2013-08 Ealing Incinerator

Planning Committee 14/08/2013 Item: 04
Schedule
Ref : Address:
PP/2012/3267 ENERGY RECOVERY CENTRE CHANNEL GATE ROAD PARK ROYAL NW10 6UQ East Acton Construction of an energy recovery centre comprising a single purpose designed building to provide an advanced conversion technology facility and an anaerobic digestion facility with an integrated education/visitors centre, and four 25-metre high flues; four external anaerobic digestion/digestate tanks; associated access, parking and landscaping; gas holder tank; emergency gas flare; electrical substation; two weigh bridges; wheel washing aparatus and a security house building CPPL-03/00-01; CPPL-03/05-01; CPPL-03/05-02; CPPL03/05-03; CPPL-03/10-01; CPPL-03/10-02; CPPL-03/1003; CPPL-03/10-04; CPPL-03/10-05; CPPL-03/10-06; CPPL-03/20-01; CPPL-03/30-01; and CPPL-03/10-02 (received 01.08.2012) Full applications - Majors 03/08/2012 Revised: 08/10/2012
Ward: Proposal:
Drawing numbers:
Type of Application: Application Received:
Report by: Peter Lee Executive Summary: Recommendation: Resolve to Grant permission with Conditions, subject to the prior completion of an appropriate Legal Agreement, with respect to the provision of financial contributions toward air quality monitoring and improvements to transprt infrastructure in the vicinity of the application site and referral to the Mayor, as required by Article 5 of the Town and Country Planning (Mayor of London) Order 2008. The application site is located toward the western end of Channel Gate Road, Park Royal and has an area of 2.43 hectares. The site forms part of a larger 10 hectare site known as the Willesden Junction Freightliner Terminal site, owned by Network Rail. The site currently accommodates a number of light and general industrial uses, including a concrete batching plant, skip hire and storage uses, commercial vehicle repair and maintenance operations, road surfacing contractors and open storage and distribution uses.
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Planning Committee 14/08/2013
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The proposal seeks permission for the demolition of the existing buildings and structures on the site, with a floor area of 1,527 square metres, and for the erection of an Energy Recovery Centre that would process up to 195,000 tonnes per annum (tpa) of waste. The facility would comprise of an 8 MegaWatts Electric (MWe) Pyrolosis Advanced Conversion Technology (ACT) plant, which would recover approximately 128,000 tpa of Municipal Solid Waste and commercial and industrial waste and a 2 MegaWatt Anaerobic Digestion (AD) facility that would recover approximately 67,000 tpa of green (pure biomass) waste. The main building would comprise a warehouse type structure of 5,711 square metres where waste would be loaded and processed in a sealed (including negative air pressure) building and the majority of non-recyclable waste would be used to generate electricity that would supply the National Grid by burning the material, in the absence of oxygen, to power turbines. In addition there would be the Anaeobic Digsetion facility that would comprise two AD tanks, with a height of 9.5 metres, the same height as the existing concrete silos on the site, where biodegraded material would be broken down by bacteria to produce gas and two digestate tanks, of the same, where the remaining material would be stored after the gas had been piped away to be used to create electricity. The development would also be provided with four flue stacks, of 25 metres in height. Other development would comprise other ancillary structures, two weighbridges, a wheel washing facility, car parking areas, cycle racks, a rail unloading area and a balancing pond, along with associated landscaping. The main issues with this application are the potential impacts on neighbouring residential amenity in respect of issues such as air quality, noise and traffic generation balanced against the need for the provision of more sustainable ways to deal with waste, in order to move waste processing up the waste hierarchy, by encouraging recycling and disposing of waste in productive ways that does not require continued land-fill. Several hundred local residents, in Ealing, Brent and Hammersmith & Fulham, have written in objection to the proposal and over 1,000 have signed a petition. A number of amenity societies, residents associations and other groups have also raised concerns. The main issues raised relate to noise and smell and traffic generation. The application is, however, recommended for approval as it is considered to represent a highly sustainable, green development that would go a significant way to allowing Ealing and the other West London boroughs to process the waste generated in the local area more effectively and efficienly without having to transport it significant distances to be processed elsewhere, often as land-fill. The proposal is therefore considered to accord with current Government guidance on waste processing and also to accord with relevant development plan policies. The technology to be used should not result in detrimental impacts on neighbouring amenity due to noise or smell given the strict permitting regime that wouldd be put in place and the fact that the waste processing will take placed within a sealed building. In terms of traffic generation, the proposal should result in a significant decrease in vehicle movements to and from the site, including a reduction in HGV numbers. Appropriate conditions are also recommended to restrict, amongst other things, the hours when HGVs can access or egress the site. On balance, therefore, it is considered that the benefits of the proposal outweigh any potential harm to neighbouring amenity and it therefore recommended that the Committee resolve to approve the application, subject to appropriate conditions, the prior completion of a legal
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agreement in respect of air quality monitoring and local transport infrastructure improvements, and referral of the application to the Mayor.
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Recommendation:
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Resolve to Grant permission with Conditions, subject to the prior completion of a legal agreement and referral to the Mayor of London Conditions/Reasons: 1. Time Limit 3 years - Full Permission The development permitted shall be begun before the expiration of three years from the date of this permission. REASON: In order to comply with the provisions of the Town and Country Planning Act 1990 (as amended). 2. Approved Plans The development hereby approved shall be carried out in accordance with drawing title number(s) CPPL-03/00-01; CPPL-03/10-01; CPPL-03/10-02; CPPL-03/10-03; CPPL-03/10-04; CPPL-03/10-05; CPPL-03/10-06; CPPL-03/20-01; CPPL-03/30-01; and CPPL-03/30-02 unless otherwise agreed in writing by the local Planning Authority. Reason: For the avoidance of doubt, and in the interests of proper planning. 3. Details of Hard and Soft Landscaping No development shall take place until full details of both hard and soft landscape works, including a phased programme of works, have been submitted to and approved in writing by the Local Planning Authority and these works shall be carried out as approved prior to the occupation of any part of the development or in accordance with the programme agreed by the Local Planning Authority. Any trees or other plants which die or are removed within the first five years following the implementation of the landscaping scheme shall be replaced during the next planting season. REASON: To ensure that the development is landscaped in the interests of the visual character and appearance of the area, in accordance with policies 5.10, 5.11, 7.19 and 7.21 of the London Plan (2011), policies 1.1(i) and 5.3 of the Ealing Development (or Core) Strategy (2012), Ealing Local Variation to London Plan policy 5.10, Ealing Local Variation to London Plan policy 5.11 and policy 7B of the draft Ealing Development Management Development Plan Document (2012) and saved policies 3.2, 3.8 and 4.5 of the adopted Ealing Unitary Development Plan, 'Plan for the Environment' (2004). 4. No Open Storage or Operations No goods or materials shall be stacked or deposited on the site, and no operations carried out unless within a roofed and enclosed building. REASON: To protect the living conditions of nearby occupiers, and to safeguard the visual appearance of the area, in accordance with policies 7.1 and 7.4 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012) and saved policy 4.1 of the adopted Ealing Unitary Development Plan, 'Plan for the Environment' (2004).
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5. Construction Management Plan
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Before the development hereby permitted is commenced a Construction Management Plan (CMP) shall be submitted to and approved, in writing, by the Local Planning Authority. The CMP will describe the means by which demolition and construction activity at the site and construction traffic to the site shall be controlled. The development hereby permitted shall only be carried out and completed in accordance with the CMP, unless any changes are agreed, in advance, by the Local Planning Authority. REASON: To ensure the impact of the development on neighbouring amenity is appropriately controlled, in accordance with policy 7.1 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policies 2.1 and 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 6. Delivery and Servicing Plan Before the development hereby permitted is first brought into use a Delivery and Servicing Plan (DSP) shall be submitted to and approved, in writing, by the Local Planning Authority. The DSP shall describe the means by which goods vehicles delivering material to the site and collecting material from the site shall be controlled. The DSP will require goods vehicles delivering or collecting material to be fully enclosed when transporting materials that are liable to smell and to be fitted with low noise tyres and low noise equipment such as reversing alarms and tail lifts. The development hereby permitted shall only be carried out and completed in accordance with the DSP. REASON: In order to ensure that the development has as limited an impact as possible on neighbouring amenity, in accordance with policies 5.16, 5.17, 7.4, 7.14 and 7.15 of the London Plan (2011), policies 1.1(j), 1.1(k), 1.2(f), 1.2(i) and 3.3 of the Ealing Development (or Core) Strategy (2012), Policy 7A, Ealing Local Variation to London Plan policy 7.4 and Policy 7B of the draft Ealing Development Management Development Plan Document (2012) and saved policies 2.6, 2.9, 2.10, 2.11, 4.11 and 9.9 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 7. Staff Travel Plan Before the development hereby permitted is first brought into use a Staff Travel Plan (STP) shall be submitted to and approved, in writing, by the Local Planning Authority. The STP shall describe the means by which staff shall be encouraged to travel to the site by means other than the private car. The STP as approved shall be monitored and reviewed in accordance with an approved programme and a copy of those reviews and action plans arising shall be submitted to the Local Planning Authority. The measures described in the action plans shall be implemented in the time period identified. REASON: To minimise traffic generation as a result of the development, in accordance with policies 6.3, 6.9, 6.10 and 6.13 of the London Plan (2011), policy 1.1(f) of the Ealing Development (or Core) Strategy (2012), Ealing Local Variation to London Plan policy 6.13 and Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policies 2.6, 9.1 and 9.9 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004).
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8. Resurfacing of Channel Gate Road
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Before the development hereby permitted is first brought into use Channel Gate Road shall be resurfaced from the limit of the public highway at Old Oak Lane to a point no less than 100 metres west of the nearest residential property using a twin-layer porous asphalt. REASON: To minimise potential noise generation from vehicles accessing the site, in accordance with policies 7.1 and 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policy 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 9. Restriction on Hours of HGV Movements No goods vehicles with a gross vehicle weight exceeding 7.5 tonnes shall operate on the site, or enter or leave the site, except between the hours of 0600 to 2300 hours on Mondays to Fridays, 0600 to 1500 hours on Saturdays and not at all on Sundays or on Bank and Public holidays. REASON: To minimise potential noise generation from vehicles accessing the site, in accordance with policies 7.1 and 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policy 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 10. Vehicle Waiting No goods vehicles associated with the use of the site with a gross vehicle weight exceeding 7.5 tonnes shall park or wait on Channel Gate Road within 100 metres of any residential property. REASON: To minimise potential noise generation from vehicles accessing the site, in accordance with policies 7.1 and 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policy 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 11. Freight Movements Canal Prior to commencement of development: A) a feasibility study of the practicality and economic viability of utilising the canal for the transport of construction materials shall be submitted to and approved, in writing, by the Local Planning Authority. B) should the Council be satisfied that it would be feasible and viable to utilise the canal for the transport of construction materials, the applicant shall submit a strategy for approval, in writing, prior to commencement of the development. The construction of the development shall be carried out in accordance with the approved strategy. C) a feasibility study of the practicality and economic viability of utilising the canal for the transport of material associated with the operation of the development shall be submitted to and approved, in writing, by the Local Planning Authority.
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D) should the Council be satisfied that it would be feasible and viable to utilise the canal for the transport of material associated with the operation of the development, the applicant shall submit a strategy for approval in writing prior to commencement of any part of the use hereby permitted. The operation of the development shall be carried out in accordance with the approved strategy. REASON: To ensure that alternative means of servicing the development are considered in detail, in accordance with policies 6.14, 7.15 and 7.26 of the London Plan (2011), policies 1.1(f) and 1.1(j) of the Ealing Development (or Core) Stragey (2012), Policy 7A of the draft Development Management Development Plan Document (2012) and saved policies 2.6, 4.11 and 9.10 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 12. Freight Movement Rail Prior to commencement of development the following shall be submitted: A) a feasibility study of the practicality and economic viability of utilising the rail freight network for the transport of material associated with the operation of the development shall be submitted to and approved, in writing, by the Local Planning Authority. B) should the Council be satisfied that it would be feasible and viable to utilise the rail freight network for the transport of material associated with the operation of the development, the applicant shall submit a strategy for approval, in writing, prior to commencement of any part of the use hereby permitted. The operation of the development shall be carried out in accordance with the approved strategy. REASON: To ensure that alternative means of servicing the development are considered in detail, in accordance with policies 6.14 and 7.15 of the London Plan (2011), policies 1.1(f) and 1.1(j) of the Ealing Development (or Core) Stragey (2012), Policy 7A of the draft Development Management Development Plan Document (2012) and saved policies 2.6, 4.11 and 9.10 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 13. Archaeological Investigation A) No development shall take place until the applicant has secured the implementation of a programme of archaeological mitigation in accordance with a Written Scheme of Investigation which has been submitted by the applicant and approved, in writing, by the Local Planning Authority. B) No development or demolition shall take place other than in accordance with the Written Scheme of Investigation approved under Part (A). C) The development shall not be occupied until the site investigation and post investigation assessment has been completed in accordance with the programme set out in the Written Scheme of Investigation approved under Part (A), and the provision made for analysis, publication and dissemination of the results and archive deposition has been secured. REASON: Heritage assets of archaeological interest may survive on the site. The Local Planning Authority wishes to secure the provision of archaeological investigation and the subsequent recording of the remains prior to development, in accordance with policy 7.8 of the London Plan (2011), policy 1.1(h) of the Ealing Development (or Core) Strategy (2012), Policy 7C of the draft
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Ealing Development Management Development Plan Document (2012) and saved policy 4.9 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004).. 14. Waste Processing Within Building Waste shall only be deposited and collected inside the Energy Recovery Centre building and not externally and all doors shall be closed during this operation. REASON: In order to limit any potential disturbance to neighbours, in accordance with policies 7.1, 7.14 and 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policies 2.6, 2.10, 2.11 and 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 15. External Plant Details shall be submitted for the approval of the Local Planning Authority before the development is commenced, to demonstrate that the rating noise level emitted from the proposed external plant and machinery at the proposed development, as assessed under BS4142: 1997, shall be lower than the existing background noise level by at least 5 dBA as measured at 3.5 metres from the nearest ground floor sensitive facade and 1 metre from upper floor noise sensitive facades, during the relevant periods of operation. REASON: In order to ensure that the development does not result in unacceptable levels of noise generation, in accordance with policy 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policy 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 16. Noise Attenuation - Building Envelope Details shall be submitted for the approval of the Local Planning Authority before any development is commenced, to demonstrate that the composite sound reduction index of the building envelope of the proposed energy recovery centre, Rw, will achieve the following criteria with windows and doors shut and other means of ventilation provided: " The rating noise level emitted from the operation of internal plant and machinery at the proposed development, as assessed under BS4142: 1997, shall be lower than the existing background noise level by at least 5 dBA as measured at 3.5 metres from the nearest ground floor sensitive facade and 1 metre from upper floor noise sensitive facades, during the relevant periods of operation. REASON: In order to ensure that the development does not result in unacceptable levels of noise generation, in accordance with policy 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policy 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 17. Mechanical Ventilation Details shall be submitted for the approval of the Local Planning Authority before the development is commenced, for a suitable mechanical ventilation system for the principal
