeq, 1hr ReFood AD plant 42.1 Keel Close 34.0 Barking Riverside 39.7 Receptor Shaw Gardens 44.9 Measured current LAeq of the locality (Vibrock Study) 52 35.0 37.5 49 48.8 49.3 53 Combined noise level Potential Future LAeq of locality (increase) 52.8 (+0.8dB) 49.3 (+0.3dB) 54.5 (+1.5dB) Table 25 shows that should both developments proceed, that residential receptors on Shaw Gardens and Keel Close could experience a maximum increase in ambient noise of 0.8dB which is below the 1dB level of human perception under normal conditions and therefore would not be considered to be a significant impact. With regard to the proposed properties at the Barking Riverside Development a change in the ambient noise climate of 1.5dB may occur should both 21 Condition 14: The rating level of the noise from the combined operation of plant installed pursuant to this permission shall not exceed the existing background noise level at the outside of noise sensitive buildings. Any assessment of compliance with this condition shall be made according to the methodology and procedures presented in BS4142:1997 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 107 developments proceed. However, it is important to note that the noise from the proposed development is significantly lower than that estimated from the ReFood AD plant such that the increase is predominantly as a result of the ReFood development; the proposed development alone would not result in an ambient increase at this location. Moreover, as previously described, the noise levels reported within the Noise.co.uk assessment for the ReFood AD facility are already in breach of the levels imposed within the planning consent. It is therefore considered somewhat unrealistic to base a cumulative assessment on these levels as the ReFood facility would be required to meet the planning permission noise limits, and as such noise from the facility would be reduced as a consequence. 7.4 Mitigation measures 7.4.1 Construction Condition 25 of the extant consent required the development of a construction noise and vibration monitoring plan (CNVMP). The scope of the CNVMP was agreed through discussion with LBBD earlier this year and is included in Appendix D. The purpose of the CNVMP is to quantify any potential noise and vibration impacts associated with the construction of the development and to outline how these will be both policed and controlled. The CNVMP will be included within a wider Construction and Environmental Management Plan (CEMP) to be produced by the main contractor. 7.4.2 Operation The assessment makes a number of recommendations as follows, which are summarised below and described in greater detail in Appendix D: Waste reception building has been assumed to have an internal noise climate of <85dB(A) Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 108 Noise from the 55m stack is required to be controlled. A reduction of 25dB(A) on the generated sound power level has been assumed, reducing the noise emitted to 90dB(A) All external plant (with the exception of the stack) has been assumed to have a sound pressure level value at 1m of 85dB(A) Façades of RODECS plant building to provide minimum Rw composite sound reduction value of -35dB(A) attenuation including roof provision with all doors to this building achieving a minimum Rw of -25dB(A). Façades of the waste reception building to provide a minimum Rw composite sound reduction value of -25dB(A) attenuation including roof provision with all doors to this building achieving a minimum Rw of 15dB(A). Vehicular access doors remain shut during normal operations. Personnel doors to provide the same sound reduction as surrounding cladding system. 7.5 Conclusion The assessment of the daytime and nightime periods indicate that impact of noise from the proposed development at the nearest sensitive receptors ranges from less than ‘marginal significance’ towards a ‘positive indication that complaints would be unlikely’. Predicted levels are also below the acceptable criteria of L90 +0dB applied by the LPA to planning consents for other developments within the LSIP. Predicted internal noise levels at the identified sensitive receptors would also be acceptable when considered in accordance with the design criteria of BS8233. Therefore, noise resulting from the proposed development would not be detrimental to the amenity of the nearest noise residential sensitive receptor locations in the area. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 109 8 Visual impact 8.1 Introduction This chapter considers the visual impact of the proposed development on the site and its surroundings. The assessment has been undertaken in accordance with the Guidelines for Landscape and Visual Assessment published by the Landscape Institute and the institute of Environmental Management and Assessment and Landscape Character Assessment, Guidance for England and Scotland published by the countryside Agency and Scottish National Heritage. These documents do not provide a prescriptive approach to assessment but identify principles and good practice. The full assessment is contained in Appendix E. 8.2 Existing conditions 8.2.1 Baseline visual context Appendix E provides detailed information about the baseline landscape and visual context in the area of the proposed development and includes photographs of views into and on the site and the surroundings. The proposed development is located in an industrial area with views punctuated by numerous vertical elements; other tall buildings, pylons, telecommunication masts, stacks, wind turbines etc. Views over the surrounding area are limited due to the flat topography and the considerable amount of existing industrial development, to the north, east and south of the site. Significant elevated views are restricted to the artificially raised land at Barking Riverside to the west, Choats Manor Way as the road crosses over the rail line, the pedestrian footbridge across the A13 Ripple Road, the A13 dual carriageway and from the upper storey of the flats at the end of Keel Close (off Choats Road). Generally these views are characterised by substantial residential, industrial and transport infrastructure development. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 110 A 2 km radius around the site zone represents the zone of theoretical visibility (ZTV), which is the area in which significant effects from the proposed development are likely to be experienced. Six receptor types were identified and used in the assessment as follows: Residential R1: Goresbrook Road / New Road R2: Scrattons Farm Estate R3: Residential area east of Renwick Road (Keel Close) R4: Thames View Estate west of Renwick Road R5: Thamesmead Barking Riverside BR: Eastern end of Barking Riverside development area Commercial / industrial B1: Dagenham Dock B2: Rippleside industrial area B3: Pooles Way Logistic Area Public open space PO1: Castle Green / Goresbrook Sports Centre PO2: Scrattons Farm public open space Roads RO1: A13 RO1a: A13 Pedestrian footbridge RO2: Choats Road RO3: Choats Manor Way CTRL rail corridor R1: CTRL corridor Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 111 8.2.2 Classification of receptors Receptors vary in their sensitivity and are typically classified and ranked on a scale from high – medium – low sensitivity. Examples of the categories are given below: High Occupiers of residential properties with views affected by the development. Users of outdoor recreational facilities including rights of way where interest may be focused on the landscape. Medium Users of outdoor recreational facilities where the view is less important to the activities (e.g. sports pitches). People at places of work. Low People travelling through the area in cars or on trains, or people at places of work with limited views potentially affected by the development (e.g. industrial sites). 8.2.3 Magnitude of change The magnitude of the change in the view can be similarly ranked in a qualitative manner as follows: High adverse Where the scheme would cause a significant deterioration in the view Medium adverse Where the scheme would cause a noticeable deterioration in the view Low adverse Where the scheme would cause a minor deterioration in the view. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 112 No change Where the scheme overall would not form a noticeable deterioration or improvement in the view Low beneficial Where the scheme would cause a minor improvement in the view Medium beneficial Where the scheme would cause a noticeable improvement in the view High beneficial Where the scheme would cause a significant improvement in the view 8.2.4 Significance of change The significance of any effect on visual receptors is directly related to the sensitivity of the receptor and the magnitude of the change in the view e.g. potentially significant effects could occur if high sensitivity receptors (residential) experience major changes in their view because of development. Conversely, a major change in a view (high magnitude) experienced by a low sensitivity receptor (industrial building) would be classified as not significant. The visual resources may also change over time as vegetation installed as part of the development becomes established and the existing landscape planting outside the site evolves. 8.2.5 Visual sensitivity of identified receptors Residential receptors The majority of the residential receptors identified are located at least a kilometre away and their views of the development will be largely restricted to the flue stack in a flat landscape that already contains a large number of other vertical elements such as the pylons and wind turbines at the Ford Motor Works. These receptors can be deemed to be of Low to Medium Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 113 Sensitivity depending on their distance from the development and the orientation of the individual properties. Barking Riverside receptors Presently as this is open ground not used for recreational purposes (other than possibly occasional dog walkers) it can be classified as Medium Sensitivity since although it generally has good views over the development site, users are restricted to those people undertaking surveying or other construction related activities. However the whole of the portion within the zone of theoretical visibility is earmarked for either residential development, informal public open space or sports pitch provision over the coming years. Consequently some elevated portions of the site (and in particular the occupiers of the proposed five or six storey residential blocks south of Choats Road) would be deemed to be of Medium to High Sensitivity depending on the exact location, orientation and elevation of their residences. Commercial / industrial receptors The large windowless nature of many of the buildings in this category, the distance of many of the units from the site and with the fact that the occupants are accustomed to working in a similar environment mean all these receptors can be deemed to be of Low Sensitivity. Public open space receptors The open space just to the north of the site on the southern edge of the Scrattons Farm Estate includes a fenced ball games area and a small play area and is deemed to be of local significance, the occupiers of the adjacent estate walking dogs probably constituting one of the principal user groups. The eastern portion, which was visible, appeared to be overgrown with brambles with little evidence of informal use. