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
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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
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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
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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
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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
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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.
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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
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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
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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.
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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
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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
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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
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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
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
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
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
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
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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
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
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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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,
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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)
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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
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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.
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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.
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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
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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)
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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
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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
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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.
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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.
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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
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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
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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
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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
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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
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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
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
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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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
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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
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