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building, to ensure doors and windows are kept closed and externally sited ventilation plant associated with this system will be silenced to meet the criteria specified at condition 18 above. REASON: In order to ensure that the development does not result in unacceptable levels of noise generation, in accordance with policy 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policy 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 18. Roller Shutter Doors All roller shutter doors shall be the fast acting roller shutter type and shall also be fitted with lobbies. REASON: In order to ensure that the development does not result in unacceptable levels of noise generation, in accordance with policy 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policy 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 19. Detail of Doors The doors required under condition 20 shall be orientated away from sensitive dwellings surrounding the site and details of the design and layout of these doors shall be submitted to the Local Planning Authority for approval, before the development is commenced. REASON: In order to ensure that the development does not result in unacceptable levels of noise generation, in accordance with policy 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policy 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 20. Internal Noise Attenuation The proposed offices and educational/visitor facility will be affected by significant noise from rail, traffic and commercial sources. The composite sound reduction provided by the building envelope shall be sufficient to achieve internal noise levels of not greater than 40 dB LAeq,1hr inside the facilities with windows shut and other means of ventilation provided. REASON: In order to ensure that the development does not result in unacceptable levels of noise nuisance for occupiers of and visitors to the facility, in accordance with policy 7.15 of the London Plan (2011), policy 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A of the draft Ealing Development Management Development Plan Document (2012) and saved policy 4.11 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004).
21. Lighting Details Details of all proposed lighting schemes for the development, including floodlighting, shall be submitted for approval of the Local Planning Authority before the development is commenced, to
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demonstrate that the recommendations made at the following guidance is met where appropriate: ILP Guidance Notes for the reduction of Obtrusive Lighting 2011 CIBSE/SLL - FF7 Environmental Considerations for Exterior Lighting CIBSE/SLL - LG6 Lighting Guide - Outdoor Lighting CIE 92 - Guide for Floodlighting BS 5489 Part 3 Code of Practice for Lighting for Subsidiary Roads and Associated Pedestrian Areas The information submitted should include: a) A layout plan with beam orientation.
b) A schedule of equipment in the design (luminaire type; mounting height; aiming angles and luminaire profiles). c) An isolux contour map to show light spill levels down to 1 lux and showing neighbouring buildings. REASON: To ensure that the develoment would not give rise to nuisance from lighting or have a detrimental impact on wildlife, in accordance with policies 7.1, 7.3 and 7.19 of the London Plan (2011), policies 1.1(h) and 1.1(j) of the Ealing Development (or Core) Strategy (2012), Policy 7A and Ealing Local Variation to London Plan policy 7.3 of the draft Ealing Development Management Development Plan Document (2012) and saved policies 3.2, 3.8, 3.9 4.1 and 4.12 of the adopted Ealing Unitary Development Plan, Plan for the Environment (2004). 22. Details Of Walls and Fences No development shall take place until there has been submitted to and approved in writing by the Local Planning Authority a plan indicating the positions, design, materials and type of boundary treatment to be erected. The boundary treatment shall be completed prior to the first use of the development hereby approved. Development shall be carried out in accordance with the approved details. REASON: To protect the visual appearance of the area and the living conditions of neighbouring occupiers, in accordance with policy 7.4 of the London Plan (2011), policy 1.1(h) of the Ealing Development (or Core) Strategy (2012) and saved policy 4.1 of the adopted Ealing Unitary Development Plan, 'Plan for the Environment' (2004). Informatives: 1. The decision to grant planning permission has been taken having regard to the National Planning Policy Framework, Planning Policy Statement 10: Planning for Sustainable Waste Management, the policies and proposals in the London Plan, the Ealing Development (or Core) Strategy, the draft Ealing Developoment Management Development Plan Document and the
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adopted Ealing Unitary Development Plan and to all relevant material considerations including Supplementary Planning Documents/Guidance: National Planning Policies National Planning Policy Framework (2012) 1. Building a Strong Competitive Economy; 4. Promoting Sustainable Transport; 7. Requiring Good Design; 8. Promoting Healthy Communities; 10. Meeting the Challenge of Climate Change, Flooding and Coastal Xhange Planning Policy Statement 10: Planning for Sustainable Waste Management London Plan Spatial Development Strategy for Greater London July 2011 Policy 2.7 2.8 2.13 2.16 2.17 4.1 4.4 4.12 5.2 5.3 5.5 5.6 5.7 5.8 5.9 5.10 5.11 5.12 5.13 5.14 5.15 5.16 5.17 5.18 5.21 5.22 6.1 6.3 6.5 6.9 6.10 6.11 6.13 6.14 Summary Outer London: Economy Outer London: Transport Opportunity Areas and Intensification Areas Strategic Outer London Development Centres Strategic Industrial Locations Developing Londons Economy Managing Industrial Land and Premises Improving Opportunities for All Minimising Carbon Dioxide Emissions Sustainable Design and Construction Decentralised Energy Networks Decentralised Energy in Development Proposals Renewable Energy Innovative Energy Technologies Overheating and Cooling Urban Greening Green Roofs and Development Site Environs Flood Risk Management Sustainable Drainage Water Quality and Wastewater Infrastructure Water Use and Supplies Water Self-Sufficiently Waste Capacity Construction, Excavation and Demolition Waste Contaminated Land Hazardous Substances and Installations Strategic Approach Assessing Effects of Development on Transport Capacity Funding Crossrail and Other Strategically Important Transport Infrastructure Cycling Walking Smoothing Traffic Flow and Tackling Congestion Parking Freight
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7.2 7.3 7.4 7.6 7.8 7.13 7.14 7.15 7.19 7.21 7.24 7.26 7.30 8.2 8.3
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An Inclusive Environment Designing Out Crime Local Character Architecture Heritage Assets and Archaeology Safety, Security and Resilience to Emergency Improving Air Quality Reducing Noise and Enhancing Soundscapes Biodiversity and Access to Nature Trees and Woodlands Blue Ribbon Network Increasing the Use of the Blue Ribbon Network for Freight Transport Londons Canals and Other Rivers and Waterspaces Planning Obligations Community Infrastructure Levy
Ealing Development (or Core) Strategy April 2012 Policy 1.1(c), (f), (h), (j), (k) 1.2(e), (f), (g), (i), (m) 3.1 3.3 5.3 6.4 Summary Spatial Vision for Ealing 2026 Delivery of the Vision for Ealing 2026 Realising the Potential of the A40 Corridor & Park Royal Promote Business & Industry in Park Royal Protect & Enhance Green Corridors Planning Obligations and Legal Agreements
Draft Ealing Development Management Development Plan Document (2012/2013) Policy Ealing Local Variation to London Plan policy 5.2 Minimising Carbon Dioxide Emissions Ealing Local Variation to London Plan policy 5.10 Urban Greening Ealing Local Variation to London Plan policy 5.11 Green Roofs and Development Site Environs Ealing Local Variation to London Plan policy 5.12 Flood Risk Management Ealing Local Variation to London Plan policy 5.21 Contaminated Land Ealing Local Variation to London Plan policy 6.13 Parking Policy 7A Operational Amenity Ealing Local Variation to London Plan policy 7.3 Designing Out Crime Ealing Local Variation to London Plan policy 7.4 Local Character Policy 7B Design Amenity Policy 7C Heritage Unitary Development Plan Saved Policies Policy 1.10 2.1 2.5 2.6 2.9 2.10 2.11 Summary Legal Agreements and Partnerships Environmental and Other Sustainability Impacts Water Drainage, Flood Prevention and Environment Air Pollution and Quality Energy Waste Minimisation and Management Waste Environmental Impacts
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4.1 4.3 4.4 4.5 4.8 4.9 4.11 4.12 6.4 9.1 9.9
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Design of Development Inclusive Design Access for All Community Safety Landscaping, Tree Protection and Planting Conservation Areas Ancient Monuments and Archaeological Interest Areas Noise and Vibration Light Pollution Industry and Warehousing in Major Employment Locations Development, Access and Parking Highways and Traffic Management
Supplementary Planning Guidance/Documents SPG/SPD SPG1 SPG2 SPG3 SPG4 SPG7 SPG8 SPG9 SPG10 SPG20 SPG21 SPD9 Summary Sustainability Checklist Water, Drainage and Flooding Air Quality Refuse and Recycling Facilities Accessible Ealing Safer Ealing Trees and Development Guidelines Noise and Vibration Sustainable Transport: Transport Assessments Sustainable Transport: Green Travel Plans Legal Agreements, Planning Obligations and Planning Gain (Draft)
In reaching the decision to grant permission specific attention was paid to the impact of the proposed development on neighbouring residential amenity, particularly in respect of air quality, noise and traffic disturbance, the impact of the development of the character and appearance of the area, taking account of the account of its proximity to the Old Oak Conservation Area and the wider impacts of the development in terms of the processing and minimization of waste. The proposal is considered acceptable on these grounds, and it is not considered that there are any other material considerations sufficient to warrant refusal of the application. 2. To assist applicants in a positive manner, the Local Planning Authority has produced policies and written guidance, and offers and encourages a comprehensive pre-application advice service, all of which is available on the Council's website and outlined in a 24 hours automated telephone system. The scheme complied with policy and guidance. The Local Planning Authority delivered the decision proactively in accordance with requirements of the National Planning Policy Framework. 3. Construction and demolition works, audible beyond the boundary of the site shall only be carried out between the hours of 0800 and 1800 hours Mondays to Fridays and 0800 and 1300 hours on Saturdays and not at all on Sundays and Public Holidays. The maximum permitted noise levels are: - not greater than 72 dB L Aeq.10 hr Mondays to Fridays
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- not greater than 72 dB L Aeq.5 hr Saturdays. 4. No bonfires should be lit on site. Site Description:
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The application site has an area of 2.43 hectares and forms part of a larger 10 hectare site known as the Willesden Junction Freightliner Terminal site. The site lies at the western end of Channel Gate Road, to the west of Old Oak Lane, Park Royal (the A4000). The site has a single point of access for both pedestrians and vehicles from Channel Gate Road. The site is located to the south west of Willesden Junction railway station and is bordered by rail tracks to the north and west, by the Grand Union Canal to the south and by industrial land to the east. The site comprises previously developed land, within an established industrial/employment area that originally formed part of the operational rail network, and currently accommodates a range of industrial and storage uses. These uses comprise a cement batching plant, skip hire and storage, commercial vehicle repair and maintenance, road surfacing contractors and open storage and distribution. The site is generally level and devoid of any vegetation, being entirely laid to hardstanding. Existing built development is currently limited comprising some 1,527 square metres of floorspace. The main buildings comprise a part two-storey, part single storey industrial building in the westernmost corner of the site and the two large concrete silos and associated development again located toward the western end of the site. The application site is located within a Major Employment Location and a Mineral Aggregate Distribution Site as identified on the adopted UDP Proposals Map and is identified as a Strategic Industrial Location within the adopted London Plan. The site is also located within the Park Royal Opportunity Area. Surrounding development comprises a range of industrial and commercial uses, including the National Grid Visitor Centre, further open storage areas, skip storage and hire operations and vehicle hire operations to the east; commercial uses within the Victoria Industrial Estate, accessed off Atlas Road, to the south (on the other side of the Grand Union Canal); rail tracks, with travelling cranes and other rail infrastructure to the north; and further industrial/commercial uses, including a power station and industrial units within the Hanover West Industrial Estate and the Powergate Business Park, to the west. The nearest residential units to the site are the former railway workers cottages in Stephenson Street, located some 110 metres to the south east of the site boundary and dwellings in Harley Street, Harlesden, located some 140 metres to the north of the site on the opposite side of the rail tracks. The access to the site, along Channel Gate Road, does however run in close proximity to existing dwellings in Goodhall Steet, Old Oak Lane and Stephenson Street. The area alongside the Grand Union Canal that forms the southern boundary of the site is designated as a Green Corridor. The Proposal:
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The application proposes the redevelopment of the site to provide an energy recovery centre that would process around 195,000 tonnes per annum (tpa) of waste and would comprise an 8 MegaWatts Electric (MWe) Pyrolysis Advanced Conversion Technology (ACT) plant which would recover approximately 128,000 tpa of Municipal Solid Waste and Commercial and Industrial Waste; and a 2 MWe Anaerobic Digestion (AD) facility which would recover approximately 67,000 tpa of green (pure biomass) waste. The operational development associated with the proposal would comprise the provision of a warehouse type building of 5,711 square metres gross floor area. The building would be located close to the northern and western boundaries of the site and would have dimensions of 130.6 metres by 40.6 metres and with a maximum height of 9 metres. In addition to the warehouse-type building the Anaerobic Digestion (AD) element of the facility would include two AD tanks, both of which would have a radius of 12.5 metres (and a diameter of 25 metres), and two digestate storage tanks, each with a radius of 15 metres (and a diameter of 30 metres). All four tanks would have a maximum height of 9.5 metres and would take up an area of 2,394 square metres. These tanks would be located to the south east of the building, between the access road to the south west and the rail tracks and rail infrastructure to the north east. The proposal would also involve the provision of four flue stacks, all 25 metres in height. Three of these stacks would be grouped together to the northwest corner of the building and would serve the engines within the building and the fourth would be located adjacent to the north western wall of the building and would serve the pyrolysers. Other development would include the provision of a Site Reception building (to log materials in and recyclates out) on the northern side of the entrance road close to the site entrance, an electrical substation and district heating connection building to the south of the entrance road in the southern corner of the site, two weighbridges and a wheel washing facility in the access road, car parking areas for 41 vehicles, bicycle racks, a rail unloading area and a balancing pond (with a capacity of 928 cubic metres). The main building would be constructed of pale green colour-coated metal profiled cladding to the walls with a mid-metallic metal standing seam roof. As the site will be open to the public to access the proposed visitors centre, within the main operations building at first floor level, it is intended that planting would be incorporated into the development to provide an interface between the built form and the natural features in the surrounding area. The development would operate on a 24-hour a day, 7 days a week basis and would generate 30 full-time jobs. However, night time HGV movements would be subject to a night-time curfew. Access to the site would remain as existing from Old Oak Lane via Channel Gate Road, but this road would be re-surfaced to reduce potential vehicle movement noise. The application is accompanied by an Environmental Statement. Relevant Planning History
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Ref: P/1966/7426 Date: 02/12/1966
Schedule Item:04
Proposal: Demolition of existing properties and construction of new means of vehicular access to serve freight liner depot Erection of single storey extension to storage building and erection of single storey office building Change of use from storage to offices, including provision of car parking area and erection of fencing Construction and use of two 25.2 metre high cement storage silos with associated compressor house and ancillary works Provision of a 10 Megawatt energy from waste facility comprising a pyrolysis advanced conversion technology plant and an anaerobic digestion facility housed in a rectangular building with an associated stack, three gas engines, two anaerobic digester tanks (Environmental Impact Assessment Scoping Opinion) Decision: Approved
P/1974/1237
16/10/1974
Approved
P/1992/1376
28/01/1993
Approved
P/2001/2236
24/07/2002
Allowed on Appeal
P/2012/0755
02/04/2012
Environmental Statement required
Consultation: Public Consultation - Summary Neighbour Notification: Initiated on the 17/08/2012. Re-consultation, in respect of the increase in the tonnage of waste to be processed each year by the development, was initiated on the 23/10/2012 (expired on 14/11/2012). The application was also advertised in the local press and by site notice. 1,054 surrounding residential and commercial occupiers were notified in Brent as well as Ealing. 711 responses (from 586 addresses, plus 22 who provided no address) were received. Five of these representations were from Brent councillors (Cllrs. Lincoln Beswick; Janice Long; James Powney; Bobby Thomas; and Zaffar Van Kalwala). In addition, a further letter of objection, with 11 signatures, and a petition from Harlesden Environmental Action Residents and Traders, with 1,321 signatures and objecting to the proposal, have been received. The 699 letters of objection raised the following summarised comments/points of concern:
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Schedule Item:04
