EH RESPONSE TO CONSULTATION
REFERRAL FROM PLANNING:
DEVELOPMENT CONTROL
Planning Reference:
Planning Officer:
PP/13/04728
Steven Roberts
Environment Officer:
Telephone:
Email:
13th November 2013
Kyri Eleftheriou-Vaus
020 7341 5686
Kyri.Eleftheriou-Vaus@rbkc.gov.uk
EH Acolaid Number
SRENE/: 13/139382
Application site address: Land South of Carlyle Building, Hortensia Road, London,
SW10 0QS
Pre-Application
Full Application
Informal Advice
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Appeal
Notification
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Planning brief
Policy
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Date received
Date returned to planning officer :
Consultation deadline from
planning website:
Date(s) of discussion(s) with Planning officers
Environmental issue covered in this response :
Air Quality
X
Noise
Other (describe) such as
Licensed premises issues
Notification has also been
forwarded to (EH officer name)
Notification has also been
forwarded to (EH officer name)
Contaminated land
Date
Date
Other
For comments on:
(subject area)
For comments on:
(subject area)
Summary of application proposal
Construction of part 3, part 5 and part 7 storey residential building comprising 31
dwellings with commercial unit (Flexible A1,A2,B1 & D1 uses) at ground and basement
(435 sqm) with ancillary landscaping (Major Application)
Comments
A revised air quality assessment has been provided for the proposed development,
comprising a basement housing plant space and commercial space (135 m2 GIA)
Ground floor retail unit for A1/A2/B1/D1 unit of 256 m2 GIA; and 31 residential
units arranged over six floors.
The site is located on the corner of Hortensia Road and King’s Road and consists of
existing hard standing with no buildings currently on the land. Therefore the new
development should seek to reduce emissions as currently there are none
associated with the site.
Energy Statement
It is proposed that the development will include a centralised energy centre to
provide heating and hot water to all residential units. The original proposal was for
the installation of a 10 kWe (17kWth) combined heat and power (CHP) unit to
provide base load heating and electricity, (supplemented by 3 x 250 kW low NOx
boilers to provide additional heating and hot water). In addition approximately
25m² of PV panels which will reduce CO2 emissions by approximately 6%.
AQ assessment of Boiler /Energy emissions
The NOx emissions of the initially proposed boiler and CHP micro turbine provided
in the air quality report was given as 39.7 mg/kWh (0% Oxygen) for the low NOx
Boilers and 45.5 mg/kWh (0% O2) for the Micro Turbine CHP. A different model for
the CHP plant is now being proposed and the NOx emissions are expected (as given
by Ener-g, the CHP manufacturer) as 499 mg/Nm3 (0% O2), at full load increasing to
3484 mg/Nm3 (75%) and 2233 mg/Nm3 (50%) at partial loads. A catalyst is
proposed to reduce emissions to 46mg/Nm3 or 40 mg/kWh (0% O2) based on the
full load emissions).
The calculations (using the EPUK CHP tool) in Annex A and B are based on a
concentration of 236 mg/m3 and 22 mg/m3 at reference conditions (i.e. 11% O2,
101Kpa 273K) without catalyst; this may not be representative of the range of
operational conditions of the CHP plant. At this level of emissions there is an
increase of 2.4 µg/m3 at the nearest receptor to Hortensia Road without the
catalyst. The predicted reduction with the use of a catalyst is expected to result in
an increase of approx 0.20-0.23 µg/m3.
However at partial loads the NOx emissions for the plant selected are higher as the
operational conditions will vary considerably the unit will not be able to achieve the
reductions stated and the impact will be greater. Therefore the plant should not be
operated on partial loads and the effectiveness of the catalyst needs to be
demonstrated before installation.
Ideally rather than relying on abatement equipment more should be done to
improve the energy efficiency of the building as a whole as this will reduce all
emissions i.e. CO2, NO2 and PM10. However the option to use CHP plant whilst this
is deemed to reduce emissions this is based on a partial assessment based on the
expected reduction in carbon due to electricity replacement from the grid. These
calculations take no account of the reduced energy efficiency for delivering the base
load heating. The use of more non combustion renewable technology such as PV
panels would again reduce all emissions locally.
If the approach recommended above is not pursued then as a minimum we require
that the AQ assessments is updated to include the total emissions without the
catalyst (which would be 3650*(130*499) = 236775500 mg/yr (236.8kg/yr).
We will also require confirmation from the manufacturer that the specific unit can
be supplied with a catalyst and evidence that that it will reduce the emissions to 40
mg/kWh (0% O2) at all operational conditions.
Conclusions
More of the energy provision should be made through low polluting options such as PV
panels rather than CHP and total demand reduced through improved energy efficiency.
In addition the AQ report should be amended to include the total emissions for the
boiler and CHP plant without catalyst and the effectiveness of the catalyst. It should
also provide information on the likely impact on the NOx concentrations and emissions
if the CHP is operated at partial loads.
Confirmation will be required from the manufacturer that this specific unit can be
supplied with a catalyst (at a viable cost) and evidence that that it will reduce the
emissions as described. Therefore the following conditions should be set to ensure
that the emissions are no higher than those stated in the assessment.
To mitigate the impacts of the construction I recommend a condition for a Construction
Environmental Management Plan to be prepared.
Requested
condition(s)
Combustion plant emissions
1 Prior to installation of the boilers and CHP plant, certificates
should be provided to show indicative emissions of the
combustion plant (the emission factor should meet a dry NOx
level of 40mg/kWh at 0% O2). Where this is to be achieved by
abatement technology, evidence of the reductions to be
achieved at varying operational conditions must be provided.
2 Prior to the occupation of the building the CHP plant must be
tested at full and partial loads for its NOx emissions by an
accredited laboratory. The report must be submitted for
approval and should not exceed emissions of dry NOx of
40mg/kWh (at 0% O2)
Reason: To comply with the requirements of the NPPF, the
Policies 7.14 a and c of the London Plan and Policy CE5 of the
Core Strategy
Construction
No development shall commence until a risk assessment and the
appropriate mitigation measures to minimise dust and emissions
are incorporated into the site specific Construction Management
Plan based on the Mayor’s Best Practice Guidance (The control of
dust and emissions from construction and demolition) or the
London Plan control of emissions from construction and
demolition SPG. This should include an inventory and timetable
of dust generating activities, emission control methods and
where appropriate air quality monitoring). This must be
submitted to and approved in writing by the Local Planning
Authority.
Reason: To comply with the requirements of the NPPF, Policy
7.14 b of the London Plan, and Policy CE5 of the Core Strategy
S.106
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