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THAMES

GATEWAY

Waste to Energy Limited

Proposed energy generation facility at London

Sustainable Industries Park, Choats Road, Dagenham,

Essex, RM9 6LF

Environmental Statement

December 2013

Thames Gateway Waste to Energy Ltd

21 Arlington Street,

London

SW1A 1RN

Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable

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Contents

1 Introduction .................................................................................... 1

1.1 Layout and purpose of this document .................................................... 1

1.2 The applicant ..................................................................................... 1

2 The proposals .................................................................................. 2

2.1 The proposed development .................................................................. 2

2.2 Site location and surroundings .............................................................. 2

2.3 The extant consent ............................................................................. 4

2.4 The Environmental Statement and the environmental impact assessment

process .............................................................................................. 4

2.5 The requirement for environmental impact assessment ........................... 6

2.6 Scoping ............................................................................................. 7

2.7 The purpose, content and structure of this report ................................... 8

3 Detailed development description .................................................. 10

3.1 Key elements of the proposed development .......................................... 10

3.2 Site access and circulation .................................................................. 11

3.3 Hours of operation ............................................................................. 12

3.4 Staffing ............................................................................................ 12

3.5 Security ............................................................................................ 12

3.6 Lighting ............................................................................................ 13

3.7 Technology overview .......................................................................... 13

3.8 Operational control and regulation of the proposed development ............. 19

3.9 Construction ...................................................................................... 21

4 Policy analysis ............................................................................... 23

4.1 Introduction ...................................................................................... 23

4.2 European policy and legislation ............................................................ 23

4.3 National policy and strategy ................................................................ 26

4.4 Regional and local policy ..................................................................... 34

4.5 Issue-specific policy analysis ............................................................... 59

5 Land use ........................................................................................ 65

5.1 Introduction ...................................................................................... 65

5.2 Context ............................................................................................ 65


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5.3 East London Waste Authority projected arisings and apportionment ......... 66

5.4 Existing and proposed facilities in the ELWA area ................................... 68

5.5 Mayor’s Business Waste Strategy for London ......................................... 71

5.6 Conclusion ........................................................................................ 74

6 Air quality ...................................................................................... 75

6.1 Introduction ...................................................................................... 75

6.2 Assessment criteria ............................................................................ 75

6.3 Existing conditions ............................................................................. 77

6.4 Assessment of impact ......................................................................... 78

6.5 Mitigation measures and residual impacts ............................................. 99

6.6 Conclusion ...................................................................................... 100

7 Noise and vibration ...................................................................... 101

7.1 Introduction .................................................................................... 101

7.2 Existing conditions ........................................................................... 101

7.3 Assessment of impacts ..................................................................... 102

7.4 Mitigation measures ......................................................................... 108

7.5 Conclusion ...................................................................................... 109

8 Visual impact ............................................................................... 110

8.1 Introduction .................................................................................... 110




8.5 Conclusion ...................................................................................... 122

9 Ecology, nature conservation and biodiversity ............................. 124

9.1 Introduction .................................................................................... 124




9.5 Conclusion ...................................................................................... 127

10 Transport and access ................................................................... 128

10.1 Introduction .................................................................................... 128




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10.5 Conclusion ...................................................................................... 136

11 Geology, ground conditions and land quality ............................... 137

11.1 Introduction .................................................................................... 137




11.5 Conclusion ...................................................................................... 150

12 Water resources .......................................................................... 151

12.1 Introduction .................................................................................... 151




12.5 Conclusion ...................................................................................... 156

13 Energy and sustainability ............................................................. 157

13.1 Introduction .................................................................................... 157




13.5 Conclusion ...................................................................................... 159

14 Socio-economic and health .......................................................... 160

14.1 Introduction .................................................................................... 160




14.5 Conclusion ...................................................................................... 166

15 Conclusion ................................................................................... 167


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Tables

Table 1: London Plan projected waste arisings at key milestones ................... 66

Table 2: London Plan apportionment of waste to be managed by ELWA boroughs

........................................................................................................ 66

Table 3: Summary of average capacity surplus/deficit within the ELWA boroughs

required to meet the London Plan apportionment ................................... 68

Table 4: Recovery facilities given in Schedule 1 of the joint waste DPD ........... 70

Table 5: Projected commercial and industrial waste infrastructure capacity gap 72

Table 6: IAQM dust risk assessment methodology ........................................ 78

Table 7: Receptor locations ....................................................................... 81

Table 8: Ecological receptors (vegetation and ecosystems) ........................... 83

Table 9: Maximum predicted (process contribution) annual average and 99.8th

percentile of hourly average concentrations of nitrogen dioxide (µg m-3) ... 84

Table 10: Predicted annual average concentrations of NO2 at specific receptors

(µg m-3) ............................................................................................ 85

Table 11: EPUK Significance Criteria(NO2, µg m-3) ........................................ 86

Table 12: Predicted 99.8th percentile of hourly average concentrations (µg/m3) of

NO2 at specific receptors ...................................................................... 88

Table 13: Maximum predicted incremental concentrations due to emissions to

atmosphere from the proposed facility (µg m-3) ...................................... 90

Table 14: Predicted increment (process contribution (PC)) of annual average

concentrations of oxides of nitrogen (NOx) at ecological receptors ............ 93

Table 15: Predicted environmental concentration (PEC) of annual average

concentrations of oxides of nitrogen (NOx) at ecological receptors ............ 94

Table 16: Predicted increment (PC) of annual average concentrations of sulphur

dioxide (SO2) at ecological receptors ..................................................... 94

Table 17: Predicted environmental concentration (PEC) of annual average

concentrations of oxides of nitrogen (SO2) at ecological receptors ............ 95

Table 18: Site description, habitat and nitrogen deposition critical load range (Kg

N ha-1 year-1) ..................................................................................... 96

Table 19: Predicted annual average ground level concentrations and calculated

nitrogen deposition rates ..................................................................... 96


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Table 20: Nitrogen deposition rate and critical loads (Kg N ha-1 yr-1) .............. 97

Table 21: Deposition as percentage of critical load function (keg ha-1 year-1) ... 98

Table 22: Noise survey results – Vibrock, 2009 .......................................... 101

Table 23: Predicted noise impacts at nearest sensitive receptors .................. 104

Table 24: BS8233 weekday overnight noise impact assessment ................... 106

Table 25: Cumulative daytime noise levels ................................................ 107

Table 26: Summary of visual impact assessment findings ........................... 120

Table 27: Statutory nature conservation sites within 5 km of the proposed

development .................................................................................... 125

Table 28: Operational HGV movements – extant and proposed .................... 131

Table 29: Staff vehicle movements – extant and proposed .......................... 131

Table 30: Predicted traffic flows – staff and HGVs for extant consent and

proposed operations ......................................................................... 134

Table 31: Preliminary conceptual model .................................................... 140

Table 32: Locations where reference values exceeded ................................ 144

Table 33: Elevated groundwater concentrations recorded in 2013 study ........ 145

Table 34: Revised conceptual model ......................................................... 147

Table 35: Carbon dioxide emissions after each stage of the energy hierarchy 159

Table 36: Regulated carbon dioxide savings from each stage of the hierarchy 159

Table 37: Employment by sector in Barking and Dagenham ........................ 161

Figures

Figure 1: Site location ................................................................................ 3

Figure 2: Process schematic ...................................................................... 15

Figure 3: Location of human health receptors and stack ................................ 82

Figure 4: Annual average NOx concentrations .............................................. 89

Figure 5: 99.8th percentile of hourly average NOx concentrations .................... 89

Figure 6: Predicted annual average ground level concentrations of oxides of

nitrogen dioxide (NOx) (µg m-3) ............................................................ 98

Figure 7: Predicted annual average ground level concentrations of sulphur

dioxide (SO2) (µg m-3) ........................................................................ 98

Figure 8: Current site condition – November 2013 ..................................... 124


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Appendices

Appendix A: Scoping request

Appendix B: Scoping opinion

Appendix C: Air quality assessment

Appendix D: Noise assessment

Appendix E: Visual impact assessment

Appendix F: Draft travel plan

Appendix G: Phase 1 environmental assessment report

Appendix H: Phase 2 environmental assessment report

Appendix I: BREEAM pre-assessment

Appendix J: Energy assessment

Appendix K: Consultation event

Appendix L: Landscape plan


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Drawings and plans

Drawing 7487-20-001 – Internal building layout

Drawing 7487-20-002 – Office internal layout

Drawing 7487-20-003 – Facilities plan

Drawing 7487-20-010 – Elevations

Drawing 7487-20-011 – Office elevations

Drawing 7487-70-001 – Topographical survey

Drawing 7487-70-002 – Location plan

Drawing 7487-70-004 – 3D views

Drawing 7487-70-003 – Site layout plan

Drawing 7487-70-005 – Sunpath studies


Drawing 7487-73-001 – Site circulation

Drawing 7487-73-002 – Site surfaces

Drawing MA9580–200 – Drainage strategy

Drawings MA9580–VT101, VT102, VT103 – Vehicle tracking drawings

Drawing 30582-60-003 – Utilities

Drawing 30582-63-001 – External lighting


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1 Introduction

1.1 Layout and purpose of this document

This document is an environmental statement submitted in support of a full

planning application by Thames Gateway Waste to Energy Ltd (TGW2E) for

the development of an energy generation facility on a site known as Plot 2 in

the London Sustainable Industries Park in Dagenham.

This document provides a detailed development description, an analysis of

planning policy and assessment of potential environmental issues associated

with the proposed development such as noise, air quality, contaminated land,

visual impact assessment, transport etc; detailed topic-specific assessments

are contained in the accompanying appendices where appropriate and

necessary. It is supported by a stand-alone non-technical summary.

A design and access statement has also been prepared to accompany the

application, which is a separate, stand-alone document.

1.2 The applicant

Thames Gateway Waste to Energy Ltd (TGW2E) is a special purpose vehicle

formed by Chinook Investment Partners (Chinook Urban Mining) in order to

develop and operate the site on the London Sustainable Industries Park.

The technology is provided by Chinook Sciences, based in Cranford, New

Jersey, with UK headquarters in Nottingham. Chinook Sciences was founded

in 1998 and is a leading manufacturer and operator of advanced gasification

technology. Its RODECS® gasification system is now in its ninth design

generation and is capable of processing a wide range of waste streams. It

has been installed in 17 locations throughout the world where it gasifies

organic material without using incineration and fully recovers metals in its

patented ACTIVE PYRO® process. Chinook Sciences has planning permission

for two sites in the UK, one of which is currently under construction.


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2 The proposals

2.1 The proposed development

The proposed development relates to the generation and export of electricity

from 180,000 tonnes of residual commercial and industrial waste that would

otherwise be landfilled. Some 19 MW electricity / year will be generated of

which 5MW, will be used to power the facility itself with the remaining 14MW

exported to the grid; the power exported is sufficient to power approximately

32,000 homes for a year.

2.2 Site location and surroundings

The proposed location is shown in Figure 1 and is known as Plot 2 of the

London Sustainable Industries Park (LSIP). The LSIP is located off the A13 at

Dagenham Dock via the Goresbrook Interchange and Choats Manor Way and

Choats Road. Junction 30 of the M25 lies approximately 9 km to the east,

whilst the North Circular / A406 lies approximately 5 km to the west.

Dagenham Dock Rail Station is approximately 600m to the northeast.

The site is largely rectangular in shape, measures approximately 3.35 ha and

is relatively flat. It is bounded to the east by Choats Manor Way, which links

to the A13. To the immediate south of the site lies vacant land, for which

planning permission has recently been granted for a 160,000 tonnes / year

anaerobic digestion facility (ref 13/00649/FUL).

The site has been cleared and levelled, landscaping implemented around the

perimeter and an access road provided by the landowner, the Greater London

Authority (GLA). The land benefits from an existing consent for an electricity

generation facility granted in March 2011 (ref 10/00287/LBBD).

The nearest residential properties to the proposed development are in Shaw

Gardens, some 350m to the north and Keel Close some 950m west. The

proposed Barking Riverside development is some 500m to the west.


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There is one nature conservation site, Goresbrook and Ship and Shovel Sewer

SINC, adjacent to the west and northern boundaries of the site. Within a 5

km radius of the site there are eight statutory and important non-statutory

sites as well as a number of other SINCs.

An on-road cycle route runs along Choats Road although the high numbers of

heavy goods and commercial vehicles using this road probably discourage

cyclists. A cycle route is proposed to the immediate north of the site running

along the southern boundary of the Goresbrook; this route would form part of

the National Cycle Network (NCN13) and would provide an alternative route

to Choats Road for cyclists and pedestrians.

The EL2 bus service between Ilford and Dagenham stops near the site on

Choats Road; there are no other bus services within acceptable walking

distance.

The site records an extremely poor public transport accessibility level (PTAL)

of 1a on a scale of 1 – 6.

Figure 1: Site location

(Image Source: Imagery ©2013 Bluesky, DigitalGlobe GeoEye Getmapping plc. Infoterra Ltd & Bluesky, The Geoinformation Group, Map data ©2013 Google)


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2.3 The extant consent

On 31 March 2011, the London Thames Gateway Development Corporation

(now London Borough of Barking and Dagenham for planning purposes)

granted planning permission to Thames Gateway Power, for an energy

generation facility on a site previously known as Abacus Park, Choats Road,

Dagenham (ref 10/00287/LBBD); now known as plot 2 of the LSIP.

The consent contains 34 conditions, 21 of which need to be discharged pre-

commencement. TGW2E commenced work on discharge of these pre-

commencement conditions, with condition 10 (breeding birds), 23

(archaeology) and part a) of condition 22 (contaminated land) having been

discharged by TGW2E.

Initially, TGW2E hoped to submit an application under Section 73 of the Town

and Country Planning Act 1990 (as amended), which allows amendment of

the conditions attached to a planning consent for minor material changes to

the development proposals after permission has been granted. The section

73 application would have enabled TGW2E to inter alia replace the approved

drawings under the extant consent thereby allowing it to substitute its own

technology and layout for that which had been approved.

However, as TGW2E progressed with detailed design, it became apparent

that the differences between the extant consent and TGW2E’s own design

were too great to be approved as a minor amendment to the extant consent

and so TGW2E would need to submit a new application.

2.4 The Environmental Statement and the environmental impact

assessment process

2.4.1 Legislative background

Environmental impact assessment (EIA) is the process by which the positive

and negative environmental effects of a proposed development are identified

and assessed before development consent is granted.


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The process systematically identifies and assesses a project's expected

significant environmental effects and culminates in the preparation of an

Environmental Statement (ES).

The requirement for EIA originates in EU law under EC Directive 85/337 (as

amended by Directive 97/11/EC), on the assessment of the effects of certain

public and private projects on the environment (the EIA Directive). The EIA

Directive has been transposed into English legislation by various regulations,

the primary regulations in England being the Town and Country Planning

(Environmental Impact Assessment) Regulations 2011 (SI 2011/1824) (the

‘EIA Regs’).

Formal guidance on the regulations is contained in Department for

Communities and Local Government (DCLG) Circular 02/99: Environmental

Impact Assessment.

Schedule 4 of the EIA Regs, requires the EIA to consider any ‘…direct effects

and any indirect, secondary, cumulative, short, medium and longterm,

permanent and temporary, positive and negative effects’.

The findings of the EIA process are then documented in an Environmental

Statement (ES) that is submitted with the planning application to provide the

local planning authority (LPA) with appropriate levels of information for

decision-making and the determination of the planning application.

Statutory and non-statutory consultation takes place throughout the EIA and

planning application process.

2.4.2 Content of an ES

Schedule 4 of the Regulations specifies information to be included in an ES

viz.:

A description of the development.


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An outline of the main alternatives studied and an indication of the main

reasons for the choice.

A description of the aspects of the environment likely to be significantly

affected including in particular:

population,

fauna,

flora,

soil,

water,

air,

climatic factors,

material assets, including the architectural and archaeological heritage,

landscape, and

the interrelationship between the above factors.

A description of the likely significant effects of the development on the

environment, to include direct, indirect, short, medium and long term,

permanent and temporary, positive and negative effects etc.

Mitigation measures to prevent or reduce any significant adverse effects.

A non-technical summary of the information contained in the ES.

2.5 The requirement for environmental impact assessment

Certain types of development (projects listed in Schedule 1 of the EIA Regs)

always require EIA by virtue of their size, type and potential environmental

effects.

The proposed development falls into the following category:

Schedule 1 part 10 - Waste disposal installations for the incineration or

chemical treatment (as defined in Annex IIA to Council Directive

75/442/EEC under heading D9) of non-hazardous waste with a capacity

exceeding 100 tonnes / day.


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2.6 Scoping

Part 4 of the Regulations provides for an applicant to ask the relevant

planning authority to state its opinion on the proposed EIA content

(‘scoping’).

A detailed request for a scoping opinion was submitted to the London

Borough of Barking and Dagenham (LBBD) as planning authority on 30

September 2013 (Appendix A).

In identifying topics proposed to be addressed in the EIA, a detailed review

was undertaken of the application for the extant planning consent

(10/00287/LBBD) and in particular its accompanying EIA, the scope of which

was agreed with the LPA with comments also received from the Greater

London Authority (GLA).

The scoping opinion issued by the LPA1 in respect of the EIA undertaken in

support of the extant consent application required that the following topics be

addressed:

Land use

Landscape and visual

Ecology, nature conservation and biodiversity

Transport and access

Geology, ground conditions and land quality

Hydrology and hydro-geological

Drainage

Archaeology

Flood risk

Noise and vibration

Air quality

1 Letter from LTGDC dated 8 October 2009


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Construction environmental management

Energy and sustainability

Socio-economic and health

The Officer’s report on the planning application2 noted that in terms of

environmental considerations (flood risk / contamination / air quality / noise /

visual impact / biodiversity), the Environmental Statement concluded that

impacts are either negligible or minor beneficial; a position supported by

consultees subject to appropriate conditions.

Given the findings of the previous EIA and the work already undertaken by

TGW2E in discharging planning conditions, it was possible to scope some

topics out of detailed consideration in the EIA.

LBBD issued a formal scoping opinion on 8 November 2013 (Appendix B),

which required that the following topics be addressed in the EIA:

Land use

Air quality

Noise and vibration

Ecology, nature conservation and biodiversity

Visual impact

Transport and access

Geology, ground conditions and land quality

Hydrology and hydrogeology

Energy and sustainability

Socio-economic and health

2.7 The purpose, content and structure of this report

This document is the Environmental Statement (ES), which accompanies the

application for planning permission.

2 London Thames Gateway Development Corporation Planning Committee Meeting 8 July 2010. Report

No: LTGDC/10/PC34. Application number 10/00287/LBBD


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This document addresses all pertinent environmental issues related to the

construction and operation of the proposed development. Potentially

significant impacts relating to the development have been identified and

addressed and where possible, potentially adverse impacts have been

designed out. If this is not possible then mitigation measures are proposed

to minimise and ideally eliminate the effects. Beneficial impacts of the

proposed development are also identified and maximised wherever possible.

This document and accompanying technical appendices and the free-standing

non-technical summary comprise the Environmental Statement for the

proposed development. All relevant issues listed in Schedule 4 of the

Regulations have been addressed.

The EIA has been undertaken by Amberley Consulting Ltd with input from a

number of specialist consultants whose technical reports are included in the

appendices to this ES.

The remainder of this document is structured as follows:

Section 3: Detailed development description

Section 4: Policy analysis

Section 5: Land use

Section 6: Air quality

Section 7: Noise and vibration

Section 8: Visual impact

Section 9: Ecology, nature conservation and biodiversity

Section 10: Transport and access

Section 11: Geology, ground conditions and land quality

Section 12: Water resources

Section 13: Energy and sustainability

Section 14: Socio-economic and health

Section 15: Conclusion


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3 Detailed development description

3.1 Key elements of the proposed development

The proposed development is shown in a series of drawings and plans, which

accompany this application as follows:

Drawing 7487-20-001 – Internal building layout

Drawing 7487-20-002 – Office internal layout

Drawing 7487-20-003 – Facilities plan

Drawing 7487-20-010 – Elevations

Drawing 7487-20-011 – Office elevations

Drawing 7487-70-001 – Topographical survey

Drawing 7487-70-002 – Location plan


Drawing 7487-70-003 – Site layout plan

Drawing 7487-70-005 – Sunpaths


Drawing 7487-73-001 – Site circulation

Drawing 7487-73-002 – Site surfaces

Drawing MA9580–200 – Drainage strategy

Drawings MA9580–VT101, VT102, VT103 – Vehicle tracking drawings

Drawing 30582-60-003 – Utilities

Drawing 30582-63-001 – External lighting

Key elements of the proposed development include:

Erection of a building comprising a waste reception, post-processing and

materials storage hall (89.8m x 65.6m x 17m)

Erection of a RODECS® process building (26.9m x 58.5m x 20.5m)

Erection of a two storey office building (34.3m x 11.25m x 8.5m)

Installation of a 55m stack

Installation of a dedicated electricity substation with associated fencing

and export connection


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Installation of a weighbridge and erection of associated office

Installation of external energy conversion, emissions treatment and

control equipment

Erection of perimeter fencing around the external boundary of the site

Drainage infrastructure including underground water storage tanks

Hardstanding, roadways, vehicle and bicycle parking areas

Soft landscaping.

3.2 Site access and circulation

There are two accesses to the site as shown on Drawing 7487-70-003.

Vehicle movements associated with the proposed development will include

HGVs and staff / visitor vehicles; site circulation is shown on Drawing 7487-

73-001.

Material for processing will be brought onto site by HGVs from a number of

locations in the London area.