Potential smell and pollution from waste; Site too close to residential properties, schools and nurseries; Traffic generation, including large trucks, will result in more fumes, noise and damage to roads; Potential noise pollution; The four flues will be an eyesore; Guarantees about the development being odourless and noiseless are not trustworthy; Development would create toxic air pollution with associated health issues; Site is not allocated in the West London Waste Plan and there are other better locations where the development could be sited; Road safety concerns due to the number of schools along the access routes; Proposal would have an adverse impact on Harlesden town centre due to HGV movements; Dangerous to locate the development alongside a major rail route; Environment Agency would not regulate the site sufficiently; The Transport Assessment is not credible likely vehicle movements would be much greater if the assumptions in the TA do not come to fruition; The proposal is for an incinerator and should have been publicised as such; Insufficient public consultation was carried out; Explosion risk due to processes to be carried out; Proposal will reduce recycling and contribute to greenhouse gases; Potential car parking issues related to casual visitors to the site; Access runs too close to existing dwellings that already suffer from noise nuisance and air quality issues; To be acceptable an alternative access from Atlas Road, via a bridge over the canal, should be constructed; 24 hour operation would cause sleep disturbance; Odour management plans under-perform in reality and the proposition put forward by the developer that the plant will run at optimum performance with an optimised feedstock/waste supply are unrealistic as contamination and other supply issues mean that this optimum performance cannot be guaranteed; Site lies in an Air Quality Management Area and even a negligible deterioration in air quality is inappropriate; No evidence has been provided to support the assertion that vehicle movements on Channel Gate Road will decrease. Current vehicle movements to the site are very low as the site is currently under-used by Network Rail; No consideration has been given to the impact of odours being transported into or out of the site; Environment Agency guidance indicates that anaerobic digestion facilities up to 3 Megawatts should not be located within 250 metres of a residential dwelling or workplace or in a specified Air Quality Management Area. Homes in Stephenson Street and Harley Road lie within 250 metres of the development and are located in an AQMA; Development would lead to increased vermin problems; Visual impact of the development when viewed from the childrens playground in Harley Road would be detrimental;
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Impact of vibrations associated with HGV movements on residential amenity; Proposition that the development will utilise rail and canal transport is not a commercial reality all material will be brought in and out by road; Potential light pollution; Mains water system is already stressed and without upgrades local residents will suffer water problems; Land is safeguarded for the HS2 rail programme and therefore the development should not be allowed to go ahead.
The existing occupier of part of the site, Tarmac Limited, have objected on the basis that the landowners are legally obligated to provide commercially suitable, rail-fed alternative premises, with planning permission and all other necessary consents, under Tarmacs terms of occupation. The application does not provide a proposal to meet this legal obligation. Officers Response: The concerns raised by local residents are considered to be material to the determination of this application and it is clear that there are widespread misgivings about the impact of the proposal on neighbouring amenity particularly in relation to potential fumes and air quality issues related to the material likely to be discharged from the proposed flues. Local residents are concerned about health issues due to poor air quality particularly in relation to the quality of life of those with existing respiratory problems and children attending local schools. The information submitted in support of the application indicates that there should be no implications in respect of air quality in relation to the proposed development and suggests there should be an overall improvement in air quality in the area as a result of the reduction of vehicle movements from the site should the existing uses be replaced by the Energy Recovery Centre. Concerns have also be raised in respect of the implications on air quality from vehicle movements associated with the proposed use but again it is considered that as vehicle movements from the site are likely to be reduced is unlikely that a detrimental impact would arise. The 12 letters of support raised the following issues: Proposal would result in a reduction in the number of vehicle movements and is good news for local residents; Fully support green technology that does not burn/incinerate waste into the atmosphere and produces energy; Innovative way of solving the energy and waste problems that exist and would help to bring an end to incineration and landfill; Waste from the area is currently transported miles which is harmful to the environment. The new facility will allow the waste to be processed where it is created and will provide clean energy.
Officers Response: Noted. External Consultation List Brent Council Object to the proposal. They have significant concerns about the location of the
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Schedule Item:04
development and the potential negative impacts of aspects of the proposal in terms of environmental and transport impact on Brent and its residents and the strategic policy context. In particular, concerns have been raised in respect of: 1/. The modelling of the impact of both the stacks and the traffic on air quality in the local area along with more general concerns with the assumptions that are made in the assessments. In general the models fail to make use of localised data sets and instead use estimates which show current air quality levels to be better than the existing; 2/. The modelling in relation to the impact of Nitrogen Dioxide emissions from the stacks appears to be on a best-case scenario rather than the worst-case scenario that would normally be used. Brent does not accept that the air quality assessment has demonstrated that the processes will have an acceptable impact on the local environment for Brent residents particularly in relation to this pollutant; 3/. The model used to show the potential impact of traffic levels on air quality uses a very high adjustment factor which suggests that the model inputs may be flawed. This fails to suitably demonstrate that projected traffic movements of HGV and refuse vehicles to and from the facility will not have a detrimental impact on local air quality; 4/. The main building containing the auto-claving, pyrolysis chambers and combustion tanks will only have an acceptable impact on odours if measures for controlling the odours suggested in the assessment are implemented along with the appropriate contingency measures prior to the operation of any part of the process; 5/. However, the anaerobic digestion facility has not been sufficiently assessed within the odour control section and as such Brents environmental specialist is not convinced that the measures to control odours from this will be sufficient. We would, therefore, object to the proposal on the grounds that it has not been sufficiently demonstrated that the proposed development would have an acceptable impact on Brent residents in terms of odours emitted; 6/. In terms of noise impact Brent are concerned that the noise assessment does not provide adequate measures to guarantee that there will be no detrimental impact on Brent residents in the local area particularly on Harley Road. The noise assessment suggests that an acceptable impact on Brent residents is feasible but does not guarantee it. An objection is therefore raised to the proposed energy recovery centre on the grounds that it has not been demonstrated that the proposal will have an acceptable impact in terms of noise and disturbance for Brent residents. Officers Response: The concerns raised by Brent are noted. The issues raised have been taken up with the applicants and the following information is considered to be relevant: 1/. The applicants have confirmed that monitoring data from Old Oak Lane has been used for model verification. General background concentrations in the area have been taken from DEFRA maps which are considered to be a credible source of information. The maps showed a difference of only 0.5 ug/m3 compared to the mean concentration measured at the nearest two urban background monitoring sites. The background maps actually show higher concentrations of NO2 than one of the two
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Schedule Item:04
background monitoring sites and are therefore considered to be robust. As the impacts are predicted to be imperceptible and would remain imperceptible regardless of the background concentration used, it is not considered that the information provided incorrectly underestimates the potential impact of the development. 2/. The applicants have also confirmed that the submitted assessment is based on worst-case (i.e. 100% load and 100% operation) of the proposed plant configuration. The modelling therefore assumes operation for 8,760 hours per year at 100% load. In reality, it is not expected that the plant will operate for more than 8,000 hours per year due to maintenance down-time and will not constantly be operating at 100% load as assumed in the modelling exercise. The emissions modelled are based on guarantees from engine/plant manufacturers of the maximum potential emissions (i.e. the worst case scenario) and therefore actual emissions will be lower than such guaranteed performance figures. Results from the worst-case meteorological year are also presented in the Environmental Statement and it is not considered that the impact of potential Nitrogen Dioxide emissions from the stacks has been underestimated. 3/. The adjustment factor utilised is considered to be commonly used, particularly when assessing London based scenarios, to verify the model (i.e. adjusting it to reallife circumstances). The submitted Environmental Statement identifies that there should be a reduction in vehicle movements with the proposed development in place and these findings are based on specific traffic counts and utilising industry standard computer modelling. The findings are therefore considered to be accurate and the development should therefore result in beneficial impacts on local air quality from vehicle emissions. 4/.The proposal does not contain any combustion tanks and it is assumed this reference relates to the engines. It is, however, considered that the measures set out in the Environmental Statement will be implemented in full as they will be required to be provided, and enforced, by the Environment Agency by means of an Environmental Permit. An odour management plan will be put in place for the installation as part of the Environmental Permit. This plan would have to be fully compliant with the EAs H4 requirements and would cover all aspects of operational control, storage and handling of waste. This would detail how odour would be detected, monitored and recorded and provide information on all odour abatement plant. Each potential odour source, management control requirement and emergency control measure would be detailed. 5/. Potential odour effects from the proposed facility as a whole have been assessed in detail within the Environmental Statement and this includes the Anaerobic Digestion component of the development. All external plant associated with the Anaerobic Digestion process would be sealed (i.e. sealed tanks and associated pipework) and should not result in any odour emissions. The waste reception area for the Anaerobic Digestion process would be within the same main process building and has been assessed in detail.
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All gases produced by the Anaerobic Digestion process would be treated to remove any odorous components and then combusted within the Combined Heat and Power plant. 6/.The potential issue of noise egress has been taken into account in the design of the facility. The following mitigation measures would be put in place: There would be no external plant at the application site; As for internal plant (e.g. waste screening plant), the enclosing building would be double skinned and all plant would be acoustically treated to ensure that it would meet any adopted criteria (i.e. 5 dB below the rating level, including any penalty for tonal components, of BS4142 at the nearest noise sensitive receptor); All waste loading/unloading would be within the process building and therefore noise egress should be minimised as the process building would be double skinned and sealed. All protrusions and building apertures would be acoustically treated. Access doorways would be fast acting roller shutter type fitted with lobbies. All roller shutter doors would be orientated away from key receptors. Significant screening from buildings would occur; As for noise due to HGVs accessing the site it has been confirmed that Channel Gate Road would be resurfaced with porous asphalt and vehicles would be required to observe site speed limits. Site orientation and layout have been selected to screen transportation noise as much as practically possible. Access roads would be free of bumps to ensure a smooth road surface to minimise any short-term noise; All drive chain machinery within the building would sit on appropriately designed foundations so as to attenuate vibration levels so that they would be imperceptible at the site boundary.
The proposed development would therefore meet with the BS4142 criteria at the nearest noise sensitive premises and noise egress from the proposed development, with use of robust design process, should not affect the amenity of local residents. The proposed development would also undergo strict scrutiny by the Environment Agency prior to the issuing of an Environmental Permit for the facility. The EA would need to be satisfied that there would be no significant adverse impacts prior to issuing the Permit, otherwise the facility would not be allowed to operate. Brent Green Party Object on the following grounds: air quality; pollution to water courses; pedestrian safety issues; and concerns regarding impact of construction works noise, dust and ground contamination. Officers Response: These are all material planning considerations. The impact of construction works, however, is generally relatively short-term and construction management procedures can be put in place to control hours of operation and ensure noise, pollution and dust generation are supressed and controlled. The other issues raised are discussed within the following report. Canal & River Have no objection to the principle of the facility and consider that the development is likely to have a relatively limited visual impact on the canal environment.
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Trust
Schedule Item:04
Recommends that, if the Committee is minded to grant permission, appropriate conditions be imposed in respect of: i/ the submission of a Risk Assessment and Method Statement outlining all works to be carried out adjacent to the canal; ii/ submission of a detailed landscaping scheme; iii/ submission of details of external lighting; and iv/ the submission of a feasibility study in respect of utilising the canal for the transport of construction materials and material associated with the operation of the development. Officers Response: Noted. It is proposed that appropriate conditions would be imposed should the Committee be minded to grant permission. Confirm that the site lies in an area where archaeological remains may be anticipated. Consider that of particular note is the potential for the site to increase understanding of the industrialisation of the Park Royal and Willesden Junction area, especially in response to the introduction of the Paddington Canal in the early 19th century and the London and North Western Railway in 1866. By the later 19th century the site was occupied with engine sheds and other railway structures. Request that the archaeological position is reserved by attaching a condition to any consent granted. Officers Response: Noted. An appropriate condition is recommended to be imposed should the Committee be minded to grant permission. Initially raised concerns regarding the runoff and attenuation values stated in the submitted Flood Risk Assessment but following the submission of further information they have withdrawn their concerns and have stated that the development would be compliant with the National Planning Policy Framework if the development is carried out in accordance with the submitted Flood Risk Assessment and recommend the imposition of a condition and informatives on any permission granted to ensure appropriate mitigation measures are undertaken as part of the development. Officers Response: Noted. An appropriate condition and informatives are recommended to be imposed should the Committee be minded to grant permission. Stage 1 referral response states that the application, on balance, does not comply with the London Plan in certain regards (future railway safeguarding and verification of carbon savings) but that these issues could be addressed through amendments to the scheme and the submission of further information. Officers Response: Noted. The proposal has subsequently been amended to address the issues raised. The application will be referred back to the Mayor for further consideration after the Committee has made its decision on the proposal. No objections.
English Heritage (Archaeology)
Environment Agency
Greater London Authority
Hammersmith & Fulham Council Harlesden Town Team
Object on the following grounds site is not allocated in the West London Waste Plan; site is very close to existing residential properties in Brent and the development will have an impact on residents through extra traffic congestion, odours and poor air quality; increase in HGV movements; data used by the applicant in respect of Brent
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2010-
Schedule Item:04
air quality levels are inaccurate; and insufficient information provided to show how odour levels would be acceptably controlled. Officers Response: These issues are covered within the following report. Initially indicated that, although the application site was not contained within the draft safeguarding area for the HS2 development, the development of the site would be in conflict with the construction programme of High Speed 2 and they therefore objected to the granting of planning permission for the proposal. Subsequently, on 9 July 2013, the Secretary of State issued a formal safeguarding direction for Phase 1 of High Speed 2. The application site is situated in a gap in the formal directions but HS2 have confirmed that the site remains within the draft safeguarded area where HS2 Ltd has a surface interest and, following the issue of the formal safeguarding announcement, all land and property owners of land within the draft safeguarded area have been written to in order to inform them that land may be formally safeguarded in future (once a formal direction to proceed on the proposed Northolt tunnel is taken by the Government). HS2 have confirmed that they would use this site for the handling of excavated material from tunnels and other associated works. This material would be transferred from the Old Oak Common worksite to the application site by conveyor belt and then be transported onwards by rail. Should the consultation on design changes confirm that the Northolt section of HS2 would be in a bored tunnel, material from the main tunnelling site at Victoria Road would also be conveyed to this site. HS2 have confirmed that they have had conversations with the developer and as a result of these discussions, (combined with the fact that more material is likely to be transported to the site and the resulting space demands for this), it has become apparent that the two schemes cannot co-exist. HS2 have also stated that: The site would be utilised by HS2 Ltd to export surplus/excess material from the tunnelling operations, to other locations by rail. The use of this site would therefore reduce substantially the need to transport material by road in a busy urban area. The applicants proposed development, which is entirely within the draft HS2 safeguarded area, interacts with the Southern portion of the site that HS2 Ltd has safeguarded. As such, the Anaerobic Digestion, Pyrolysis plants, Rail Sidings, Reception Areas, Balancing Pond and internal road layout would all be, in one form or another, rendered inoperable by the proposed HS2 railway. In the light of the above HS2 Ltd maintains its objection to the proposed development and a refusal of planning permission is therefore necessary to prevent this development occurring and to avoid a conflict with the HS2 railway project. Officers Response: Noted. It is acknowledged that High Speed Two Ltd do have alternative proposals for the use of the application site. However, it is considered that, at present, there remains some uncertainty regarding the requirements of HS2 for the site. The HS2 proposals for the site would appear to be dependant to some degree on whether the Northolt section of HS2 will utilise a bored tunnel, which is still
High Speed Two Limited (HS2)
