Consultee Responses

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EH RESPONSE TO CONSULTATION

REFERRAL FROM PLANNING:

DEVELOPMENT CONTROL

Planning Reference:

PP/13/04728

Planning Officer:

Steven Roberts

9 October 2013

Environment Officer:

Telephone:

Email:

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

  

Appeal Planning brief

Policy

Date received

Consultation deadline from planning website:

Date returned to planning officer :

Date(s) of discussion(s) with Planning officers

Environmental issue covered in this response :

Air Quality X Noise Contaminated land Other

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)

Date

Date

For comments on:

(subject area)

For comments on:

(subject area)

Summary of application proposal

Construction of part 3, part 5 and part 7 storey residential building comprising 31 dwellings with commercial unit (Flexible A1,A2,B1 & D1 uses) at ground and basement

(435 sqm) with ancillary landscaping (Major Application)

Comments

The Proposed Development will comprise the following:

Basement housing plant space and commercial space (135 m2 GIA) Ground floor retail unit for A1/A2/B1/D1 unit of 256 m2 GIA; and 31 residential units arranged over six floors. The site is located on the corner of Hortensia Road and King’s Road. The site comprises existing hard standing with no buildings currently on site. Therefore the new development should seek to reduce emissions as currently there are none associated with the site.

An air quality assessment has been provided; I have also made comments on the energy statement in relation to its impact on air quality.

Energy Statement

It is proposed that the development will include a centralised energy centre to provide heating and hot water to all residential units. This will house a 10 kWe (17kWth) combined heat and power (CHP) unit to provide base load heating and electricity, which will be supplemented by 3 x 250 kW low NOx boilers to provide additional heating and hot water. In addition approximately 25m² of PV panels which will reduce emissions by approximately 6%.

The Energy statement in calculating the CO

2

savings from CHP provides the following emission factors:

Carbon Factors (kgCO

2

/kWh)

Natural Gas 0.198

Electricity 0.517

Displaced Electricity 0.529

The carbon saving has been calculated as 8%. However more up to date reports e.g.

2012 Guidelines to Defra / DECC’s GHG Conversion Factors for Company Reporting) gives the 2010 carbon dioxide rolling emissions (5 year average) as 0.491kg CO

2

/kWh from grid electricity. This is considerably lower than the figure used for the displaced electricity and will therefore result in a higher carbon saving figure being calculated.

Alternatively CO

2

emissions reductions could be achieved by deploying greater proportion of photo voltaic panels for electricity generation this would reduced both

CO2 and NOX emissions.

Boiler /Energy emissions

The NOx emissions of the boiler/plant provided in the air quality report is given as 39.7 mg/kWh (0% O2) for the low NOx Boilers and 45.5 mg/kWh (0% O2) for the Micro

Turbine CHP. However no annual emissions calculations are provided in the document. This information was requested and the estimated emissions were subsequently provided by Environ. Annual emissions were calculated as 118 kg of

NOx from the boilers and 101 kg of NOx from the CHP.

This was based on the assumption that two of the three boilers would operate for 12 hours per day and the CHP for 10 hours per day. This shows that the single CHP, whilst operating for less time produces, almost the same emissions as the two much larger

boilers. Further supporting the use of more non combustion renewable technology such as PV panels.

Transport

No parking is proposed and the site will be permit free, therefore the main source of additional traffic will result from the servicing requirements of the commercial and residential uses of the buildings. Overall this should not generate a significant number of trips.

Conclusions

Ideally more of the energy provision should be made through low polluting options such as PV panels rather than CHP, however as a minimum the AQ report should be amended to include the updated emissions factors for the boiler and CHP plant and the calculated annual emissions are included. In addition the following condition should be set to ensure that the emissions are no higher than those stated in the assessment.

R equested condition(s)

S.106 opportunities

Prior to the occupation of the building and installation of the boiler and plant, a certificate of the emissions for the equipment being installed shall be submitted for approval and should not exceed the emissions stated in the air quality assessment.

Officer(s) initials

KEV Times spent (to nearest half hour)

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