All HGVs will enter the site through the western gate. HGVs bringing material

for processing will pass over the incoming weighbridge, and proceed to the

lorry waiting / parking area, where they will be held until the reception area

in side the building is clear. They will then drive into the building to deposit

the waste before retracing their route and passing over the outgoing

weighbridge before exiting the site. Fast-acting roller shutter doors will open

to allow access / egress by HGVs; tipping will only take place when the doors

are closed. Air from the waste reception area will be extracted and passed

through carbon filters prior to discharge to remove any odours.

HGVs collecting recovered materials for further processing will pass over the

incoming weighbridge and proceed to the southern end of the building, where

metals and aggregates will be stored. They will reverse into the building for

loading and then retrace their route passing over the exit weighbridge prior

to leaving the site.


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HGVs delivering materials / fuel will pass over the incoming weighbridge

before being directed to the appropriate area of the site.

Staff / visitor vehicles will enter / exit the site through the eastern access and

proceed to the relevant parking areas.

3.3 Hours of operation

The development will operate 24 hours / day, seven days / week. HGV

deliveries to the site will be between the hours of 07:00 – 22:00 Monday –

Friday and 07:00 – 17:00 on Saturdays, over the equivalent of 304 days /

year (six days / week excluding bank holidays).

Electricity will be generated 24 hours / day, seven days / week.

3.4 Staffing

The development is expected to employ 55 staff in total. Of these 55, 45

staff will be employed in production across two or four shifts, dependent on

the specific job function, the remaining 10 non-production staff would work

general office hours.

3.5 Security

The entire site will be securely fenced with 2.4 – 3.0m high weldmesh fencing

(the 3.0 m fencing to be installed on the northern boundary where there is

considered to be a greater security risk). Access will only be possible through

the two entrances, which will be gated with security barriers controlled

remotely from the weighbridge / gatehouse.

The facility will be in operation 24 hours / day, seven days / week so there

will always be personnel present on site. A CCTV system will be installed,

maintained and operated in accordance with BS7958:2009 – Closed circuit

television (CCTV) management and operation (code of practice).


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3.6 Lighting

Operational activities would be undertaken internally in buildings and so

external lighting would be restricted to areas of hardstanding and roadways,

to enable safe movement of traffic around the site, and to areas of external

equipment. Hours of working on site mean that lighting would be required

after dusk throughout the year; lighting would be directional to prevent spill

and limit any potential adverse effects on neighbouring landuses and users.

Security and utility lighting will comprise pole or building mounted lights at

approximately 6m high, downwards oriented and inward facing. Downward

pointing lighting will also be positioned above vehicle entrances into buildings

and low-level lighting will be provided along walkways / cycle routes within

the site to allow for the safe movement of staff around the facility. Proposed

external lighting is shown on drawing 30582-63-001.

Internal lighting would be fully controlled by a combination of movement

detectors, passive infra red (PIR) detectors and daylight sensors to ensure

energy use is minimised. As far as possible, the roofs of buildings would be

perforated by an array of translucent panels that would transmit daylight into

the buildings. Artificial lighting would be required to supplement day-lighting

under certain conditions in these buildings and would be provided in the

administrative areas and externally. Emergency lighting would be provided in

line with the emergency lighting code of practice BS 5266-1.

3.7 Technology overview

3.7.1 Gasification

Gasification is the thermal decomposition of material in an atmosphere, which

does not contain enough oxygen to allow full combustion. It is a well-

established process dating from the early 1800s, when it was first used to

produce town gas from coal. The process results in the production of a

combustible gas, ‘syngas’, which typically contains a mix of predominantly

carbon monoxide, carbon dioxide, hydrogen, methane, and nitrogen. The


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syngas can be combusted and the hot exhaust gases sent to a waste heat

boiler to generate steam, which can be used in a steam turbine or used

directly to produce electricity and heat.

3.7.2 The Chinook Sciences technology

The Chinook Sciences gasification technology is called RODECS®, which

forms the core of the ‘ACTIVE PYRO®’ system. The RODECS® system

consists of a process chamber controlled by a natural gas–fired thermal

reactor. It has been operating at commercial scale for thirteen years in the

UK, Europe, the Americas and the Middle East on a range of input materials.

A schematic of the process is shown in Figure 2 and described below.

3.7.3 RODECS®

The gasification system will consist of two RODECS® batch Gasifiers, each

capable of processing the total design throughput of 90,000 tonnes per year

(7,500 hours per year). The RODECS® system will have a natural gas fired

thermal reactor to supply the primary heat for the gasification process.

Front end loaders will push the un-processed material against a wall ready for

transfer to the RODECS®. This material will then be fed, using a grabber

system, into a RODECS® bin with a volume of 100 m3. The RODECS® bin will

be positioned in the filling area using an automated trolley car system

combined with bin location stands; each movable trolley car is designed to

hold two bins. The waste will be loaded into the bin and be compressed

regularly while it is in the bin to allow more waste to be added into the bin.

This process will continue until the bin reaches the target weight of 24 tonnes

(the stand is equipped with a weigh scale system). Once the bin reaches the

target weight, loading will stop and the trolley will then move the freshly

filled feed bin towards the RODECS® immediately next to the position in

which the processed bin is removed.

Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 15

Figure 2: Process schematic

First zone

Fuel Preparation: The waste is

processed under tight Oxygen &

temperature control to ensure the

complete gasification of the organics to

produce a synthetic gas fuel (syngas) and

thermally clean all of the valuables in

the waste for further recycling.

Temperature Range: 550 - 600o

C

Second zone

Combustion chamber: The syngas is

combusted and the exhaust gases held

at a temperature of >850o

C for >2s in

accordance with the requirements of the

Waste Incineration Directive (now

incorporated in to the Industrial

Emissions Directive).

Temperature Range: 850 – 1,400o

C

Third zone

Waste heat boiler: The hot exhaust

gases from the combustion chamber are

passed through a waste heat boiler to

generate steam which is passed to a

Steam Turbine Generator (STG) set to

generate electricity.

The hot gases leave the boiler at a

reduced temperature (≈200o

C)

Fourth zone

Air pollution control system: The

exhaust gases from the boiler pass

through a bag filters to remove any

particulate that is suspended in the

gases before allowing them to exit via

the stack. Sorbent/PAC injection

removes acid gases and Dioxins.


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The processed bin will then be unlatched from the RODECS®, and the trolley

moved into a position such that the fresh feed bin is in place to be latched to

the RODECS®. After the fresh bin has been attached, the RODECS® will then

rotate 180 degrees so that the bin will be at the top of the RODECS® and

inverted, starting the process cycle. Changing bins will be accomplished in

approximately three minutes.

The RODECS® Gasifier uses a patented process by the name of ACTIVE

PYROLYSIS® to control both the atmospheric conditions within the RODECS®

and the conversion rate of the energy-containing materials in the feed into a

syngas consisting primarily of carbon monoxide (CO), hydrogen (H2), carbon

dioxide (CO2), methane (CH4), water (H2O) and nitrogen (N2) from the air fed

to the process. The temperature inside the Gasifier (550 – 600°C) is

maintained below the melting temperatures of metals enabling them to be

recovered.

The syngas is generated in the RODECS® processing chamber through a

combined action of pyrolysis and gasification. The rate of reaction is

controlled by an array of controlled parameters (among which are flow,

temperature, Oxygen-level, etc.). The rate at which the batch is heated is

determined by the process chamber movement, volume of gases and

temperature of the recycled hot gases sent to the RODECS® from the Thermal

Reactor chamber. The preheated gases provide sensible heat required for

heating. The gases are also used to fluidise the feed to enhance the rate of

production of the syngas in the RODECS®.

The remaining material, metal, glass, dirt and sand, is mechanically retained

inside the RODECS® processing chamber. At the end of the batch processing,

the RODECS® will be rotated such that the bin is back at the bottom with the

inert materials falling back into the bin for removal. The bin will be unlatched

and the contents taken to the process material separation area, after which

the separated materials will be taken to the process material storage area.


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The total cycle time will be approximately 120 minutes for a 24 tonne batch.

The time required reaching threshold syngas production is expected to be in

the region of 25 minutes. The cool down time before unlatching the bin

where the average syngas production rate has declined below the threshold

value to the complete depletion of syngas is expected to take 10 to 15

minutes. The bin will only un-latched after full depletion of the syngas.

The syngas produced in the gasifier passes to a dedicated natural gas fired

combustion chamber where it is combusted and the exhaust gases held at a

temperature of 900oC for >2s in accordance with the requirements of the

Waste Incineration Directive (now incorporated into the Industrial Emissions

Directive) which stipulates that ‘the gas resulting from the process is raised,

after the last injection of combustion air, in a controlled and homogeneous

fashion and even under the most unfavourable conditions, to a temperature

of 850°C, as measured near the inner wall or at another representative point

of the combustion chamber as authorised by the competent authority, for two

seconds’.

3.7.4 Air pollution control system

For NOx control, a Selective Non-Catalytic Reduction (SNCR) system is

employed utilising ammonia solution (NH3aq) injection in to the combustion

chamber. The amount of NH3aq injected is adjusted according to the NOx

measurement at the stack inlet by the CEM (Continuous Emissions

Monitoring) system and this is done on a continual basis.

Exhaust gases exiting the waste heat boiler, exit at 200oC and are drawn

through an Air Pollution Control (APC) system aided by an induced draft fan

and are then discharged to atmosphere via a stack.

The APC consists of a ‘barrier type’ particulate filter that utilises bag filters.

Besides filtering the exhaust gases for particulate, acid gases (e.g. HCl, HF

and SOx) will also be removed from the flue gas at the APC. Here, sodium

bicarbonate sorbent will be injected using a dry system which will form a fully


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reactive coating on the ceramic filter candles in order to neutralise the acid

gases. Powdered Activated Carbon (PAC) is also injected in order to adsorb

dioxins / furans. The sodium bicarbonate and reaction products are powders

and are discharged from the ceramic filter along with filtered particulate and

spent PAC for removal and disposal. The flue gas cleaning equipment has

been designed based on the waste feedstock characteristics.

3.7.5 Turbine / generator

The exhaust gases from the combustion chamber are passed through a waste

heat boiler to generate steam which is passed to a Steam Turbine Generator

(STG) set to generate electricity.

On discharge from the STG, the steam is condensed in an Air Cooled

Condenser (ACC). Condensate is returned to the de-aeration system via

condensate extraction pumps. Water make up is via a water treatment

plant; as the system will be running on demineralised water, the blow-down /

make-up water is a negligible amount. The STG can be by-passed through a

Pressure Reducing De-Superheating valve (PRDS) to provide steam pressure

control. A substation will be constructed on site to enable export to the grid.

3.7.6 Reclamation of inert recyclable materials

Any metals, glass and aggregates in the incoming waste will be recovered

from the inert solid residues arising from the RODECS® system and sent for

further reprocessing / recycling; it should be noted that the incoming waste

will have already been subject to recycling / reprocessing, so the quantities of

metals etc remaining in the incoming waste in particular are not expected to

be significant. It is expected that the remaining inert residue material will

be sent to landfill initially although TGW2E has committed to working with the

University of East London to find and develop markets for this material

(section 14.3).


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3.7.7 Potential for heat export

The technology to be employed in the proposed development has been

designed to maximise the amount of electricity that is generated from the

infeed material. It is therefore extremely efficient in recovering heat to

increase the efficiency of the energy conversion process as heat is recovered

from the combustion gases through the use of waste heat boilers and steam

turbines.

The efficiency of the heat recovery process means that there is less available

for potential export to a heat transmission network than would normally be

the case for an energy from waste facility.

However, given the Mayor’s commitment to decentralised energy and the

proposed district heating transmission line along Choats Road, TGW2E will

provide a CHPReady facility (section 3.8) and regularly review the potential

for heat export.

3.8 Operational control and regulation of the proposed development

The proposed development requires an Environmental Permit (EP), issued by

the Environment Agency, before it can operate.

The Environmental Permitting regime seeks to ensure that regulated facilities

do not cause harm to the environment or human health; it is the

Environment Agency’s responsibility to ensure that this is the case.

Operators have to manage and operate activities in accordance with a written

management system that identifies and minimises risks of pollution, including

those arising from operations, maintenance, accidents, incidents, non-

conformances, closure and those drawn to the attention of the operator as a

result of complaints.


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Environmental Permits have a series of conditions attached addressing

specific outcomes e.g. emissions and monitoring requirements, maintenance

of records, requirements for staff competence etc., which must be complied

with. The Agency conducts regular inspection visits to ensure that facilities

are operating in accordance with the permit conditions.

The Agency requires that all applications for Environmental Permits for new

installations regulated under the Environmental Permitting (England and

Wales) Regulations 2010 demonstrate the use of Best Available Techniques

(BAT) for a number of criteria, including energy efficiency.

The Agency recognises that one of the principal ways in which energy

efficiency can be improved is through the use of CHP. With respect to the

use of CHP, there are three applicable BAT tests.

1. Use of CHP in circumstances where there are technically and

economically viable opportunities for the supply of heat from the outset.

2. In cases where there are no immediate opportunities for the supply of

heat from the outset, the Environment Agency considers that BAT is to

build the plant to be CHPReady (CHP-R) to a degree which is dictated by

the likely future opportunities which are technically viable and which

may, in time, also become economically viable. The term ‘CHP-R’ in this

context represents a plant which is initially configured to generate

electrical power only but which is designed to be ready, with

minimum modification, to supply heat in the future. The term 'minimum

modification' represents an ability to supply heat in the future without

significant modification of the original plant / equipment. Given the

uncertainty of future heat loads, the initial electrical efficiency of a CHP-

R plant (before any opportunities for the supply of heat are realised)

should be no less than that of the equivalent non-CHP-R plant.


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3. Once an Environmental Permit has been issued for a new CHP-R plant,

the applicant / operator should carry out periodic reviews of

opportunities for the supply of heat to realise CHP. Such opportunities

may be created both by new heat loads being built in the vicinity of the

plant, and / or be due to changes in policy and financial incentives which

improve the economic viability of a heat distribution network for the

plant being CHP.

The Agency has produced a CHP-R Guidance document to help satisfy the

requirements of the second BAT test.

As part of the Environmental Permit application process, TGW2E will

undertake a CHP-R study in accordance with the Agency guidance to satisfy

the requirements of the second BAT test.

3.9 Construction

The construction period is expected to take twelve – fifteen months with a

further six – nine months for equipment installation.

During construction, the workforce is anticipated to range from 50 – 130 staff

dependent on the activities on site, with a maximum workforce of 50 on site

during equipment installation.

To ensure that any mitigation measures contained in this ES are

implemented, the contractor will be required to produce a construction

environmental management plan (CEMP), which will incorporate measures for

inter alia, monitoring construction noise and vibration, protecting air quality

(dust, smoke and odour control), protecting existing services, control of

water pollution, management and control of site waste, ensuring any

biodiversity features are protected, implementation and monitoring and hours

of operation, etc.


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A separate construction logistics plan will also be prepared and submitted to

LBBD before construction commences; this plan will address traffic

management and will also investigate the feasibility of transport of

construction materials by river.

It is expected that the commitment to produce a CEMP and construction

logistics plan will be secured by way of planning condition.


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4 Policy analysis

4.1 Introduction

A detailed policy analysis is included in this section to demonstrate the extent

to which the proposed development contributes to, and is in conformance

with, prevailing policies, aims and guidance. Both energy and waste

management policies are relevant to the proposed development given that it

will utilise waste materials to produce electricity for export to the national

grid.

It is important to note that the principle of the development has clearly

already been established through the granting of the extant planning

consent.

4.2 European policy and legislation

4.2.1 Waste Framework Directive

The revised Waste Framework Directive (2008/98/EC) (WFD) came into force

on 12 December 2008. Member States were required to implement the WFD

by 12 December 2010. The objective of the WFD is to provide a

comprehensive and consolidated approach to the definition and management

of waste. The aims of the WFD are:

To provide a comprehensive and consolidated approach to the definition

and management of waste.

To shift from thinking of waste as an unwanted burden to a valued

resource and make Europe a recycling society.

To ensure waste prevention is the first priority of waste management.

To provide environmental criteria for certain waste streams, to establish

when a waste ceases to be a waste (rather than significantly amending

the definition of waste).


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Article 3 sets out the key WFD definitions (with the exception of the definition

of "by-product", which is set out in detail in Article 5). In particular, the WFD

clarifies the definitions of recovery and disposal to make a clear distinction

between them:

Recovery means any operation, the principal result of which is waste

serving a useful purpose by replacing other materials, which would

otherwise have been used to fulfil a particular function, or waste being

prepared to fulfil that function, in the plant or in the wider economy.

Annex II to the WFD sets out a non-exhaustive list of recovery operations.

Disposal means any operation, which is not recovery, even where the

operation has as a secondary consequence the reclamation of substances

or energy. Annex I to the WFD sets out a non-exhaustive list of disposal

operations.

The list of recovery operations provided in Annex II includes ‘R1 – Use

principally as a fuel to generate energy’.

The proposed development is defined as a recovery operation by the WFD

and is in accordance with its aims.

4.2.2 Industrial Emissions Directive

The recast Directive on Industrial Emissions (2010/75/EU) came into force on

7 January 2011. It combines seven directives, listed below, into one:

the Large Combustion Plant directive (LCPD);

the Integrated Pollution Prevention and Control directive ( IPPCD);

the Waste Incineration directive (WID);

the Solvent Emissions directive (SED); and

the three existing directives on Titanium dioxide on (i) disposal

(78/176/EEC), (ii) monitoring and surveillance (82/883/EEC) and (iii)

programs for the reduction of pollution (92/112/EEC).


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Member states have two years to transpose the directive into national law i.e.

by 6 January 2013; draft regulations, amending the Environmental Permitting

(England and Wales) Regulations 2010, were laid before parliament in

December 2012.

The purpose of the Directive is ‘to achieve a high level of protection for the

environment taken as a whole’ from harmful effects of industrial activities

(Article 1). It does so for many activities by requiring each of the industrial

installations concerned to have a permit from the competent authority.

Permit conditions and pollutant emission limit values therein have to be set

on the basis of the application of best available techniques (BAT).

4.2.3 Renewable Energy Directive

Directive 2009/28/EC on the promotion of the use of energy from renewable

sources requires the UK to source at least 15% of its total energy from

renewables by 2020.

To meet this target, the Government has estimated that renewable sources

will need to contribute:

At least 32% of the UK’s electricity, with one-third of this coming from

biomass, of which waste forms a part.

At least 12% of UK heat requirements. At present this is less than 1%.

The proposed development will contribute to the renewable energy target by

generating electricity from waste.

4.2.4 Landfill Directive

The landfill directive (99/31/EC) requires Member States to draw up

strategies for a reduction in the quantity of biodegradable waste disposed of

to landfill. The landfill directive was introduced in order to prevent, or reduce


Industries Park 26

as far as possible, the negative effects of landfilling waste on the

environment and on human health.

The proposed development would divert a significant amount of waste from

landfill.

4.3 National policy and strategy

4.3.1 Introduction

National planning policy in England changed last year with the publication of

the National Planning Policy Framework (NPPF) on 27 March 2012 and the

consequent revocation of planning policy guidance and planning policy

statements (PPG and PPS). The only PPS still in place is PPS 10: Planning for

sustainable waste management; an updated national waste planning policy

document was out for consultation this summer although PPS10 and the

supporting guidance will remain in effect until it is replaced by the updated

policy and practice guidance respectively3.

4.3.2 The National Planning Policy Framework

The NPPF states that the purpose of planning is to ‘help achieve sustainable

development’ and that ‘development that is sustainable should go ahead,

without delay – a presumption in favour of sustainable development that is

the basis for every plan, and every decision’.

Para. 14 states that at the heart of the NPPF is a ‘presumption in favour of

sustainable development, which should be seen as a golden thread running

through both plan-making and decision-taking.’ For decision-taking this

means, (unless material considerations indicate otherwise):

3 para 11: Updated national waste planning policy: Planning for sustainable waste management. Consultation July 2013


Industries Park 27

Approving development proposals that accord with the development plan

without delay

Where the development plan is absent, silent or relevant policies are out

of date, granting permission unless:

Any adverse impacts of doing so would significantly and demonstrably

outweigh the benefits, when assessed against the policies in the NPPF

taken as a whole or

Specific policies in the NPPF indicate development should be restricted.

The NPPF sets out 12 core planning principles that should underpin both plan-

making and decision-taking. Those relevant to the proposed development

include requirements for planning to:

Proactively drive and support sustainable economic development

Always seek to secure high quality design

Support the transition to a low carbon future in a changing climate and

encourage the use of renewable resources

Contribute to conserving and enhancing the natural environment and

reducing pollution. Allocations of land for development should prefer land

of lesser environmental value

Encourage the effective use of land by re-using brownfield land.

Annex 1 sets out how the NPPF will be implemented. It explains that policies

in the Local Plan should not be considered out of date, simply because they

pre-date the NPPF (para. 211), but that policies contained within the NPPF

are material considerations which need to be taken into account immediately

(para. 212). Decision makers may also give weight to relevant policies in

emerging plans according to (para. 216):

The stage of preparation of the emerging plan with a greater weight given

to later stages

The extent to which there are unresolved objections to relevant policies

(greater weight given, the less significant the objections)


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The degree of consistency of the relevant policies in the emerging plan to

the policies in the NPPF (increased weight for greater consistency)

Under the heading ‘Delivering sustainable development’, the NPPF sets outs

the policies under 13 sections. Those relevant to the proposed development

are as follows:

Policy 1: Building a strong, competitive economy

‘The government is committed to securing economic growth in order to

create jobs and prosperity, building on the country’s inherent strengths,

and to meet the twin challenges of global competition and of a low carbon

future (para. 18)’.

Government is committed to ensuring that the planning system does

everything it can to support sustainable economic growth. Planning

should encourage and not act as an impediment to sustainable growth,

with significant weight placed on the need to support economic growth

through the planning system (para. 19).