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the subject of public consultation. The application site is currently shown to be within a draft safeguarded area. The guidance notes sent to the Council indicate that the Secretary for State has decided to separate the issuing of Safeguarding Directions for Phase One of the HS2 route into two stages, Stage A and Stage B. The Safeguarding Direction issued on 9 July 2013 includes the whole of the Phase One route except for the sections relating to the Northolt tunnel and the Bromford Viaduct tunnel. These sections will be subject to Safeguarding Directions once decisions have been made on whether to proceed with those tunnels have been taken. The information supplied to the Council indicates that: These decisions will be made following the outcome of the design refinements consultation launched in May 2013. In the interim period it has been stated that: HS2 Limited would still find it helpful to be informed of planning applications in the areas covered by the design refinements consultation. It is not therefore considered that the Council is restricted from resolving to grant permission for the Energy Recovery Centre proposal should it consider that this would be appropriate in land use planning terms, having taken account of all material considerations, including the HS2 objection. Proposal would be an interesting addition to the industrial architecture along this section of the Paddington Arm of the Grand Union Canal. Particularly welcome the inclusion of an educational facility within the new building and would hope that the scheme could include a short term mooring facility to allow visitors to arrive by water. The IWA supports the use and development of freight carriage on UK inland waterways, where this is sustainable in economic, environment and social terms. Officers Response: Noted. No comments to make regarding this application, any building control issues will be dealt with using the formal consultation process. London Fire & Emergency Planning Authority National Grid Officers Response: Noted. Initially objected to the proposal due to the proximity of the development to the London Tunnel Drive site. However, this objection was subsequently withdrawn following the submission of more detailed information regarding the extent of the proposed development. Officers Response: Noted. Objects on the following grounds: Sarah Teather MP Project would be disastrous to the local area due to traffic generation and emissions from the chimney stacks; Air quality would be compromised due to Nitrogen Oxide emissions; Noise from the centre and traffic would be detrimental to residential amenity; Proposal is not in compliance with the West London Waste Plan; There have been recorded incidents of fatal explosions at similar centres in Germany, and a recorded death at a centre in Dorset. Risk of confined space asphyxiation and hydrogen sulphide and gas poisoning if appropriate site
Inland Waterways Association Middlesex Branch
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management is not put in place.
Schedule Item:04
Officers Response: Noted. The issues raised are discussed, where relevant, in the following report. Initially raised concerns as they considered there was an inability of the existing wastewater infrastructure to accommodate the needs of the application. However, following the submission of further information by the applicants drainage advisors it has been confirmed that Thames Water do not have any concerns as it appears the overall wastewater flows off the site would be a reduction from the existing situation. With regard to water infrastructure it has been confirmed that Thames Water has no objections. Officers Response: Noted
Thames Water
Raise objections on the following grounds: The Island Triangle Residents Association The Freightliner site is an unsuitable location given its non-compliance with the West London Waste Plan which guides waste treatment strategy and the ending of Ealings reliance on landfills for waste disposal; Clean Power Property Ltds inadequate assessment of potential pollution from the site poses serious potential pollution risks to local residential areas in both Ealing and Brent; There are clear site and transport issues from using this site including: Harmful environmental impacts from the planned CPPL development particularly exacerbation of known PM10s in an air quality management area and adverse effect on local amenities through 24/7 noise and vibration issues; The Applications failure to consider safety risks associated with: o Commissioning and training of personnel for AD plants; o Increased vehicular traffic near houses and local schools; Site regulation and odour management issues: o Difficulties in integrating the previous regulatory systems (planning permission and operators licence) of the nearby Powerday waste treatment plant have led to years of odour problems for North Acton and Brent residents in the very same residential area which is targeted by CPPLs application; Inadequate public consultation because of: o Inaccurate presentation of residents views by CPPLs community involvement statement apparently to bolster the overall Application; o Inadequate public consultation given the restatement of the CPPL plants capacity through an addendum. Officers Response: The weight that can be afforded to the policies in the draft West London Waste Plan is limited at this early stage in the production of this document. The wider, 7 hectare, Freightliner Terminal site was considered for allocation as a waste processing site but was not put forward due to its proximity to residential properties. The application site, of 2.4 hectares, is divorced from residential properties and would, it is considered, achieve a higher scoring in the shortlisting process if considered in isolation.
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The submitted documentation is considered to describe and assess the proposed development adequately and the potential impacts of the development, including pollution, are considered to be given appropriate consideration in the Environmental Statement. PM10 concentrations in the vicinity of the application site, either with or without the development, would be below the set thresholds. From the information submitted it is believed that the development, through the reduction in traffic flows, could result in a reduction in PM10 concentrations from road vehicles accessing and egressing the application site. The commissioning and training of personnel is not considered to be a material planning consideration except in so far as is necessary to encourage developers to utilise local labour resources wherever appropriate. The application has been accompanied by a detailed Transport Assessment which indicates that total vehicle movements from the application site would be reduced as a result of the development. The data provided for existing vehicle flows was obtained using an automatic traffic counter installed for a full week at the site. There are therefore felt to be no grounds for questioning the figures provided. The Residents Association have provided their own figures, but these are based on a single days observation and still indicate that the existing uses at the application site generate 533 movements a day, which is significantly more than would be generated by the proposal. The TITRA response refers to problems experienced in relation to the Powerday site and considers that similar issues would occur as a result of the proposed development. The Powerday operation is not considered to be comparable as that site is a Waste Transfer Site where operations are carried out in the open; where the buildings are not designed to have acoustic mitigation(such as double skinning); and where doors to the building are often left open during waste processing. The public consultation process is considered to have been appropriately carried out. Initial comments sought clarification that the operation of the development would not affect current or future use of the freightliner terminal; clarification between the employee and the National Grid visitor car parking spaces; and, evidence to show where coaches would park on site for the National Grid visitor centre. Officers Response: Noted. Further information has subsequently been submitted in respect of the issues raised. Object to the application on the basis that they consider there are a number of concerns that need addressing before a decision of acceptance should be considered. West Acton Residents Association Internal Officers response: Noted. The following report discusses the issues raised, which reflect those of local residents and other amenity societies.
Transport for London
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Consultation List Ealing Access Officer
Schedule Item:04
The disabled car parking space should be 4.8m x 2.4m with a 1.2m circulation space to the side and rear. The accessible toilet facility should comply with Part M of the Building Regulations 2004 (revised 2010), Officers Response: Noted. The proposed development would accord with these requirements.
Energy & Sustainability Officer
No objections, subject to the provision of additional information/clarification relating to carbon savings and links to district heating network. Officers Response: Noted. The requested additional information/clarification has subsequently been submitted.
Environmental Services (Refuse) Regulatory Services (Pollution)
No objections.
With regard to potential noise and light nuisance it has been confirmed that if the Committee is minded to grant planning permission that appropriate conditions be imposed in order to safeguard the amenity of local residents. The suggested conditions relate to: i/ the control of the times of HGV movements; ii/ the control of the number of vehicle movements; iii/ the control of the maximum weight of vehicles accessing the site; iv/ the control of HGV parking in Channel Gate Road; v/ the restriction of vehicle speeds within the site; vi/ the restriction of vehicle loading and unloading to within the building; vii/ the submission of details of noise emissions from external plant and machinery; viii/ the submission of details of noise attenuation measures to be incorporated into the building envelope; ix/ the submission of details of mechanical ventilation measures to be incorporated into the building; x/ the provision of fast acting roller shutter doors; xi/ the orientation of roller shutter doors away from dwellings; xii/ the submission of noise attenuation details in respect of the proposed office and educational/visitor facility areas; xiii/ the submission of details of all external lighting; and xiv/ the submission of a construction management plan. With reference to air quality issues: It is clear that the applicant has built in to the proposed plant a variety of controls and safeguards designed to minimise any adverse impacts on the surrounding areas. In principle, the proposal provides a high standard of emissions control. The applicant has sought to demonstrate, through the modelling and assessment undertaken, that the impact on the surrounding area will be negligible. The merits of the scheme in relation to renewable energy provision are noted and it is acknowledged that the proposed combination of waste treatment technologies offers a promising route to sustainable waste management. There is the need however to weigh these considerations against the potential impacts of what is, in air quality terms, a polluting industrial installation.
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Emissions to air from the pyrolysis and anaerobic digestion plants within the proposed development will be subject to regulation through an environmental permit to operate as a Part A(1) process issued by the Environment Agency under the Environmental Permitting (England and Wales) Regulations 2010 (as amended). The permitting regime, though it sets limits for emissions and provides a regulatory framework for enforcing the limits, cannot in itself guarantee that no adverse impact arises during the lifetime of a given permitted installation. Indeed I am of the view that no such guarantee can be reasonably be provided, given the possibility of human error and unforeseen incidents. Recent experience in the London Borough of Ealing points to the need to secure an appropriate location for such developments. The inspector, in dismissing the Southall Gas Pressure Reduction Station appeal (ref. APP/A5270/A/09/2114021) noted, in relation to the proposed renewable energy scheme concerned, A benefit of the scheme is that it would provide necessary heat to the PRS operation and so there would be some justification in siting the proposal on the appeal site, even in the absence of the WSRS [West Southall Regeneration Scheme]. If the WSRS were to go ahead there would be a greater benefit from siting the proposal in Southall. Whilst Blue-NG has been granted planning permission for a similar plant at Beckton, that would be close to Europes largest sewage treatment works in an area with several industrial plants and not far from Barking Power Station. I do not consider that scheme would justify allowing this proposal in a densely populated residential area in Southall. National Planning Policy Framework, paragraph 120 advises, To prevent unacceptable risks from pollution and land instability, planning policies and decisions should ensure that new development is appropriate for its location. The effects (including cumulative effects) of pollution on health, the natural environment or general amenity, and the potential sensitivity of the area or proposed development to adverse effects from pollution, should be taken into account. In having regard to this guidance, account must be taken of the effects of pollution on general amenity and the potential sensitivity of the area. The proposal site is in close proximity to the Island Triangle, a sensitive residential area where environmental quality is already compromised, to some degree, by impacts from a variety of existing uses including waste management. There is therefore a cumulative aspect in response to which, in my view, a precautionary approach should apply. L.B. Ealings Policy 2.6.3 states that The cumulative effect of individual developments will be taken into account, both in terms of impact and remedial measures. This policy has particular relevance to a case of this kind, where though breaches of air quality objectives are not predicted, there is nonetheless an impact which serves in part to reverse the incremental progress made through national and local measures to secure long-term reductions in pollutant concentrations. Such impact can contribute to background creep. It is noted that for three of the pollutants modelled (benzene, carbon monoxide and sulphur dioxide) the increase is quantified in the Entran assessment as small rather than imperceptible. Because of the dramatic improvements achieved nationally for these three pollutants, urban background concentrations, even in Greater London, are at their lowest for decades.
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The proposed development is predicted however to produce maximum increases in the concentrations of these pollutants of 11.3% (benzene, annual mean), 45.4% (carbon monoxide, max 8-hour mean) and 79.7% (sulphur dioxide, 99.9th percentile of 15-minute means). I note that the London Borough of Brents Air Quality Action Plan for 2012-2015 includes the following action (F2):- Reduce emissions to air from industrial installations and waste facilities. Any such background increases in Harlesden attributable to an industrial installation in L.B. Ealing would appear, specifically, to interfere with L.B. Brents Action Plan. There are, of course, also predicted increases within Ealings area. On balance I consider that the safeguarding of residential amenity in both the London boroughs of Ealing and Brent must be paramount and that there is insufficient evidence to hand to demonstrate that the proposed energy recovery centre would have no adverse impact on such amenity. Furthermore, the process emissions will conflict with the local authorities efforts to secure long -term, progressive improvements in the background concentrations of a number of national strategy pollutants for which they are responsible. I therefore recommend refusal of this application on the ground of detriment to air quality and amenity, in accordance with Policy 2.6. Further information has been submitted by the applicants to attempt to address the air quality concerns raised, but the Regulatory Services team have confirmed they do not believe that there is yet a sufficient level of confidence to assume an absence of adverse impact from this proposed use. On balance, therefore their recommendation remains that the application should be refused. Officers Response: Noted. The issue of the impact of the proposal on neighbouring residential amenity, including not only residents within Ealings administrative area, but also those within Brent and Hammersmith & Fulham, is clearly a very important material consideration in the determination of this application. The level of response to the public consultation process demonstrates that a significant number of residents in the vicinity of the application site have very strong concerns about the potential impact of the proposed Energy Recovery Centre on their residential amenities and also in respect of the wider implications of the proposal on their health and well-being. The concerns raised about potential air quality issues, by local residents and by specialist officers both at Ealing and Brent, are acknowledged. Nevertheless, these concerns have to be considered carefully and it is necessary for the Local Planning Authority to balance all the relevant issues and come to a decision as to whether the concerns raised are of such weight that refusal could be justified. In this particular case it is not considered that the impact of the development on existing air quality is likely to be such that the development could be argued to be unacceptable in this location. The detailed reasons for this conclusion are covered in the following report. Transport No objections, subject to the provision of improvements to the local public transport and footway network, through the provision of an appropriate financial contribution. Officers Response: Noted. The applicant has agreed to make a financial contribution toward the improvement of the local public transport and footway network. Planning Policies:
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These are as detailed in Informative 1 to the planning permission above. Reasoned Justification: Background Information: The proposed Energy Recovery Centre would comprise a single purpose designed building which would house two complementary waste technologies. The design of the building and configuration of internal equipment has been carried out to try and ensure the smallest possible footprint and height could be achieved. The form and appearance of the building would be that of a modern warehouse type building. The proposal would also include four external anaerobic digestion tanks and these tanks would be similar in appearance to agricultural storage tanks and would have sealed membrane roofs. The main building would be a double skinned, sealed portal frame construction and would be clad using a proprietary composite curtain walling system to ensure very high building permeability and acoustic performance. The main building would be subdivided internally and would contain the main processing plant and equipment. The technologies to be used by the proposed development are Advanced Conversion Technology (ACT) which would be coupled with autoclave pre-processing to segregate and recycle all recoverable materials; and Anaerobic Digestion (AD) which would be used to generate bio-methane from food waste. The ACT plant would convert all non-recyclable biomass materials into a synthesis gas which would subsequently be combusted along with the biomethane produced by the AD process within a combined heat and power (CHP) plant to produce renewable electrical and heat energy. The autoclave and ACT processes have the capacity to recover up to 128,000 tonnes per annum whilst the AD facility has the capacity to recover approximately 67,000 tonnes per annum. Both the ACT and the AD processes are certified renewable technologies that are eligible for Renewables Obligation Certificates (ROCs). The associated infrastructure would include four 25 metre high flues, a small Gas Holder Tank, an emergency gas flare, electrical substation, two weighbridges, wheel washing apparatus and security gatehouse building. The proposed main building would be subdivided into four zones. All waste entering the site (irrespective of the nature of transportation) would be received and prepared within the Waste Reception Area (Zone 1). Zone 1 would be a sealed building area which would be operated under negative pressure to control odour emissions. Within Zone 1, there would be a dedicated reception bay for the processing and pumping of pure biomass wastes and slurries directly to the digester tanks for anaerobic digestion treatment. All other waste streams would be transferred into a Waste Processing and Treatment Area (Zone 2) where the waste would pass through an autoclaving and mechanical separation processing line that would remove and segregate all potential recyclates (plastic, metal, glass etc) into recyclate bays for off-site recycling.