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 114 The other zone located to the north of the A13 categorised as public open space is of a far more varied nature. The eastern area closest to the site contains a wide range of leisure uses. The western half consists of a newly constructed High School complex and Castle Green public open space (which again is only deemed to be of relatively local significance). Two other public green spaces, Parloes Park and Beam Valley Parklands, probably receive much higher levels of visitors although they are considered to be too distant from the site to warrant consideration in the context of this particular development. Consequently this whole group of recreational and educational users referred to above can be deemed to be of no more than Medium Sensitivity. Road receptors Although the section of the A13 north of the site is elevated, the relatively high speeds of vehicles on this dual carriageway, mean that this receptor is deemed to be of Low sensitivity. Users of the pedestrian footbridge over the A13 are deemed to be of Medium sensitivity due to the fact that some of their movements may be leisure related and the elevated nature of the views. The adjacent public highways, are predominately used by commercial vehicles visiting the surrounding industrial premises. Choats Road is deemed to be of Low sensitivity while the elevated section of Choats Manor Road located immediately to the east of the site has been categorised as of Medium Sensitivity because of its close proximity to the eastern end of the site. Rail receptors Rail receptors consist of the Channel Tunnel Rail and an associated fright depot. As trains will be travelling at high speed along this stretch and the depot is a place of work both of these are deemed to be Low Sensitivity receptors. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 115 8.3 Assessment of impacts 8.3.1 Views from residential areas Within the Goresbrook Road / New Road (R1) area there will be no change in the existing view in the majority of cases although the flue stack will be visible from the first floor windows of some properties and other locations like the play area in Martin Kinggett Gardens (situated to the south of Goresbrook Road). The magnitude of this effect is however only considered to be Low as in most instances the skyline already includes a large number of vertical elements such as highway lighting columns, sports court floodlights and the upper portions of electricity pylons. Consequently at its worst the impact is considered to be Slight Adverse. Although there are some properties on the Scrattons Farm Estate (R2) facing in the direction of the site, much of the proposed development will be screened by existing vegetation for the majority of the year. Again the flue stack will introduce a new vertical element into the views but as discussed above this is considered to be in scale with the other existing vertical structures. As a result the impact is again categorised as Slight Adverse. Parts of the development and the stack will be visible from the first and second floor windows of the flats at the end of Keel Close (R3); much of it is likely to be screened by the existing vegetation on the intervening areas of open ground. Although the height of the proposed stack is 55 metres above ground level it does not exceed that of the adjacent pylons and consequently the magnitude of change can be classed as Low. As a result the visual impact is only deemed to be Slight Adverse and it is possible that the level of impact may become negligible over time. In relation to the both of the remaining residential areas (Thames View Estate west of Renwick Road and Thamesmead (R4 and R5 respectively)), it is considered that the development will result in a negligible change in the existing view due to their distance from the proposed facility, the screening Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 116 effects of other properties and the industrial character of the adjacent landscape. Consequently the level of impact has been classed as Negligible. Views from Barking Riverside The development will introduce a prominent new element in to the existing view although it will not be out of scale or character with its surroundings and can be considered to contribute a degree of unity by screening portions of pylons and the urban clutter currently visible in the background. The degree of magnitude of change is considered to be Medium. Views of the lower part of the southern elevation are softened to some extent by the LSIP strategic tree planting carried out by the GLA. In addition the finished ground levels of this part of the Barking Riverside development are envisaged to be several metres lower than those currently existing. Consequently it is considered that the careful design and detailing of the western and southern elevations as shown in Drawing 7487-20-010 will consolidate this improvement of the existing view and result in a Slight to Moderately Beneficial visual impact. A photomontage of the proposed development from this receptor (viewpoint 2) has been prepared and is contained in Appendix E. Views from commercial / industrial areas The proposed development will result in a Medium degree of magnitude of change for businesses located on Choats Road and Choats Manor Way although it will be entirely in keeping with the scale and character of existing views. As the development will serve to screen some of the presently unsightly Kuehne and Nagel buildings situated to the north of the CTRL and careful consideration is being given to the detailed design of the proposed development, it is considered that it will result in an overall improvement of the existing views. Consequently the level of impact is deemed to be Moderately Beneficial within the overall context of this industrial area. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 117 From the Rippleside Industrial area there will be a Negligible to Low degree of change to existing views although the upper portion of the stack may be visible from some locations. Consequently there is considered to be Negligible visual impact overall. The magnitude of change in available views from the Pooles Lane Logistic area is considered to be Low. There is deemed to be a Slight Beneficial effect as some of the visual clutter of the container yard in the south west corner of the LSIP will be screened from view. Views from public open space Due to the number of existing vertical elements in a highly urbanised landscape, the magnitude of change is deemed to be Low with an overall Negligible effect on the quality of the existing view. A photomontage of the proposed development from the Scrattons Farm Public Open Space (Viewpoint 3 in Appendix E) shows that views are likely to be restricted during the summer months due to the existing trees and shrubs present on the southern boundary although a greater portion is likely to be visible over the winter period. Consequently the magnitude of change is considered to be Low to Medium depending on the time of year with an overall Slight Adverse visual effect. Views from roads The magnitude of change in relation to the A13 is deemed to Negligible or Low depending on the direction of travel. The proposed northern and eastern elevations of the proposed development will only be partly visible for a very brief period of time to drivers of vehicles and are overall deemed to have a Negligible effect on the existing views in the context of the character of the surrounding landscape. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 118 For users of the pedestrian footbridge over the A13 the magnitude of change to the view southwards over the site is likely to be Low during the summer and Medium during the winter months when the screening effect of existing vegetation is less effective. At its worst in the winter months the significance of the effect could be Low Adverse. Seen from Choats Road the magnitude of change will be Medium although the development of Plot 5 will probably serve to reduce this to Low, for at least some of the views. The overall significance of impact is consequently likely to be Slight to Moderately Beneficial depending on the particular viewpoint. Viewpoint 1 in Appendix E shows that the magnitude of change of the existing view from Choats Manor Way is undoubtedly High with the flue stack being particularly prominent. In visual terms the arrangement of the various elements at the eastern end of the scheme is altogether more disparate. However the reduction in scale of the pylons, the partial screening of the Kuehne and Nagel warehouses and the positive visual contribution that the proposed surface treatments will make along with the filtering of views resulting from the proposed tree planting (section 9.4) mean that the overall significance of effect is only considered to be Negligible to Slight Adverse. Views from the CTRL rail corridor It is considered that the speed of travel of the majority of passengers will mean that in the context of the surrounding urban landscape the magnitude of change will be Low and the visual impact Negligible. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 119 Summary Table 26 provides a summary of the above analysis for each receptor. Table 26: Summary of visual impact assessment findings Range of effects Reference, receptor and location Sensitivity Magnitude Significance Low Slight adverse Low Slight adverse Medium Low Slight adverse Low Negligible Negligible Low Negligible Negligible Medium Slight to Moderately beneficial Residential areas R1 Goresbrook Road / New Road R2 Scrattons Farm Estate Residential area east of Renwick Road R3 (Keel Close) Thames View Estate west of Renwick R4 Road R5 Thamesmead Barking Riverside BR Eastern end of Barking development area Riverside Low medium Medium Medium High - to Commercial / industrial areas B1 Dagenham Dock Low Medium Moderately beneficial B2 Rippleside industrial area Low Negligible low Negligible B3 Pooles Way Logistic Area Low Low Slight beneficial Public open space PO1 Castle Green / Goresbrook Sports Centre Low Low Negligible PO2 Scrattons Farm public open space Medium Low medium Slight adverse RO1 A13 Low RO1a A13 Pedestrian footbridge Medium RO2 Choats Road Low Medium RO3 Choats Manor Way Medium High Rail R1 CTRL corridor Low Low Roads Negligible low Low medium Negligible Slight adverse Slight beneficial Negligible Slight adverse Negligible Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 120 8.4 Mitigation measures The proposed development is unique in many ways given its location in the London Sustainable Industries Park (LSIP), a dedicated site for emerging technologies operating in the field of sustainable resources and energy technology. Buildings in the LSIP will be required to achieve high benchmarks for energy efficiency and sustainability and the environmental infrastructure that supports them will be exemplary in design and designed to be self-sustaining as far as practically possible. In addition to the responsible siting of the proposed development, the materials used to construct the building will create visual interest and improve the overall quality of the surrounding industrial landscape. As discussed in this section and the accompanying Design and Access Statement, it is proposed to use colour and other surface treatments to ensure that the development makes a positive contribution to its immediate environment and that the visual impact of prominent elements such as the flue stack, is minimised. The landscape infrastructure of Extra Heavy Standard trees already installed by the GLA will filter views of the facility from the south and Choats Manor Way as it becomes more established over the coming years. Plot 5, referred to above, has just received planning approval from the LPA and it is considered that as the remainder of the LSIP is developed, the visual quality of the area will improve, serving to further assimilate this proposed development into its surroundings. The landscape plan prepared for the proposed development is given in Appendix L. The plan has been formulated to augment the ‘Urban Woodland’ character stipulated for the LSIP in design guidance produced by Sergison Bates Architects and subsequently adhered to by Barry Chinn Associates when the strategic landscape proposals were produced and implemented on behalf of the GLA. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 121 Some residual impacts will remain once the proposed development is fully constructed and mitigation measures outlined above have been implemented although some of these will be reduced over time as the tree planting associated with the site, the LSIP and the proposed new open space in the northern section of Barking Riverside becomes established. Due to the height of the stack it is impossible to entirely mitigate its impact however the proposed treatment of the stack is likely to assist in reducing its visual impact. The proposed development is located in an industrial area with numerous other tall buildings, pylons, telecommunication masts, chimney stacks, wind turbines etc. so although the stack will be visible from a relatively wide area it is not generally considered to be out of keeping with the existing visual resource. 8.5 Conclusion An assessment of the proposed development’s potential impact on the visual amenity of the surrounding area has been carried out. The assessment considered 16 different locations where people are likely to be exposed to changes in the visual amenity. The development’s greatest impact on the existing visual amenity has been judged as Moderately Beneficial in relation to the Dagenham Docks industrial area, where it is considered within the context of the existing industrial area that the development will result overall in a beneficial improvement to existing views. There is one Slight to Moderately Beneficial Impact in relation to the elevated views from Barking Riverside. There are two Slight Beneficial impacts on the limited views available from the Pooles Lane Logistic area (Kuehne and Nagel) and on the views from Choats Road. Six Slight Adverse impacts have been identified in areas where the development is largely screened from view for most of the year but the upper Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 122 portion of the flue stack remains visible, due to its overall height above ground level. The height of the flue stack was one of the principal factors in the determination of the impact on the view from Choats Manor Way as Negligible to Slight Adverse although this may reduce to Negligible over time as the strategic LSIP and site related tree planting becomes established. All other impacts were considered to be Negligible. Overall it is considered that the development does not result in any unacceptable impacts on the visual resource for the area due to its established highly industrial character and the very large number of prominent vertical structures already existing within the surrounding landscape. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 123 9 Ecology, nature conservation and biodiversity 9.1 Introduction This section considers the potential impact of the proposed development on ecology and nature conservation, both on the site itself and in the surrounding area. 9.2 Existing conditions The site has been completely cleared by the GLA as part of its infrastructure enabling works for the LSIP. A breeding bird survey was undertaken in May 2013 by London Conservation Services to enable discharge of condition 10 of the extant consent. The survey found no breeding birds within the survey area and concluded that it was unlikely that there would be any breeding birds as there was an ‘almost complete absence of suitable nesting habitat’. The current condition of the site is shown in Figure 8 below; there is limited ruderal vegetation on the site margins. Figure 8: Current site condition – November 2013 There are no internationally designated sites (Ramsar, Special Protection Area, Special Area of Conservation) within 10 km of the proposed Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 124 development. Within 5 km, there are a number of statutory (SSSI and LNR) designated sites as well as further non-statutory sites (Sites of metropolitan or borough importance and site of importance for nature conservation (SINC). Statutory sites within 5 km are shown in Table 27 below. Table 27: Statutory nature conservation sites within 5 km of the proposed development Site name Ingreborne Marshes Inner Thames Marshes Abbey Wood Beam Valley St Peter and St Paul Church Yard Crossness East Brookend Country Park Ingrebourne Valley Lesnes Abbey Woods Ripple Parsloe’s Park Squatts Maysbrook Park South The Chase Rainham Marshes Scrattons Park and extension Designation SSSI SSSI SSSI LNR LNR LNR LNR LNR LNR LNR LNR LNR LNR LNR LNR 9.3 Assessment of impacts 9.3.1 Direct impacts – habitat loss / alteration Distance (km) 3.8 3.5 4.2 2.0 2.1 2.2 4.1 4.6 4.8 1.4 2.3 2.3 3.5 3.5 0.6 There will be no direct impacts from the proposed development in terms of loss / alteration of habitat on site due to the lack of habitats on the site itself. 9.3.2 Indirect impacts - emissions There is the potential for off-site impacts principally as a result of emissions to air. The potential impact on designated sites from the stack emissions has been assessed in detail in section 6.4.4. The assessment has considered both emissions of oxides of nitrogen (NOx) and sulphur dioxide (SO2) on a selection of statutory and important non-statutory sites within a 5 km radius Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 125 as previously agreed with the Environment Agency in accordance with its guidance (AQTAG06) for nutrient nitrogen and acid deposition. In all cases, the assessments show that the impact of the proposed development, in terms of the predicted increments to annual average concentrations, disposition rates or critical load, is not significant. Where any critical level is exceeded, this is as a direct result of the prevailing background concentrations. Given that the impact of the proposed development on sites within 5 km is insignificant, it is not necessary to consider potential impact on designated (or candidate) European or internationally protected sites, the closest of which are more than 10 km away from the proposed development. 9.3.3 Indirect impacts - shading In its scoping opinion, LBBD specifically requested that the potential impact of the proposed development on the Goresbrook and Ship and Shovel Sewer SINC due to overshadowing be addressed. A series of sunpaths have been prepared illustrating the shadow cast by the proposed development throughout the year (Drawing 7487-70-005). The Goresbrook and Ship and Shovel Sewer SINC runs close to the western and northern boundaries of the site; the sunpaths clearly show that there is no shadow cast across the SINC during the summer months (June – September). There is a shadow cast across the SINC in December but this is not considered to be significant given that any vegetation in or adjacent to the brook will be dormant at this time of year anyway. 9.4 Mitigation measures There will be significant positive impacts from the landscaping scheme that will be implemented as part of the proposed development (Appendix L). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 126 The landscape design seeks to augment the urban woodland theme of the London Sustainable Industries Park and the complementary proposals recently approved for Plot 5. It consists of the following principal elements: two to three rows of Extra Heavy Standard tree planting on southern and eastern boundaries and some taller faster growing trees on a green island within the site that will serve to filter views of the facility from both within the park and from Choats Manor Way shrub planting comprising of species of value to wildlife around the car park and in the garden area adjacent to the office building excavation of linear depression to create new damp habitat at eastern end of the site which will reinforce the similar ecological niche along established in the Goresbrook corridor establishment of wildflower species associated with woodland and hedges and wetter ground in order to encourage a wide range of invertebrates and assist in the achievement of a BREEAM excellent rating for the development. 9.5 Conclusion The site has been cleared ready for development. The landscape plan continues the GLA’s urban woodland theme and will encompass the creation of a range of new habitats. Implementation of the proposed development therefore will provide direct and indirect ecological benefits. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 127 10 Transport and access 10.1 Introduction This section assesses the impact of vehicle movements associated with the proposed development during construction and operation. 10.2 Existing conditions The site is currently unoccupied and so there are no vehicle movements at present. However the site already has planning consent for an identical use to that proposed. The approach to assessment of transport-related impacts taken in the EIA, submitted in relation to the extant consent, was to compare the vehicle movements from the proposed development with those expected under the outline consent (ref 04/00524), which allowed the LSIP site to be developed for B1/B2/B8 uses. This approach, and its conclusions, were accepted by the GLA / TfL and the LPA (Thames Gateway Development Corporation / LBBD): In the stage 1 referral report (ref PDU/2507/01), Transport for London’s comments note that ‘although the site is currently partly vacant, this actually represents a reduction of the trip levels anticipated to be generated by the previous consented use for the site. As a result, TfL accepts that the development would not have a significant impact on the local highway network of Transport for London Road Network’. Para 1.4 of the planning committee report states that ‘in terms of transport movements to and from the site during both the construction and operations phase, the conclusions of the Environmental Statement that the impacts in respect of highway capacity and highway safety are considered either negligible or moderately beneficial predicated on the Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 128 transport assumption made as part of the extant outline planning permission are accepted.’ A daily total of up to 86 HGV trips and 70 car trips was estimated to result from the consented development, which represented a significant reduction compared with the development consented under 04/00524/OUT. 10.3 Assessment of impacts 10.3.1 Construction Construction of the proposed development would create approximately 50 – 130 temporary jobs (section 3.9). The construction workforce would be expect to be located close to the site and would be encouraged to use a common vehicle between a number of workers to reduce vehicle movements. Parking for construction workers will be provided on-site during construction, within the development boundary. HGV deliveries during the construction period will vary dependent on the activities on site with larger numbers of deliveries, estimated to be up to 20 / day, associated with earthworks and foundations. At other times, HGV deliveries will be approximately 2 – 5 / day. There will also be approximately 20 oversized loads associated with key items of the process equipment. Movement of oversize loads would be coordinated with the local highway authority. It is anticipated that construction traffic will not exceed the levels associated with the operational phase which is discussed in the following section. 10.3.2 Operation Assessment methodology The methodology used for predicting the impact of the proposed development on transport is set out below. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 129 The same approach as that undertaken in relation to the extant consent has been followed i.e. vehicle movements from the proposed development will be compared with those expected under the extant consent (ref 10/00287/LBBD), which allows the site to be developed for use as an energy generation facility. There are four principal changes from the development permitted under the extant consent that have an impact on vehicle movements: Waste to be treated at the facility will increase to 180,000 tonnes / year from 120,000 tonnes / year. Waste will be delivered and residual waste exported in bulk HGVs resulting in a higher payload / vehicle (assumed to be 20 tonnes / HGV rather than 10 tonnes / HGV). Metals will be exported from the facility for further recycling / processing resulting in an additional stream. Employee numbers are increased over that assumed in the extant consent from 35 to 55 staff in total. Of these 55, 45 staff will be employed in production across either two or four shifts, dependent on the specific role, and 10 non-production staff, who would work general office hours. There is no change proposed to delivery hours i.e. deliveries will be accepted between the hours of 07:00 – 22:00 Monday – Friday and 07:00 – 17:00 on Saturdays, over the equivalent of 304 days / year (six days / week excluding bank holidays). All other assumptions are the same as in the assessment submitted for the extant consent e.g. all staff assumed to drive to work, HGV movements Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 130 spread evenly throughout allowed delivery hours, no backfilling of vehicles etc22. Table 28 below summarises the vehicle movements associated with deliveries of waste and export of residual materials / recyclables under the extant consent and the proposed scenarios. Table 28: Operational HGV movements – extant and proposed Parameter Extant consent Proposed Waste (in) Ash (out) Waste (in) Ash (out) Recyclables (out) Tonnes 120,000 10,980 180,000 25,900 8,600 Tonnes / HGV 10 11 20 20 20 Deliveries / year 12,000 1,000 9,000 1,295 430 Total 13,000 10,725 Table 29 below summarises the vehicle movements associated with staff journeys to and from work for the extant consent and the proposed amendment. The four shift system in operation for production staff means that there will be a maximum of 47 staff on site in any 24 hour period. Table 29: Staff vehicle movements – extant and proposed Time 05:00 - 06:00 Extant consent In Out 9 06:00 - 07:00 Proposed In Out 16 8 6 07:00 - 08:00 08:00 - 09:00 9 10 9 15 09:00 - 10:00 10:00 - 11:00 11:00 - 12:00 12:00 - 13:00 13:00 - 14:00 14:00 - 15:00 9 16 15:00 - 16:00 22 It is likely that some backfilling of vehicles will occur, which will reduce the number of HGV movements. However, it is not possibly to accurately quantify the amount at this stage and so to ensure a conservative and robust assessment, it is assumed that no backfilling will take place. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 131 Extant consent In Time Out Proposed In Out 16:00 - 17:00 17:00 - 18:00 9 10 18:00 - 19:00 19:00 - 20:00 20:00 - 21:00 21:00 - 22:00 8 22:00 - 23:00 Total 6 9 35 35 15 47 47 Summary Table 30 below shows the overall vehicle trips for both the extant consent and proposed operations. It can be clearly seen that the proposed change to the tonnage treated has no significant impact on vehicle movements and in fact, total number of HGV movements is reduced compared with the extant consent owing to the use of larger vehicles. The report of the Director of Planning for the extant consent stated in para 1.4 that ‘in terms of transport movements to and from the site during both the construction and operations phase, the conclusions of the Environmental Statement that the impacts in respect of highway capacity and highway safety are considered either negligible or moderately beneficial predicated on the transport assumptions made as part of the extant outline planning permission are accepted’. Furthermore, in para 9.57, the Council’s ‘Transport Development Management team and TfL … accept that the development would not have a significant impact on the local highway or the TfL road network’. Therefore, given that the vehicle movements associated with the extant consent do not have a significant impact, it can be concluded that the similar number of movements associated with the proposed development will have no impact either, particularly as the HGV movements associated with the proposed development are lower than in the extant consent; the increase of Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 132 8 trips / day overall is due to the increased number of employees resulting in assumed additional car trips. It is important to note that the assessment assumes that all employees drive to work on their own. Census travel to work data referred to in the accompanying draft travel plan (Appendix F), indicate that it is more likely that around 20 staff would drive to work, two would be a passenger in a car / van, 19 would use public transport, four walk, and one each travel by motorcycle and bicycle. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 133 Table 30: Predicted traffic flows – staff and HGVs for extant consent and proposed operations Extant consent vehicle movements Staff Time In Commercial Out In Cars 05:00 - 06:00 Out In Total In All vehicles 8 07:00 - 08:00 Staff Out HGV 9 06:00 - 07:00 Proposed vehicle movements Total Out In Cars 9 0 9 0 8 8 2.9 2.9 2.9 2.9 5.8 2.9 2.9 11.9 2.9 14.8 09:00 - 10:00 2.9 2.9 2.9 2.9 10:00 - 11:00 2.9 2.9 2.9 11:00 - 12:00 2.9 2.9 2.9 2.9 Total Commercial Out In HGV Out Total All vehicles 16 6 16 0 16 0 6 6 2.4 2.4 2.4 2.4 4.7 2.4 2.4 12.4 2.4 14.7 5.8 2.4 2.4 2.4 2.4 4.7 2.9 5.8 2.4 2.4 2.4 2.4 4.7 2.9 2.9 5.8 2.4 2.4 2.4 2.4 4.7 2.9 2.9 2.9 5.8 2.4 2.4 2.4 2.4 4.7 2.9 11.9 2.9 14.8 2.4 2.4 17.4 2.4 19.7 2.9 2.9 2.9 11.9 14.8 2.4 2.4 2.4 18.4 20.7 15:00 - 16:00 2.9 2.9 2.9 2.9 5.8 2.4 2.4 2.4 2.4 4.7 16:00 - 17:00 2.9 2.9 2.9 2.9 5.8 2.4 2.4 2.4 2.4 4.7 2.9 2.9 2.9 11.9 14.8 2.4 2.4 2.4 12.4 14.7 18:00 - 19:00 2.9 2.9 2.9 2.9 5.8 2.4 2.4 2.4 2.4 4.7 19:00 - 20:00 2.9 2.9 2.9 2.9 5.8 2.4 2.4 2.4 2.4 4.7 2.9 2.9 2.9 2.9 5.8 2.4 2.4 2.4 2.4 4.7 2.9 2.9 10.9 2.9 13.8 2.4 2.4 8.4 2.4 10.7 0 9 9 15 15 78.5 78.5 157 82.3 165 08:00 - 09:00 9 12:00 - 13:00 13:00 - 14:00 9 14:00 - 15:00 9 17:00 - 18:00 9 20:00 - 21:00 21:00 - 22:00 8 22:00 - 23:00 Total 9 35 35 43.5 43.5 10 15 16 10 6 15 47 47 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 35.3 35.3 82.3 134 10.4 Mitigation measures 10.4.1 Introduction The assessment in section 10.3 above has demonstrated that vehicle movements associated with the proposed development are very similar to those under the extant consent; whilst assumed employee trips are slightly higher, HGV movements are reduced. As vehicle movements under the extant consent had no significant impact on the existing network (section 10.3.2) there are therefore no specific mitigation measures required with respect to vehicle movements. However, a number of policies at national, regional and local level (e.g. NPPF policy 4, London Plan policies 6.3 and 6.9 and Barking and Dagenham DPD policies BR10 and BR11 (section 4.3.3)) require measures to reduce the need to travel where possible and encourage travel by more sustainable means; mitigation measures with respect to more sustainable transport options are discussed below. 10.4.2 Waterborne transport The residual waste to be treated at the proposed development will come from a number of locations within the east and north London area. It is not practicable therefore to consider transport by water during the operation of the development. The possibility of bringing in materials by river during the construction phase will be reviewed with shortlisted contractors during the procurement process. 10.4.3 Cycle parking Twenty secure, covered cycle parking spaces will be provided in two locations; adjacent to the office entrance and close to the materials reception building as shown on drawing 7487-70-003. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 135 10.4.4 Electric cars Dedicated parking spaces and charging points for four electric cars, with passive provision provided in a further two spaces will be provided as shown on drawing 7487-70-003. 10.4.5 Shuttle service TGW2E has committed to the provision of a minibus shuttle service to / from Dagenham Dock station at appropriate times of day to be agreed once the facility is operational. 10.4.6 Travel plan A draft travel plan has been produced which is included in Appendix F. The travel plan cannot be finalised until the development is operational and the preferred travel modes of staff and their journeys are known. The travel plan will be finalised within six months of the development becoming operational and submitted to LBBD for approval. 10.5 Conclusion The vehicle movements associated with the proposed development are very similar to those under the extant consent, which were found to have no significant impact on the local highways or TfL road network. HGV movements are reduced but employee car movements are slightly higher reflecting the increased number of jobs. Employee vehicle movements have also been calculated on a worst case basis assuming all employees drive; in reality staff will use a number of transport modes and the travel plan is specifically targeted at reducing single person car journeys to and from the site. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 136 11 Geology, ground conditions and land quality 11.1 Introduction Existing ground conditions under the proposed development have been characterised through numerous desktop and intrusive investigations on the site and the surroundings, the findings of which have been previously submitted to LBBD in support of earlier planning applications for the site. Most recently, a Phase 1 desk-based assessment was undertaken by TGW2E (Appendix G) and submitted to LBBD to discharge condition 22a of the extant consent, which states that: No development approved by this permission shall be commenced prior to a contaminated land assessment and associated remedial strategy, together with a timetable of works, being submitted to the Local Planning Authority for approval: a) The contaminated land assessment shall include a desk study to be submitted to the Local Planning Authority for approval. The desk study shall detail the history of the site uses and propose a site investigation strategy based on the relevant information discovered by the desk study. The strategy shall be approved by the Local Planning Authority prior to investigations commencing on site. Following approval of the Phase 1 desk study, TGW2E has undertaken a site investigation in accordance with the assessment methodology approved by LBBD. The assessment has included relevant sampling and analysis and production of a revised conceptual model. The Phase 1 and Phase 2 assessments are contained in Appendix G and Appendix H respectively and the findings are summarised in this chapter. