EH RESPONSE TO CONSULTATION REFERRAL FROM PLANNING: DEVELOPMENT CONTROL Planning Reference: CON/15/03905 Environment Officer: Telephone: Email: Planning Officer: Kevin Crilly Date: 20th July 2015 Tamsin Williams EH Acolaid Number 020 8753 3746 15/169853 Tamsin.Williams@lbhf.gov.uk Application site address: Development Site at, 205-219 Holland Park Avenue, LONDON, W11 4XB Pre-Application Full Application Informal Advice Appeal Notification Planning brief Policy Date received Date returned to planning officer : Consultation deadline from planning website: Date(s) of discussion(s) with Planning officers Environmental issue covered in this response : Air Quality X Noise Other (describe) such as Licensed premises issues Notification has also been forwarded to (EH officer name) Notification has also been forwarded to (EH officer name) Contaminated land Date Date Other For comments on: (subject area) For comments on: (subject area) Summary of application proposal Details required by condition 29 (evidence of chimney stack/ flue location) of planning permission 14/06548 (Variation of condition 2 (submitted plans) and condition 3(i) energy strategy of planning permission 10/03130 for a change to approved drawings and to make amendments to the approved energy strategy). Comments The borough is an air quality management area because it does not meet air quality objectives; the council must take steps to ensure air quality objectives are met in the borough. New development should comply with Policies as required by Core Strategy Policy CE5 and 7.14 a, b, c of the London Plan. The wording of the condition was: Condition 29 29. Prior to installation of any combustion plant evidence must be provided to show that any chimney stack/flue will be located so that it is away from ventilation intakes or accessible areas and at a sufficient height and discharge velocity to disperse the exhaust emissions. Details of the selected combustion plant (including abatement equipment), their emissions (and maintenance schedule shall be provided to the Local Planning Authority for approval. Boilers shall have NOx emissions not exceeding 40mg/kWh of dry NOx (at 0% O2) and CHP plant not exceeding 95mg/Nm3 (at 5% 02). Reason - To Comply with Policies as required by Core Strategy Policy CE5 and 7.14 a and c of the London Plan The proposed flue system is shown on drawing 1504-01. In the top right hand corner there is a drawing of flue termination at roof height. A roof structure is shown in the drawing which may impact upon dispersion of emissions. Further drawings of all sides of the roof are required to show the position of ventilation intakes, roof structures and accessible areas in order to confirm that the chimney stack and/ flue are located away from any ventilation intakes/ accessible areas. The height of flue termination above roof level needs to be included. A D1 stack height calculation should be completed to ensure the flue is at a sufficient height, note this should be calculated from ground level. Information has been provided on the outlet velocities for both the CHP and boilers. For CHP: outlet velocity at chimney is stated as 6.1 nominal and 1.9 minimum m/s For Boiler outlet velocity at chimney is 4.1% nominal or 2.1% minimum m/s The velocities stated do not meet those required by the GLA SPG Sustainable Design and Construction 2014 page 135/136. As per previous environmental quality comments, a gas exit velocity of 15m/s provides optimal dispersion. Details of selected combustion plant (including abatement equipment) have been provided, and states 3 Hamworthy FI50W boilers. The CHP unit is a Helec PB138SNG, with thermal output of 207 kWt and fuel consumption of 392 kW. The Catalyst is an extra low NOx Catalyst to ensure <27 mg/Nm3 .The technical sheets confirm boiler emissions are less than 40mg/kwh and CHP is less than 30mg/ nm3 A sheet on care and maintenance has been submitted for both CHP and boilers. However, a statement of commitment to the manufacturer’s proposed maintenance programme should be included. Conclusions I would not recommend this condition be discharged, further information is required. Officer(s) initials Times spent (to nearest half hour)