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The remaining biomass material would then be conditioned to create a fibre flocculent that would be advanced to the Pyrolysis Area (Zone 3). Pyrolysis Plant Systems would pyrolyse the fibre flocculent in Zone 3 and convert it into synthesis gas (syngas). The pyrolisers would be heated through a solid fuel burner system which would utilise the char residues from the pyrolysis process as fuel to create the heat for the system. The syngas would then pass through a gas cleaning line and would be stored in a gas holding vessel (gasometer) prior to combustion. The Power Generation Zone (Zone 4) would be the final component of the operation with the ACT and AD gasses fed to the three gas engines that would be coupled to an electrical generation plant producing approximately 10MWe. The electrical generation would be provided for the National Grid network. The facility would be designed to ensure that all usable generated heat could be exported to local heat distribution networks, nearby commercial or residential users should they be available. The proposed facility would process Municipal Solid Waste, Commercial & Industrial Waste and green waste. The centre would not accept any hazardous waste, dangerous substances, tyres, asbestos, gas cylinders, radioactive waste, oil, solvents or car batteries. Principle of Development: The principle of the development needs to be considered in the light of relevant national guidance and development plan policies. Policies and guidance relevant to the determination of this application are contained within the following documents: Planning Policy Statement 10: Planning for Sustainable Waste Management; The National Planning Policy Framework (2012); The adopted London Plan (2011); The adopted Ealing Development (or Core) Strategy (2012); The draft Ealing Development Management Development Plan Document (2012/2013); The adopted Ealing Unitary Development Plan (2004); and The emerging West London Waste Plan.
The principal Government guidance on Planning for Sustainable Waste Management is contained within Planning Policy Statement 10, published in 2005. PPS10 promotes the treatment and disposal of waste in accordance with the waste management hierarchy of: Waste Reduction or Minimisation; Re-use; Recycling; Other Recovery; and Disposal.
PPS10 advocates a step-change in the way waste is handled and identifies that there is a need for significant new investment in waste management facilities. National planning policy states
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that the planning system is pivotal to the adequate and timely provision of the new facilities that will be needed. In the context of the adopted Development Plan for the area, the application site comprises an unallocated windfall site. Paragraph 24 of PPS10 relates to such sites and states that: Planning applications for sites that have not been identified, or are not located in an area identified, in a development plan document as suitable for new or enhanced waste management facilities should be considered favourably when consistent with: (i) the policies in this PPS, including the criteria set out in paragraph 21; (ii) the waste planning authoritys core strategy. Paragraph 21 of PPS10 states: In deciding which sites and areas to identify for waste management facilities, waste planning authorities should: (i) assess their suitability for development against each of the following criteria: - the extent to which they support the policies in this PPS; - the physical and environmental constraints on development, including existing and proposed neighbouring land uses; - the cumulative effect of previous waste disposal facilities on the well-being of the local community, including any significant adverse impacts on environmental quality, social cohesion and inclusion or economic potential; - the capacity of existing and potential transport infrastructure to support the sustainable movement of waste, and products arising from resource recovery, seeking when practicable and beneficial to use modes other than road transport. (ii) give priority to the re-use of previously-developed land, and redundant agricultural and forestry buildings and their curtilages. Looking at each of these criteria in turn, it is considered that: The extent to which the facility would support the policies in PPS10: The proposed facility would include ACT and AD technologies, which constitute a form of energy recovery in terms of the waste hierarchy. In addition, the autoclave process would ensure that recyclable products are removed from the waste products imported into the site and would be recycled. The technology proposed would also comprise renewable technologies with a zero net carbon impact, by virtue of the fact that they would combust a renewable fuel to generate electricity. The processes would also result in no end waste product and would therefore constitute a high standard form of recovery. The development would therefore support the policies laid down in PPS10 as it would use waste as a resource and use waste as a source of energy when the waste cannot be recycled. The physical and environmental constraints on development: Annex E of PPS10 specifies Locational Criteria that should be used to test the suitability of sites for new waste management facilities. These criteria comprise protection of water resources; land instability; visual intrusion; nature conservation; historic environment and built heritage; traffic and access; air emissions, including dust; odours; vermin and birds; noise and vibration; litter; and, potential land use conflicts.
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The proposed development has been considered by both the Environment Agency and Thames Water and both have indicated that they do not object to the proposal on the grounds of impact on water resources, subject to the imposition of appropriate conditions. The site is not liable to be affected by land instability. The visual impact of the development would be comparable to existing structures on the site and would be seen in the context of surrounding commercial and industrial development, including travelling cranes, railway gantries and industrial/warehouse buildings. The visual impact of the development would therefore be appropriate. The site currently has no nature conservation value and the proposed development would include some soft landscaping provision so would represent a small improvement in nature conservation terms. The site does not lie within a conservation area, nor are any of the buildings on, or close to the site, listed. The site is however an area of archaeological interest and does lie close to the Old Oak Lane Conservation Area. The archaeological interest issue could reasonably be addressed by imposing a condition on any permission granted requiring the carrying out of further investigations into the history of the site and any remains. As far as the impact of any development on the character and appearance of the conservation area is concerned it should be noted that the Councils adopted Old Oak Lane Conservation Area Management Plan (March 2007) indicates that the character of the area is considered to be under threat by a number of issues, including the effect of the freight depot on the adjoining residential area in terms of noise and general activity. The Management Plan also indicates that the Council regards it as important to improve identified negative features and to ensure that actions are taken to positively improve or enhance the Old Oak Lane CA in a number of ways, including: Issue 1: The impact of the surrounding environment It has already been noted how the neighbouring industrial sites have had a detrimental impact on the residential streets within the conservation area, including the impact of noise from large machinery and the traffic generated by the depot. The Council already has policies to control future development, which must clearly take the impact on the setting of the Old Oak Lane CA into consideration. The owners of Channel Gate Road should be encouraged to remove unnecessary signage, reduce the impact of the existing signage as far as possible, maintain the highway and pavements to a high standard, and generally consider the impact of their business on the adjoining residential streets. The design of the development is considered to be appropriate in this generally industrial/commercial setting and would be located some distance from the conservation area such that its impact would not be detrimental. The potential impact of the activities associated with the proposed use of the site are discussed in detail later in this report. Traffic and access issues, including the suitability of the road network and the extent to which access would require reliance on local roads, are important in respect of the application site and are discussed in detail below. However, it is considered that, in the light of the authorised use of the site and the level of traffic generation associated with the existing operations carried out on the site in comparison to those likely to be associated with the new development, the proposal is acceptable in highways and access terms.
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Air emissions, including dust, are an important consideration in respect of the proposed development as the site is located within an Air Quality Management Area. The submitted air quality assessment indicates that proposal would have an imperceptible effect on air quality and the proposal should also result in a reduction in traffic movements, including heavy goods vehicles with a consequent improvement in terms of air emissions. Odour production is also a significant issue in respect of the proposed development given the proximity of residential development and the type of material to be transported to and processed at the development site. Overall, however, it is considered that any potential issue could satisfactorily be mitigated at the application site. Vermin and birds should not be an issue at the application site given the enclosed nature of the proposed processing of waste material and the absence of any external storage of waste. Noise and vibration from within the development should be able to be reasonably addressed through the design of the facility. Vehicle movements to and from the site do however need to be given careful consideration but again it is considered that any potential nuisance could be reasonably mitigated in this case. The applicants have indicated that they would put in place a number of measures to reduce potential noise nuisance at unsociable hours, including restrictions on night time HGV movements. Litter should not be a problem at the application site given the enclosed nature of the waste processing activities, subject to appropriate site management to control any possible material falling from vehicles entering or leaving the site. Lastly, it is not considered that any land use conflicts would arise given the nature of surrounding development and future land use designations. The cumulative effects of previous waste disposal facilities: Whilst it is noted that there are no other waste facilities within the London Borough of Ealing in close vicinity to the application site, there is an existing facility within the administrative area of the London Borough of Hammersmith & Fulham to the east of Old Oak Lane the PowerDay waste recycling facility. This facility is located on Old Oak Sidings, some 350 metres to the east of the application site. The Council is aware that many local residents have previously expressed concerns about odours generated at the PowerDay facility. However, this facility involves external storage of waste materials and is not considered to be comparable with the proposed development. The development proposal would have all the waste and processes contained within a sealed building, which would be operated under negative pressure to ensure that there would be no odours associated with the processing of waste products. The proposed facility would also enhance social cohesion through the creation of local employment and through the provision of an education centre which would create awareness about energy recovery and recycling in the local community and schools. The operators have also indicated that they would meet with the local community on a periodic basis to establish and build relationships within the community. The capacity of existing and proposed transport infrastructure:
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The application is accompanied by a detailed Transport Impact Assessment which has assessed the worst case scenario that all movements would be made via the existing road network. The TIA has identified that the proposed development would have a negligible impact on existing transport infrastructure. The proposed development would potentially reduce the number of trip movements generated by the site, including the number of HGV movements, as it would replace the existing cement batching facility and the existing associated industrial uses. The applicant has also indicated that they are committed to the use of rail should this be commercially viable and the scheme has been designed to utilise the rail network for freight purposes should this be a viable option, particularly for the transportation of recyclates off the site. Priority to the re-use of previously developed land; The application site comprises land which originally formed part of the operational rail network but has since been in use for commercial purposes including skip hire, open storage, cement batching and lorry maintenance. The proposed use is therefore considered to accord with this criterion. On balance therefore the proposed energy recovery centre is considered to accord with the policies and objectives of PPS10. National Planning Policy Framework (NPPF): The NPPF, published in March 2012, states, at paragraph 5, that: This Framework does not contain specific waste policies, since national waste planning policy will be published as part of the National Waste Management Plan for England. However, local authorities preparing waste plans and taking decisions on waste applications should have regard to policies in this Framework so far as relevant. Paragraph 14 of the NPPF states that there is a general presumption in favour of sustainable development: At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development, which should be seen as a golden thread running through both planmaking and decision-taking For decision-taking this means: Approving development proposals that accord with the development plan without delay; The NPPF also encourages the effective use of land by re-using land that has been previously developed (brownfield land) (paragraph 17) and supports renewable energy development (paragraph 98). Paragraph 98 states: When determining planning applications, local planning authorities should:
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not require applicants for energy development to demonstrate the overall need for renewable or low carbon energy and also recognise that even small-scale projects provide a valuable contribution to cutting greenhouse gas emissions; and approve the application if its impacts are (or can be made) acceptable. Once suitable areas for renewable and low carbon energy have been identified in plans, local planning authorities should also expect subsequent applications for commercial scale projects outside these areas to demonstrate that the proposed location meets the criteria used in identifying suitable areas. Paragraph 121 states that planning decisions should ensure that the site is suitable for its new use and that adequate site investigation information is presented. Paragraph 122 further states that: In doing so, local planning authorities should focus on whether the development itself is an acceptable use of the land, and the impact of the use, rather than the control of processes or emissions themselves where these are subject to approval under pollution control regimes. Local planning authorities should assume that these regimes will operate effectively. Equally, where a planning decision has been made on a particular development, the planning issues should not be revisited through the permitting regimes operated by pollution control authorities. Paragraph 123 of the NPPF states that planning decisions should aim to: avoid noise from giving rise to significant adverse impacts on health and quality of life as a result of new development; and mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions.
The London Plan (2011): The London Plan details the strategic objectives for development proposals and identifies the application site as being within a Strategic Industrial Location (Park Royal). At policy 2.17 the London Plan states that: The Mayor will, and boroughs and other stakeholders should, promote, manage and, where appropriate, protectstrategic industrial locations (SILs)as Londons main reservoirs of industrial and related capacity, including general and light industrial uses, logistics, waste management and environmental industries (such as renewable energy generation), utilities, wholesale markets and some transport functions. Annex 1 of the London Plan identifies Park Royal/Willesden Junction as an Opportunity Area and states that: Park Royal is one of Londons key industrial locations, with potential to meet modern logistics and waste management requirements as well as other industrial type functions. A range of opportunities exist for industrial related development and in selected locations outside of SIL for mixed-use intensification where there is good public transport accessibility. These selected locations include a series of gateway sites identified in the Park Royal OAPF comprising the Eastern Gateway at Willesden JunctionDevelopment should take account of Londons future rail and water freight requirements and their land use implications, and the scope for improvements in strategic rail accessibility.
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The London Plan states that an objective of the Park Royal Opportunity Area Planning Framework (OAPF) is to increase renewable energy production and to improve waste management utilising the latest technology. The Framework states that development proposals in Park Royal should promote an efficient approach to waste management. The OAPF also seeks to encourage and increase the use of rail transport for the movement of freight. In addition, policy 6.1 of the London Plan seeks to increase the use of the Blue Ribbon Network, including the Grand Union Canal, for passenger and freight use. Policy 5.16 of the London Plan details the Mayors objective to manage 100 per cent of Londons waste within London by 2031, create positive environmental and economic impacts from waste processing and work towards zero biodegradable/recyclable waste to landfill by 2031. Policy 5.8 indicates that: The Mayor supports and encourages the more widespread use of innovative energy technologies to reduce use of fossil fuels and carbon dioxide emissions. In particular the Mayor will seek to work with boroughs and other partners in this respect, for example by stimulating: a the uptake of electric and hydrogen fuel cell vehicles b hydrogen supply and distribution infrastructure c the uptake of advanced conversion technologies such as anaerobic digestion, gasification and pyrolysis for the treatment of waste. Policy 5.17 sets out the specific criteria against which waste applications should be assessed and states that: Strategic A The Mayor supports the need to increase waste processing capacity in London. He will work with London boroughs and waste authorities to identify opportunities for introducing new waste capacity, including strategically important sites for waste management and treatment, and resource recovery parks/consolidation centres, where recycling, recovery and manufacturing activities can co-locate. Planning decisions B Proposals for waste management should be evaluated against the following criteria: a locational suitability (see LDF preparation paragraphs F and G below) b proximity to the source of waste c the nature of activity proposed and its scale d 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 e the environmental impact on surrounding areas, particularly noise emissions, odour and visual impact and impact on water resources f 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.