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 137 11.2 Existing conditions 11.2.1 Previous contaminative uses The site itself and the wider area have been developed over approximately the last 100 years for a range of uses including rail sidings, sewage treatment plant and most recently as a depot during construction of the Channel Tunnel Rail Link. A number of historic landfills have been identified within 250m of the site boundary but these are not considered to pose a significant risk to the site. 11.2.2 Ground conditions BGS borehole records at the site confirm the presence of Made Ground to depths of between 1.5m and 3m depth over soft alluvial clays and peat typically to 6m depth. Sand and Gravel consistent with River Terrace Deposits were noted to depths of around 10 to 12m overlying the silt and clay of the Lambeth Beds. 11.2.3 Groundwater The recorded permeability of the drift geology is moderate to very low reflecting the variability of the Alluvium and underlying sand and gravels. Permeability of the solid geology is identified as moderate to very low reflecting the variability of the Lambeth Beds which are inter-bedded sands. The site does not lie within outside any source protection zone and there are no groundwater abstraction wells within 2000m of the site. The site is shown as being at very high risk of groundwater flooding. This is likely to be due to the potential for near surface groundwater within the Alluvium. As site levels appear to have been raised as part of land reclamation works this risk is considered a lower risk more likely to be associated with underground structures, which can be addressed through design. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 138 11.2.4 Hydrology The closest surface main watercourse to the site is the Gores Brook located 10m from the northern and western boundary of the site. The Gores Brook flows from the north to the south and discharges into the River Thames. A drain is present 15m E of the site flowing along the site boundary and discharging in to the Gores Brook. A review of the Environment Agency’s flood maps indicate that the proposed site lies within Flood Zone 3. There are no licensed surface water abstractions within 250m of the site. 11.2.5 Coal mining search No coal or other mining activity is identified below or close to the site. 11.2.6 Ground Workings No active ground workings have been identified within 250m of the site. A number of historic surface extractions have been identified within 250m of the site; all are considered low / no risk. 11.2.7 Radon The Groundsure Report indicates that no radon precautions are necessary. 11.2.8 Summary The site is considered to be of moderate sensitivity for the following reasons: The end purpose is for commercial / industrial use. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 139 The bedrock is classified as a Principal Aquifer, however this is overlain by a secondary aquifer. 11.3 The site is situated outside of a Source Protection Zone. There are no ecological sensitivities on site or adjacent to the site. There are no groundwater abstractions on site or adjacent to the site. Assessment of impacts 11.3.1 Preliminary conceptual model The conceptual site model (CSM) is a dynamic representation of the site, to be refined and developed at each stage of the site investigation process. The conceptual site model contains three principal elements: Source - probable or actual contaminants; their nature and location. Receptor– existing and, within reason, foreseeable targets, on or off-site, which the source may affect. Pathway – the means by which the source and the receptor may come into contact. Where a source – pathway – receptor pollutant linkage is envisaged, an estimation of the risk posed by this linkage can be made. Should any one of the three elements (source, pathway or receptor) be absent, then there is no risk. Table 31 presents the preliminary conceptual model for the site in its existing state. Table 31: Preliminary conceptual model Source Human health Metals Hydrocarbons Location Exposure pathway Former sewage works Ingestion dermal Oil tanks storage Ingestion, dermal inhalation and and Potential receptor Probability of exposure Details Construction workers Site users Dismissed Construction workers Site users Dismissed Normal PPE will address risk No contamination identified Normal PPE will address risk No contamination identified Negligible Negligible Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 140 Source Location Heavy metals (lead TP703) Made ground Hydrocarbons, metals and asbestos Hydrocarbons and metals Ground gas Made ground Unforeseen contamination Made ground and landfill Groundwater Hydrocarbons Potential and metals spillage on site Surface water Hydrocarbons Potential and metals spillage on site Environmental receptors On site contaminants Building services On site contaminants Exposure pathway Ingestion, dermal and inhalation Potential receptor Construction workers Site users Probability of exposure Dismissed Ingestion, dermal inhalation Construction workers Dismissed Site users Negligible Construction workers Dismissed Site users Low Construction workers Site users Low Vertical migration Groundwater Negligible DQRA shows no significant risk Horizontal migration Watercourses Negligible DQRA shows no significant risk Ecology Dismissed No ecological designations Archaeology Geology Dismissed Dismissed Phytotoxic Phytotoxic Ingestion, dermal and inhalation Woodland Crops Livestock Dismissed Dismissed Dismissed No receptor No sensitive receptor No receptor No source No source Direct Historic building Proposed buildings Water pipes Dismissed No receptor Dismissed No significant source No significant source Ingestion, dermal inhalation Inhalation explosive Ingestion, dermal inhalation Direct Direct and and and Low and Direct Permeate pipework Low into Dismissed Details Normal PPE will address risk Remediation in soft landscape areas recommended Normal construction PPE will address risk under CDM No significant sources identified Normal construction PPE will address risk under CDM Discovery strategy No confined entry likely Characteristic situation 2 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 141 11.3.2 2013 site investigation The full report is contained in Appendix H with key findings summarised in this section. The site works comprised eight trial pits (TP1 – TP8) and seven cable percussive boreholes (BH1 – BH7) and were undertaken between 16st and 31st July 2013. Groundwater and gas monitoring wells were installed within the five of boreholes. Locations of all exploratory holes are shown on Drawing CRM.035.006.D.003 in Appendix H. Contamination samples were generally taken within the upper 1m as this material is likely to have been impacted by potential spillage and leakage associated with the previous industrial use. In addition, samples were taken from soils showing evidence of contamination and also samples from below areas of potential contamination. Four return visits were undertaken to monitor ground gas and measure depth to groundwater. During one of the visits, groundwater samples were taken from the boreholes with the wells. Ground conditions The site investigation confirmed the published geology and identified the following strata: Made ground Alluvium Terrace Gravels Lambeth beds Thanet sands Groundwater was encountered within all exploratory holes. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 142 Visual and olfactory evidence of contamination, black staining in the made ground, was encountered in TP3, TP5, BH5 and BH7 with black staining at a greater depth in the Lambeth Beds encountered in BH4 and BH6. 11.3.3 Risk assessment A Tier I risk assessment has been undertaken using available and current screening values for human health and where appropriate controlled waters. The risk assessment is undertaken based on the findings of the preliminary conceptual model given in Table 31. Based on the contamination testing and Tier I assessment a revised Conceptual Model has been prepared, which is given in Table 31 below. Where significant risks are identified remedial measures are recommended. Human health Assessment of the risks to human health has been undertaken by comparing the soil quality data from both the current (2013) investigation and analyses previously undertaken by others, with reference values obtained from the Contaminated Land Exposure Assessment (CLEA), Soil Guideline Values (SGV) and General Acceptance Criteria (GAC). A summary table of the reference values is included in Appendix H. Where an exceedance is identified the risk is assessed by considering the sensitivity of the proposed development and the potential pathway. As the site is to be developed as an Energy Recovery Facility it is considered that commercial values are applicable. The soil quality analyses from all studies only show exceedances above the reference values for a commercial end use as shown in Table 32 below. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 143 Table 32: Locations where reference values exceeded Location / depth / study Enzygo 2013 TP4A at 0.35m BH2 at 0.30 – 0.50m PBA 2007 TP703 2.40m ESI 2007 69316 2.50m ES1 2010 TP22 0.80m (off site) Determinand GAC (mg/kg) Concentration (mg/kg) Lead Lead 590 590 2136 610 Lead 590 7222 Arsenic 640 1028 Lead 590 930 Asbestos fibres, confirmed as chrysotile, were detected in two locations (TP3 and TP5) at a depth of 0.40 m. The elevated lead and arsenic are considered to originate from ash and clinker within the made ground and are only considered to pose a risk where they can be exposed to site users. Encapsulation below hardstanding will effectively break the source pathway-receptor scenario. Controlled waters A detailed quantitative risk assessment (DQRA) was undertaken in 2010, the results of which are summarised in Appendix H. The DQRA showed no significant risks to controlled waters although identified a possible impact from ammoniacal nitrogen, probably resulting from the former sewage treatment works, which could impact controlled waters after 500 years. It is considered that capping the site with hardstanding as part of the proposed development will reduce water ingress and therefore reduce the potential impact from this ammoniacal nitrogen. Groundwater concentrations measured in samples collected during the 2013 investigation have been compared against threshold concentrations derived Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 144 from the 2010 DQRA or reference values23 as appropriate. An assessment of likely risk has then been made based on a source-pathway-receptor model. Determinands were generally below the respective limits and most are below screening values with the exception of the results given in Table 33 below. Table 33: Elevated groundwater concentrations recorded in 2013 study Location Determinand Threshold (mg/l) Concentration (mg/l) BH2 Anthracene 0.02 0.03 BH5 Anthracene 0.02 0.03 BH6 Zinc 254 300 There were no elevated concentrations of anthracene or zinc measured in soil samples collected from these