The proposed development directly supports this policy through the

creation of employment (section 14.3.1) and the active reduction of

emissions of CO2 (section 13). CO2 savings are due to the displacement of

electricity generation from fossil fuels, the recycling of metals which

avoids them being replaced through energy intensive primary metal

smelting processes as well as the avoidance of landfill gases.

Policy 4: Promoting sustainable transport

All developments that generate significant amounts of movement should

be supported by a Transport Statement or Transport Assessment (para.

32) and required to provide a Travel Plan (para. 36). Where practical,

developments should be located and designed to:

accommodate efficient delivery of goods and supplies,


Industries Park 29

give priority to pedestrians and cyclists,

create safe and secure layouts, incorporate facilities for charging plug-

in and other ultra-low emission vehicles,

consider the needs of people with disabilities (para. 35).

An assessment of the transport implications of the development has been

undertaken and is contained in section 10. A draft travel plan has also

been prepared and is included in Appendix F. The design also includes

provision for charging points for electric vehicles. The needs of people

with disabilities have been considered and inclusive access provision is

discussed in the accompanying Design and Access Statement.

Policy 7: Requiring good design

Good design is a key aspect of sustainable development, indivisible from

good planning and should contribute positively to making places better for

people (para. 56). Planning policies and decisions should aim to ensure

that developments inter alia, function well and add to overall quality of the

area, optimise the potential of the site to accommodate development,

create and sustain an appropriate mix of uses, respond to local character

and history and reflect the identity of local surroundings and materials,

are visually attractive as a result of good architecture and appropriate

landscaping (para. 58).

The layout of the proposed development has been dictated by the

operational requirements of the technology, constraints imposed by pylons

and by the location of the vehicular accesses into the site, which are

already fixed. The appearance of the development is described in detail in

the accompanying Design and Access Statement and a detailed visual

impact assessment has also been undertaken (section 8).


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Policy 10: Meeting the challenge of climate change, flooding and coastal

change

LPAs should recognise the responsibility on all communities to contribute

to energy generation from renewable or low carbon energy sources. LPAs

should inter alia have a positive strategy to promote energy from

renewable / low carbon sources, design policies to maximise renewable /

low carbon energy development while ensuring adverse impacts are

satisfactorily addressed (para. 97). When determining planning

applications, LPAs should not require applicants for energy development to

demonstrate the overall need for renewable or low carbon energy and

recognise that even small-scale projects provide a valuable contribution to

cutting greenhouse gas emissions and approve the application, unless

material considerations indicate otherwise, if its impacts are (or can be

made) acceptable. Once suitable areas for such development are

identified in plans, LPAS should expect subsequent applications for

commercial scale projects outside these areas to demonstrate that the

location meets site selection criteria (para. 98).

New development should be planned to avoid increased vulnerability to

the range of impacts arising from climate change (para. 99).

Development should be directed away from areas at highest risk of

flooding but where development is necessary, it should be made safe

without increasing the risk elsewhere (para. 100). Flood risk assessments

will be required for developments of 1 hectare or greater in Flood Zone 1

and for all proposals for new development, including minor development

and change of use, in Flood Zones 2 and 3 or for an area in Flood Zone 1

which has a critical drainage problems and where the proposed

development may be subject to other sources of flooding (para. 103).

The proposed development directly supports this policy through the

considerable reduction of CO2 emissions, which will result from its

implementation; an energy statement has been prepared which


Industries Park 31

demonstrates the significant savings from the proposed development

(section 13).

A flood risk assessment (FRA) was undertaken to support the application

for the extant consent. TGW2E has incorporated the mitigation measures

described in the FRA into its design and confirms that the proposed

changes in terms of the new technology and site layout will not affect the

findings of the FRA. LBBD confirmed in its scoping opinion (Appendix B)

that flood risk did not need to be addressed in this application.

Policy 11: Conserving and enhancing the natural environment

The planning system should contribute to and enhance the natural and

local environment by:

protecting and enhancing valued landscapes,

recognising the wider benefits of ecosystem services,

minimising impacts on biodiversity and providing net gains where

possible,

preventing both new and existing development from contributing to, or

being put at unacceptable risk from, or being adversely affected by

unacceptable levels of soil, air water or noise pollution or land

instability

remediating and mitigation despoiled, degraded, derelict, contaminated

and unstable land, where appropriate (para. 109).

Planning policies and decisions should encourage effective land use by re-

using previously developed land provided that it is not of high

environmental value (para. 111).

Planning policies and decisions should ensure that:

a site is suitable for its new use taking account of ground conditions

and land instability, including that from natural hazards and former

activities such as mining and pollution from previous uses and any


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proposals for mitigation, including impacts on the natural environment

arising from any remediation

after remediation, as a minimum, the land should not be capable of

being determined as contamination land under Part IIA of the

Environmental Protection Act 1990

adequate site investigation prepared by a competent person is

presented (para. 121).

Planning decisions should aim to avoid noise that gives rise to significant

adverse impacts on health and quality of life as a result of new

development (para. 123).

The proposed development complies with the aims of this policy:

It reuses a former industrial site, which is allocated for a use such as

the proposed development.

A landscape plan has been prepared, which increases the number and

range of habitats present in the immediate area (section 9.4)

A phase 2 site investigation has been undertaken (section 11) which

demonstrates that there are no significant risks to human health for

the site’s end users once the development is completed.

A noise assessment has been undertaken which demonstrates that

there will not be any adverse impacts on health and quality of life

(section 7).

Policy 12: Conserving and enhancing the historic environment

Applicants are required to describe the significance of any heritage assets

affected by the proposed development, including any contribution made

by their setting. The level of detail should be proportionate to the assets’

importance. Where a site includes, or has the potential to include, assets

of archaeological interest, developers will be required to submit an

appropriate desk-based assessment and where necessary a field

evaluation.


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A programme of archaeological investigation was undertaken by TGW2E in

summer 2013 in order to discharge condition 23 of the extant consent

(section 2.3), which found no archaeological remains and concluded that

the site was of limited archaeological potential. LBBD confirmed in its

scoping opinion (Appendix B) that archaeology / heritage did not need to

be addressed in this application.

4.3.3 Planning Policy Statement 10: Planning for sustainable waste management

PPS10 identifies that ‘positive planning’ has an important role to play in

delivering sustainable waste management by inter alia ‘providing sufficient

opportunities for new waste management facilities of the right type, in the

right place and at the right time’. Moving waste management up the waste

hierarchy remains a key objective of Government waste policy in order to

reduce the environmental impact of waste and is therefore included as a key

planning objective in PPS10. Other key objectives include:

Providing a framework for self-sufficiency at the community level;

Helping implement the national waste strategy and supporting targets;

Helping secure the recovery / disposal of waste without endangering

human health or harming the environment and in accordance with the

proximity principle;

Reflecting the concerns and interest of communities.

PPS10 also notes that in determining planning applications, planning

authorities should adhere to the principle that controls under the planning

and pollution control regimes should complement rather than duplicate each

other.

The proposed development complies with the aims of this policy statement; it

would move waste management up the waste hierarchy and would treat

waste without endangering human health or harming the environment.


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4.4 Regional and local policy

4.4.1 Context

At a regional level, the London Plan, published in July 20114, is the overall

strategic plan for London, and sets out a fully integrated economic,

environmental, transport and social framework for the development of the

capital to 2031.

The London Plan forms part of the development plan for Greater London.

Boroughs’ local plans need to be in general conformity with the London Plan,

and its policies guide decisions on planning applications by councils and the

Mayor.

The Barking and Dagenham Local Plan consists of a series of documents.

The Core Strategy, which was adopted in July 2010, sets out the spatial

vision for Barking and Dagenham and a strategy for how this vision will be

achieved. The Development Management Policies Document, the Site Specific

Allocations Document, the Barking Town Centre Area Action Plan and the

Joint Waste Plan support the strategic objectives set out in the Core Strategy.

4.4.2 The London Plan

The vision for London set out in the London Plan is that ‘over the years to

2031 – and beyond, London should: excel among global cities – expanding

opportunities for all its people and enterprises, achieving the highest

environmental standards and quality of life and leading the world in its

approach to tackling the urban challenges of the 21st century, particularly

that of climate change’.

4 On 11 October 2013, the Mayor published Revised Early Minor Alterations to the London Plan (REMA).


Industries Park 35

This vision is supported by six detailed objectives, which link the vision to

detailed policies. Policies are set out in topic specific chapters as follows:

London’s places

London’s people

London’s economy

London’s response to climate change

London’s transport

London’s living places and spaces

Policies relevant to the proposed development are set out below.

Chapter two – London’s places

Policy 2.17 – Strategic industrial locations (SIL) identifies areas, which

will be promoted and managed as London’s principal reservoirs of industrial

and related capacity. Suitable uses include ‘waste management and

environmental industries (such as renewable energy generation)’.

Development proposals in SILs should only be approved if they inter alia are

for an appropriate industrial use and comply with an opportunity area

planning framework or borough development plan document as appropriate.

The proposed development lies in the London Sustainable Industries Park

(LSIP), which is part of the Dagenham Dock Preferred Industrial Location

(PIL). PILs are a class of strategic industrial location, which are particularly

suitable for general industrial, light industrial, storage and distribution, waste

management, recycling, some transport related functions, utilities, wholesale

markets and other industrial related activities.

Chapter four – London’s economy

Policy 4.1 – developing London’s economy states that the Mayor will

work with partners to inter alia drive London’s transition to a low carbon


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economy and to secure the range of benefits this will bring and support and

promote outer London as an attractive location for businesses.

The proposed development directly supports the aims of this policy; it is a

low (negative) carbon development, which will be located in outer London.

Policy 4.10 – new and emerging economic sectors requires that the

Mayor, boroughs, statutory agencies and other stakeholders support the

development of green enterprise districts such as that proposed in the

Thames Gateway.

The proposed development is an emerging sector, located in an area that will

be supported.

Policy 4.12 – improving opportunities for all states that strategic

development proposals should support local employment, skills development

and training opportunities.

The proposed development will create 55 new jobs. TGW2E is committed to

maximising the number of jobs provided from within the local community and

providing appropriate training opportunities and has had discussions with

LBBD to explore ways in which the opportunities can be maximised (section

14.3).

Chapter five – London’s response to climate change

Policy 5.1 – climate change mitigation sets out a target for an overall

reduction in London’s carbon dioxide emissions of 60% (below 1990 levels)

by 2025.

The proposed development results in significant carbon dioxide savings

(section 13) and therefore directly supports the target in this policy.


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Policy 5.2 – minimising carbon dioxide emissions requires that

development proposals make the fullest contribution to minimising carbon

dioxide emissions in accordance with an energy hierarchy:

1. Be lean: use less energy

2. Be clean: supply energy efficiently

3. Be green: use renewable energy

Major developments will have to meet specific targets for carbon dioxide

emissions reduction in buildings5.

It also specifies the required content of energy assessments needed to

accompany major development proposals.

An energy assessment has been undertaken in accordance with GLA guidance

(Appendix J), which demonstrates that the development easily meets the

required target of a 40% improvement on 2010 Building Regulations.

Policy 5.3 – sustainable design and construction requires development

proposals to demonstrate that sustainable design standards are integral to

the proposal, including its construction and operation, and ensure that they

are considered at the beginning of the design process.

Major development proposals should meet the minimum standards outlined in

the Mayor’s supplementary planning guidance and this should be clearly

demonstrated within a design and access statement.

The standards include the following sustainable design principles:

minimising carbon dioxide emissions across the site, including the building

and services (such as heating and cooling systems)

avoiding internal overheating and contributing to the urban heat island

effect

5 expressed as minimum improvements over the Target Emission Rate (TER) outlined in the national

Building Regulations leading to zero carbon non-domestic buildings from 2019


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efficient use of natural resources (including water), including making the

most of natural systems both within and around buildings

minimising pollution (including noise, air and urban runoff)

minimising the generation of waste and maximising reuse or recycling

avoiding impacts from natural hazards (including flooding)

ensuring developments are comfortable and secure for users, including

avoiding the creation of adverse local climatic conditions

securing sustainable procurement of materials, using local supplies where

feasible, and

promoting and protecting biodiversity and green infrastructure.

The BREEAM assessment (Appendix I) and energy assessment (Appendix J)

demonstrate how the proposed development minimises CO2 emissions, avoids

overheating and minimises use of natural resources. Topic-specific

assessments in this Environmental Statement explain how pollution has been

minimised, natural hazards avoided and biodiversity enhanced.

Policy 5.5 – decentralised energy networks contains an expectation for

25% of the heat and power used in London to be generated through the use

of localised decentralised energy systems by 2025.

Although the proposed development will be connected to the grid to export

electricity, there is the potential for power and heat to be supplied to

endusers more locally within the LSIP. Initial discussions have already taken

place with one of the other occupiers on the LSIP who is interested in taking

power from TGW2E through a private wire network.

Policy 5.6 – decentralised energy in development proposals requires

that development proposals evaluate the feasibility of Combined Heat and

Power (CHP) systems, and where a new CHP system is appropriate also

examine opportunities to extend the system beyond the site boundary to

adjacent sites.


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The proposed development has been designed to maximise the conversion of

input energy into electricity and to this end, produces very little waste heat

that can be exported. However, there is a requirement for consideration of

the potential for CHP as part of the Environmental Permit application (section

3.8) and it is recognised that there is a proposed heat transmission network

along Choats Road and so the potential for export of heat will be evaluated in

detail.

Policy 5.7 – renewable energy includes an aim to increase the proportion

of energy generated from renewable sources, thereby enabling projections

for installed renewable energy capacity outlined in the Climate Change

Mitigation and Energy Strategy and in supplementary planning guidance to be

achieved in London.

Within the framework of the energy hierarchy (Policy 5.2), major

development proposals should provide a reduction in expected carbon dioxide

emissions through the use of on-site renewable energy generation, where

feasible.

The purpose of the proposed development is to generate energy from waste.

Policy 5.8 – innovative energy technologies encourages the more

widespread use of innovative energy technologies to reduce use of fossil fuels

and carbon dioxide emissions, which includes ‘the uptake of advanced

conversion technologies such as … gasification … for the treatment of waste’.

The proposed development utilises gasification, which is specifically referred

to in this policy.

Policy 5.10 – urban greening requires that development integrate green

infrastructure into the design, which may include tree planting, green roofs

and walls and soft landscaping.


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A landscape plan has been developed which includes tree planting and soft

landscaping (section 9.4).

Policy 5.11 – green roofs and development site environs requires that

major development proposals should be designed to include roof, wall and

site planting, especially green roofs and walls where feasible, to deliver as

many of the following objectives as possible:

adaptation to climate change (i.e. aiding cooling)

sustainable urban drainage

mitigation of climate change (i.e. aiding energy efficiency)

enhancement of biodiversity

accessible roof space

improvements to appearance and resilience of the building

growing food.

The proposed development utilises sustainable urban drainage techniques

and is highly energy efficient. A landscape plan has been designed which

enhances biodiversity and improves the appearance of the development.

Policy 5.12 – flood risk management requires that developments comply

with the flood risk assessment and management requirements set out in the

NPPF and have regard to measures proposed in Thames Estuary 2100

(TE2100 – see paragraph 5.55) and Catchment Flood Management Plans.

The development complies with the flood risk assessment requirements set

out in the NPPF as described in section 4.3.2 above. In the event of a flood,

a safe haven can be provided for all personnel / visitors on site on the first

floor of the office building.

Policy 5.13 – sustainable drainage requires that developments utilise

sustainable urban drainage systems (SUDS) wherever practicable, and should

aim to achieve greenfield run-off rates and ensure that surface water run-off

is managed in accordance with a specified drainage hierarchy.


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The proposed development includes surface water storage on site with run-off

rates restricted in accordance with the measures set out in the flood risk

assessment (section 12).

Policy 5.16 – waste self-sufficiency aims to manage as much of London’s

waste within London as practicable, working towards the equivalent of 100%

of London’s waste within London by 2031 whilst also creating positive

environmental and economic impacts from waste processing and working

towards zero biodegradable or recyclable waste to landfill by 2031.

The proposed development will take waste from London (section 5), thereby

contributing to the target of set out in this policy and also creating positive

environmental and economic impacts from waste processing.

Policy 5.17 – waste capacity states that the Mayor supports the need to

increase waste processing capacity in London and sets out criteria against

which development proposals should be evaluated as follows:

locational suitability

proximity to the source of waste

the nature of activity proposed and its scale

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

the environmental impact on surrounding areas, particularly noise

emissions, odour and visual impact and impact on water resources

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.

The policy also lists developments that will be supported and includes:

developments that contribute towards renewable energy generation, in

particular the use of technologies that produce a renewable gas


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developments for producing renewable energy from organic/biomass

waste.

Wherever possible, opportunities should be taken to provide combined heat

and power and combined cooling heat and power.

Boroughs are required to allocate sufficient land and identify waste

management facilities to provide capacity to manage the tonnages of waste

apportioned in this Plan. Land to manage borough waste apportionments

should be brought forward through ‘…identifying sites in strategic industrial

locations’.

Waste is deemed to be managed in London if it is used for energy recovery in

London, or it is compost or recyclate sorted or bulked in London material

recycling facilities for reprocessing either in London or elsewhere.

In terms of the criteria listed in this policy, the proposed development is in a

suitable location, will treat London’s waste within London, has a positive

carbon outcome and does not have any significant adverse effects on

surrounding areas. The development is also of a type that is supported by

this policy and is to be located on land specifically identified for waste

management which has an extant planning consent for an identical use.

Policy 5.21 – contaminated land supports the remediation of

contaminated sites.

The site and surrounding area has been the subject of extensive desk-based

and intrusive investigations. The site has been remediated and mitigation

measures recommended to address any remaining contamination (section

11) and therefore the proposed development complies with this policy.


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Chapter six – London’s transport

Policy 6.3 – assessing effects of development on transport capacity

requires that development proposals ensure that impacts on transport

capacity and the transport network, at both a corridor and local level, are

fully assessed with transport assessments undertaken in accordance with TfL

Guidance for major planning applications. Travel plans, construction logistics

plans and delivery and servicing plans should be secured in line with the

London Freight Plan.

The transport implications of the development have been assessed in section

10 and a draft travel plan prepared (Appendix F). It is assumed that a

construction logistics and deliveries and servicing plan will be secured by way

of condition.

Policy 6.9 – cycling requires that developments should inter alia provide

secure, integrated and accessible cycle parking facilities in line with specified

minimum standards, and on-site changing facilities and showers for cyclists

with the aim of encouraging and promoting cycling in London.

The development will provide secure cycle parking facilities for twenty cycles.

Changing facilities and showers for staff are provided.

Policy 6.13 – parking standards sets out the maximum number of car

parking spaces and minimum numbers of spaces for cycles, disabled places

and electric vehicle charging points to be provided in developments.

The number of parking spaces proposed at eighteen is in line with this policy,

whilst the number of cycle places provided (twenty) slightly exceeds the

minimum requirement of one space / 500m2 floorspace (eighteen spaces

required). Disabled places and electric vehicle parking points comply with the

requirement set out in the policy, with two disabled spaces and six for electric

vehicles (four active and two passive) respectively.


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Chapter seven - London’s living places and spaces

Policy 7.6 – architecture requires that architecture make a positive

contribution to a coherent public realm, streetscape and wider cityscape,

incorporating the highest quality materials and design appropriate to its

context.

Buildings and structures should:

be of the highest architectural quality

be of a proportion, composition, scale and orientation that enhances,

activates and appropriately defines the public realm

comprise details and materials that complement, not necessarily replicate,

the local architectural character

not cause unacceptable harm to the amenity of surrounding land and

buildings, particularly residential buildings, in relation to privacy,

overshadowing, wind and microclimate. This is particularly important for

tall buildings

incorporate best practice in resource management and climate change

mitigation and adaptation

provide high quality indoor and outdoor spaces and integrate well with the

surrounding streets and open spaces

be adaptable to different activities and land uses, particularly at ground

level

meet the principles of inclusive design

optimise the potential of sites

The accompanying design and access statement explains how the proposed

development meets the requirements of this policy.

Policy 7.8 heritage assets and archaeology requires development

proposals to identify, value, conserve, restore, re-use and incorporate

heritage assets, where appropriate and make provision for the protection of

archaeological resources, landscapes and significant memorials.


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A programme of archaeological investigation has been undertaken, which

found no archaeological remains and concluded that the site was of limited

archaeological potential. LBBD confirmed in its scoping opinion (Appendix B)

that archaeology / heritage did not need to be addressed in this application.

Policy 7.14 improving air quality requires development proposals to:

promote sustainable design and construction to reduce emissions from the

demolition and construction of buildings following best practice guidance

be at least ‘air quality neutral’ and not lead to further deterioration of

existing poor air quality (such as areas designated as Air Quality

Management Areas (AQMAs)).

ensure that where provision needs to be made to reduce emissions from a

development, this is usually made on-site.

provide a detailed air quality assessment and forecast pollutant

concentrations where required.

A detailed air quality assessment has been undertaken (section 6), which

demonstrates that the maximum predicted concentrations of all substances

comply with relevant air quality objectives at nearby sensitive locations and

the impact of the proposed development is considered to be insignificant.

A Construction and Environmental Management Plan (CEMP) will be

produced, which will detail measures to control air quality during the

construction period (section 3.9).

Policy 7.15 – reducing noise and enhancing soundscapes seeks to

reduce the potential adverse impacts of noise from development proposals

through design, location, screening and promotion of new technologies and

improved practices to reduce noise at source.

A noise assessment has been undertaken (section 7) which demonstrates

that the proposed development will not have any adverse impacts on the

nearest residential receptors.