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The following will be supported: g developments that include a range of complementary waste facilities on a single site h developments for manufacturing related to recycled waste i developments that contribute towards renewable energy generation, in particular the use of technologies that produce a renewable gas j developments for producing renewable energy from organic/biomass waste. C Wherever possible, opportunities should be taken to provide combined heat and power and combined cooling heat and power. D Developments adjacent to waste management sites should be designed to minimise the potential for disturbance and conflicts of use. E Suitable waste and recycling storage facilities in all new developments. LDF preparation F Boroughs must allocate sufficient land and identify waste management facilities to provide capacity to manage the tonnages of waste apportioned in this Plan. Boroughs may wish to collaborate by pooling their apportionment requirements. G Land to manage borough waste apportionments should be brought forward through: a protecting and facilitating the maximum use of existing waste sites, particularly waste transfer facilities and landfill sites b identifying sites in strategic industrial locations c identifying sites in locally significant employment areas d safeguarding wharves with an existing or future potential for waste management. H If, for any reason, an existing waste management site is lost to non-waste use, an additional compensatory site provision will be required that normally meets the maximum throughput that the site could have achieved. Table 5.3 of the London Plan indicates the amount of waste expected to be managed in London apportioned by borough and indicates that Ealing is expected to manage 359,000 tonnes of waste per annum in 2016, increasing to 507,000 tonnes of waste per annum by 2031 The proposed development would meet 54% of the 2016 target and 38% of the 2031 target. Ealing Adopted Development (or Core) Strategy (2012): The Development Strategy is the principal document of the Local Development Framework and sets out the vision, objectives, spatial development strategy and overarching policies that will guide the development in the borough to 2026. One of the key policies that are intended to help deliver the Councils vision is policy 1.2 (i) which states that the Council will seek: To make provision to manage 455,000 tonnes of waste per annum, or put arrangements in place to ensure that the pooled waste management requirements of Ealing, Brent, Harrow,
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Hillingdon, Hounslow and Richmond are accommodated within the six boroughs by 2026. It will give priority to waste reduction, recycling and composting. The Development Strategy indicates that the most recently available information from official sources showed that West London currently produces just over two million tonnes of municipal and commercial waste each year and that this figure is expected to increase to 2.11 million tonnes by 2026. At the moment 70% is transferred to sites outside London. Policy 3.3 (b) of the Development Strategy indicates that the Council will seek to promote Park Royal as a centre for green industry in the borough and also states that the boroughs commitment to tackling climate change through new development means that Ealing is well placed to accommodate expansion of the green business sector, with particular opportunities in the manufacture of renewable energy equipment, low carbon technologies, other sustainable solutions and waste management. It is also stated that: In line with the policies of the London Plan (2011), the council will promote a Green Enterprise District in Park Royal. Ealing Unitary Development Plan (2004): The application site is identified as being located within a Major Employment Location in the adopted UDP. Policy 6.4 indicates that in such locations industry is the preferred use In respect of waste minimisation and management policy 2.10 of the UDP confirms that, in order to achieve more sustainable waste management, the Council will permit proposals for waste management installations provided that they do not create undue adverse environmental effects or nuisance. Policy 2.11 indicates that planning applications for waste handling installations will be approved if the authority is satisfied that there are no feasible and more sustainable alternatives in the waste hierarchy, and there are no unacceptable impacts. Table 2C Waste Handling Proposals indicates that such proposals should cause no unacceptable impacts in terms of these criteria: 1. Transport, traffic and access; 2. Dust; 3. Odours; 4. Vermin and birds; 5. Noise; 6. Litter; 7. Pollution to air (including gas emissions), and surface and underground water; 8. Land instability or contamination; 9. Visual intrusion; 10. Detriment to nature and archaeological conservation; 11. Detriment to urban design and conservation; 12. Hours of operation; 13. Duration of operations at the site; and 14. Effects on residential amenity and adjacent development. The proposed development needs to be considered in the context of the existing authorised activities carried out from the site, including the effect of existing vehicle movements. Traffic surveys undertaken in March/April 2012 indicate that the existing uses utilising Channel Gate Road generate an average of 1243 vehicle movements per day over a 7-day period. It is estimated that the application site could reasonably be expected to generate around 60% of
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these movements, which would equate to 700 vehicle movements a day and of these it is estimated that 149 movements, or 21%, would be by Heavy Goods Vehicles. With regard to dust, it is not considered likely that the proposed development would lead to any dust issues given the nature of the operation and the fact that all loading and unloading of vehicles would take place within the building. The loading of railway containers with recyclable material would also not generate any dust. Dust generation could however be an issue during the construction phase but this issue would be temporary and could be mitigated by the adoption of best practice mitigation measures. Odour issues would be addressed by unloading vehicles carrying waste that may generate odours within the building that would be maintained at negative pressure, so no air would escape from the structure. Management procedures would be established to ensure that all vehicles entering the site carrying waste would be operated so that no smell would be emitted from the waste material being carried by sealing all containers carrying odorous waste. An Odour Management Plan and Standard Operating Procedures would be adopted and would form part of an application to the Environment Agency for an Environmental Permit for the site. These procedures would have to be strictly followed and reviewed on an annual basis to retain the license for the site. If the procedures were not to be complied with then the license for the facility would be revoked and the centre would no longer be able to operate. As there would be no external storage of any waste material and the building within which waste material would be unloaded and processed would be kept under negative pressure so that the odour from the material would not escape to the outside air the development would not be likely to attract vermin or birds. Appropriate site management techniques would be utilised to keep the external areas of the site clear of any material likely to attract vermin and birds and vermin control measures would be put in place to prevent any vermin entering the building from the surrounding area. Noise from the activities carried out within the building would be mediated through the design of the building envelope and by utilising noise suppression measures in the construction of the development. The main external impact would be likely to be the noise associated with vehicle movements, particularly heavy goods vehicles, entering and leaving the site. However, this impact would need to be considered in the light of existing activities generated by the site. Litter would be unlikely to be an issue in respect of the proposal as all unloading of waste carrying vehicles would take place within the building and all vehicles carrying waste materials to the site would be sealed to prevent material falling from the vehicles whilst they were moving. Pollution to air, and surface and underground water, would also be carefully controlled. Apart from the impact of potential dust generating activities detailed air quality modelling using an appropriate dispersion model has been undertaken to predict the impacts associated with potential stack emissions from the pyrolysers and gas engines to be provided at the site. As a worst-case, emissions from the stacks have been assumed to be at WID (Waste Incineration Directive) limits, although actual emissions from the site are likely to be significantly lower. The submitted Environmental Statement concludes that the predicted maximum concentrations of air pollutants would be well within the short and long term air quality objectives for all the pollutants that have to be assessed. Whilst there would be a small increase in NO2 concentrations due to stack emissions for some receptors it has been argued that these
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increases are effectively cancelled out by the decrease in concentrations due to reduced vehicular emissions that would result from the development. As indicated above, it is considered that odour impacts associated with the development would be effectively mitigated by the design of the installation and the implementation of an Odour Management Plan. In respect of pollution to surface and underground water the proposal would be likely to have a negligible impact. All waste would be stored within the building, in order to control odour emissions, and therefore any surface water runoff would be unlikely to come into contact with waste stored on the site. All chemicals used in the process would be stored in appropriately bunded tanks and the risk of contamination from this source is therefore considered to be low. All surface water runoff originating from operational areas, such as HGV manoeuvring areas, would be routed through an oil interceptor to the balancing pond. There would be no discharge of process water from the site as this would be recycled. The proposal is considered to be provided with appropriate mitigation measures which would be adopted to control any residual risk from routine site drainage. There are not considered to be any land stability issues in respect of the application site. With regard to contaminated land issues it is noted that the site has been under railway usage since the mid-1890s, with an extensive network of railway sidings and associated engine sheds and tanks. Given the historical usage of the site there is considered to be the potential for widespread soil contamination associated with the presence of ash ballast and spillages/leaks of fuels, lubricating oil and chemicals such as solvents and anti-freeze. More recent activities may also have resulted in localised hydrocarbon contamination from fuel leaks/spills. However, given the anticipated low permeability of the London Clay underlying the site, any contamination is likely to be restricted to the made ground/upper soil horizons and pockets of perched groundwater within the made ground. It is, however, considered that this issue could be reasonably addressed through the imposition of an appropriate condition requiring the submission and approval of details of mitigation measures to be adopted prior to any works being carried out on the site. With reference to visual intrusion views of the application site would be available from a number of public viewpoints. Adjacent properties along Stephenson Road and the southern section of Goodhall Street would have limited views of the site due to the existing high security fencing and mixed deciduous/coniferous tree planting to the rear of those properties as well as due to the presence of tall structures within the adjacent freight terminal compound including floodlighting, overhead cranes and a tower crane. Views of the site are likely to be from upper floor windows whilst ground level views are likely to be obstructed. Properties in Harley Road, within Brents administrative area, would however have open views of the site from their upper storey south facing windows, as well as partially obscured views from ground level and from outside the properties from the front courtyards or gardens. Properties on the southern side of Harley Road to the west of the First Bus depot are likely to have a full view of the site from their rear lower and upper storey windows. Existing tall structures within the site and adjacent to it are discernible in views from Hanger Hill, Ealing and One Tree Hill, Alperton, particularly the overhead cranes and tower cranes. These structures are however set against a backdrop of the City of London skyline where other taller buildings dominate the view. Views from other viewpoints (Ringwood Park, St. Marys RC
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Cemetery and Wormwood Scrubs Park) are obstructed by existing large industrial units, residential buildings and tree planting. The proposed development would be visible from a number of locations but it is considered that, in the context of the application sites existing character and its surroundings, comprising an established industrial townscape of large buildings on extensive plots with significant areas of hardstanding around them and with associated industrial infrastructure, such as tower cranes, gantries, floodlighting columns and cement silos, the visual impact of the development would be appropriate in this location. In respect of nature and archaeological conservation the site currently is largely devoid of any significant vegetation and provides limited natural habitat. The site is not within a defined Archaeological Interest Area but is considered to have archaeological potential due to its history of use for canal/railway infrastructure from the mid to late 19th century. The proposal would therefore not be detrimental to nature conservation and overall the biodiversity value of the site would be improved by enhancement of the wildlife corridor area along the southern boundary of the site, adjacent to the Grand Union Canal, and the installation of bat and bird boxes, should the development be approved. An appropriate condition would be imposed to require further archaeological survey work to be undertaken to reserve the archaeological position should permission be granted. The scheme would therefore not be detrimental to archaeological conservation. Urban design and conservation considerations would not be detrimentally affected by the proposal as the nature of the proposed development, in design terms, would respect and reflect the nature of surrounding development and would enhance the visual quality of the site and the application site is located some distance from the nearest designated heritage asset, the Old Oak Lane Conservation Area, and would not have any detrimental impact on the character or appearance of that area. The proposed hours of operation of the development are 24 hours a day, 7 days a week. However, the applicants have indicated that HGV movements to the site would be restricted to prohibit movements of vehicles of more than 7.5 tonnes outside of the hours of 06:00 hours to 23:00 hours Monday to Friday, 06:00 hours to 15:00 hours on Saturdays and not at all on Sundays and Public Holidays. The duration of operations at the site would be on a permanent basis following a 16 to 18-month demolition and construction period. The effects of the development on residential and neighbouring amenity are likely to be negligible subject to the implementation of appropriate mitigation and site management measures. On balance, therefore, the principle of the development is considered to be compliant with relevant development plan policies and Government guidance. Draft West London Waste Strategy (2011): The West London Waste Plan is currently under preparation and aims to identify and safeguard sufficient sites for waste management facilities in the boroughs of Brent, Ealing, Harrow, Hillingdon, Hounslow and Richmond upon Thames to satisfy the waste apportionment targets
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established in the London Plan. The document is in the early stages of preparation and the Proposed Submission version is currently being reviewed in order to ensure that it complies with relevant legislative requirements, particularly the duty to co-operate introduced by the Localism Act, 2011. The Plan is unlikely to be placed on deposit for consultation until late 2013 or 2014. The draft document identifies 14 potential sites for new waste management facilities, including 5 within Ealing, all of which are located within the Park Royal area and comprise two sites in Coronation Road, a site in Chase Road, a site in Victoria Road and lastly a site in Atlas Road, on the opposite side of the Grand Union Canal from the application site. The application site, however, is not identified as a possible waste management site within the draft plan, although it was part of a site on the long-list of potential sites. WLWP Policy 1 states that: Waste development proposals on sites listed in Tables 4-1 and 4-2 will generally be supported, provided that the proposals comply with other WLWP policies and the boroughs Local Development Framework. Waste developments on other sites, not listed in Tables 4-1 and 4-2, may be permitted if the proposals comply with other WLWP policies and the boroughs Local Development Framework, and: it can be demonstrated that the development is not suitable for any Sites listed in Tables 4-1 and 4-2; and for some reason, identified Sites have not come forward and it can be demonstrated that there is emerging shortfall in capacity.
To ensure no loss in existing capacity, re-development of any existing waste sites must ensure that the quantity of waste to be managed is equal to or greater than the quantity of waste which the site is currently permitted for. The amount of weigh that can be apportioned to this early draft document is considered to be limited as the approach suggested has not yet been subject to an Examination-in-Public and the applicants have stated that they consider the proposed windfall site policy to be inconsistent with the policies and guidance set out in PPS10, the NPPF and the London Plan. Other Relevant Guidance: The Government has also produced a number of papers and strategies in respect of sustainable waste management, renewable energy, biomass and anaerobic digestion that are considered to be material to the determination of the application proposal. i) Energy White Paper 2007
The Energy White Paper sets out the Governments vision for a cleaner, smarter energy system and it makes reducing carbon emissions a central plank of energy policy. Paragraph 5.3.67 of the White Paper states that: Recognising the particular difficulties faced by renewables in securing planning consent, the Government is:
