EH RESPONSE TO CONSULTATION
REFERRAL FROM PLANNING:
DEVELOPMENT CONTROL
Planning Reference:
Planning Officer: Fergal O’Donnell
24/2/2015
PP/15/00369
Environment Officer:
Telephone:
Email:
Kyri Eleftheriou-Vaus
EH Acolaid Number
Tamsin
15/163648
020 7341 5686
Kyri.Eleftheriou-Vaus@rbkc.gov.uk
Application site address: Land comprising of 348-350 Old Brompton Road, a cutting for
the West London Line, hard standing to the south of Earl's Court Exhibition Centre
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
Demolition and alteration of existing buildings and structures and redevelopment of the
Site, for the erection of buildings comprising single storey basement, and part three,
part four storey buildings for 638sqm of retail space (A1), 16 residential units (C3), and
related ancillary uses; together with the provision of new open space; provision of
vehicular and pedestrian accesses and routes from Old Brompton Road; including all
associated highway works; structures for decking over existing rail lines and tunnels;
and other ancillary and incidental works to the development (MAJOR DEVELOPMENT
AND EIA DEVELOPMENT)
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 application submits no new information on air quality impacts. The air quality
assessment submitted relates to applications PP/11/01937 and 2011/02001/OUT.
The Energy Strategy 2015 states that if temporary plant is needed it will provide one of
two options i.e. to either include boilers and CHP plant within a basement or provide a
‘stand-alone packaged unit’. Neither of these options have been assessed indeed the
Sustainability Statement January 2015 makes no reference to the temporary plant or
the air quality impacts of the plant, only that that the site will not be provided with onsite combustion plant. In addition the 2012 A14 ES Volume I Addendum: Air Quality
states that ‘it is proposed that temporary boiler plant will be used across the site
during the early stages of development’, which makes no reference to the use of CHP
units (which typically have NOx emissions which are far higher than most boilers).
No information on the temporary plant is provided therefore as a minimum the
following information about any combustion plant proposed should be provided i.e.
the size, model, the emissions levels as mg/Nm3 and mg/kWh (at standard reference
conditions) the location of the combustion plant, height of exhaust emissions above
ground level, and abatement equipment. It should be noted that any flues/chimneys
must terminate above the height of any nearby buildings (appropriate guidance should
be used to determine the height). Emissions from combustion plant should conform to
the standards contained in the Sustainable Design and Construction SPG (London
Plan).
The Sustainability Statement January 2015 Rev04, 3.3 Pollution Management details
that the Proposed Development Response to minimise and mitigate against exposure
to poor air quality, is to ensure that ventilation controlled by the MVHR will be filtered
to remove airborne pollutants.
As detailed in the ES Volume 1 Addendum: Air Quality (Application2) A14.140 mean
annual NO2 concentrations are anticipated to be exceeded across the Earl’s Court. It
also includes results which show that some receptors may be vulnerable to
exceedence of the short term objective for PM10 during construction phases which
may be further affected by this additional development. Therefore to support
proposed filtration of airborne pollutants I would suggest the use of a condition.
Conclusions
I would recommend that further air quality conditions, to those contained in the
outline planning permission numbers 60 and 61 of planning permission PP/11/01937
are applied to ensure air quality for future occupiers of this development and
neighbouring receptors. A condition is required to ensure temporary plant as proposed
by the Energy Strategy 2015 does not result in a deterioration of air quality. I have also
drafted a condition to support the proposed filtration of airborne pollutants (suggested
draft below). Please note the condition needs to ensure an annual check to the system
as the filtration media has a limited life span.
Combustion plant
a) Prior to installation or use of any combustion plant including
temporary installations 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 etc 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 the
Band B emissions standards (at reference conditions).
Requested
condition(s)
Reason: To Comply with Policies as required by Core Strategy Policy
CE5 and 7.14 a and c of the London Plan
Ventilation
Prior to the commencement of development details of a system of
mechanical ventilation, with filtration to remove airborne pollutants,
for residential properties shall be submitted to and agreed in writing by
the LPA. Filtration should ensure that the national Air Quality
Objectives for Nitrogen Dioxide (NO2) and Particulate Matter (PM10) are
not exceeded in residential properties.
The approved system shall be installed before occupation of residential
accommodation. The system shall be checked and maintained
annually, filtration media replaced as necessary and an annual report
submitted to the LPA for approval.
Reason: To Comply with Policies as required by Core Strategy Policy
CE5 and 7.14 b of the London Plan
S.106
opportunities
Officer(s)
initials
KEV
Times spent (to nearest half hour)