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Policy 7.19 – biodiversity and access to nature requires that wherever

possible, developments should not adversely affect protected sites / species

and should make a positive contribution to the protection, enhancement,

creation and management of biodiversity with a focus on assisting the

achievement of targets in biodiversity action plans (BAPs).

Section 9 demonstrates that the proposed development will not adversely

affect protected species or sites. The proposed landscape plan will create

new habitats on the site, with a focus on selecting species in the wildflower

mixes to support identified priority invertebrate species (section 9.4).

Policy 7.26 - increasing the use of the Blue Ribbon Network for

freight transport requires that development proposals close to navigable

waterways should maximise water transport for bulk materials, particularly

during demolition and construction phases.

Waste for processing at the proposed development will be delivered from a

number of sources in the London area, including from a facility within 5 km of

the proposed development, and it is therefore not practicable to use the

water network during operation. Detailed consideration will be given to the

potential use of the water network for delivery of certain bulk construction

materials or key items of plant during the detailed design phase.

4.4.3 The Barking and Dagenham Core Strategy

The Core Strategy contains thirteen strategic objectives and a spatial

strategy built around five themes: Managing Growth; Sustainable Resources

and the Environment; Creating a Sense of Community; Ensuring a Vibrant

Economy and Attractive Town Centres; and Creating a Sense of Place.

Policies relevant to the proposed development are set out below.


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Managing growth

Policy CM1 – general principles for development notes that employment

growth will be focussed on Dagenham Dock.

The proposed development lies within the Dagenham Dock area.

Sustainable resources and the environment

Policy CR1 – climate change and environmental management sets out

measures to contribute towards global, national, regional and local

sustainability, and in particular to address the causes and potential impacts

of climate change. These measures include:

Requiring all new development to meet high environmental building

standards and encourage low and zero carbon developments.

Promoting sustainable waste management.

Protecting water and air quality.

Promoting the remediation of contaminated land.

The proposed development complies with this policy as follows:

It is a low carbon development, which meets BREEAM excellent (section

13)

It promotes sustainable waste management by recovering energy from

waste generated in the local area

The enclosed nature of the process (section 3.7) and emissions control

systems ensure that there are no significant adverse impacts on air /

water quality (section 6 and section 12 respectively).

The remaining pollutant linkages resulting from in-ground contamination

will be removed (section 11).

Policy CR3 – sustainable waste management states that the Borough

will seek to manage waste in a sustainable way and to help achieve national

targets through prioritising waste reduction, re-use, recycling and


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composting, new and emerging recovery technologies and conventional

incineration over landfill, which will only be considered acceptable as a last

resort.

Appropriate existing waste management capacity will be safeguarded and

preferred sites identified for new facilities as set out in the Joint Waste DPD.

The proposed development complies with the aims of this policy and is to be

located on a safeguarded site as identified in the Joint Waste DPD.

Policy CR4 - flood management contains a presumption against

development that places people and property at risk from flooding, or which

would have an adverse impact on watercourses.

A Flood Risk Assessment will be required for all proposals for new

development in flood zones 2 (medium probability) and 3 (high probability).

The development lies in flood zone 3 but an FRA has already been

undertaken in relation to the extant consent, and LBBD has confirmed that no

further consideration of flood risk is required; the proposed development

complies with the mitigation measures set out in the FRA (section 12).

Ensuring a vibrant economy and attractive town centres

Policy CE3 – safeguarding and release of employment land states that

the Council will safeguard, promote and manage the Strategic Industrial

Locations at … Dagenham Dock. Land within these locations will not be

released for other purposes.

The proposed development is specifically identified as a suitable enduse for

SIL land in Dagenham Dock.

Policy CE4 – mix and balance of uses within designated employment

areas states that proposals to establish recycling and reprocessing activities

and other industries in the environmental business sector are particularly


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encouraged within the Dagenham Dock area which will be developed and

promoted as a Sustainable Industries Park.

The proposed development is within the environmental business sector and

will enable the recovery of high quality metals from the process.

Creating a sense of place

Policy CP3 – high quality built environment sets out requirements for

high quality standards in relation to the design and layout of new buildings

and spaces.

Requirements relevant to the proposed development are as follows:

New developments should achieve a high standard of inclusive design. It

should be legible, usable and permeable, and accessible to all those who

may need to use them.

The safety of occupants, visitors and passers-by should be considered in

the design of all development, and all reasonable efforts taken in the

design and planning processes to prevent crime and minimise fear of

crime. This should be undertaken in liaison with the Council’s crime

prevention design officer.

All new development should conform to the highest standards of

sustainable design.

Development should respect and strengthen local character and history

and provide a sense of place.

Buildings and spaces should be functional, durable, flexible and adaptable.

Inclusive design and sustainability are discussed in the accompanying design

and access statement. Safety of all people visiting and working at the site

has been a key consideration in the development of the layout. Crime

prevention has been considered in the specification of the fencing (a taller

fence on the northern boundary for example) and in requirements for CCTV


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and lighting. The site will be operational and manned 24 hours / day, which

will reduce opportunities for crime.

4.4.4 Supplementary planning guidance

Green infrastructure and open environments: The all London green grid

The All London Green Grid (ALGG) SPG aims to promote green infrastructure

in the form of a ‘green grid’ – an integrated network of linked green and open

spaces together with the Blue Ribbon Network of rivers and waterways across

London.

The Epping Forest and Roding Valley Green Grid Area (GGA) includes two

strategic links in the vicinity of the proposed development; the Goresbrook

Link and the London Riverside Link.

4.4.5 Barking and Dagenham borough-wide development policies DPD

The borough-wide development policies development plan document (DPD)

was adopted in March 2011 and contains detailed policies that build on the

content of the Core Strategy (section 4.4.3) and London Plan (section 4.4.2)

above.

Policies are set out in chapters under the same headings as the core

strategy; those directly relevant to the proposed development are

summarised below.

Sustainable resources and the environment

BR1 – environmental building standards states that all developments are

expected to meet high standards of sustainable design and construction.

Applicants for all major and strategic developments must produce an

environmental assessment such as the Building Research Establishment’s

Environmental Assessment Method (BREEAM).


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Minimum standards for non-housing development under BREEAM are very

good – excellent for major development.

The policy notes that there may be exceptional circumstances, for example

due to economic viability, where achieving targets in this policy is not

appropriate.

A BREEAM assessment has been undertaken (section 13), which

demonstrates that the proposed development achieves a rating of excellent.

BR2 – energy and on-site renewables sets out requirements for major

and strategic development to demonstrate in an energy assessment that

heating, cooling and power systems have been selected to minimise CO2

emissions.

An energy assessment has been undertaken (Appendix J), which

demonstrates that CO2 emissions are minimised in accordance with this

policy.

BR3 – greening the urban environment states that where there are no

existing features of nature conservation on a site, development should seek

to create nature conservation enhancements to help ‘green the urban

environment’.

Examples of enhancements include the provision of green walls, bio-diverse

green roofs, wildlife gardens, buffer strips, nesting, and roosting boxes and

commitment to the implementation of a Habitat Management Plan.

The landscape plan prepared for the proposed development creates a number

of new habitats on the site, with a focus on selecting species to support

identified priority invertebrate species. It includes wildlife gardens, nesting

and roosting boxes and a five-year ecological mitigation and maintenance

plan (EMMP) will be produced (section 9.4).


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BR4 – water resource management requires development to ensure that

greenfield surface water run-off rates are achieved, where possible, through

the use of SUDS. New development will be expected to achieve a high

standard of water efficiency, by incorporating appropriate measures to

minimise water use.

The drainage strategy for the proposed development has been designed to

comply with the overall site drainage strategy for the LSIP. The surface

water discharge rate from the site has been limited to a greenfield rate as

agreed with the Environment Agency. The SUDS strategy is based upon

attenuated surface water to final discharge into public sewer incorporating

rainwater harvesting for use on site where possible (section 12).

BR5 - contaminated land states that development on or near land that is

known to be contaminated or which may be affected by contamination will

only be permitted where an appropriate site investigation and risk

assessment (agreed by the local planning authority) has been carried out.

If contamination is found which would pose an unacceptable risk, the Council

will impose a condition to ensure the applicant undertakes appropriate

remedial measures to ensure that the site is suitable for the proposed end

use and the development can safely proceed.

A site investigation has been undertaken (section 11), which demonstrates

that small number of pollutant linkages that exist will be removed by the

development and that there are no significant risks to human health for the

site’s end users once the development is completed

BR9 – parking states that the car and cycle parking standards set out in the

London Plan and TfL guidance will be used.

Parking has been provided in accordance with the relevant standards.


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BR10 – sustainable transport requires developers to submit a transport

statement where there are any identifiable transport impacts or a transport

assessment and a travel plan where there are significant transport

implications (in accordance with the London Plan).

The transport impacts of the proposed development have been assessed

(section 10) and a draft travel plan prepared.

BR11 – walking and cycling requires that the design and layout of new

development take account of the needs of cyclists and walkers by providing

inter alia:

Safe, secure, convenient, accessible and direct access for pedestrians and

cyclists to, from and within development.

Sufficient, convenient, safe, secure and where possible integrated, cycle

parking facilities.

Provision of safe walkways and cycleways, segregated from HGV traffic has

been a key consideration in the development of the layout. Cycle storage is

in two locations in the proposed development; adjacent to the office entrance

for office-based staff and adjacent to the materials reception building for

operational employees.

BR13 – noise mitigation states that if it is not possible to fully separate

noise sensitive and noise generating land uses, planning permission will only

be granted if there will be no exposure to noise above an acceptable level.

Measures should be taken to minimise noise and mitigate its impact in

accordance with the London Plan.

A noise assessment has been undertaken which demonstrates that the

proposed development will have no adverse impact on the nearest offsite

sensitive receptors.


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BR14 - air quality requires the submission of an air quality impact

assessment if a development is likely to have a significant negative impact on

air quality.

Permission will only be granted where mitigation measures are introduced

which bring the levels of air pollution to an acceptable level.

An air quality assessment has been undertaken (section 6), which

demonstrates that the development will not have a significant negative

impact on air quality.

BR15 - sustainable waste management sets out a series of measures by

which sustainable waste management will be achieved, which includes:

Using waste as a resource, including for the generation of energy,

wherever possible.

Prioritising waste management according to the waste hierarchy

Ensuring all waste is handled in the most sustainable manner, without

endangering human health or harming the natural environment.

Ensuring sufficient and timely provision of waste management facilities in

appropriate locations, including for waste disposal, to meet the needs of

communities and accommodate waste management capacity requirements

for at least the next 10 years.

Ensuring new waste management facilities do not detract from the quality

or character of distinct areas.

The proposed development uses waste as a resource for the generation of

energy. The topic-specific assessments in this EIA demonstrate that there

will be no harm to human health or the natural environment as a result of

the development. The visual impact assessment demonstrates that it will

not detract from the quality of character of the area.


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Creating a sense of place

BP8 – protecting residential amenity requires that developments have

regard to the local character of an area and ensure that existing and

proposed occupiers are not exposed to unacceptable levels of pollution,

disturbance or significant overshadowing.

The design of the proposed development is described in the accompanying

Design and Access Statement; key features such as the concealment of

pitched roofs behind a parapet reflects the design on previously consented

developments in the LSIP. Detailed topic-specific assessments in subsequent

chapters demonstrate that the proposed development would not lead to

significant offsite impacts on air quality, noise, shadowing etc

BP11 – urban design sets out a series of principles that new developments

need to address in both layout and design. These principles include

requirements for high quality architecture and landscaping, accessible and

inclusive features, safe environments, sustainable design and construction

features, and integration of renewable energy features.

The accompanying design and access statement, visual impact assessment,

landscape scheme and energy assessment all show that the development

addresses the required principles.

4.4.6 Statement of community involvement

LBBD’s Statement of Community Involvement (SCI) sets out the Council’s

policy for involving communities in the planning process, both in the

preparation of planning documents and in considering applications for

planning permission.

Minimum standards for consultation for applications accompanied by an

Environmental Statement comprise advertisement in the local newspaper and

a site notice or neighbour notification.


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The Council encourages developers to engage in pre-application discussions

on proposals before submitting a planning application.

Applicants are also encouraged to engage in pre-application consultation with

the community, particularly for applications, which may have an impact on

the local community.

Developers should ensure the Council is aware that consultation is being

undertaken, and should disseminate the results including details of what

involvement was carried out and who was involved.

Detailed discussions have taken place with LBBD and the GLA throughout the

preparation of the planning application.

A community exhibition was held on 10 December at Barking Learning

Centre. A notice was placed in the Barking and Dagenham Post and fliers

advertising the event sent to some 765 properties. A summary of the event

is given in Appendix K.

4.4.7 The East London Joint Waste DPD

The joint waste development plan document (DPD) for the four East London

Waste Authority (ELWA) boroughs (Barking and Dagenham, Havering,

Newham and Redbridge) was adopted by LBBD in February 2012.

The Joint Waste DPD is part of each borough’s Local Plan / Local

Development Framework, however it differs from other borough DPDs as it

sets waste management targets and allocates sites suitable for waste

development for implementation across all of the four boroughs. Each of the

four ELWA borough core strategies contains a strategic policy, which sets the

framework for the joint waste DPD.

The vision for the East London Joint Waste DPD is that it ‘aims to manage

waste produced in the boroughs of Barking and Dagenham, Havering,


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Newham and Redbridge in line with the growth set out in the boroughs’

adopted and emerging Local Development Framework Core Strategies … and

identifies required levels of waste management capacity, which can be

delivered by 2021 … Boroughs will work with the Mayor of London to deliver

his aspiration that no untreated waste will go directly to landfill, as set out in

London’s emerging Waste Strategy. The Joint Waste Plan will deliver

sustainable development by addressing waste as a resource without

endangering health or harming the environment. In dealing with waste,

boroughs will ensure that well designed, high quality waste facilities are

developed, including the promotion of green industries, which integrate with

and complement opportunities for regeneration across East London’.

The Joint Waste DPD has eight objectives, as follows:

A. Deliver sustainable development by driving waste management up the

waste hierarchy, addressing waste as a resource and looking to disposal

as the last option, while recognising that disposal must be adequately

catered for.

B. Work towards meeting targets set out in the Waste Strategy for England

2007, and the London Plan.

C. Enable the provision of a range of waste technologies.

D. Enable the provision of facilities to allow for net self-sufficiency in the

ELWA boroughs in accordance with the London Plan.

E. Enable waste to be managed in one of the nearest appropriate

installations without endangering health or harming the environment.

F. Integrate waste planning with other spatial concerns, including

regeneration plans.

G. Reverse the historical trend of the ELWA area being the dumping ground

for London’s waste.

H. Encourage our communities to take more responsibility for their waste.

The proposed development is in accordance with these objectives. It drives

waste management up the hierarchy by enabling energy to be recovered

from waste, which would otherwise be landfilled, and for valuable recyclables


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to be recovered from that waste. It will help to meet policy targets for

recovery, enable waste to be managed in a local installation and will bring a

new waste technology to the ELWA area.

Policy W2 - waste management capacity, apportionment and site

allocation sets out the two measures by which the ELWA boroughs will meet

their London Plan apportionment:

Safeguarding the capacity of existing waste management facilities listed in

Schedule 1 and encouraging increased processing of waste at these

facilities

Approving strategic waste management facilities where it will contribute to

the ELWA boroughs meeting the London Plan apportionment on sites

within the locations listed in Schedule 2.

In all cases applications will be required to meet the relevant borough design

guidance and Policy W5.

The LSIP is specifically identified as a safeguarded site suitable for waste

management uses in Schedule 2 of the Waste DPD. Furthermore, the extant

consent application is specifically referred to in Schedule 2. The development

is a strategic waste management facility, which will significantly contribute to

London Plan apportionment.

Policy W3 - energy recovery facilities states that applications for

advanced treatment technologies will only be considered where the waste

cannot practicably and reasonably be reused, recycled or processed and

where there is provision for energy recovery and co-location with

complementary facilities. Facilities will be required to meet relevant design

guidance and requirements of Policy W5.

The residual waste to be treated by the proposed development is currently

landfilled; there are no suitable processing facilities for this residual waste

and energy recovery is the most appropriate treatment option. The proposed

development will further enable recovery of recyclable materials from the


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waste after processing. The LSIP has been developed to encourage and

promote green economy businesses to the area and it will therefore be co-

located with complementary facilities.

Policy W5 - General considerations with regard to waste proposals

states that planning permission will only be granted where it can be

demonstrated that there are no significant adverse impacts on people, land,

infrastructure and resources. The policy also sets out information that may

be required to accompany a planning application dependent on the proposals

and its location.

The topic-specific assessments in this ES demonstrate that there are no

significant adverse impacts that would result from the proposed

development.

4.5 Issue-specific policy analysis

The policy analysis above has considered the extent to which the proposals

comply with relevant policies assessed on a plan-by-plan basis. This section

groups the analysis under a series of key issue headings.

4.5.1 Land use

The site is specifically allocated for industrial development as a strategic

industrial location (Policy 2.17 London Plan and Policy CE3 LBBD Core

Strategy) and a suitable use of the site is further defined as ‘waste

management and environmental industries (such as renewable energy

generation)’. Policy CE4 of the LBBD Core Strategy specifically encourages

environmental sector businesses in the Dagenham Dock area whilst Policy W2

of the Joint Waste DPD specifically identifies the LSIP as a safeguarded site

with specific reference to the extant consent in Schedule 2.

The proposed development is therefore an appropriate use of the site that is

fully in accordance with policy.


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4.5.2 Economy

Policy 1 NPPF commits to ensuring the planning system does everything

possible to support sustainable economic growth and to meet the challenges

of inter alia a low carbon future. The proposed development directly supports

this policy; not only does it create a significant number of new jobs but these

jobs will themselves directly contribute to a low carbon future. At a local

level, London Plan Policies 4.1 and 4.12 and LBBD Core strategy SO.5

encourage local employment opportunities whilst LBBD Core Strategy Policy

CM1 states that employment opportunities in the borough will be focussed on

Dagenham Dock and London Plan policy 4.10 requires that green enterprise

districts such as Thames Gateway are supported. TGW2E has committed to

working with LBBD and Dagenham college to maximise local employment and

training opportunities.

4.5.3 Climate change, renewable energy and decentralised energy

Various policies state a presumption in favour of, or at the very least

encourage, renewable energy schemes (Policies 1 and 10 NPPF, London Plan

policies 5.7 and 5.8, policy CR1 LBBD core strategy) and require

developments to minimise carbon dioxide emissions (Policies 5.1 and 5.2

London Plan, policy BR2 LBBD DPD) whilst London Plan policies 5.5 and 5.6

set targets for decentralised energy and require the consideration of

combined heat and power (CHP) in development proposals.

The proposed development will generate renewable energy from waste which

would otherwise be landfilled and is therefore directly supported by these

policies. The energy statement (Appendix J) demonstrates the significant

carbon dioxide (CO2) savings that result from the development. The

proposed development has been designed to maximise electricity production

but the potential for heat export will be kept under review.


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4.5.4 Waste management

London Plan policy 5.16 seeks to manage as much of London’s waste within

London as practicable. London Plan policy 5.17, LBBD Core Strategy Policy

CR3, LBBD DPD Policy BR15 and Joint Waste DPD Policies W2, W3 and W5

relate to sustainable management of waste in accordance with the proximity

principle and the waste hierarchy, support the need for new waste

management infrastructure and set out measures against which waste

development proposals will be assessed. Under London Plan policy 5.17,

boroughs are required to identify and safeguard sufficient land to manage

their waste apportionment under the London Plan.

The proposed development will help to reduce the amount of London’s waste

that is sent outside the capital for final treatment (section 5). It will treat

residual waste, which would otherwise be landfilled, and will enable the

recovery of valuable recyclables and is therefore in accordance with the

waste hierarchy. The location is on a site safeguarded for such as use in the

Joint Waste DPD.

4.5.5 Design and appearance

Policy 7 NPPF, Policies 5.3 and 7.6 in the London Plan, Policy CP3 LBBD Core

Strategy and Policy BR1 and BP8 LBBD DPD all relate to design and require

developments to accord with principles of sustainability in design as well as

set out general design criteria against which applications will be assessed.

The design philosophy of the development is addressed in the accompanying

Design and Access Statement.

The overall layout of the development has been driven by the need to

maximise utilisation of the site for the range of uses proposed and to ensure

appropriate segregation of HGV traffic on site and the safety of all working /

visiting. Within these constraints, careful thought has been given to

maximising the amount of landscaping that can be provided and ensuring


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that the landscaping enhances biodiversity through the creation of new

habitats.

Given the size of the proposed development it has not been possible to

completely eliminate its visual impact (section 8) although the use of

landscaping and surface treatments goes someway to ameliorating the

impact.

A BREEAM pre-assessment has been undertaken which confirms that the

development should achieve an ‘excellent rating (section 13).

4.5.6 Ecology and nature conservation

There is a raft of policies which seek to ensure that new development

provides appropriate landscaping and new biodiversity features and protects

or enhances existing features and designated sites where appropriate (e.g.

Policy 11 NPPF, policies 5.10, 5.11 and 7.19 London Plan, policy BR3 LBBD

DPD).

A detailed scheme has been prepared which adds new biodiversity features

and complements and enhances the existing landscaping on the wider LSIP

(section 9). An ecological mitigation and management plan will be prepared

and it is assumed that long-term management of the landscaped areas on

site will be secured by an appropriate planning condition.

The air quality assessment has included consideration of designated sites

around the proposed development and has demonstrated that there is no

impact on any of the sites from emissions from the stack (section 6).