boreholes. Ash was noted in the made ground in BH6 which may account for the elevated zinc concentration. BH6 is located on the southeast of the site away from Gores Brook and boreholes located nearer the brook did not record elevated zinc concentrations indicating that it is unlikely that the zinc will migrate to the brook. Moreover, any groundwater entering the brook will be significantly diluted and so the exceedance of the EQS in groundwater at BH6 is not considered to have any significant impact on surface water quality. Risk to the aquifer is dismissed as the concentration is below drinking water standards. No sources of anthracene were noted in the boreholes and no other polyaromatic hydrocarbons (PAH) concentrations exceed threshold values. It is likely that the minor exceedance by anthracene may be a result of residual water impact following previous remediation works and that 23 Fresh water Environmental Quality Standards (EQS), UK drinking water Standards (DWS) and World Health Organisation (WHO) values for drinking water Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 145 anthracene has been identified as a potential exceedance due to its very low EQS value. Again, as groundwater entering Gores brook will be significantly diluted, the marginal exceedance for anthracene is not considered to have any significant impact on surface water quality. The installation of hardstanding / buildings over 84% of the site, together with the proposed drainage system will eliminate the potential for future surface water percolation into the underlying materials and groundwater. As a previous remediation exercise has been carried out and the chemicals identified have only been encountered in isolated pockets and the exceedances have not been encountered in groundwater closer to the receptor it is considered that the residual EQS exceedances identified in the groundwater are not migrating to the receptor. It is therefore considered that these residual determinants will naturally attenuate into the surrounding ground before reaching the receptor. Ground gas Where potential risk from ground gas has been identified from the preliminary conceptual model and the intrusive ground investigation works, the results of the monitoring are compared against relevant gas screening values24. From this analysis, the Characteristic Situation is identified and remedial measures proposed as appropriate. When assessing the risk and type of remedial measures appropriate, consideration is given to the likely construction of the development, the nature of the gas posing a risk and the nature of the likely source. Given the presence of peaty materials and as carbon dioxide concentration was recorded above 5% during a number of visits consideration has been 24 CIRIA Report 665 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 146 given to increasing the gas risk situation. However, due to the absence of measurable gas flow and the nature of carbon dioxide, which is heavier than air, there is not considered to be a significant risk that gas can enter buildings. Therefore, it is considered that Characteristic Situation 1 still applies and no special precautions are required. 11.3.4 Revised conceptual model The preliminary conceptual model (Table 31) has been revised in the light of the findings of the site investigation and the risk assessment discussed in section 11.3.3 above. The revised conceptual model is given in Table 34 below. Table 34: Revised conceptual model Source Location Exposure pathway Potential receptor Probability of exposure Details Former sewage works Ingestion and dermal Low Remediation recommended Hydrocarbons Oil tanks Ingestion, dermal and inhalation Dismissed No exceedance of GAC values Heavy metals (lead TP703) Made ground Ingestion, dermal and inhalation Low Remediation recommended Hydrocarbons, metals and asbestos Made ground Ingestion, dermal and inhalation Dismissed No exceedance of GAC values Hydrocarbons and metals Unforeseen contamination Ingestion, dermal and inhalation Construction workers Site users Construction workers Site users Construction workers Site users Construction workers Site users Construction workers Dismissed Ground gas Made ground and landfill Inhalation and explosive Site users Construction workers Site users Low Dismissed Normal construction PPE will address risk under CDM Discovery strategy Characteristic situation 1 Groundwater Hydrocarbons and metals Potential spillage on site Vertical migration Groundwater Negligible DQRA shows no significant risk. Concentrations below DWS Surface water Zinc BH6 Horizontal migration Watercourses Dismissed Source away from surface watercourse. Any ingress will be diluted below EQS. Capping site will reduce potential migration. Human health Metals storage Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 147 Source Location Anthracene BH2 and BH5 Environmental receptors On site contaminants Building services On site contaminants Exposure pathway Horizontal migration Potential receptor Watercourses Probability of exposure Dismissed Details Ingestion, dermal and inhalation Direct Direct Phytotoxic Phytotoxic Ingestion, dermal and inhalation Ecology Dismissed No designations Archaeology Geology Woodland Crops Livestock Dismissed Dismissed Dismissed Dismissed Dismissed No No No No No Direct Historic building Proposed buildings Water pipes Dismissed No receptor Dismissed No significant source Dismissed No significant source Direct Permeate into pipework 11.4 No source noted. Slight exceedance of EQs only. Any ingress will be diluted below EQS. Capping site will reduce potential migration. ecological receptor sensitive receptor receptor source source Mitigation measures The proposed development utilises hard landscaping, which will provide a barrier between future site users and any contamination present within the underlying soils effectively breaking the source-pathway-receptor model. As concentrations of determinands where the primary pathway is inhalation have not been detected above the relevant GAC value the risk from indoor inhalation can be dismissed. There is a low risk to construction workers from concentrations of lead, arsenic and potential asbestos fibres in the soil; these risks should be addressed by the Contractor under its Construction Stage Health and Safety Plan, as required by the Construction, Design and Management (CDM) Regulations. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 148 These measures are likely to include: Management of the construction works to limit access to potentially contaminated soils by construction staff. Securing the site to prevent access by unauthorised people and requirements for site induction for site staff. Use of a clean area with appropriate welfare facilities. Management of dust through control of any bulk earthworks operation and where necessary wetting down. Use of appropriate PPE. Remedial measures to protect controlled waters are not considered necessary following the assessment of the results. It is recommended that the hardstanding is utilised to manage future surface water ingress to the site thereby reducing potential migration of groundwater into watercourses. This will provide environmental the betterment surface through construction. It is recommended that surface water samples are collected from Gores Brook for analysis to confirm that there are no adverse impacts on surface water quality prior to and following the construction works. Samples should be collected as follows: one sample up-stream of the site one sample adjacent to the site one sample down-stream of the site. If unforeseen contamination is encountered during construction works such as localised spillage outside the areas investigated an Environmental consultant will be available on a ‘call out’ basis to undertake an assessment of risk. If ‘unforeseen contamination’ is encountered, the discovery strategy will be to remove the source as it is likely to be very limited in extent. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 149 11.5 Conclusion The small number of pollutant linkages that exist will be removed through the installation of hardstanding on site. There are no significant risks to human health for the site’s end users once the development is completed. Potential risks to workers during construction will be addressed through appropriate working procedure and equipment. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 150 12 Water resources 12.1 Introduction Assessment of impact on water resources – hydrology, hydrogeology, flood risk and drainage was initially scoped out of consideration (Appendix A) on the basis of the findings of the previous EIA and the fact that the proposed changes in terms of the new technology / layout would not affect these findings. LBBD agreed that there was no need for a new FRA to accompany the application on the basis that the mitigation measures described in the previous assessment and included in condition 21 of the extant consent have been incorporated into the design of the proposed development and will be complied with for the life of the development. However, Thames Water, in its response to LBBD during the scoping process, expressed a concern that the network may be unable to cope with demand and requested that the following issues be considered: The proposed development’s demand for water supply and network infrastructure both on and offsite The proposed development’s demand for sewage treatment and network infrastructure both on and offsite The surface water drainage requirements and flood risk of the development both on and offsite Piling methodology and its potential impact on neighbouring utility services. These specific issues raised by Thames Water are addressed in this section. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 151 12.2 Existing conditions The ground conditions including groundwater and hydrology have been described in section 11.2. The site is at high risk of groundwater flooding due to the potential for near surface groundwater within the Alluvium. The site does not lie within outside any source protection zone and there are no groundwater abstraction wells within 2000m of the site. The closest surface main watercourse to the site is the GoresBrook located close to the northern and western boundary of the site. The GoresBrook flows from the north to the south and discharges into the River Thames. There are no licensed surface water abstractions within 250m of the site. A review of the Environment Agency’s flood maps indicate that the proposed site lies within Flood Zone 3. There is currently no drainage infrastructure on the site. 12.3 Assessment of impacts 12.3.1 Construction Specific impacts on water resources during construction of the proposed development may include: Pollution of ground waters caused by improper handling and disposal of construction site wastewater. Spillage or infiltration of oils, fuels, and hydraulic fluids etc from plant maintenance and refuelling areas onto ground. The production of wastewater with potentially high particulate loads which may require treatment prior to disposal. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 152 Piling methodology The proposed development will utilise precast driven piles, which will only have a localised effect on the surrounding ground. The buildings and equipment foundations that are to be piled are all within the site, a minimum of 5m away from the site boundary; there will therefore be no impact on any services outside the site. 12.3.2 Operation Water supply Detailed discussions with Essex and Suffolk Water to date have not identified any concerns with respect to provision of a water supply to the site. The flood risk assessment undertaken by Price and Myers in relation to the whole LSIP identifies that the site of the proposed development is already above the minimum build level of 1.625m AOD agreed with the Environment Agency. A maximum rate of surface water discharge has been set at 6l/s/ha for all storm conditions. Surface water will be collected on site by traditional below ground drainage systems with incorporated attenuation tanks designed for the various storm conditions and finally discharged into the estate drainage system at the two site entrances provided by the GLA as part of the overall LSIP development. Waste water Waste water from the proposed development site will be collected by traditional below-ground gravity drainage systems and prior to discharge into the estate drainage system at the two site entrances provided by the GLA as part of its infrastructure enabling works. The maximum discharge requirement of 5l/s and specified chemical content has been agreed with the GLA. TGW2E understands that the GLA is currently in negotiation with Thames Water to improve the downstream foulwater drainage system and Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 153 pumpstation to meet the requirements from all of the existing and proposed developments on the LSIP. Drainage design The proposed drainage strategy is shown in Drawing MA9580/200 and has been designed in accordance with the FRA for the LSIP undertaken by Price and Myers (report dated 29 January 2010) and the Surface Water Management Strategy for Plot 2 undertaken by MMI Civils in relation to the extant consent (report dated February 2010). Key elements of the drainage design area as follows: Discharge limited to greenfield surface water run-off rate of 6l/s/ha. Infiltration-based drainage methods are not feasible due to the highly variable and unpredictable percolation characteristic combined with the high water table. The SUDS strategy is based on attenuated surface water to final discharge into public sewer incorporating rainwater harvesting for use on site where possible. 1890m3 of underground storage will be installed, located as shown on Drawing MA8605/200 to provide sufficient storage for 1 in 100 year event. An additional 300m3 storage will be provided for rainwater harvesting subject to enduser requirements. 12.4 Mitigation measures 12.4.1 Construction The mitigation measures described below are based on best practice detailed in the Environment Agency’s Pollution Prevention Guidelines (PPGs), and anticipated construction techniques and will be incorporated into the Construction Environmental Management Plan (section 3.9). Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 154 Surface water runoff Site surfaces should be compacted to help reduce the amount of surface water soaking into the ground and the amount of silty water that has to be dealt with. Open stockpiles of materials and areas of exposed, unmade ground will be minimised. Stockpiles of construction materials (e.g. aggregates sand and fill materials) should be covered with tarpaulin or a silt fence constructed using a suitable geotextile, as a matter of course, but particularly during rainstorms. Plant and wheel washing All vehicles and plant will be cleaned if necessary, before leaving the construction site, to ensure that no earth or mud etc is deposited on the road. Wheel washers and plant washing facilities will be securely constructed with no overflow and the effluent will be contained for proper treatment and disposal. Fuel and oil storage All fuel and oil will be stored on an impermeable base within a bund and secured. The base and walls will be impervious to the material stored and of an adequate capacity. Drip trays will be used under compressors, pumps, motors and any redundant plant and during refuelling. When plant maintenance is carried out on site, used oil should be stored in a bunded area for collection. Oil and fuel filters should also be stored in a designated bin in a bunded area for separate collection. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 155 12.4.2 Operation Leaks and spillages The majority of potential operational-related impacts have been minimised or eliminated through the design of the proposed development which means that all operations will take place in enclosed buildings with appropriately designed water treatment plant. Fuel storage and filling areas will be permanently bunded during operation to ensure any spillages are contained and can be dealt with accordingly. Design of tanks and bunds will be in accordance with the requirements of the Oil Storage Regulations (2001) and the guidance given in Environment Agency Pollution Prevention Guideline 2 – above ground oil storage tanks. Flooding The drainage strategy, which includes water storage to be provided on site and discharge rates to be restricted, means that the site is not at increased risk of flooding, nor will it increase the flood risk elsewhere. Regulatory requirements All discharges to controlled waters from the proposed development will be in accordance with either an Environmental Permit or discharge consent. All trade effluent discharged to foul sewer will be in accordance with a trade effluent consent issued by the statutory sewerage undertaker. 12.5 Conclusion The principal potential impact on water resources from the proposed development is in relation to its location in an area of high flood risk. However, implementation of the mitigation measures described in the LSIP FRA and summarised in this section mean that the site will not be at increased risk of flooding once developed, nor would it increase the risk of flooding elsewhere. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 156 13 Energy and sustainability 13.1 Introduction The efficiency of the proposed development has been calculated using the GLA’s prescribed methodology for energy statements25. A BREEAM pre-assessment has also been undertaken which identifies indicative credits that can be achieved and also the target standard achieved in each category and overall. 13.2 Existing conditions The existing baseline in relation to energy and sustainability is essentially one where the waste to be treated by the proposed facility is sent to landfill. 13.3 Assessment of impacts 13.3.1 BREEAM rating The BREEAM pre-assessment is included in Appendix I and demonstrates that the proposed development should achieve an ‘excellent’ rating. The assessment will be developed further as detailed design proceeds. 13.3.2 Energy assessment The energy assessment (Appendix J) investigates the use of passive energy efficiency measures, the use of Combined Heat and Power and further complimentary Low / Zero Carbon Generating Technologies (LZCGTs) to reduce regulated CO2 emissions associated with energy consumption within the proposed development to a level 40% below the current Target CO2 emission rate as set out in Part L2 of the Building Regulations. 25 Energy planning: GLA guidance on preparing energy assessments – September 2013 Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 157 The following benchmarks are considered in relation to the ‘Lean’, ‘Clean’ and ‘Green’ target benchmarks set out in Policy 5.2B of the London Plan. Lean – Reducing demand through passive energy efficiency measures Clean – Consideration of CHP / district heating and mandatory incorporation of heat export / district heating infrastructure where feasible. Green – Consideration of renewable technologies (complimentary to CHP) The energy strategy, and influencing factors, can be summarised as follows: There is a clear commitment to reduce regulated CO2 emissions to a level below that required within Part L of the 2010 Building Regulations through energy demand reduction measure, ie through maximising passive energy efficiency measures (these measures are discussed further in Appendix J). Further to maximising energy efficiency measures the building will make use of electricity generated by the proposed development itself to provide all building heating and electricity. In line with Policy 5.17B of the London Plan, the ‘Carbon Intensity’ for electricity generated by the development has been calculated. This figure has been confirmed as -629g CO2/kWh, which is considerably below the ‘Carbon Intensity Floor’ of 400g CO2/kWh as set out in Policy 5.17B of the London Plan. As such electricity supplied to the building from the plant itself has been defined as Carbon Neutral within this assessment, i.e. a CO2 emission Rate of 0.0 kg.CO2/kWh. Table 35 and Table 36 below summarise the carbon dioxide savings at each stage of the hierarchy. It can be seen that the proposed development exceeds Part L2 of the 2010 Building Regulations by passive energy efficiency measures alone. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 158 Incorporating the savings from energy generation reduces building CO2 emissions by approximately 80% relative to the part L 2010 target emission rate (TER) and therefore the proposed development exceeds the target in Policy 5.2 of the London Plan. Table 35: Carbon dioxide emissions after each stage of the energy hierarchy Hierarchy Baseline building: Building Regulations 2010 Part L compliant development Lean – after energy demand reduction Clean – after CHP Green – after renewable energy Carbon dioxide emissions (tonnes CO2 / year) Regulated Unregulated 33.92 1.194 28.95 6.53 6.53 1.194 1.185 1.185 Table 36: Regulated carbon dioxide savings from each stage of the hierarchy Regulated carbon dioxide savings Tonnes CO2 / year % 4.97 14.64 22.42 77.45 0.00 0 27.39 80.75 13.57 40 13.82 Hierarchy Savings from energy demand Savings from CHP Savings from renewable energy Total cumulative savings Total target savings Annual surplus 13.4 Mitigation measures The proposed development meets the policy requirements with respect to BREEAM and energy efficiency and so no specific mitigation measures are required. 13.5 Conclusion The results of the BREEAM assessment and energy assessment summarised in this section demonstrate that the proposed development meets the requirements to achieve a BREEAM excellent rating and to achieve a 40% improvement on 2010 Building Regulations. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 159 14 Socio-economic and health 14.1 Introduction This section considers the prevailing socioeconomic environment in the area and identifies the key impacts that the proposed development will have in terms of environment, social and community impacts. Information in this section has been drawn from a range of publicly available sources, which are referenced as appropriate. 14.2 Existing conditions 14.2.1 The London Borough of Barking and Dagenham The borough was formed in 1965 by the London Government Act (1963) as the London Borough of Barking and renamed the London Borough of Barking and Dagenham in 1980. Census data show that the population was approximately 165,000 in 1961, falling to a low of 146,000 in 1991. Over the last twenty years the population has increased significantly to 186,000 (2011 census). Barking and Dagenham manufacturing sector. has traditionally been known for its strong In recent years manufacturing employment has declined, to be replaced by a more service-based economy. However, manufacturing still accounts for 16% of employment in the Borough, compared with just 4% across London as a whole. Table 37 below shows a breakdown of employment by sector in the Borough26. 