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underlining that applicants will no longer have to demonstrate either the overall need for renewable energy or for their particular proposal to be sited in a particular location; creating the expectation amongst applicants that any substantial new proposed developments would need to source a significant proportion of their energy supply from low carbon sources (including on and off-site renewables); encouraging planners to help create an attractive environment for innovation and in which the private sector can bring forward investment in renewable and low carbon technologies; and giving a clear steer to planning professionals and local authority decision makers, that in considering applications they should look favourably on renewable energy developments. ii) Climate Change Act 2008 & The Fourth Carbon Plan This Act establishes a long term framework to address climate change. The Act sets out a legally binding long term emission target for 2050. The Act obliges the UK to reduce its greenhouse gas emissions by at least 34% by 2020 and at least 80% below 1990 levels by 2050. As a result of the Act, the Committee on Climate Change published a report in 2008 detailing emissions for the first three carbon budgets. The Government set out the proposed level of reductions needed in the fourth Carbon Budget which highlighted the Governments high level ambitions for reducing greenhouse gas emissions and also to stimulate low carbon investment. The Fourth Carbon Budget the limit on emissions for the five year period from 2023 to 2027 provides for a 50% reduction from 1990 levels. The information provided by the applicant indicates that the proposed Energy Recovery Centre would save the equivalent of 78,000 tonnes of carbon dioxide emissions per year in the generation of 10MW of energy, when compared with the amount of carbon dioxide generated by a standard power station. In summary, therefore, it is considered that the principle of this development, relating to an unallocated site in the context of the guidance contained within PPS10 and the development plan for the area, does accord with relevant guidance and development plan policy. The proposal is considered to comply with the guidance set out in PPS10 which advocates the promotion of waste up the waste hierarchy. The proposed facility would include both Advanced Conversion Technology and Anaerobic Digestion technologies which would recycle and recover waste using autoclaves in accordance with the waste hierarchy. The proposed Energy Recovery Centre would make a significant contribution toward the boroughs waste apportionment target set out in Table 5.3 of the London Plan, would reduce waste sent to landfill sites and would assist in meeting carbon reduction targets. The application site is located within a Major Employment Location/Strategic Industrial Land where development plan policies indicate that such a location would be appropriate for green industry and a suitable location for waste management facilities. Design, Scale and Siting: The primary building associated with the proposal would be set in an industrial context. As such it has been designed to have the appearance of a modern industrial building to accommodate modern industrial processes.
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The design of the building is considered to be compatible with the predominantly industrial nature of the area. The building would be 130 metres long and 40 metres wide. The structure would have a maximum height of 9 metres to the central ridge. The building would be predominantly constructed from pale green colour-coated metal profiled cladding to the long north east and south west elevations and dark grey aluminium framed curtain walling to the shorter south east and north west elevations with a mid-metallic metal standing seam roof. The main front (north east) elevation would be broken up by extensive areas of glazing to the entrance, reception and office areas. There would also be five mid blue coloured metal roller shutter doors to provide vehicular access into the building set within metallic grey metal cladding panels and two metallic grey escape doors. The rear elevation would be broken up by a metallic grey metal louvred wall system toward the northern corner of the building along with a metallic grey escape door. Both the shorter south east and north west elevations would be provided with three mid blue metal roller shutter doors. The proposed flues would be 25 metres high, comparable to the height of the existing concrete batching silos on the site. These structures would be constructed of finished steel with metallic grey colourcoated caged structures around the flues. The 6 metre high gas holder located adjacent to the northern corner of the site would be finished in metallic grey metal panel cladding. The digester and digestate tanks would also be finished in metallic grey metal panel cladding. The siting of the structures would result in the main building being located close to the western end of the site, in excess of 300 metres from the rear of the nearest dwellings in Stephenson Street and around 175 metres to the south west of the nearest dwellings in Harley Road, Harlesden. The gas holder tank and the group of three flues would be located adjacent to the north west elevation of the building, with the fourth flue stack located alongside the north eastern elevation of the building alongside the rail tracks. The four free-standing tanks would be located to the south east of the building around 200 metres from the dwellings in Stephenson Street and would be separated from the site boundary by a proposed balancing pond with tree planting proposed along the boundary to screen and soften the development. The overall design is considered to be in keeping with the industrial nature of the proposed use and surrounding development and would not be out of character or visually intrusive in the context of the location of the site adjacent to railway lines with large scale structures, such as travelling cranes, gantries and existing industrial buildings. Impact on Residential Amenities of Adjoining Properties: The nearest residential dwellings to the development site are located at 13-71 (odd) Stephenson Street, some 120 metres to the south east of the site boundary, and at 2-36 (even) Harley Road, some 150 metres to the north east of the site boundary within Brents administrative area. However the access to the site, from Old Oak Lane, along Channel Gate Road, would run in very close proximity to existing houses in Goodhall Street (nos. 8, 9, 11 and 13), Old Oak Lane (no. 50) and Stephenson Street (no. 13) and it is these properties that are likely to be most directly affected by the proposed Energy Recovery Centre due to the vehicle movements associated with the proposal. In visual terms the proposed development would represent an improvement over the existing situation and would not result in any loss of amenity to any nearby properties.
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The impact of lighting associated with the proposed use has been raised as a concern by some local residents. It is however considered that the effects of external lighting could be reasonably mitigated by the imposition of a planning condition requiring the submission of full details of all external lighting, including light spill diagrams and information relating to the shielding of light fittings to reduce visual impact. The noise generated by the proposed on-site operations would be contained within the purpose built processing building and should not result in any adverse impact. The effect of vehicle movements associated with the proposed use could potentially be problematic especially in respect of the amenities of those occupiers living in close proximity to the access to the site. As a result, the applicants agents have confirmed that they would accept a number of conditions to minimise and mitigate any potential noise nuisance, including the submission of a Construction Management Plan, a Delivery and Servicing Plan (including a requirement for goods vehicles accessing the site to be fitted with low noise tyres and other low noises equipment, such as directional reversing alarms and tail lifts), the preparation and submission of a Staff Travel Plan to minimise vehicle movements, the resurfacing of Channel Gate Road using a twin-layer porous asphalt, the prohibition of night time HGV movements (vehicles over 7.5 tonnes) and the restriction of HGVs from parking or waiting in Channel Gate Road within 100 metres of any residential property. The other noise related issue raised by a number of residents is that associated with vehicle movements from and to the site on the local highway network. However, it is considered that the development would be likely to result in an overall reduction in vehicle movements from the site, including a reduction in HGV movements. Concerns have also been raised regarding air quality issues in respect of emissions from the processes carried out at the site, fumes from the waste products being transported to and processed at the site and emissions from vehicles utilising the site. A full air quality assessment has been undertaken as part of the Environmental Impact Assessment process to determine any likely impact the development proposal could have on the current air quality and the technical information submitted with the application indicates that, once appropriate mitigation measures have been implemented, the processes carried out would result in either no or a negligible impact on air quality. The scheme is therefore considered to comply with relevant development plan policy requirements in respect of air quality. It should also be noted that Government guidance, contained within the National Planning Policy Framework (paragraph 122), states that, in determining planning applications, local planning authorities should: focus on whether the development itself is an acceptable use of the land, and the impact of the use, rather than the control of processes or emissions themselves where these are subject to approval under pollution control regimes. Local planning authorities should assume that these regimes will operate effectively. In this case the development is covered by the requirements of the Environmental Permitting (England and Wales) Regulations 2010 (as amended) and would undergo strict scrutiny by the Environment Agency prior to the issuing of an Environmental Permit. Residents have commented that the Environment Agency regulations relating to anaerobic digestion facilities, including the use of the resultant biogas (SR2010 No.15) prohibit the provision of such facilities within 250 metres of a dwelling or workplace and within a specified Air Quality Management Area (AQMA). In fact, the regulations indicate that, if an anaerobic digestion facility is proposed to be located within 250 metres of a dwelling or workplace and/or
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within an AQMA then a standard permit cannot be applied for, but instead a bespoke permit is required in such cases any application must include additional information about the criteria that cannot be met and how it is intended to control the associated risks. Concerns have been raised by the Councils Regulatory Services team, as well as by the London Borough of Brent, regarding air quality issues. The concerns raised by Regulatory Services relate primarily to the impact of possible odour impacts from waste vehicles accessing the proposed facility, rather than the direct odour impacts from the operation of the facility itself. In either case, however, the issue is considered to be whether the impacts are likely to be such as to be unacceptable in the location where the facility would be sited. Unlike the control of the facility itself through the environmental permitting system, there is no direct means for the Environment Agency to control vehicles transporting waste to the proposed facility. The odour impacts of vehicles on local amenity could in principle form a valid reason for refusal. However, the Council must consider whether such impacts could be adequately addressed through planning controls on the types of vehicles used to transport odorous waste. If there are types of vehicles which could avoid unacceptable escapes of odour, then refusal would be unreasonable. It would not be reasonable to require all odour to be obviated entirely the question is whether the odour would be at an acceptable level, which is ultimately a matter of planning judgment. In this regard, it is considered there is no reason why if a vehicle is fully and securely enclosed that would not be sufficient to avoid odour escaping. Concerns have also be raised about the cumulative impact on air quality that could result due to the proximity of the application site to the existing PowerDay facility located within the administrative area of the London Borough of Hammersmith and Fulham. Cumulative impacts on air quality are a material consideration, but it is considered that those impacts could not be argued to be significant in planning terms when seen against the controls that could be put in place in respect of the operation of the application site. The issue of why the PowerDay facility continues to cause odour nuisance problems, despite being regulated by the Environment Agency, has been raised by local residents. It is understood that the Environment Agency is working with PowerDay to try and resolve the odour issues at their site, but it appears the problem has arisen because the operation existed before the advent of the current H4 Odour Management Guidance, which means that the EA has an obligation to collaborate with the operator rather than just enter into enforcement. The PowerDay operation is considered to be significantly different from that of the proposed development. PowerDays operation is carried out both internally and externally and from buildings that do not benefit from any pressure control or thermal oxidisation. The building in the application proposal would be significantly smaller in volume, would be fully enclosed and operate under negative pressure and utilise a thermal oxidisation process to control odour with a back-up compact fluidised bed bio-filter to provide additional odour control when the thermal oxidisation system is undergoing maintenance. The key difference in terms of the environmental permitting regime is that the application site operation would not be allowed to be brought into operation unless it can be demonstrated that it would meet all the requirements laid down in the Environment Agencys odour control guidance. In the event that the plant then creates an odour nuisance, the Environment Agency has the full regulatory authority to carry out enforcement action and if necessary terminate all operations at the site. Concerns have also been raised that as there are no comparable developments currently operating in the same proximity to residential dwellings it is impossible to confirm that no odour nuisance would occur. However, as a reason for refusal in itself, the absence of a comparable
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site operating satisfactorily in a comparable location, would not be a strong reason and would risk an adverse award of costs, should an appeal be lodged against a decision to refuse permission. In respect of vehicle movements likely to be associated with the proposed use the development is estimated to be likely to generate 89 vehicle movements per day. The TRAVL computer programme has been utilised to ascertain predicted vehicle movements from the extant uses on the site in comparison to those likely to be generated by the Energy Recovery Centre. These calculations indicate that the proposal is likely to result in a reduction in the number of vehicle movements by 419 movements per day, from 508 to 89. If data from the observed traffic flows is utilised (from a week long traffic survey using an automatic traffic counter carried out earlier this year) the potential reduction in vehicle movements is estimated to be even greater, from 700 per day down to 89, a reduction of 611 movements per day. Of these movements 67 of the daily movements in association with the Energy Recovery Centre would be HGVs this compares with 149 HGV movements associated with the extant uses from the observed traffic flows, a reduction of 82 HGVs movements per day. Concerns have been expressed that the observed figures may be artificially high due to vehicles associated with the Crossrail tunnelling project, but even using the TRAVL database figures the number of vehicle movements associated with the proposed use compared to the extant uses on the application site would still be lower. Of the 67 HGV movements per day it is predicted that 15 would be carrying material such as anaerobic digestion digestate utilising sealed tankers or carrying sterilised material for recycling. All such material would be non-odorous or completely sealed. The remaining 52 HGVs would be delivering commercial and industrial waste for the energy recovery process. Some of this material would be non-odorous, such as cardboard, woodchip or horticultural clippings, but some would be potentially odorous and require controlled transport conditions which would be set out in a Delivery & Servicing Plan that would be submitted to the Council for approval prior to the commencement of the use. The submitted Transport Assessment indicates that the predicted average breakdown of the 52 HGVs by vehicle type would be as follows: VEHICLE Bulk Trailer Container Commercial Waste Refuse Vehicle Average Payload 24t 15t 8t 4.5t Tonnes Per Day 348t 209t 70t 70t Ave. No. Per Day 14 14 9 15
Of the 52 HGVs, the majority (28) would therefore be Bulk Trailers or Containers. The Bulk Trailers are large, usually articulated vehicles which would be fully enclosed, including fixed sides (no curtain-sided vehicles would be used) and have heavy duty top covers. The Containers are commercial skips, which are very similar to shipping containers and would also be fully enclosed. Nine of the daily HGVs would be Commercial Waste vehicles carrying 8 tonne loads. Only nonodorous material would be permitted to be transported in open or netted vehicles. The Transport Assessment also anticipates 15 Refuse Vehicles per day. The assessment assumes that these vehicles would carry 4.5 tonne loads whereas it is likely that many of these vehicles would deliver 7 or 8 tonne loads, thereby potentially reducing the number of vehicles. These vehicles would not be collecting waste as they accessed the site and so would be sealed