4.5.7 Traffic and transport

Policy 4 NPPF, policies 6.3, 6.9 and 6.13 in the London Plan, policies BR9,

BR10 and BR11 in the Barking and Dagenham DPD require the transport

implications of developments to be appropriately considered and addressed


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with an emphasis on reducing the need to travel where possible. London

Plan policy 7.26 requires water transport is considered for proposals close to

navigable waterways; given the origin of the infeed material, use of nearby

wharves is not appropriate for the operational phase but will be investigated

for construction. An assessment has been undertaken which has

demonstrated that the network can accommodate the demand from the

development (section 10). The nature of the proposed development is such

that it is not practical for travel to be reduced by measures such as e.g.

working from home. A draft travel plan has been prepared (Appendix F)

however, which focuses on encouraging travel by more sustainable means; it

is expected that implementation and on-going monitoring of the travel plan

would be secured by way of condition.

4.5.8 Pollution

Various policies (e.g. policy 11 NPPF, London Plan policies 5.21, 7.14 and

7.15, Policies BR5, BR13, BR14, BP8 in the LBBD DPD) relate to pollution in

the widest sense i.e. encompassing air quality, noise, soil, water etc. and the

desire to prevent new development from contributing to unacceptable levels

of pollution.

A range of detailed assessments have been undertaken and are described in

subsequent sections and demonstrate that the development will not have a

significant adverse impact on any off-site receptors e.g. potentially sensitive

land uses such as nature conservation sites, ground and surface waters,

residential receptors etc.

4.5.9 Water resources

Policies 10 NPPF, 5.12 London Plan, and CR4 LBBD core strategy and all

relate to development in areas at risk of flooding or development that would

increase the risk of flooding elsewhere. Policy 5.13 London Plan and BR4

LBBD DPD require that developments use sustainable drainage systems

(SUDS) where possible and reduce runoff to greenfield rates. A strategic


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level FRA was undertaken for the whole of the LSIP and mitigation measures

defined; the proposed development is in accordance with the strategic FRA

and the drainage strategy incorporates SUDS measures and restricts runoff to

agree rates (section 12).


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5 Land use

5.1 Introduction

This section considers the need for the proposed development in terms of the

amount of waste generated in London, current and proposed treatment

options and capacity in London and, more specifically, the east London area

and policy aims and targets for the management of London’s waste going

forward to 2031.

5.2 Context

The proposed development will generate some 19 MW of electricity from up

to 180,000 tonnes of residual commercial and industrial (C&I) waste, which

would otherwise be landfilled.

Residual waste is that portion of the waste stream that is not reused,

recycled or composted and remains to be treated through the recovery of

energy and / or materials or through disposal to landfill. Residual waste will

have undergone some form of segregation, recycling and processing to

remove recyclable materials.

Policy 5.16 of the London Plan relates to waste self-sufficiency and sets out

strategic aims to inter alia manage as much of London’s waste within London

as practicable, work towards managing the equivalent of 100% of London’s

waste within London by 2031 and work towards zero biodegradable or

recyclable waste to landfill by 2031.

However, London currently exports a significant amount of waste generated

within its boundaries. The Environment Agency estimates that of the 6.6

million tonnes of London’s waste that was landfilled in 20086, some 5.6

6 This figure includes commercial and industrial, construction, demolition and excavation and municipal waste


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million tonnes (85%) was transported outside of the region to the south east

and east of England. Of the total landfilled, around 48% is unsegregated,

mixed waste.

5.3 East London Waste Authority projected arisings and apportionment

Table 5.2 in the London Plan gives municipal and C&I waste projections at

Borough level at key milestones through to 2031 as shown in the excerpt for

the four ELWA Boroughs contained in Table 1 below.

Table 1: London Plan projected waste arisings at key milestones

Borough 2011 2016 2021 2026 2031

MSW C&I MSW C&I MSW C&I MSW C&I MSW C&I

Barking & Dagenham 103 74 113 72 123 75 133 79 141 81

Havering 135 132 143 130 152 126 160 126 168 125

Newham 154 123 170 123 186 124 202 124 215 127

Redbridge 123 114 128 109 134 104 139 98 143 95

Total 958 988 1024 1061 1095

Table 5.3 in the London Plan then apportions waste to be managed in London

across all the boroughs. The amounts to be managed by the ELWA boroughs

are as shown in Table 2 below.

Table 2: London Plan apportionment of waste to be managed by ELWA boroughs

Borough Apportion-

ment1

2011 2016 2021 2026 2031

MSW C&I MSW C&I MSW C&I MSW C&I MSW C&I

Barking &

Dagenham

6.1 159 283 194 309 230 336 270 366 309 399

Havering 4.0 105 187 128 204 152 222 178 241 204 263

Newham 4.9 129 229 156 249 186 272 218 296 250 323

Redbridge 1.9 49 87 60 95 71 104 83 113 95 123

Total 1,228 1,395 1,573 1,765 1,966

1: % share of waste to be managed in London

London Plan Policy 5.17 requires the Joint Waste DPD to identify sufficient

land to provide capacity to manage the apportioned tonnages of municipal

solid waste (MSW) and commercial and industrial (C&I) waste. Waste is


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deemed to be managed in London if it is used for energy recovery in London,

or it is compost or recyclate sorted or bulked in London material recycling

facilities for reprocessing either in London or elsewhere.

Taking into account the reduced apportionment in the London Plan (2011),

Policy W2 of the joint waste DPD sets out that the ELWA boroughs will need

to provide sufficient waste management capacity for municipal and

commercial and industrial waste as follows:

1.228 million tonnes in 2011

1.395 million tonnes in 2016

1.573 millions tonnes in 2021

Table 2 of the Joint Waste DPD lists existing waste management capacity in

the ELWA area7. There is one facility listed under incineration taking clinical

waste with an annual permitted tonnage of 7,000 tonnes, which translates as

a throughput of 5,250 tonnes8.

The number and mix of facilities that will be required within the ELWA area is

dependent not only on the amount of waste that will require treatment but

also how it is treated.

Targets for recycling, composting, recovery etc are set in Waste Strategy

2000 and the London Plan. Additionally, the ELWA boroughs have planned on

the basis that waste which is not recycled or composted is recovered and

therefore no waste will go to landfill. Based on this approach for the

management of waste in the ELWA area, and the existing waste management

capacity, the ELWA boroughs need to provide capacity as summarised in

7 Date is not given but assumed to be 2011 8 It is generally accepted that most facilities are licensed for a throughput in excess of what they achieve in practice. As there is considerable uncertainty surrounding actual throughput and little available data, the Joint Waste DPD Technical Report uses an estimate for actual throughput of 75% of maximum available capacity to maintain consistency with data used in the London Plan.


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Table 3 below in order to manage the apportionment of MSW and C&I waste

in the London Plan (2011). The figures in Table 3 are based on an

assumption of 75% utilisation of existing facilities.

Table 3: Summary of average capacity surplus/deficit within the

ELWA boroughs required to meet the London Plan apportionment

Waste management route Capacity required

2011 2016 2021

Recycling (MSW and C&I) 786,203 674,313 415,428

Composting (MSW and C&I) -47,440 -109,170 -320,255

Recovery (all facilities) -262,710 -256,090 -269,370

Bold text is deficit in capacity Italic is surplus

‘Recovery’ is defined in the waste DPD as obtaining value from waste through

one of the following means:

Recycling

Composting

Other forms of material recovery (such as anaerobic digestion)

Energy recovery (combustion with direct or indirect use of the energy

produced, manufacture of refuse derived fuel, gasification, pyrolysis, or

other technologies).

Table 3 clearly shows that there is a projected deficit in recovery facilities

within the ELWA boroughs and therefore that without additional capacity the

London Plan apportionment for recovery will not be met.

5.4 Existing and proposed facilities in the ELWA area

Since the figures in Table 3 were derived, three recovery facilities, all in the

LSIP, have received planning consent

TEG Environmental composting and anaerobic digestion facility

Cyclamax energy generation facility

Refood UK Ltd anaerobic digestion facility


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In the Officer’s report for the Refood application (application ref

13/00649/FUL, para 6.1.10) it was noted that this proposal (i.e. Refood)

‘would result in a total of 330,000 tpa of consented recovery capacity which is

over the 270,000 tpa recovery capacity gap identified in the JWDPD. It is

important to stress though that PPS10 regards apportionments as a

benchmark for the preparation of local development documents and the focus

of the JWDPD is on identifying a suitable range of sites with sufficient

flexibility to meet the apportionment…Therefore whilst this proposal

surpasses the capacity gap by 60,000 tpa it is not considered reasonable to

assess this element as non-apportioned waste under policy W5 of the JWDPD

as this would be treating the apportionment as a maximum target rather than

a benchmark contrary to PPS10’.

However, given that the figures for capacity used in the London Plan and the

JWDPD assume an actual throughput of 75% of maximum available capacity

to maintain consistency with data used in the London Plan, the three facilities

with planning consent actually represent a recovery capacity of 247,500

tonnes / year (assuming throughput is 75% of maximum available

(consented) capacity of 330,000 tonnes / year as above).

The Cyclamax consent has obviously not been implemented and will be

superseded by the proposed development, with a maximum throughput of

180,000 tonnes / year i.e. an increase of 45,000 tonnes capacity over the

total of 247,500 tonnes / year given above, which is 22,500 tonnes above the

capacity gap.

The proposed development would therefore result in an overprovision of

capacity in the ELWA area. However, as the extract from the Officer’s report

cited above clearly states, it is not considered reasonable to assess this

additional tonnage as non-apportioned waste as that would be treating

apportionment as a maximum target. Given the support for energy recovery

schemes, particularly in the LSIP, it would also conflict with a range of

policies in the London Plan and LBBD core strategy and borough-wide DPD.


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A further factor that needs consideration is that the London Plan and JWDPD

combine MSW and C&I waste streams to enable assessment of capacity

required.

Schedule 1 of the JWDPD lists existing waste management facilities. Five

facilities are listed under the ‘recovery’ heading in Schedule 1 as shown in

Table 4 below.

Table 4: Recovery facilities given in Schedule 1 of the joint waste DPD Facility name Borough Facility type Annual permitted

tonnage (tonnes)

Hunts Wharf

Barking &

Dagenham

A16 – Physical Treatment Facility 150,000

Clinical Waste Ltd

(Goodmayes Hospital)

Redbridge A18 – Incinerator (Clinical Waste) 7,000

Novera Gasification (Frog

Island)

Havering

A17 - Physico-chemical Treatment

Facility (gasification)

90,000

Frog Island Bio-MRF Havering

A23 – Biological Treatment Facility 93,600

Jenkins Lane Bio-MRF

Newham A23 – Biological Treatment Facility 99,840

The Frog Island and Jenkins Lane Bio-MRF facilities treat municipal waste as

part of Shanks’ long-term contract with ELWA whilst the ‘Novera’ (now

Biossence) gasification facility is not yet built; revised planning consent was

received March 2013. It is understood that it will use the refused derived fuel

produced by the ELWA facilities at Frog Island and Jenkins Lane.

Therefore, even though the throughput at these facilities is used to derive the

overall capacity requirements for MSW and C&I waste, in practice, these

facilities are not available for the commercial and industrial residual waste

arisings, which would be treated at the proposed TGW2E facility.

Although the projected figures given in the above analysis indicate that the

ELWA area is providing slightly in excess of its apportionment, these figures

just relate to broad categories of treatment e.g. recycling, recovery etc. All

wastes are not equal and different treatment options are needed for different

waste streams. For example, whilst both AD and gasification are classed as


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recovery, the AD processes operated by TEG Environmental and Refood, will

take food / wet organic wastes, whereas the proposed TGW2E development

will take much drier mixed residual wastes and RDF type wastes. The waste

to be treated by TGW2E would not be suitable for AD nor would TGW2E seek

to take the wet organic waste streams targeted by TEG or Refood.

5.5 Mayor’s Business Waste Strategy for London

Making Business Sense of Waste – The Mayor’s Business Waste Strategy

(MBWS) for London was published in November 2011.

There is no statutory requirement for a Business Waste Strategy but given

that business waste accounts for around 80% of solid waste generated in

London, in order to ‘fully realise the economic and environmental value of

waste as a resource, London requires a truly holistic approach to managing

all of the waste that it generates’ and not just waste from local authority

collected sources, which is addressed in the statutory Mayor’s Municipal

Waste Management Strategy.

The MBWS sets out the Mayor’s vision for the management of London’s

business waste and contains three overriding aims:

Focus on waste reduction and more efficient management of resources to

reduce the financial and environmental impact of waste

Manage as much of London’s waste within its boundaries as practicable by

taking a strategic approach to developing new capacity

Boost recycling performance and energy generation to deliver

environmental and economic benefits to London.

The strategy contains four policies to help deliver the aims as follows:

1: Promoting the commercial value of a resource efficient business

2: Boosting reuse, recycling and composting participation in the commercial

and industrial sector


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3: Supporting the waste infrastructure market in London to grow and deliver

for businesses

4: Drive improvements in resource efficiency in the construction and

demolition sector while continuing to maintain the good levels of reuse

and recycling performance already achieved.

In 2010, London generated 6,496,000 tonnes of C&I waste. Some 17% of

C&I waste is known to be landfilled but there is a further 17% whose

destination is unknown, which equates to some 1.1 million tonnes landfilled

and a further 1.1 million tonnes whose destination is unknown.

Some 74% of the industrial waste element and 37% of the commercial waste

element respectively was in the form of mixed general waste; the MBWS

considers it likely that a proportion of this waste could be segregated for

reuse, recycling, composting or other recovery; this mixed general waste is

precisely the waste stream that will be targeted by the proposed TGW2E

development. The proposed TGW2E technology also means that metals,

glass and aggregates present in this general mixed waste can be recovered.

Policy 3 is directly relevant to the proposed development. The policy vision is

to ‘…assist the development of new waste infrastructure, which will help to

manage London’s business waste within the capital, so that there is less

reliance on landfill…’

The MBWS sets out the projected commercial and industrial waste

infrastructure gap for the whole of London.

Table 5: Projected commercial and industrial waste infrastructure capacity gap

Facility type Infrastructure capacity gap (tonnes)

2015 2020 2031

Materials reclamation facility (MRF) 1,835,000 2,259,000 2,282,000

Composting and anaerobic digestion 648,000 819,000 880,000

Mechanical biological treatment 542,000 505,000 1,904,000

New energy generation1 338,000 238,000 1,175,000


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Facility type Infrastructure capacity gap (tonnes)

2015 2020 2031

Thermal treatment2 361,000 302,000 479,000

Total 3,724,000 4,123,000 6,720,000

1: New energy generation is back-end thermal treatment capacity required for refuse-derived fuel produced following mechanical biological treatment of waste. 2: Thermal treatment exclude treatment capacity required for refuse-derived fuel produced following mechanical biological treatment of waste

Table 5 clearly shows a need for energy generation infrastructure in London;

the proposed development would make a significant contribution to closing

this gap.

The MBWS identifies two related key impediments in the development and

delivery of infrastructure for the C&I waste sector:

The lack of contracts available for significant amounts of C&I waste;

businesses contract individually with waste management collection

operators requiring a significant number of contracts to accrue sufficient

waste for treatment.

The short duration of feedstock supply contracts: businesses generally

only enter into contracts for two - three years.

Developments such as that proposed by TGW2E typically have a lifespan of

twenty – thirty years and the sophisticated nature of the technology means

very high capital costs.

The proposed development will treat C&I waste and so the challenges

identified in the MBWS are directly relevant. Discussions with local and

national waste management companies (who have an extensive local

presence) are at an advanced stage with respect to waste supply

agreements. However, for precisely the reasons identified in the MBWS,

specifically the short term nature of contracts, as well as commercial

confidentiality, TGW2E is not in a position to publicly state which operator(s)

will be providing the waste for the proposed development, given that it will


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not be operational until 2015. Additional issues that make obtaining forward

supply agreements exceedingly challenging are the time taken to obtain the

necessary consents that can cause considerable delays to projects and the

number of energy from waste schemes that have successful passed the

planning and permitting hurdles but have not been implemented.

TGW2E does have agreement in principle with a national waste operator to

supply residual waste to the proposed development. Approximately one third

of the throughput is C&I waste from the ELWA area; further waste is

available from the same operator, which would come from north London.

TGW2E is also keen to explore possibilities of taking residual waste from

other operators and businesses on the LSIP.

5.6 Conclusion

The analysis of projected waste arisings and treatment options in east London

and the wider London area has demonstrated that there is a capacity gap.

New infrastructure is needed in London required to meet the targets for self-

sufficiency and recovery set in the London Plan. The proposed development

will make a significant contribution to the targets and would not compete with

existing and planned (consented) infrastructure in the east London area.


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6 Air quality

6.1 Introduction

This section provides an overview of the existing legislation and assessment

criteria in relation to air quality. The Local Air Quality Management (LAQM)

review and assessment process is outlined together with a summary of the

assessment findings and monitoring data for the Dagenham area.

The impact of the proposed development on air quality is assessed and

mitigation measures recommended as appropriate. The full air quality

modelling and assessment report is included within Appendix C and the

results summarised in this section.

6.2 Assessment criteria

6.2.1 Air quality limit values and objectives

Air quality limit values and objectives in the UK can be split into four groups,

each of which have different legal status and are handled in a different way

within UK air quality policy:

UK air quality objectives set down in regulations for the purpose of local

air quality management (Air Quality (England) Regulations)

UK air quality objectives not included in regulations

EU Limit Values transcribed into UK legislation (Air Quality Limit Value

Regulations)

Air quality guidelines with no legal basis (e.g. World Health Organisation).

The most recent version of the Air Quality Strategy (AQS) for England,

Scotland, Wales and Northern Ireland was published in July 20079 and sets

objectives for 10 pollutants10 to be achieved between 2003 and 2010.

9 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland (July, 2007)


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The standards set out in the AQS are aimed primarily at the protection of

human health. However, it also provides for standards for the protection of

vegetation and ecosystems in respect of two of the pollutants (nitrogen

dioxide and sulphur dioxide).

The air quality standards in the UK are derived from the European

Commission (EC) Directives, and adopted into English law via the Air Quality

(England) Regulations 2000 and Air Quality (England) Amendment

Regulations 2002.

The European Union’s (EU) Framework Directive 96/62/EC on ambient air

quality assessment and management was formally adopted on 27 September

1996 and had to be implemented by Member States by 21 May 1998. The

Directive aims to protect human health and the environment by avoiding,

reducing, or preventing harmful concentrations of air pollutants. As a

Framework Directive it requires the Commission to propose “Daughter”

Directives setting air quality objectives, limit values, alert thresholds and

guidance on monitoring, siting and measurement for individual pollutants. To

date there have been four “Daughter” Directives.

In April 2008, the EU agreed and adopted a new European Air Quality

Directive (2008/5O/EC). The Directive merges four Directives and one

Council decision into a single directive on air quality. It sets standards and

target dates for reducing concentrations of fine particulate matter (PM2.5),

together with coarser particles known as PM10, which is already subject to

legislation.

The Air Quality Standards Regulations 200711 implement Council Directive

96/62/EC on ambient air quality assessment and management and all related

Daughter Directives. Legislation is pending to implement the requirements of

10 Benzene, 1,3-butadiene, carbon monoxide, lead, oxides of nitrogen, ozone, particulate matter PM10 and

PM2.5, polyaromatic hydrocarbons (PAH), sulphur dioxide 11 SI No. 2007/64


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the new EU Air Quality Directive.

The Environment Act 1995 places statutory duties on Local Authorities for

Local Air Quality Management (LAQM) and requires Local Authorities to

contribute to the achievement of AQS objectives and conduct periodic reviews

and assessments of air quality.

6.2.2 Pollutants relevant to the proposed development

The principal pollutants that will be released to atmosphere from the

proposed development are:

Oxides of nitrogen (NOx)

Sulphur dioxide (SO2)

Fine particulate matter (PM10)

In addition to these pollutants, consideration is given to:

Carbon monoxide (CO)

Hydrogen chloride (HCl)

Hydrogen fluoride (HF)

Polychlorinated dibenzodioxins (dioxins, PCDD)

Polychlorinated dibenzofurans (furans, PCDF)

Metals

Descriptions of these pollutants, including their effects on human health and

relevant standard and guidelines values are given in Appendix C.

6.3 Existing conditions

6.3.1 LBBD air quality assessment and review

The London Borough of Barking and Dagenham declared an Air Quality

Management Area (AQMA) across the whole borough for nitrogen dioxide and

particulates.


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6.4 Assessment of impact

6.4.1 Construction

No demolition or site clearance is required for the proposed development.

The closest residential properties to the proposed development are those off

Shaw Gardens which are about 150 m to the north of the development.

The Institute of Air Quality Management (IAQM) has published guidance on

how to assess impacts of emissions of dust from demolition and constructions

sites. This guidance has been followed in Table 6, which shows the steps

undertaken to determine the risk of dust from construction giving rise to

annoyance.

Table 6: IAQM dust risk assessment methodology

Step Outcome

Step 1: Need for detailed assessment Assessment required due to proximity of

sensitive receptors within 350 m

Step 2: Assess the risk of dust effect Low risk site due to receptors at a distance of

150 m

Step 3: Identify the need for site-specific

mitigation

Mitigation measures detailed in the GLA best

practice guidance for Low Risk will be followed

Step 4: Define effects and their

significance

Negligible impact (following mitigation)

Given the distance to the closest sensitive receptors, the risk of dust

annoyance occurring during construction is considered to be low. Following

the implementation of appropriate mitigation measures the significance of the

impacts is considered to be negligible.

The effect on air quality of emissions to atmosphere from construction

vehicles will be negligible.


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6.4.2 Operation

The principal types of emissions to air that may result from operation of the

proposed development are:

Emissions associated with vehicle movements.

Process emissions vented through the proposed facility’s stack.

The potential impacts of these types of emissions are considered in turn

below.