26 http://www.nomisweb.co.uk/reports/lmp/la/2038431874/report.aspx Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 160 Table 37: Employment by sector in Barking and Dagenham Employment sector Number of jobs Employees (%) Manufacturing 7,400 16.3 Construction 2,000 4.5 Services 36,000 79.1 Distribution, hotels and restaurants 11,100 24.4 Transport and communications 4,200 9.1 Finance, IT, other business activities 6,000 13.3 Public administration, education and health 12,600 27.7 Other services 2,100 4.5 The Barking and Dagenham Joint Strategic Needs Assessment27 published in October 2013, identifies that some 12,370 residents have been claiming out of work benefits (Incapacity Benefit and Employment Support Allowance, lone parents, Job Seekers Allowance/unemployment) for 1 year or more. This figure represents 10.4% of the working age population, compared with 7.3% London-wide. Over the last 10 years the rate in the borough has consistently been at least 3% higher than the figure for London. In Barking and Dagenham only 62.9% of working age people (aged 16-64) are in employment. Over 8400 residents would need to move into work to ensure convergence with the London employment rate (69.5%). The Barking and Dagenham workforce is relatively low skilled and the borough has much lower proportions of qualified adults at every level compared with London or England although the borough is improving at a faster rate than national or regional averages. The Index of Multiple Deprivation (IMD) provides a means of ranking areas (lower super output areas (LSOA)) in terms of the multiple extent of 27 http://www.barkinganddagenhamjsna.org.uk/Documents/JSNA2013-all.pdf Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 161 deprivation experienced by people living in that area. There are 38 separate indicators organised across seven distinct domains which address employment, income, health deprivation and disability, living environment, crime, education skills and training, and barriers to housing and services. These indicators are then combined and ranked to provide indicators at borough level. When considering the population weighted average of the combined scores for the LSOAs, Barking and Dagenham is ranked 22nd out of 326 local authorities in England, which places it in the top 7% most deprived boroughs in England. When considering the population weighted average of the combined ranks for the LSOAs, Barking and Dagenham is ranked 8th out of 326 local authorities in England, which places it in the top 3% most deprived boroughs in England. In 2007, the Borough had 13 LSOAs ranked within the 10% most deprived in England. In 2010, this figure had reduced to 11. The entire borough lies within the worst 50% LSOAs in the country. Barking and Dagenham has been awarded Beacon Status for tackling climate change, has a Low Carbon Zone and forms part of the East London Green Enterprise District. 14.2.2 Thames Ward Thames Ward is the largest, but the lowest populated, ward in the Borough with 9,425 residents28. It has the highest proportion of 16 – 74 year olds employed in manufacturing industries. There were 400 unemployment claimants in the ward in September 2010. 28 http://www.barkingdagenhampartnership.org.uk/facts-figures/Documents/Thames.pdf Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 162 Of the 11 LSOAs ranked within the 10% most deprived in England, three of them (1974, 2420 and 2801) lie in Thames Ward. The rest of Thames Ward is within the 30% most deprived LSOAs in the country. 14.2.3 The London Sustainable Industries Park The aim of the London Sustainable Industries Park (LSIP) is to create the UK’s largest concentration of environmental industries and technologies. The vision is for a closed loop system, with businesses delivering waste to energy projects, combined heat and power schemes, recycling and reprocessing facilities, and renewable energy technologies. This system enables businesses to develop synergies with their neighbours, maximise resource efficiency and innovation and minimise waste. 14.3 Assessment of impacts 14.3.1 Employment opportunities There will be significant direct employment opportunities as a result of the construction of the facility. Levels of employment will vary throughout the construction period dependent on the activities on site. However, it is likely that employees will range between 50 - 130 per day during the first 12 – 15 months of construction and a maximum of 50 employees per day during the remaining six – nine months. Peak levels of employment are likely to be associated with concrete works and building of the superstructure and internal works. It is anticipated that some 55 permanent jobs will be created at the facility when operational. Operational positions would include jobs for engineers, managers and administrators, control room operators, skilled and semi-skilled tradesmen and general workers. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 163 There will also be a number of indirect employment opportunities for e.g. support services, equipment and materials and catering suppliers as a result of the proposed development both during construction and operation. TGW2E has committed to work with LBBD to maximise the number of positions filled from the local community and has met with the Group Manager - Economic Development and Sustainable Communities to explore ways in which the opportunities can be maximised. TGW2E has also met with key staff at Barking and Dagenham College and has agreed to work in partnership with the college to develop a bespoke apprenticeship scheme for the proposed development, specifically in relation to mechanical and electrical engineering maintenance for the development once operational. TGW2E hopes that it will be possible to accommodate 5 – 6 apprentices. Further specialist training would be given as appropriate, providing opportunities for employees to increase their skills. The contractor selected for the construction of the facility will also be required to enter into a commitment to take on local apprentices. TGW2E has also entered into a Memorandum of Understanding with the Sustainability Research Institute of the University of east London to work together to identify potential end uses for the residual material arising from the process. The proposed development therefore has the potential for a considerable positive impact on local employment. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 164 14.3.2 Ongoing community liaison and engagement The design of the facility includes a visitor / education area in the office building. TGW2E is happy to offer opportunities for pre-arranged visits from local schools and colleges. Updates and news about the facility will also be posted on the website. 14.3.3 Other effects The assessments in sections 5, 7, and 11 have demonstrated that the proposed development will have no adverse impact on health arising from emissions to air, noise or contaminated land. There will be no adverse odour impacts from the proposed development as all waste handling operations will take place indoors and all exhaust air from the waste-handling area will be passed through carbon filters to remove any odours (section 3.7). Internal handling of all wastes and residues means that there will be no windblown litter as a result of the proposed development. However, as a proactive measure, staff will be required to walk the perimeter of the site at regular intervals and to remove any wind-blown litter promptly. Finally, the proposed development will bring a major derelict site back into use. The expected lifespan of the facility is twenty – thirty years. The site will be principally laid to hardstanding and so it is not anticipated that any remediation will be required during decommissioning. In any case, it is a requirement of the permitting process (section 3.8) that a site closure report be produced which demonstrates that the site is in the same condition at the end of operations as at the start. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 165 14.4 Mitigation measures There are no specific mitigation measures required for potential socioeconomic or health impacts. 14.5 Conclusion Barking and Dagenham Council’s vision for the year 2020 is ‘to build communities and transform lives’. One of its three key priorities is to: ‘Increase prosperity for all by encouraging the development of a well-educated and skilled workforce, increasing access to jobs, supporting existing businesses to grow and attract new investment’. The proposed development will directly contribute to this key priority by bringing a new employer to the area that will provide jobs and training opportunities in one of the more deprived areas of the borough. As one of the larger sites to be developed in the LSIP, it will also directly contribute to the success of the LSIP itself. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 166 15 Conclusion The proposed development relates to an energy generation facility at the London Sustainable Industries Park in Dagenham. The principle of development of an energy generation facility on this site is fully established and has already been subject to rigorous examination and assessment through the process of determination of the extant consent. This Environmental Statement has assessed the potentially significant environmental effects of the proposed development and demonstrated that: The proposed development is in accordance with European, national, regional and local policy. The proposed development would have no significant adverse effects on air quality. The proposed development would not have a significant impact on background noise levels. There are no significant soil and groundwater associated with the development. The proposed development is in an area at risk of flooding but the mitigation measures implemented will mean that the site itself is not at significant risk of flooding nor would it increase the risk of flooding elsewhere. The proposed development would not have a significant adverse visual impact. There are no significant transport impacts as a result of the proposed development; travel and deliveries and servicing plans will also be developed. The proposed development is highly energy efficient and exceeds the requirements of the London Plan with respect to energy efficiency. The proposed development achieves a BREEAM rating of excellent. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 167 The proposed development would have no significant adverse effects on ecology and nature conservation; implementation of the proposed landscape design would have a positive impact on the biodiversity potential of the site. The proposed development would have a positive socio economic impact through the creation of 55 permanent jobs during operation, including apprenticeships and training opportunities, as well as temporary jobs during construction. The proposed development would reduce greenhouse gas emissions. The National Planning Policy Framework states that LPAs should approve applications for renewable or low carbon energy developments unless material conditions dictate otherwise and provided the impacts are (or can be made) acceptable. The proposed development would provide low carbon energy and this environmental impact assessment has demonstrated that impacts are acceptable. Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 168