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the odour from refuse vehicles arises when the vehicles are being loaded with waste and the sealed loading door is open. Of these 15 movements it is predicted 7 would arrive from the north and 8 from the south, across a 12-hour day and this would equate to 2 Refuse Vehicles every 3 hours along the most affected lengths of road. At present it is not possible to confirm how many vehicles would be carrying potentially odorous waste as this would depend on the source of the material and the nature of the operators who contract to use the facility. However, it is likely that not all 52 vehicles would carry odorous waste. It should be noted that site management, including the management of vehicles, would form part of a comprehensive Odour Management Plan and this would be a key part of the sites Operational Management System. The Odour Management Plan would form one of the many documents by which the Environment Agency would set conditions in relation to the permit for the site. Although technically the regulation and management of vehicles once they are outside of the facility does not fall under the responsibility of the Environment Agency, all aspects of the operation, which includes the procedures to be followed for all incoming waste deliveries and exports, does form part of the regulatory controls under the EA permit. All incoming vehicles would be required to have been pre-notified prior to their arrival, the pre-notification procedures would cross reference such things as types of vehicle, vehicle routing and delivery times. Failure to comply with these procedures would be a breach of condition of the permit and hence both the EA and LBE (due to breach of condition in respect of the Delivery & Servicing Plan) would be able to take enforcement action. Daily odour monitoring and periodic third party sampling and measurement would form part of the routine (and mandatory) management activities at the site. All monitoring would be carried out in accordance with the Environment Agencys Guidelines for Odour Management (Guidance note H4) and should be technically robust. All potential odour sources on site would be contained within the main processing building. This building would be a sealed pressure controlled building equipped with extraction and odour abatement. All of the plant and equipment would be monitored and controlled by a central control system. In the event that any aspect of the plant is not operating properly it should be able to immediately identify this on the control system and to take appropriate action accordingly. Given that there should be no odours external to the building any odours prevalent in any external area should be able to be immediately observed by the site management and appropriate measures taken. The applicants have also indicated that they are prepared to enter into a Section 106 legal agreement with the Council to provide a financial contribution for air quality management purposes to ensure that resources are available and ring-fenced for continued air quality monitoring and, where relevant, enforcement. The applicant also proposes to establish a local liaison/stakeholder group which would include representatives from the local community, the Council, the Environment Agency and the operators to provide a forum to discuss any issues relating to the facility. Other issues raised relate to the potential risk to local residents, and users of the rail network, due to the nature of the activities to be carried out at the Energy Recovery Centre and in particular the risk of explosion, with residents drawing attention to three explosions associated
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with anaerobic digestion facilities in Germany. No further information has been provided about these incidents and it is not known what the circumstances were. However, it should be noted that there are in excess of 6,800 Anaerobic Digestion facilities operating in Germany, along with numerous other facilities in other countries around Europe. The latest information available from the UK Government is that there were 213 Anaerobic Digestion facilities operating in the UK (as at August 2011) and the Government is committed to increasing the creation of energy from waste through Anaerobic Digestion and has produced an AD Strategy and Action Plan for England (published in June 2011). The process does create gas, including methane, but the plant is designed to use the gas as it is produced to produce heat and energy in the engines that will provide electricity to the National Grid and only a small amount would be stored. The gas holder has been designed and sited in accordance with gas safety regulations, and if it were to explode (which is considered to be highly unlikely) then the effects would be confined to within the site. . Impact on Heritage Aspects: The nearest heritage asset to the application site is the Old Oak Lane Conservation Area, which was first designated in 1990 (by Hammersmith & Fulham) and was then extended in 1994 to incorporate Goodhall Street and Stephenson Street when the administration of the area was passed to Ealing. The general character is of a high density urban estate of the late 19th Century, comprising approximately 194 properties. All available space is allocated to buildings, small gardens and road access, in contrast to typical suburban middle class development in West London around the same period. Street trees, verges or any other than hard surfacing played no part in the original layout, although some planting, including a line of street trees on Old Oak Road, has occurred recently. There is no central focus. The character is formed of, and highly dependent on, the collective impact of self-contained uniformity. Although there are subtle variations of facing brick and detail from one terrace to another, the overall impression is one of uniformity, to a degree in which even a minor alteration to any one element along a street front does detract from the character of the group. The only relief to this strongly repetitive pattern is provided by the Institute and the pub. The proposed development, whilst likely to be visible from parts of the conservation area, would be set some distance to the west and would replace the existing industrial infrastructure on the site, comprising cement silos, industrial buildings and open storage, with a large industrial-type building with associated structures. Including emission stacks. These stacks, at 25 metres in height, would be of the same height as the existing cement silos, albeit that they would be narrower and located further away from the conservation area than the silos. It is therefore considered that the proposed development would enhance the character and appearance of the conservation area and would therefore accord with relevant development plan guidance. In terms of archaeology it is considered that the site does lie in an area where archaeological remains may be anticipated. Of particular note is the potential for the site to increase understanding of the industrialisation of the Park Royal and Willesden Junction area, especially in response to the introduction of the Paddington Canal in the early 19th Century and the London and North Western Railway in 1866. By the later 19th Century the site was occupied with engine and carriage sheds and other railway structures. In accordance with the recommendations given in the NPPF and to comply with relevant development plan policies it is considered that a record should be made of the heritage assets
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prior to the development, in order to preserve and enhance understanding of the assets. The archaeological position should therefore be reserved by attaching a condition to require the submission of a written scheme of investigation relating to archaeological issues. Car Parking, Access and Traffic: The site has a Public Transport Accessibility Level of 5 (Good) and is accessible by bus services 18, 187, 206, 224, 226, 228, 260, 266 and 487, via stops at Greenhill Park, Acton Lane; Willesden County Court; Harlesden Jubilee Clock; Station Road/Caple Road; Willesden Station; and Harlesden Station, which are located within a 4 to 8 minute walk-time distance of the site. Bakerloo Line London Underground services can be accessed at Willesden Junction and Harlesden stations, both located around 7 minute walk-time distance from the site. National Rail services are also available from both these stations. Vehicular and pedestrian access to the site would be provided from Old Oak Lane (the A4000) via the existing access along Channel Gate Road (which is privately owned). The development proposes the provision of 39 car parking spaces of which 25 would be like-forlike replacement provision for spaces already on the site for use by the National Grid offices, and 14 spaces for the Energy Recovery Centre which would comprise operational parking for staff and invited visitors plus an allowance for shift change, and including 2 disabled standard spaces and 2 wide spaces. In addition 10 secure and covered cycle parking spaces are proposed located close to the main entrance to the process building. Electric vehicle charging points at a 20% active and 20% passive ratio are proposed in accordance with London Plan requirements. In terms of highway capacity it has been agreed that the development would be likely to result in a reduction in total vehicle movements from the application site of 561 PCUs (Passenger Car Units, where an HGV movement equates to 2 PCUs) per day, with a reduction of 17 PCUs in the morning peak and 18 PCUs in the evening peak. As such, it is not considered that the development would have any detrimental impact on traffic flows in the vicinity, or on queuing at the Old Oak Lane signal junction. The details of the proposal have been considered by both Transport for London and the Councils Transport Planning team and no objections have been raised in respect of traffic generation, highway capacity or highway safety issues. Both TfL and the Councils Transport Planning team have requested that the developer provide appropriate financial contributions for improvements to the local highway network. These requirements comprise a contribution towards improvements to the nearest bus stop to the site; the upgrading of the existing pedestrian crossing in Old Oak Lane, the provision of cycle training for staff employed at the development site and pedestrian realm improvements around Willesden Junction railway station. The applicants have agreed to meet all these requirements through the payment of a total contribution of 56,500 by way of a section 106 legal agreement. Channel Gate Road does however run in very close proximity to a number of residential properties and despite the likely reduction in vehicle movements from the application site it is considered appropriate to require other measures to be put in place to minimise disturbance to the occupiers of these dwellings. A number of planning conditions have therefore been agreed with the applicant, including a requirement to resurface Channel Gate Road with porous asphalt, to restrict hours of access for HGVs, to limit the size of vehicles accessing the site, to prohibit HGVs parking or idling in Channel Gate Road, to require HGVs to be fitted with low noise tyres and for them to be fitted with low noise tail lifts and directional reversing warnings.
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With the contributions proposed and the imposition of appropriate conditions it is considered that the development would comply with relevant development plan requirements in respect car parking, access and traffic issues. Accessibility: The site is relatively flat and the main process building would be provided with level access to all entrance doors. Appropriate provision would be made for disabled standard parking spaces on site close to the building entrance and the building would be provided with wide corridors (1.2 metre width) and doorsets (1 metre minimum width) and disabled toilet facilities at ground floor level. A wheelchair accessible lift would be provided from the ground floor reception area to the first floor giving access to the conference/education suite and visitor viewing platform. Improvements to nearby transport facilities would be financed through section 106 contributions to facilitate their use by those with restricted mobility. Refuse & Recycling: Given the nature of the facility it is not anticipated that the development would generate any waste that would need to be transported off the site. Appropriate waste management procedures would be put in place to ensure any waste generated by employees and visitors would be processed on-site or removed if of a type not able to be processed at the facility. Details of the proposal have been considered by the Councils Refuse team and no objections have been raised.
Energy efficiency/Sustainability: The proposed development has been designed to provide a sustainable alternative to traditional waste management practices. The technologies selected would provide a means to recover most available recyclable materials whilst providing significant renewable energy in the form of heat and electricity from the remaining non-recyclable material. The facility would be able to accept, treat and process all types of non-hazardous commercial and municipal wastes which would be typically sent to landfill of for incineration. The proposed development would provide a bulk recycling facility designed to recover and sterilise all metals, plastics and glass materials in a form that would be suitable for further recycling. All non-recyclable organic material would be converted to a fibrous biomatter that would then by pyrolysed to create synthesis gas and charcoal to create heat and power. The following key sustainability measures have been incorporated into the design of the facility: Recovery of recyclates: All plastics, metals and glass would be recovered from the waste stream received at the facility and sent to third parties for recycling;
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Energy conservation: The chars created by the pyrolyser would be used as the primary thermal energy source for all treatment processes and syngas generation; Use of waste heat: The waste heat from the pyrolyser would be used to produce the steam for the autoclave, the Anaerobic Digester tank heating, water sterilisation processes, space heating and hot water; Water conservation: All rainwater and process greywater would be harvested and recovered for use in the process plant to minimise the need for main supplied water; Liquid effluents: There would be no liquid effluent discharges from the plant or releases to controlled water; Recyclable waste products: The waste ash produced by the pyrolysation process would be vitrified and turned into inert aggregate material suitable for use in the construction sector; Production of agricultural fertilisers: All liquid digestate produced by the Anaerobic Digestion process would be used as agricultural liquid fertiliser.
Both the Advanced Conversion Technology and Anaerobic Digestion processes are certified renewable technologies that are eligible for Renewables Obligation Certificates (ROCs) - the Renewables Obligation is designed to encourage generation of electricity from eligible renewable sources in the United Kingdom. The RO places an obligation on licensed electricity suppliers in the United Kingdom to source an increasing proportion of electricity from renewable sources. With respect to the main process building, this has been designed to achieve a BREEAM Very Good rating and scores very highly in all areas. The key sustainability measures are as follows: Energy/CO2 The development would incorporate a highly efficient building fabric and photovoltaic panels which would achieve a 100% improvement on the Target Emissions Rates as required by Part L of the Building Regulations; all internal and external lighting systems would have high efficiency LED fittings and would be automatically controlled to reduce energy consumption; Water All rainwater would be harvested by the scheme and used for industrial and domestic uses; high efficiency fittings would be installed to reduce the demand for potable water within the development; Materials The majority of the key building elements would achieve a Green Guide rating of A+ to B and the developer would ensure that procurement practices are in accordance with government procurement policy; Transport A comprehensive Travel Plan has been submitted with the application which, amongst other measures, includes the provision of electric vehicle charging points to encourage the uptake of electric vehicles.
Both the GLA and the Councils Sustainability officers have considered details of the proposal and, subject to the provision of further technical information relating to the predicted levels of carbon savings and other related issues, have raised no objections to the application. Biodiversity: The application site is currently largely devoid of any features of biodiversity value, although it does abut the Grand Union Canal to the south which has extensive tree and shrub coverage along its northern bank, which is designated as a Green Corridor and a Site of Metropolitan and Local Importance for Nature Conservation.
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The application proposal would provide soft landscaping where possible and principally along the eastern and western boundaries of the site and along parts of the northern and southern boundaries. Planting along the canal edge would be used to reinforce the existing tree and shrub planting. Boundary planting would be provided to the front of the site where it meets the adjoining industrial uses and to provide some screening of views of the development from the residential properties in Stephenson Street and, to a lesser extent, Goodhall Street. A detailed landscape strategy submission would be required by planning condition should the Committee be minded to grant permission along with details of other biodiversity enhancements measures, such as the provision of bird and bat boxes within the landscaped areas. Other Issues: The development would provide 30 full-time equivalent jobs, with workers employed on a shift basis with no more than 13 employees on site at any one time. The proposal would also include a visitors centre which would be predominantly aimed at school children and students to provide them with information about the need for increased recycling and more sustainable ways of handling waste. Legal Agreement: The applicants have agreed to make a financial contribution toward air quality monitoring in the area and also to provide for transport infrastructure improvements in the vicinity of the application site. These contributions comprise: Air Quality Monitoring c.25,000; Pedestrian crossing contribution - 25,000 to upgrade the existing zebra crossing on Old Oak Lane to a pelican or puffin crossing; Bus stop contribution - 7,000 to make improvements to bus stops on Old Oak Lane for the benefit of passengers with mobility or sensory impairments; Cycle training contribution - 4,500 to provide cycle training for staff working at the development; Willesden Junction pedestrian realm improvements contribution - 20,000 to improve drainage and surfacing and to de-clutter the pedestrian realm in the vicinity of Willesden Junction station. Community Infrastructure Levy: The Mayors Community Infrastructure Levy (CIL) was adopted on 1st April 3012. This has introduced a charging system within Ealing of 35 per square metre of gross internal floor area to be paid to the GLA to go towards the funding of Crossrail. The proposed development may be liable to a CIL payment of up to 199,885 (5,711 x 35), although some parts of the floor area of the development may be exempt if they constitute structures or buildings that people only enter for the purpose of inspecting or maintaining fixed plant or machinery. Human Rights Act: In making your decision, you should be aware of and take into account any implications that may
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arise from the Human Rights Act 1998. Under the Act, it is unlawful for a public authority such as the London Borough of Ealing to act in a manner, which is incompatible with the European Convention on Human Rights. You are referred specifically to Article 8 (right to respect for private and family life), Article 1 of the First Protocol (protection of property). It is not considered that the recommendation for approval of the grant of permission in this case interferes with local residents right to respect for their private and family life, home and correspondence, except insofar as it is necessary to protect the rights and freedoms of others (in this case, the rights of the applicant). The Council is also permitted to control the use of property in accordance with the general interest and the recommendation for approval is considered to be a proportionate response to the submitted application based on the considerations set out in this report.
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2013-08 Ealing Incinerator

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2013-08 Ealing Incinerator

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Planning Committee 14/08/2013 Item: 04

Type of Application: Application Received:

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Environmental Statement required

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

English Heritage (Archaeology)

Greater London Authority

Hammersmith & Fulham Council Harlesden Town Team

Planning Committee 14/08/2013

High Speed Two Limited (HS2)

Planning Committee 14/08/2013

Inland Waterways Association Middlesex Branch

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Transport for London

Planning Committee 14/08/2013

Energy & Sustainability Officer

Environmental Services (Refuse) Regulatory Services (Pollution)

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013

Planning Committee 14/08/2013