6.4.3 Vehicle movements

The EPUK guidance for development control12 includes criteria for when an air

quality assessment is required and states that an assessment is required

when there is a change in AADT of more than 10% (or 5% in an AQMA). An

assessment is also required if there is an increase in HGV movements of

more than 200 per day.

During operation there will be a maximum of ten deliveries per hour.

Emissions to atmosphere from ten heavy duty vehicles (HDVs) per hour will

not have a significant effect on air quality and will not be considered further.

6.4.4 Atmospheric dispersion modelling

In order to quantify the potential impact of emissions from the process, and

to determine the optimum stack height for dispersion, detailed atmospheric

dispersion modelling using the industry standard atmospheric dispersion

model ADMS version 5.0 has been undertaken. The full dispersion modelling

report is included in Appendix C and results are summarised below. A

detailed analysis was undertaken to assess the sensitivity of the predicted

12 EPUK (2010) Development Control for Air Quality (2010 Update).


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concentrations to inter alia variations in meteorological data, grid spacing,

stack height and dispersion model used; the sensitivity analysis is included in

Appendix C.

Short term versus long term impacts

Defra technical guidance13 states that for elevated point sources the focus of

the assessment should be on short term impacts. However, for urban areas

where the prevailing annual average concentration of nitrogen dioxide (NO2)

are close to, or exceed, the Air Quality Strategy objectives, even for point

sources, it is often the case that the increment to the annual average is of

more significance that the short term impact. This is also because the effect

on the 99.8th percentile can be negligible as peak ground level concentrations

from point sources do not necessarily coincide with the peak background

concentrations; the meteorological conditions that give rise to maximum

ambient pollutant levels, e.g. still conditions, are not those that give rise to

maximum impacts from point sources e.g. high wind speeds or unstable

conditions. For this assessment equal weight is given to both long and short

term impacts although it is considered that the increment to the annual

average concentration is of greater significance than the short term impact.

The assessment is undertaken for continuous full load normal emissions at

the emissions limits.

Receptor locations

To determine the maximum ground level concentrations occurring due to

emissions to atmosphere from the proposed facility and the distribution of

impacts, predictions are made of ground level concentrations for a grid of

receptors; making predictions for a grid of receptors also allows the predicted

ground level concentrations to be presented as contour plots.

13 Defra (2009). Local Air Quality Management Technical Guidance LAQM TG(09)


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The specific receptors used in the assessment can be divided into three

groups:

Monitoring locations, which allows for predicted impacts to be directly

compared and added to measured concentrations

Locations where there is relevant exposure such as residential properties.

Statutory and non-statutory sites of ecological importance within 5 km of

the site.

For the purpose of Local Air Quality Management (LAQM) the Air Quality

Strategy Objectives (AQS) only apply where there is relevant exposure. This

is defined as being where members of the public are regularly present and

are likely to be exposed for a period of time, appropriate to the averaging

period of the objective. For the annual average objective, locations of

relevant exposure include residential properties, schools and hospitals.

Receptor locations used in the assessment are given in Table 7 below.

Table 7: Receptor locations

No. Description Distance (km)

R1 Warehouse 1 0.1

R2 Dagenham Dock Station 0.4

R3 Allotment Gardens (NW) 0.5

R4 Residential Property on New Road (1) 1.0

R5 Residential Property on New Road (2) 1.2

R6 Beam Valley Country Park 2.0

R7 School - Leys Avenue 2.3

R8 School - School Road 1.5

R9 Allotment Gardens (N) 1.6

R10 School - New Road 1.0

R11 Schools - Lowen Road 2.2

R12 School - Gores Bridge 0.8

R13 Playground - Goresbrook Park 1.0

R14 Goresbrook Leisure Centre 1.1

R15 School - Goresbrook Road 1.3

R16 Shaw Gardens 0.6

R17 Castle Green 1.6

R18 School - Burnham Road 2.0

R19 School - Dawson Avenue 3.1

R20 Hospital 3.2

R21 Schools - Sandringham Road 3.2


Industries Park 82

No. Description Distance (km)

R22 Mayesbrook Park 2.8

R23 School - Cannington Road 2.4

R24 Parsloes Park 2.1

R25 Recreation Ground - Reede Road 2.6

R26 Playing Fields - Tom Thumb Lake 3.3

R27 Allotment Gardens - Tom Thumb Lake 3.6

R28 Allotment Gardens - Rainham Road 4.2

R29 School - Tangmere Crescent 4.8

R30 School Heron Flight Avenue 4.3

R31 Albyns Farm 4.5

R33 Allotments - Ingreborne Road 4.1

54 Diffusion Tube No 109 0.6








62 Scrattons Monitor 0.7

Figure 3 shows the locations of the receptors, as well as the location of the

stack.

Figure 3: Location of human health receptors and stack


Industries Park 83

Table 8 lists the ecological receptors used in the assessment. The

Environment Agency (EA) has confirmed that Table 8 includes the statutory

and 'important non-statutory sites' that need assessment following the EA

AQTAG06 guidance for nutrient nitrogen and acid deposition (14) (15)

.

Table 8: Ecological receptors (vegetation and ecosystems)

No. Description Designation Distance

(km)

E1 Ingreborne Marshes SSSI 3.8

E2 Inner Thames Marshes SSSI 3.5

E3 Crossness LNR 2.2

E4 Ripple Site of metropolitan importance 1.7

E5 Scrattons Park Site of borough importance 0.6

E6 St Peter and St Paul Church Yard LNR 2.1

E7 Thames Important bird area 1.0

E8 Abbey Wood SSSI 4.2

In addition to the sites shown in Table 8, there are a number of other sites

that have received a local designation of importance for nature conservation

(SINC), including Goresbrook and the Ship & Shovel SINC and Scratton’s

Farm Ecopark SINC. Modelling has also been undertaken to assess the

impacts on these sites.

Nitrogen dioxide modelling and assessment results

Oxides of nitrogen (NOx), which all progressively becomes nitrogen dioxide

(NO2) in the atmosphere, is the principal pollutant released to atmosphere

from the proposed development.

Table 9 shows the maximum predicted ground level concentration of nitrogen

dioxide (NO2) occurring as a consequence of emissions to atmosphere from

the development for each of the five years of meteorological data used in the

assessment.

(14) Email from Nick Bettinson (EA) to David Harvey (ADMs Ltd) 9 October 2012. (15) Environment Agency (20 April 2010) AQTAG 06; Technical Guidance on detailed modelling approach for an appropriate assessment

for emissions to air.


Industries Park 84

Table 9: Maximum predicted (process contribution) annual average and 99.8th percentile of hourly average concentrations of nitrogen

dioxide (µg m-3)

Year Annual average(a)

99.8th percentile of

hourly averages(a)

2008 2.6 8.9

2009 2.1 9.3

2010 1.5 9.7

2011 2.5 9.1

2012 2.2 9.3

Background Concentration 33.3(b) -

Background + Maximum Impact (PEC) (c) 35.9 76.3(d)

Assessment Criteria 40 200

(a) Assumes 70% oxidation for annual average and 35% for 99.8th percentile.

(b) Measured ambient concentration assumed as a little higher that estimated values.

(c) Predicted Environmental Concentration

(d) Defra (TG4(00)) and Environment Agency (H1) guidance; 99.8th + 2 x annual average background.

Table 9 shows that shows that 2008 meteorological data gives rise to the

highest predicted increment to annual average ground level concentrations

and 2010 for the 99.8th percentile of hourly averages.

For 2008 meteorological data, at the point of maximum predicted impact, the

incremental increase in annual average ground level concentration is

2.6µg m-3 which can be compared to the air quality strategy objective of

40 µg m-3. When added to the prevailing background concentration of

33.3µg m-3, the resulting total concentration of 35.9 µg m-3 is less than the

objective.

The maximum predicted 99.8th percentile of 9.7µg m-3 is small compared to

the air quality strategy objective of 200 µg m-3. To determine the

incremental increase to background occurring due to the proposed facility,

the Defra TG04(00)/H1 guidance is used. The resulting total 99.8th percentile

is 86µg m-3.

Table 10 shows the predicted annual average concentration at the specific

receptors for human exposure using 2008 meteorological data.


Industries Park 85

Table 10: Predicted annual average concentrations of NO2 at specific

receptors (µg m-3)

Location Description

Predicted

increment

(PC)(a)

Prevailing

conc. (b)

Predicted increment

+ prevailing (PEC)

Increment (PC) as

% of objective

1 Warehouse 1 0.1 33.3 33.4 0.2%

2 Dagenham Dock 1.8 33.3 35.1 4.4%

3 Allotment Gardens 0.2 33.3 33.5 0.4%

4 Property on New Road 1.3 33.3 34.6 3.2%

5 Property on New Road 1.1 33.3 34.4 2.9%

6 Beam Valley Country 0.7 33.3 34.0 1.6%

7 School - Leys Avenue 0.5 33.3 33.8 1.3%

8 School - School Road 0.7 33.3 34.0 1.7%

9 Allotment Gardens (N) 0.4 33.3 33.7 1.1%

10 School - New Road 1.3 33.3 34.6 3.4%

11 Schools - Lowen Road 0.3 33.3 33.6 0.8%

12 School - Gores Bridge 1.0 33.3 34.3 2.5%

13 PlaygroundGoresbrook 0.3 33.3 33.6 0.7%

14 Goresbrook Leisure 0.1 33.3 33.4 0.3%

15 School - Goresbrook 0.1 33.3 33.4 0.2%

16 Shaw Gardens 0.2 33.3 33.5 0.4%

17 Castle Green 0.1 33.3 33.4 0.2%

18 School - Burnham Rd 0.0 33.3 33.3 0.1%

19 School - Dawson Ave 0.0 33.3 33.3 0.1%

20 Hospital 0.0 33.3 33.3 0.1%

21 School - Sandringham 0.0 33.3 33.3 0.1%

22 Mayesbrook Park 0.0 33.3 33.3 0.1%

23 School - Cannington 0.0 33.3 33.3 0.1%

24 Parsloes Park 0.1 33.3 33.4 0.2%

25 Recreation Ground 0.3 33.3 33.6 0.8%

26 Playing Fields 0.2 33.3 33.5 0.6%



29 School - Tangmere 0.2 33.3 33.5 0.5%

30 School Heron Flight 0.2 33.3 33.5 0.5%

31 Albyns Farm 0.1 33.3 33.4 0.4%

33 Allotments -

Ingreborne 0.1 33.3 33.4 0.2%

54 Diffusion Tube No 109 0.2 36.3 36.5 0.4%








62 Scrattons Monitor 0.2 33.3 33.5 0.4%

Assessment Criteria 40

(a) Assumes 70% oxidation.

(b) Either measured values or Defra estimated background values.


Industries Park 86

The EPUK significance criteria are applicable to locations where there is

relevant exposure and are only applicable to annual average concentration.

Defra TG(09) guidance gives the following examples of where there is

relevant exposure to annual average objectives:

Building facades of residential properties

School

Hospital

Care homes

Examples given of where there is not relevant exposure to annual average

objectives include; gardens of residential properties, hotels and kerbside

sites.

The receptors where measured concentrations are at their highest tend to be

road side locations where there is no relevant exposure and where the EPUK

significance criteria are not relevant. For example the maximum annual

average increase in concentration of nitrogen dioxide (NO2) of 2.0µgm-3

occurs at receptor number 57. This receptor is some distance from any

location where there is relevant exposure and therefore it is not appropriate

to determine the significance of the impact at this location using EPUK

significance criteria.

Table 11 shows the EPUK significance criteria applied to the nineteen

locations where there is relevant exposure to annual average objectives.

Table 11: EPUK Significance Criteria(NO2, µg m-3)


Predicted

increment

(PC)

Increase

(%) Magnitude of

Change

PEC (a) Impact

Descriptor

4 Property on New Rd 1.3 3.2% Small 34.6 Negligible

5 Property on New Rd 1.1 2.9% Small 34.4 Negligible

7 School - Leys Ave 0.5 1.3% Small 33.8 Negligible

8 School - School Rd 0.7 1.7% Small 34.0 Negligible

10 School - New Rd 1.3 3.4% Small 34.6 Negligible

11 Schools - Lowen Rd 0.3 0.8% Imperceptible 33.6 Negligible


Industries Park 87


Predicted

increment

(PC)

Increase

(%) Magnitude of

Change

PEC (a) Impact

Descriptor

12 School - Gores 1.0 2.5% Small 34.3 Negligible

13 PlaygroundGoresbrook 0.3 0.7% Imperceptible 33.6 Negligible

14 Goresbrook Leisure 0.1 0.3% Imperceptible 33.4 Negligible

15 School Goresbrook Rd 0.1 0.2% Imperceptible 33.4 Negligible

17 Castle Green 0.1 0.2% Imperceptible 33.4 Negligible

18 School - Burnham Rd 0.0 0.1% Imperceptible 33.3 Negligible

19 School - Dawson Ave 0.0 0.1% Imperceptible 33.3 Negligible

20 Hospital 0.0 0.1% Imperceptible 33.3 Negligible

21 School Sandringham 0.0 0.1% Imperceptible 33.3 Negligible

23 School Cannington Rd 0.0 0.1% Imperceptible 33.3 Negligible

26 Playing Fields 0.2 0.6% Imperceptible 33.5 Negligible

29 School Tangmere 0.2 0.5% Imperceptible 33.5 Negligible

30 School Heron Flight 0.2 0.5% Imperceptible 33.5 Negligible

31 Albyns Farm 0.1 0.4% Imperceptible 33.4 Negligible

(a) Predicted Environmental Concentration (µg m-3), includes background of 33.3 µg m-3.

Table 11 shows that the proposed development is predicted to have an

impact of negligible significance on annual average concentrations of nitrogen

dioxide (NO2) according to the EPUK significance criteria.

The conclusion of an impact of negligible significance does in part depend on

the assumed background concentration. With a 'small' magnitude of change

the significance of the impact would be no worse than 'slight adverse' if

background concentrations were higher than assumed. It is however

considered that the background concentration of 33.3µg m-3 for this

determination of significance is conservative as it is higher than the 2010

Defra background of 25.5µg m-3, which is expect to fall in the future.

It is therefore considered that the assessment of significance presented in

this assessment is robust.

Table 12 shows the predicted 99.8th percentile concentration at the specific

receptors using 2010 meteorological data.


Industries Park 88

Table 12: Predicted 99.8th percentile of hourly average concentrations

(µg/m3) of NO2 at specific receptors

Location Description Predicted

Increment (PC)

Predicted

Increment +

Prevailing

(PEC)(b)

Increment as

%age of

objective (%)

1 Warehouse 1 2.7 69.3 1.4%

2 Dagenham Dock Station 8.5 75.1 4.2%

3 Allotment Gardens (NW) 7.7 74.3 3.8%

4 Property on New Road 4.7 71.3 2.3%

5 Property on New Road 3.9 70.5 2.0%

6 Beam Valley Country 2.5 69.1 1.3%

7 School - Leys Avenue 2.3 68.9 1.1%

8 School - School Road 3.1 69.7 1.6%

9 Allotment Gardens (N) 3.0 69.6 1.5%

10 School - New Road 4.7 71.3 2.3%

11 Schools - Lowen Road 2.0 68.6 1.0%

12 School - Gores Bridge 6.0 72.6 3.0%

13 Playground -Goresbrook 4.4 71.0 2.2%

14 Goresbrook Leisure 4.7 71.3 2.3%

15 School - Goresbrook Rd 3.6 70.2 1.8%

16 Shaw Gardens 7.5 74.1 3.8%

17 Castle Green 2.8 69.4 1.4%

18 School - Burnham Road 2.3 68.9 1.1%

19 School - Dawson Ave 1.6 68.2 0.8%

20 Hospital 1.4 68.0 0.7%

21 School - Sandringham 1.3 67.9 0.7%

22 Mayesbrook Park 1.6 68.2 0.8%

23 School - Cannington Rd 1.8 68.4 0.9%

24 Parsloes Park 2.0 68.6 1.0%

25 Recreation Ground 2.2 68.8 1.1%

26 Playing Fields 1.8 68.4 0.9%

27 Allotment Gardens 1.6 68.2 0.8%

28 Allotment Gardens 1.5 68.1 0.7%

29 School - Tangmere 1.2 67.8 0.6%

30 School Heron Flight Ave 1.3 67.9 0.7%

31 Albyns Farm 1.1 67.7 0.6%

33 Allotments - Ingreborne 1.3 67.9 0.7%

54 Diffusion Tube No 109 7.3 79.9 3.7%








62 Scrattons Farm Monitor 7.0 73.6 3.5%

Assessment Criteria 200

(a) Assumes 35% oxidation.

(b) Defra guidance (TG4(00)); NO2 99.8th + 2 x annual average NO2 background.


Industries Park 89

Table 12 shows that the maximum predicted 99.8th percentile of hourly

average nitrogen dioxide (NO2) concentrations is 8.5µg m-3 at any of the

specific receptors which is only 4.2% of the objective.

The results reported above (Table 9 - Table 12) show that at the specific

receptors, the predicted incremental increase in concentrations of nitrogen

dioxide (NO2) occurring due to emissions from the proposed facility are small

compared to the assessment criteria and are not of concern to human health.

Figure 4 and Figure 5 below illustrate the distribution of oxides of nitrogen

(NOx) emissions (process contributions) from the proposed facility, using

2008 meteorological data for annual average and 2010 data for 99.8th

percentile of hourly averages.

The figures show that peak predicted increments to ground level

concentrations occur within about 500 m of the facility.

Figure 4: Annual average NOx

concentrations

Figure 5: 99.8th percentile of hourly

average NOx concentrations

Other pollutants

Table 13 below shows the results for all pollutants considered in this

assessment, assuming full load continuous operation at the IES limits and


Industries Park 90

2008 meteorological data because this gives rise to the largest increment to

annual average concentrations.

Table 13: Maximum predicted incremental concentrations due to

emissions to atmosphere from the proposed facility (µg m-3)

Pollutant Averaging

period

Predicted

concentration (µg m-3)

Assessment criteria (µg m-3)

Percentage of

assessment criteria (%)

Nitrogen

dioxide (NO2)

1 hour 8.9 200 4.5%

Annual 2.56 40 6.4%

Particulate

matter (PM10)

24 hour 0.51 50 1.0%

Annual 0.18 40 0.5%

Sulphur dioxide

(SO2)

15 minutes 7.4 266 2.8%

1 hour 6.3 350 1.8%

24 hour 4.2 125 3.4%

Carbon

monoxide

8 Hour 6.4 10,000 0.1%

Hydrogen

chloride

1 Hour 2.0 750 0.3%

Hydrogen

fluoride (HF)

Annual 0.018 16 0.1%

1 Hour 0.20 160 0.1%

Antimony (Sb)

(a)

Annual 0.0010 5 0.02%

1 Hour 0.011 150 0.0%

Arsenic (As) Annual 0.00001 0.003 0.4%

Cadmium (Cd) Annual 0.00046 0.005 9.1%

Chromium (Cr)

(b)

Annual 0.0010 5 0.0%

1 Hour 0.011 150 0.0%

Chromium (Cr,

VI) (c)

Annual 0.00000009 0.0002 0.0%

Cobalt (Co) Annual

0.0010 0.2 0.5%

Copper (Cu) Annual 0.0010 10 0.0%

1 Hour 0.011 200 0.0%

Lead (Pb) Annual 0.0010 0.25 0.4%

Manganese (Mn) Annual 0.0010 150 0.0%

1 Hour 0.011 1,500 0.0%

Mercury (Hg) Annual 0.0009 0.25 0.4%

1 Hour 0.010 7.5 0.1%

Nickel (Ni) Annual 0.0010 0.02 5.1%

Vanadium (Vn) Annual 0.0010 5 0.0%

1 Hour 0.011 1 1.1%

Dioxins Annual 1.8 (fg m-3

) - -

(a) antimony and compounds (as Sb) except antimony trisulphide and antimony trioxide.

(b) Chromium, chromium (II) compounds and chromium (III) compounds (as Cr).

(c) Chromium (VI) oxidation state in PM10 fraction.

Table 13 shows that as a percentage of the short term assessment criteria, it

is the 99.8th percentile of hourly average concentration of nitrogen dioxide

(NO2) which is 4.5% of the assessment criteria that has the largest impact.


Industries Park 91

When combined with the background concentration the PEC (Predicted

Environmental Concentration) of 75.5µg m-3 is 38% of the assessment

criteria and not considered to be of concern to human health.

For annual average impacts the increment to annual average concentration of

cadmium (Cd) is predicted to give rise to the largest percentage of the

assessment criteria of 9.1%. It should be noted that the assessment criteria

of 0.005 µg m-3 is from the World Health Organisation Air Quality guidelines

(2000) which state that the guideline is set to 'prevent any further increase of

cadmium in agricultural soils'. Given that the maximum predicted

concentration is substantially less than the assessment criteria and that the

area is predominantly urban, it is considered that there is no concern to

human health.

Dioxins and furans are a group of organic compounds that are formed as a

result of incomplete combustion in the presence of chlorine. Sources include

vehicles, domestic and industrial coal burning, power generation and

incinerators. There are no regulatory air quality standards set for dioxins and

furans and there are only limited data available on airborne dioxins and

furans in the urban environment in the UK; these show concentrations in the

range of 146 – 188 fg I-TEQ /m3. The maximum predicted ground level

concentration of dioxin of 1.8fg I-TEQ/m3 is small compared to the reported

range of urban dioxin concentrations.

As part of the 2010 permit application, a health risk assessment was

submitted (16). The 2010 Heath Risk Assessment was undertaken assuming

a maximum annual average dioxin concentration of 8 fg m-3 and concluded

'The assessment indicates that the risk to health of the local population due

to exposure to dioxins in emissions from the proposed Thames Gateway

Energy Facility is likely to be very low.' For the current design, the maximum

(16) GF Environmental Ltd (April 2010) Thames Gateway Power Ltd; Dioxin Health Risk Assessment for Proposed Thames Gateway

Energy Facility.


Industries Park 92

predicted annual dioxin concentration has reduced from 8 fg m-3 to 1.8 fg m-

3. Given that the facility is in the same location and therefore surrounded by

the same land use and subject to the same rainfall as assumed in the 2010

assessment, the recalculated dioxin intake for the re-submitted development

is 23% of that calculated for the previous scheme, which was determined to

have a 'very low' impact.

When considering the significance of the impacts on air quality of emissions

from the facility and their relevance to human health one needs to consider

both the maximum impact, the receptors exposed to the maximum impacts

and the geographic extent of the impact. Figure 4 and Figure 5 show that

the area of maximum impact is limited to an industrial area to the south east

of the facility. This reduces the significance of the impacts compared to, for

example, a larger facility where the magnitude of the impacts may be similar

but the area of impact larger and includes sensitive receptors such a

residential properties, school and hospitals.

It is also of relevance to compare the predicted impacts for this updated

proposal for the facility with those presented in the 2010 assessment report

for the original application. Table 4.4 of the 2010 report shows that the

maximum predicted increment to annual average ground level concentrations

of nitrogen dioxide (NO2) was 10.2 µg m-3, this can be compared to 2.6 µg m-

3 for the revised development. For the maximum 99.8th percentile of hourly

averages, the previous process contribution was 82 µg m-3 compared to

9.7 µg m-3 for the current proposal. The reduction in concentration is

principally a consequence of the increase in stack height from 42 m to 55 m.

Potential impact on vegetation and ecosystems

This air quality assessment has also considered the potential impact on

statutory nature conservation sites within 5 km and non-statutory sites within

2 km.


Industries Park 93

The atmospheric pollutant of most concern for sensitive vegetation and best

understood is Oxides of Nitrogen (NOx). Both the EU and WHO have set limit

and guidelines for the annual average concentration of NOx for the protection

of vegetation. For the protection of vegetation and ecosystems there is an

Air Quality Objective (AQS) and an EU target of 30 µg m-3 for NOx. This

objective does not apply to locations within 5 km of built up areas of more

than 5,000 people, or industrial sources regulated under Part A of the 1990

Environment Act. However for the purpose of the assessment, this objective

was used.

Table 14 shows that the predicted increments to annual average

concentrations of the oxides of nitrogen (NOx) are close to the 1% level of

insignificance with a maximum of 2.0% at receptor which is a Local Nature

Reserve (LNR).

Table 14: Predicted increment (process contribution (PC)) of annual

average concentrations of oxides of nitrogen (NOx) at ecological

receptors

No. Description Designation PC (NOx,

µg m-3)

PC as % of

Critical Level

(% of 30 µg

m-3)

E1 Ingreborne Marshes SSSI 0.11 0.4%

E2 Inner Thames Marshes SSSI 0.13 0.4%

E3 Crossness LNR 0.11 0.4%

E4 Ripple Site of metropolitan importance 0.45 1.5%

E5 Scrattons Park Site of borough importance 0.26 0.9%

E6 St Peter and St Paul Church Yard LNR 0.59 2.0%

E7 Thames Important bird area 0.31 1.0%

E8 Abbey Wood SSSI 0.05 0.2%

Table 15 shows the Predicted Environmental Concentration (i.e. predicted

increment + background concentration, PEC) of annual average concentration

of the oxides of nitrogen (NOx) at the eight receptors of ecological importance

and the percentage of the critical level which for the oxides of Nitrogen (NOx)

is 30 µg m-3.


Industries Park 94

Table 15: Predicted environmental concentration (PEC) of annual

average concentrations of oxides of nitrogen (NOx) at ecological

receptors

No. Description Designation

PEC

(NOx, µg

m-3)

PEC as % of

Critical Level

(% of 30 µg

m-3)

E1 Ingreborne Marshes SSSI 41.3 138%

E2 Inner Thames Marshes SSSI 41.3 138%

E3 Crossness LNR 41.3 138%

E4 Ripple Site of metropolitan importance 41.7 139%

E5 Scrattons Park Site of borough importance 41.5 138%

E6 St Peter and St Paul Church Yard LNR 41.8 139%

E7 Thames Important bird area 41.5 138%

E8 Abbey Wood SSSI 41.3 138%

Table 15 shows that the PEC exceeds the critical level at all the receptors as a

direct consequence of the prevailing background concentration.

For the protection of vegetation and ecosystems there is also an Air Quality

Objective and an EU target of 20 µg m-3 for sulphur dioxide (SO2) (annual

and winter average). This objective does not apply to locations within 5 km

of built up areas of more than 5,000 people or industrial sources regulated

under Part A of the 1990 Environment Act. However for the purpose of this

assessment the objective is used.

Table 16: Predicted increment (PC) of annual average concentrations

of sulphur dioxide (SO2) at ecological receptors

No. Description Designation PC (SO2,

µg m-3)

PC as % of

Critical Level

(% of 20 µg

m-3)

E1 Ingreborne Marshes SSSI 0.03 0.1%

E2 Inner Thames Marshes SSSI 0.03 0.2%

E3 Crossness LNR 0.03 0.1%

E4 Ripple Site of metropolitan importance 0.11 0.6%

E5 Scrattons Park Site of borough importance 0.07 0.3%

E6 St Peter and St Paul Church Yard LNR 0.15 0.7%

E7 Thames Important bird area 0.08 0.4%

E8 Abbey Wood SSSI 0.01 0.1%


Industries Park 95

Table 16 shows that the predicted increments to annual average

concentrations of sulphur dioxide (SO2) are less than the Environment

Agency's test for insignificance of 1% and therefore is insignificant. There

would therefore be justification not to consider the impact of sulphur dioxide

(SO2) further. However, for completeness, the deposition rates and

contribution to acidification are assessed.

Table 17 shows the Predicted Environmental Concentration (i.e. predicted

increment + background concentration) of annual average concentration of

sulphur dioxide (SO2) at the eight receptors of ecological importance and the

percentage of the critical level which for sulphur dioxide (SO2) is 20 µgm-3.

Table 17: Predicted environmental concentration (PEC) of annual

average concentrations of oxides of nitrogen (SO2) at ecological

receptors

No. Description Designation PEC (SO2,

µg m-3)

PEC as %age of

Critical Level

(% of 20 µg m-

3)

E1 Ingreborne Marshes SSSI 6.8 34%

E2 Inner Thames Marshes SSSI 6.8 34%

E3 Crossness LNR 6.8 34%

E4 Ripple Site of metropolitan importance 6.9 35%

E5 Scrattons Park Site of borough importance 6.9 34%

E6 St Peter and St Paul Church Yard LNR 6.9 35%

E7 Thames Important bird area 6.9 34%

E8 Abbey Wood SSSI 6.8 34%

Table 17 shows that the critical level for sulphur dioxide (SO2) is not

predicted to be exceeded.

The deposition of nitrogen (N) from the atmosphere acts as a fertiliser which

affects the natural balance of vegetation. The critical load for the deposition

of nitrogen, normally expressed as Kg N ha-1 year-1, is the exposure below

which there should be no harmful effects on sensitive elements of the

ecosystem. The critical loads vary for the type of ecosystem from as low as

5-10 Kg N ha-1 year-1 for sensitive lichen found on mountain tops to 20-30 Kg


Industries Park 96

N ha-1 year-1 for some type of meadows. A full analysis was undertaken using

the specific critical load applicable to each receptor.

Table 18 shows the habitat descriptions that are relevant to atmospheric

deposition and the critical load range for nitrogen deposition (Kg N ha-1 year-

1) which were obtained from the APIS web site (17)

.

Table 18: Site description, habitat and nitrogen deposition critical

load range (Kg N ha-1 year-1)

No. Description Habitat

Critical Load

Range

Min Max

E1 Ingreborne Marshes Fen, Marsh & Swamp 10.0 15.0

E2 Inner Thames Marshes Fen, Marsh & Swamp 10.0 15.0

E3 Crossness Grazing marsh/scrub and rough grassland 20.0 30.0

E4 Ripple Semi-improved neutral grassland 20.0 30.0

E5 Scrattons Park Neutral grassland 20.0 30.0

E6 St Peter and St Paul Church Yard Neutral grassland 20.0 30.0

E7 Thames Mud Flats 10.0 20.0

E8 Abbey Wood Woodland 10.0 20.0

Table 19 shows the calculated nitrogen deposition rates, the calculations are

made assuming a dry deposition velocity for nitrogen dioxide (NO2) of

0.003 m s-1 and assuming that the contribution from wet deposition is

negligible.

Table 19: Predicted annual average ground level concentrations and

calculated nitrogen deposition rates

No. Description Annual average NO2

concentration (µg m-3)

Nitrogen deposition rate

(µg m-2 s-1) (Kg N ha-1 y-1)

E1 Ingreborne Marshes 0.080 0.0002 0.02

E2 Inner Thames Marshes 0.093 0.0003 0.03

E3 Crossness 0.075 0.0002 0.02

E4 Ripple 0.316 0.0009 0.09

E5 Scrattons Park 0.184 0.0006 0.05

E6 St Peter and St Paul Church 0.416 0.0012 0.12

E7 Thames 0.216 0.0006 0.06

E8 Abbey Wood 0.035 0.0001 0.01

(17) Air Pollution Information System (APIS) www.apis.ac.uk.


Industries Park 97

Table 20 shows the calculated nitrogen deposition rates (Process

Contribution/additional load) as a percentage of the critical load range and

the total load (i.e. baseline + additional load).

Table 20: Nitrogen deposition rate and critical loads (Kg N ha-1 yr-1)

No. Description

Critical load

range Additional

load (PC)

% of critical load Existing

Deposition

Total

(PEC) Min Max Range

E1 Ingreborne Marshes 10 15 0.02 0.15% 0.23% 15.7 15.7

E2 Inner Thames Marshes 10 15 0.03 0.18% 0.27% 15.7 15.7

E3 Crossness 20 30 0.02 0.07% 0.11% 16.1 16.1

E4 Ripple 20 30 0.09 0.30% 0.46% 16.1 16.2

E5 Scrattons Park 20 30 0.05 0.18% 0.26% 16.1 16.2

E6 St Peter and St Paul Church 20 30 0.12 0.40% 0.60% 15.7 15.8

E7 Thames 10 20 0.06 0.31% 0.62% 16.1 16.2

E8 Abbey Wood 10 20 0.01 0.05% 0.10% 34.3 34.3

Table 20 shows that the Process Contribution / additional load are less than

1% of the critical load and therefore insignificant at all the receptors. The

total nitrogen deposition (PEC) falls within the range of critical loads, except

Abbey Woods where the existing deposition rate is the cause of the

exceedence.

The predicted increments to the nitrogen deposition rates occurring due to

emissions from the proposed facility are therefore insignificant.

Deposition of sulphur and nitrogen compounds can cause acidification and

both must be taken into account when assessing potential for emissions from

the facility to cause acidification.

For acidification, the nitrogen (N) and sulphur (S) deposition rates are

expressed as 'equivalents' which is a measure of how acidifying a substance

can be. The units for N and S deposition are Keq ha-1 year-1.

Table 21 below shows that for the ecological receptors where the habitat is

sensitive to acid deposition the predicted contribution to the acid deposition is

less than 1% and therefore insignificant.


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Table 21: Deposition as percentage of critical load function (keg ha-1

year-1)

No. Description

Process

Contribution (PC) PEC

PC (%age of

CL Function,

%)

PEC (%age of

CL Function,

%) S N

E1 Ingreborne Marshes 0.0034 0.0016 Not calculated (a)

119.4 E2 Inner Thames Marshes 0.0039 0.0019 Not calculated (a)

E3 Crossness 0.0031 0.0015 1.71 0.2% 30.3%

E4 Ripple 0.0134 0.0065 1.73 0.2% 30.3%

E5 Scrattons Park 0.0078 0.0038 1.72 0.4% 30.5%

E6 St Peter and St Paul Church 0.0176 0.0086 1.74 0.4% 29.8%

E7 Thames 0.0091 0.0044 Not calculated (a)

40.8 E8 Abbey Wood 0.0015 0.0007 2.70 0.0% 260%

(a) Not calculated as habitat is not sensitive to acid deposition.

For the non-statutory sites, Figure 6 and Figure 7 below show the predicted

distribution of the increment (process contribution) to ground level

concentration of oxides of nitrogen (NOx) and sulphur dioixide (SO2) for

emissions from facility together with the location on non statutory ecological

sites and the stack.

Figure 6: Predicted annual

average ground level

concentrations of oxides of

nitrogen dioxide (NOx) (µg m-3)

Figure 7: Predicted annual average

ground level concentrations of

sulphur dioxide (SO2) (µg m-3)

Figure 6 shows that the predicted increment to annual average

concentrations of oxides of nitrogen (NOx) at the non statutory sites of

ecological importance are in the range of ~0.5 µg m-3 to a peak of ~2 µg m-3


Industries Park 99

over a small area at close to the point of maximum impact. The increments

are small compared to the assessment criteria of 30 µg m-3.

Figure 7 shows that the predicted increment to annual average

concentrations of sulphur dioxide (SO2) at the non statutory sites of

ecological importance are in the range of ~0.2 µg m-3 to a peak of ~0.6 µg

m-3 over a small area at the point of maximum impact. The increments are

small compared to the assessment criteria of 20 µg m-3.

6.5 Mitigation measures and residual impacts

6.5.1 Construction

Emissions of dust generated during construction can be almost entirely

abated by appropriate mitigation measures. Mitigation measures to be

employed during construction will be drawn from the GLA’s best practice

guidance18 and will be discussed and agreed with LBBD as appropriate prior

to commencement of construction.

6.5.2 Operation

No significant adverse impacts have been identified and therefore no

mitigation measures are proposed.

The assessment has shown that the dispersion provided by the 55 m stack is

sufficient to render the emissions harmless at ground level to both human

health and ecological receptors and therefore no further mitigation measures

are required.

18 The control of dust and emissions from construction and demolition: Best

Practice Guidance. GLA November 2006.


Industries Park 100

6.6 Conclusion

The results of the atmospheric dispersion modelling and assessment clearly

demonstrate that the maximum predicted concentrations of all substances

comply with relevant air quality objectives at nearby sensitive locations and

that a stack height of 55 m would provide adequate dispersion of pollutants

such that emissions from the stack will not significantly affect air quality at

ground level and the impact is considered to be insignificant.

The overall impact on air quality of emissions to atmosphere from the

proposed facility can be described as of minor significance. This conclusion is

based on all the impacts presented in the assessment and takes account of

the localised nature of the area of maximum impact.


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7 Noise and vibration

7.1 Introduction

This section considers the potential noise impact from construction and

operation of the proposed development on nearby receptors. Enzygo Ltd was

commissioned to undertake the noise assessment of the proposed

development; the full assessment report is included in Appendix D and

summarised below.


Noise levels at the three nearest sensitive receptors and at a fourth location

immediately adjacent to the boundary were measured in 2009 and formed

the basis of the noise assessment undertaken by Vibrock Ltd in support of the

extant consent application. The locations are summarised below and the

results of the survey given in Table 22 below.

Loc 1: Shaw Gardens (to the north of the proposed development)

Loc 2: Keel Close (to the west of the proposed development)

Loc 3: Proposed cycle route (to the immediate north of the proposed

development)

Loc 4: North-eastern extent of the Barking Riverside Development (to the

south west of the proposed development)

Table 22: Noise survey results – Vibrock, 2009

Location Survey period Measured LAeq,T Measured LA90,T

Loc 1 – Shaw

Gardens

Daytime 07:00 – 23:00 52 48

Nighttime 23:00 – 07:00 47 43

Loc 2 – Keel

Close

Daytime 07:00 – 23:00 49 44

Nighttime 23:00 – 07:00 47 39

Loc 3 – proposed

cycle route

Daytime 07:00 – 23:00 53 49

Nighttime 23:00 – 07:00 50 46

Loc 4 – Barking

riverside

Daytime 07:00 – 23:00 53 50

Nighttime 23:00 – 07:00 48 46


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Vibrock noted that the noise climate of the area was ‘dominated by road

traffic noise from the A13 and surrounding road network. Aircraft arriving and

departing London City Airport also influence the noise climate as does

residential activity, train movements and bird song’.

7.3 Assessment of impacts

7.3.1 Introduction

The assessment of noise impacts arising from the proposed development has

comprised a number of key stages as follows:

A review of the noise assessment undertaken in support of the previous

application on the site (report complied by Stratus Environmental dated

March 2010 reference CY1052/ES).

Assessment of the potential impacts of the proposed development on the

adjacent sensitive receptor locations, as well as the wider environment.

Consideration of cumulative effects of the proposed development with

other significant development in the area including the adjacent ReFood

AD plant.

Quantification of suitable acoustic mitigation measures and strategies that

could be employed within the design of the site to control noise as

appropriate.

7.3.2 Construction

Construction traffic, site establishment activities and building construction

have the potential to cause short term disturbance to the amenity of nearby

sensitive receptors.

Traffic flows due to construction activities are estimated to be no more than

those during operation (section 10.3.1) and therefore construction traffic

noise is not expected to be a significant issue.


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A construction noise and vibration management plan (CNVMP) has been

prepared and is included as an appendix to the noise assessment (Appendix

D).

The limitation of a predictive noise assessment of construction is that there

are a myriad of potential locations, elevations, acoustic reflections and

refractions, screening parameters and equipment specifications and

combinations that could occur during the normal execution of the required

works. As such it is considered that acoustic control at source and the

implementation of Best Available Technique (BAT) is considered the best

method of control; this approach forms part of the RISK based assessment

contained within the CNVMP.

The assessment seeks to identify the potential main activities at the site

which have the potential to generate noise (and vibration) and provides

details of appropriate control measures that could be implemented where

appropriate.

7.3.3 Operation

Noise emission levels for the key sources were provided by Chinook Sciences

(the technology provider) and are shown on the site plan contained in

Appendix D.

A three-dimensional model of the proposed development was constructed

using the commercial noise mapping software SoundPLAN 7.2. The model

included all sources of noise on the site (both internal and external plant and

equipment and vehicles).

Noise levels were then predicted and assessed at nearby locations considered

to be noise sensitive (i.e. the residential receptors summarised in section 7.2

above).


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The likely impact of the proposed development on residential amenity at the

receptors has been assessed using BS414219 and results are presented in

Table 23 below.

A specific, external noise levels at each receptor location is calculated and

then converted to a ‘rating level’ in order to take account of any tonal or

noticeable characteristics of the noise under consideration. The difference

between the noise from the new development (expressed in terms of the

rating level) and the existing background noise level of the area is indicative

of the likelihood of complaint as follows:

A difference of around +10 dB or more indicates that complaints are likely

A difference of around +5 dB is of marginal significance

A difference of -10dB is a positive indication that complaints are unlikely

Table 23: Predicted noise impacts at nearest sensitive receptors

Location Period

Average

measured L90

‘background

noise level’ dB

Predicted

BS4142 rating

level, dB

(unrounded

value) LAeq

Difference Significance

Shaw

Gardens

Daytime 48 42 (41.6) -6 Less than ‘marginal

significance’

Night-time 43 41 (41.4) -2 Less than ‘marginal

significance’

Keel

Close

Daytime 44 34 (34.0) -10 ‘positive indication that

complaints would be

unlikely’


significance’

Barking

Riverside

Daytime 50 40 (39.7) -10 ‘positive indication that

complaints would be

unlikely’


significance’

It can be seen from Table 23 that noise as a result of operations associated

with the proposed development would be at a level considered by the BS4142

19 BS4142: 1997 Method for rating industrial noise affecting mixed residential and industrial areas


Industries Park 105

Standard to be of less than ‘marginal significance’ towards a ‘positive

indication that complaints would be unlikely’.

Furthermore, the levels predicted are also below the acceptable criteria of L90

+0dB imposed by LBBD on planning consents for other developments within

the LSIP.

It is reasonable to assume that during the nighttime period (2300 - 0700),

residents of the nearby dwellings would typically be within their properties

rather than outside. Therefore, noise impacts occurring within the nearest

dwellings as a result of the proposed development have also been assessed.

This assessment has been undertaken in line with BS823320, assuming a

bedroom on the façade overlooking the site.

In order to calculate the potential ingress of noise, it was necessary to make

an assumption as to the level of attenuation afforded by the façade of these

buildings. In the absence of information on the construction of the houses

dwellings or their glazing, attenuation for an open window for ventilation has

been assumed which could be expected to be in the order of 10 – 15dB. This

is considered to be a worstcase assumption with regard to façade attenuation

as closed windows would give significantly better performance (up to -33

dB(A) potentially). The results of the assessment are presented in Table 24

below and demonstrate that that overnight noise as a result of operation of

the proposed development are at a level which would be acceptable with

regard to the internal design criteria of BS8233.

20 BS8233: 1999 ‘Sound insulation and noise reduction for buildings - Code of practice


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Table 24: BS8233 weekday overnight noise impact assessment

Receptor Period

Predicted façade

noise levels (+3dB

on non-façade

values)

Corrected

internal

levels (-

13dB)

BS8233 Criteria

achieved

Shaw Gardens Nighttime 44.4 31.4 <35dB(A) Reasonable

Keel Close Nighttime 36.6 23.6 <30dB(A) Good

Barking Riverside Nighttime 41.6 28.6 <30dB(A) Good

7.3.4 Cumulative effects

As planning consent has very recently been granted for the ReFood anaerobic

digestion facility on plot 5, immediately to the south of the proposed

development, a cumulative assessment has been undertaken although it

should be noted that no cumulative assessment was undertaken by ReFood,

despite the existence of the extant consent on plot 2.

Data have been used from the ReFood study undertaken by Noise.co.uk in

this cumulative assessment but it is important to note that no validation of

the information or calculations therein have been made.

The Noise.co.uk study only considered one receptor, located at the southern

end of Shaw Gardens and also only considered 06:00 – 22:00 hours. It is

assumed therefore that the ReFood facility is only operational during the

daytime period, and so the cumulative consideration is restricted to these

hours.

The Noise.co.uk study predicted a level of 42.9dB(A) at the properties on

Shaw Gardens, with a resulting BS4142 assessment result of +2dB(A) above

the prevailing background noise climate noted to be of Marginal Significance.

An approximation of the noise associated with the ReFood AD facility has

been made based upon the 1min LAeq Sound Pressure Level quoted in the

Noise.co.uk report; this enables levels at Keel Close and the Barking


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Riverside Development to be estimated utilising Noise.co.uk’s own

methodology.

It is noted that the noise levels presented within the Noise.co.uk report are in

breach of the planning consent condition limit21 granted for the AD facility

and therefore additional noise mitigation will be necessary.

In order to cumulatively consider the resulting noise levels at each of the

three receptors from noise associated with both the proposed development

and the ReFood facility the predicted noise levels of both have been

logarithmically combined to provide a single expected noise level as shown in

Table 25 below.

Table 25: Cumulative daytime noise levels

Receptor

Predicted noise

level LAeq, 1hr

Proposed

development

Estimated noise

level LAeq, 1hr

ReFood AD

plant

Combined noise

level

Measured

current LAeq of

the locality

(Vibrock Study)

Potential Future

LAeq of locality

(increase)

Shaw

Gardens

41.6 42.1 44.9 52 52.8

(+0.8dB)

Keel Close 34.0 35.0 37.5 49 49.3

(+0.3dB)

Barking

Riverside

39.7 48.8 49.3 53 54.5

(+1.5dB)

Table 25 shows that should both developments proceed, that residential

receptors on Shaw Gardens and Keel Close could experience a maximum

increase in ambient noise of 0.8dB which is below the 1dB level of human

perception under normal conditions and therefore would not be considered to

be a significant impact.

With regard to the proposed properties at the Barking Riverside Development

a change in the ambient noise climate of 1.5dB may occur should both

21 Condition 14: The rating level of the noise from the combined operation of plant installed pursuant to

this permission shall not exceed the existing background noise level at the outside of noise sensitive

buildings. Any assessment of compliance with this condition shall be made according to the methodology

and procedures presented in BS4142:1997


Industries Park 108

developments proceed. However, it is important to note that the noise from

the proposed development is significantly lower than that estimated from the

ReFood AD plant such that the increase is predominantly as a result of the

ReFood development; the proposed development alone would not result in an

ambient increase at this location. Moreover, as previously described, the

noise levels reported within the Noise.co.uk assessment for the ReFood AD

facility are already in breach of the levels imposed within the planning

consent. It is therefore considered somewhat unrealistic to base a

cumulative assessment on these levels as the ReFood facility would be

required to meet the planning permission noise limits, and as such noise from

the facility would be reduced as a consequence.

7.4 Mitigation measures

7.4.1 Construction

Condition 25 of the extant consent required the development of a

construction noise and vibration monitoring plan (CNVMP). The scope of the

CNVMP was agreed through discussion with LBBD earlier this year and is

included in Appendix D.

The purpose of the CNVMP is to quantify any potential noise and vibration

impacts associated with the construction of the development and to outline

how these will be both policed and controlled.

The CNVMP will be included within a wider Construction and Environmental

Management Plan (CEMP) to be produced by the main contractor.

7.4.2 Operation

The assessment makes a number of recommendations as follows, which are

summarised below and described in greater detail in Appendix D:

Waste reception building has been assumed to have an internal noise

climate of <85dB(A)


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Noise from the 55m stack is required to be controlled. A reduction of -

25dB(A) on the generated sound power level has been assumed, reducing

the noise emitted to 90dB(A)

All external plant (with the exception of the stack) has been assumed to

have a sound pressure level value at 1m of 85dB(A)

Façades of RODECS plant building to provide minimum Rw composite

sound reduction value of -35dB(A) attenuation including roof provision

with all doors to this building achieving a minimum Rw of -25dB(A).

Façades of the waste reception building to provide a minimum Rw

composite sound reduction value of -25dB(A) attenuation including roof

provision with all doors to this building achieving a minimum Rw of -

15dB(A).

Vehicular access doors remain shut during normal operations.

Personnel doors to provide the same sound reduction as surrounding

cladding system.

7.5 Conclusion

The assessment of the daytime and nightime periods indicate that impact of

noise from the proposed development at the nearest sensitive receptors

ranges from less than ‘marginal significance’ towards a ‘positive indication

that complaints would be unlikely’.

Predicted levels are also below the acceptable criteria of L90 +0dB applied by

the LPA to planning consents for other developments within the LSIP.

Predicted internal noise levels at the identified sensitive receptors would also

be acceptable when considered in accordance with the design criteria of

BS8233.

Therefore, noise resulting from the proposed development would not be

detrimental to the amenity of the nearest noise residential sensitive receptor

locations in the area.


Industries Park 110

8 Visual impact

8.1 Introduction

This chapter considers the visual impact of the proposed development on the

site and its surroundings. The assessment has been undertaken in

accordance with the Guidelines for Landscape and Visual Assessment

published by the Landscape Institute and the institute of Environmental

Management and Assessment and Landscape Character Assessment,

Guidance for England and Scotland published by the countryside Agency and

Scottish National Heritage. These documents do not provide a prescriptive

approach to assessment but identify principles and good practice. The full

assessment is contained in Appendix E.


8.2.1 Baseline visual context

Appendix E provides detailed information about the baseline landscape and

visual context in the area of the proposed development and includes

photographs of views into and on the site and the surroundings.

The proposed development is located in an industrial area with views

punctuated by numerous vertical elements; other tall buildings, pylons,

telecommunication masts, stacks, wind turbines etc.

Views over the surrounding area are limited due to the flat topography and

the considerable amount of existing industrial development, to the north,

east and south of the site. Significant elevated views are restricted to the

artificially raised land at Barking Riverside to the west, Choats Manor Way as

the road crosses over the rail line, the pedestrian footbridge across the A13

Ripple Road, the A13 dual carriageway and from the upper storey of the flats

at the end of Keel Close (off Choats Road). Generally these views are

characterised by substantial residential, industrial and transport infrastructure

development.


Industries Park 111

A 2 km radius around the site zone represents the zone of theoretical

visibility (ZTV), which is the area in which significant effects from the

proposed development are likely to be experienced.

Six receptor types were identified and used in the assessment as follows:

Residential

R1: Goresbrook Road / New Road

R2: Scrattons Farm Estate

R3: Residential area east of Renwick Road (Keel Close)

R4: Thames View Estate west of Renwick Road

R5: Thamesmead

Barking Riverside

BR: Eastern end of Barking Riverside development area

Commercial / industrial

B1: Dagenham Dock

B2: Rippleside industrial area

B3: Pooles Way Logistic Area

Public open space

PO1: Castle Green / Goresbrook Sports Centre

PO2: Scrattons Farm public open space

Roads

RO1: A13

RO1a: A13 Pedestrian footbridge

RO2: Choats Road

RO3: Choats Manor Way

CTRL rail corridor

R1: CTRL corridor


Industries Park 112

8.2.2 Classification of receptors

Receptors vary in their sensitivity and are typically classified and ranked on a

scale from high – medium – low sensitivity. Examples of the categories are

given below:

High

Occupiers of residential properties with views affected by the

development. Users of outdoor recreational facilities including rights of

way where interest may be focused on the landscape.

Medium

Users of outdoor recreational facilities where the view is less important to

the activities (e.g. sports pitches). People at places of work.

Low

People travelling through the area in cars or on trains, or people at places

of work with limited views potentially affected by the development (e.g.

industrial sites).

8.2.3 Magnitude of change

The magnitude of the change in the view can be similarly ranked in a

qualitative manner as follows:

High adverse

Where the scheme would cause a significant deterioration in the view

Medium adverse

Where the scheme would cause a noticeable deterioration in the view

Low adverse

Where the scheme would cause a minor deterioration in the view.


Industries Park 113

No change

Where the scheme overall would not form a noticeable deterioration or

improvement in the view

Low beneficial

Where the scheme would cause a minor improvement in the view

Medium beneficial

Where the scheme would cause a noticeable improvement in the view

High beneficial

Where the scheme would cause a significant improvement in the view

8.2.4 Significance of change

The significance of any effect on visual receptors is directly related to the

sensitivity of the receptor and the magnitude of the change in the view e.g.

potentially significant effects could occur if high sensitivity receptors

(residential) experience major changes in their view because of development.

Conversely, a major change in a view (high magnitude) experienced by a low

sensitivity receptor (industrial building) would be classified as not significant.

The visual resources may also change over time as vegetation installed as

part of the development becomes established and the existing landscape

planting outside the site evolves.

8.2.5 Visual sensitivity of identified receptors

Residential receptors

The majority of the residential receptors identified are located at least a

kilometre away and their views of the development will be largely restricted

to the flue stack in a flat landscape that already contains a large number of

other vertical elements such as the pylons and wind turbines at the Ford

Motor Works. These receptors can be deemed to be of Low to Medium


Industries Park 114

Sensitivity depending on their distance from the development and the

orientation of the individual properties.

Barking Riverside receptors

Presently as this is open ground not used for recreational purposes (other

than possibly occasional dog walkers) it can be classified as Medium

Sensitivity since although it generally has good views over the development

site, users are restricted to those people undertaking surveying or other

construction related activities. However the whole of the portion within the

zone of theoretical visibility is earmarked for either residential development,

informal public open space or sports pitch provision over the coming years.

Consequently some elevated portions of the site (and in particular the

occupiers of the proposed five or six storey residential blocks south of Choats

Road) would be deemed to be of Medium to High Sensitivity depending on

the exact location, orientation and elevation of their residences.

Commercial / industrial receptors

The large windowless nature of many of the buildings in this category, the

distance of many of the units from the site and with the fact that the

occupants are accustomed to working in a similar environment mean all these

receptors can be deemed to be of Low Sensitivity.

Public open space receptors

The open space just to the north of the site on the southern edge of the

Scrattons Farm Estate includes a fenced ball games area and a small play

area and is deemed to be of local significance, the occupiers of the adjacent

estate walking dogs probably constituting one of the principal user groups.

The eastern portion, which was visible, appeared to be overgrown with

brambles with little evidence of informal use.


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The other zone located to the north of the A13 categorised as public open

space is of a far more varied nature. The eastern area closest to the site

contains a wide range of leisure uses. The western half consists of a newly

constructed High School complex and Castle Green public open space (which

again is only deemed to be of relatively local significance). Two other public

green spaces, Parloes Park and Beam Valley Parklands, probably receive

much higher levels of visitors although they are considered to be too distant

from the site to warrant consideration in the context of this particular

development. Consequently this whole group of recreational and educational

users referred to above can be deemed to be of no more than Medium

Sensitivity.

Road receptors

Although the section of the A13 north of the site is elevated, the relatively

high speeds of vehicles on this dual carriageway, mean that this receptor is

deemed to be of Low sensitivity. Users of the pedestrian footbridge over the

A13 are deemed to be of Medium sensitivity due to the fact that some of their

movements may be leisure related and the elevated nature of the views. The

adjacent public highways, are predominately used by commercial vehicles

visiting the surrounding industrial premises. Choats Road is deemed to be of

Low sensitivity while the elevated section of Choats Manor Road located

immediately to the east of the site has been categorised as of Medium

Sensitivity because of its close proximity to the eastern end of the site.

Rail receptors

Rail receptors consist of the Channel Tunnel Rail and an associated fright

depot. As trains will be travelling at high speed along this stretch and the

depot is a place of work both of these are deemed to be Low Sensitivity

receptors.


Industries Park 116


8.3.1 Views from residential areas

Within the Goresbrook Road / New Road (R1) area there will be no change in

the existing view in the majority of cases although the flue stack will be

visible from the first floor windows of some properties and other locations like

the play area in Martin Kinggett Gardens (situated to the south of Goresbrook

Road). The magnitude of this effect is however only considered to be Low as

in most instances the skyline already includes a large number of vertical

elements such as highway lighting columns, sports court floodlights and the

upper portions of electricity pylons. Consequently at its worst the impact is

considered to be Slight Adverse.

Although there are some properties on the Scrattons Farm Estate (R2) facing

in the direction of the site, much of the proposed development will be

screened by existing vegetation for the majority of the year. Again the flue

stack will introduce a new vertical element into the views but as discussed

above this is considered to be in scale with the other existing vertical

structures. As a result the impact is again categorised as Slight Adverse.

Parts of the development and the stack will be visible from the first and

second floor windows of the flats at the end of Keel Close (R3); much of it is

likely to be screened by the existing vegetation on the intervening areas of

open ground. Although the height of the proposed stack is 55 metres above

ground level it does not exceed that of the adjacent pylons and consequently

the magnitude of change can be classed as Low. As a result the visual

impact is only deemed to be Slight Adverse and it is possible that the level of

impact may become negligible over time.

In relation to the both of the remaining residential areas (Thames View

Estate west of Renwick Road and Thamesmead (R4 and R5 respectively)), it

is considered that the development will result in a negligible change in the

existing view due to their distance from the proposed facility, the screening


Industries Park 117

effects of other properties and the industrial character of the adjacent

landscape. Consequently the level of impact has been classed as Negligible.

Views from Barking Riverside

The development will introduce a prominent new element in to the existing

view although it will not be out of scale or character with its surroundings and

can be considered to contribute a degree of unity by screening portions of

pylons and the urban clutter currently visible in the background.

The degree of magnitude of change is considered to be Medium. Views of the

lower part of the southern elevation are softened to some extent by the LSIP

strategic tree planting carried out by the GLA. In addition the finished

ground levels of this part of the Barking Riverside development are envisaged

to be several metres lower than those currently existing. Consequently it is

considered that the careful design and detailing of the western and southern

elevations as shown in Drawing 7487-20-010 will consolidate this

improvement of the existing view and result in a Slight to Moderately

Beneficial visual impact. A photomontage of the proposed development from

this receptor (viewpoint 2) has been prepared and is contained in Appendix

E.

Views from commercial / industrial areas

The proposed development will result in a Medium degree of magnitude of

change for businesses located on Choats Road and Choats Manor Way

although it will be entirely in keeping with the scale and character of existing

views. As the development will serve to screen some of the presently

unsightly Kuehne and Nagel buildings situated to the north of the CTRL and

careful consideration is being given to the detailed design of the proposed

development, it is considered that it will result in an overall improvement of

the existing views. Consequently the level of impact is deemed to be

Moderately Beneficial within the overall context of this industrial area.


Industries Park 118

From the Rippleside Industrial area there will be a Negligible to Low degree of

change to existing views although the upper portion of the stack may be

visible from some locations. Consequently there is considered to be

Negligible visual impact overall.

The magnitude of change in available views from the Pooles Lane Logistic

area is considered to be Low. There is deemed to be a Slight Beneficial effect

as some of the visual clutter of the container yard in the south west corner of

the LSIP will be screened from view.

Views from public open space

Due to the number of existing vertical elements in a highly urbanised

landscape, the magnitude of change is deemed to be Low with an overall

Negligible effect on the quality of the existing view.

A photomontage of the proposed development from the Scrattons Farm

Public Open Space (Viewpoint 3 in Appendix E) shows that views are likely to

be restricted during the summer months due to the existing trees and shrubs

present on the southern boundary although a greater portion is likely to be

visible over the winter period. Consequently the magnitude of change is

considered to be Low to Medium depending on the time of year with an

overall Slight Adverse visual effect.

Views from roads

The magnitude of change in relation to the A13 is deemed to Negligible or

Low depending on the direction of travel. The proposed northern and eastern

elevations of the proposed development will only be partly visible for a very

brief period of time to drivers of vehicles and are overall deemed to have a

Negligible effect on the existing views in the context of the character of the

surrounding landscape.


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For users of the pedestrian footbridge over the A13 the magnitude of change

to the view southwards over the site is likely to be Low during the summer

and Medium during the winter months when the screening effect of existing

vegetation is less effective. At its worst in the winter months the significance

of the effect could be Low Adverse.

Seen from Choats Road the magnitude of change will be Medium although the

development of Plot 5 will probably serve to reduce this to Low, for at least

some of the views. The overall significance of impact is consequently likely to

be Slight to Moderately Beneficial depending on the particular viewpoint.

Viewpoint 1 in Appendix E shows that the magnitude of change of the

existing view from Choats Manor Way is undoubtedly High with the flue stack

being particularly prominent. In visual terms the arrangement of the various

elements at the eastern end of the scheme is altogether more disparate.

However the reduction in scale of the pylons, the partial screening of the

Kuehne and Nagel warehouses and the positive visual contribution that the

proposed surface treatments will make along with the filtering of views

resulting from the proposed tree planting (section 9.4) mean that the overall

significance of effect is only considered to be Negligible to Slight Adverse.

Views from the CTRL rail corridor

It is considered that the speed of travel of the majority of passengers will

mean that in the context of the surrounding urban landscape the magnitude

of change will be Low and the visual impact Negligible.


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Summary

Table 26 provides a summary of the above analysis for each receptor.

Table 26: Summary of visual impact assessment findings

Reference, receptor and location Range of effects

Sensitivity Magnitude Significance

Residential areas

R1 Goresbrook Road / New Road Low -

medium Low Slight adverse

R2 Scrattons Farm Estate Medium Low Slight adverse

R3 Residential area east of Renwick Road

(Keel Close) Medium Low Slight adverse

R4 Thames View Estate west of Renwick

Road Low Negligible Negligible

R5 Thamesmead Low Negligible Negligible

Barking Riverside

BR Eastern end of Barking Riverside

development area

Medium to

High Medium

Slight to

Moderately

beneficial

Commercial / industrial areas

B1 Dagenham Dock Low Medium Moderately

beneficial

B2 Rippleside industrial area Low Negligible -

low Negligible

B3 Pooles Way Logistic Area Low Low Slight

beneficial

Public open space

PO1 Castle Green / Goresbrook Sports

Centre Low Low Negligible

PO2 Scrattons Farm public open space Medium Low -

medium Slight adverse

Roads

RO1 A13 Low Negligible -

low Negligible

RO1a A13 Pedestrian footbridge Medium Low -

medium Slight adverse

RO2 Choats Road Low Medium Slight

beneficial

RO3 Choats Manor Way Medium High Negligible -

Slight adverse

Rail

R1 CTRL corridor Low Low Negligible


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The proposed development is unique in many ways given its location in the

London Sustainable Industries Park (LSIP), a dedicated site for emerging

technologies operating in the field of sustainable resources and energy

technology.

Buildings in the LSIP will be required to achieve high benchmarks for energy

efficiency and sustainability and the environmental infrastructure that

supports them will be exemplary in design and designed to be self-sustaining

as far as practically possible. In addition to the responsible siting of the

proposed development, the materials used to construct the building will

create visual interest and improve the overall quality of the surrounding

industrial landscape. As discussed in this section and the accompanying

Design and Access Statement, it is proposed to use colour and other surface

treatments to ensure that the development makes a positive contribution to

its immediate environment and that the visual impact of prominent elements

such as the flue stack, is minimised.

The landscape infrastructure of Extra Heavy Standard trees already installed

by the GLA will filter views of the facility from the south and Choats Manor

Way as it becomes more established over the coming years.

Plot 5, referred to above, has just received planning approval from the LPA

and it is considered that as the remainder of the LSIP is developed, the visual

quality of the area will improve, serving to further assimilate this proposed

development into its surroundings.

The landscape plan prepared for the proposed development is given in

Appendix L. The plan has been formulated to augment the ‘Urban

Woodland’ character stipulated for the LSIP in design guidance produced by

Sergison Bates Architects and subsequently adhered to by Barry Chinn

Associates when the strategic landscape proposals were produced and

implemented on behalf of the GLA.


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Some residual impacts will remain once the proposed development is fully

constructed and mitigation measures outlined above have been implemented

although some of these will be reduced over time as the tree planting

associated with the site, the LSIP and the proposed new open space in the

northern section of Barking Riverside becomes established.

Due to the height of the stack it is impossible to entirely mitigate its impact

however the proposed treatment of the stack is likely to assist in reducing its

visual impact.

The proposed development is located in an industrial area with numerous

other tall buildings, pylons, telecommunication masts, chimney stacks, wind

turbines etc. so although the stack will be visible from a relatively wide area

it is not generally considered to be out of keeping with the existing visual

resource.

8.5 Conclusion

An assessment of the proposed development’s potential impact on the visual

amenity of the surrounding area has been carried out. The assessment

considered 16 different locations where people are likely to be exposed to

changes in the visual amenity.

The development’s greatest impact on the existing visual amenity has been

judged as Moderately Beneficial in relation to the Dagenham Docks industrial

area, where it is considered within the context of the existing industrial area

that the development will result overall in a beneficial improvement to

existing views. There is one Slight to Moderately Beneficial Impact in relation

to the elevated views from Barking Riverside. There are two Slight Beneficial

impacts on the limited views available from the Pooles Lane Logistic area

(Kuehne and Nagel) and on the views from Choats Road.

Six Slight Adverse impacts have been identified in areas where the

development is largely screened from view for most of the year but the upper


Industries Park 123

portion of the flue stack remains visible, due to its overall height above

ground level. The height of the flue stack was one of the principal factors in

the determination of the impact on the view from Choats Manor Way as

Negligible to Slight Adverse although this may reduce to Negligible over time

as the strategic LSIP and site related tree planting becomes established.

All other impacts were considered to be Negligible.

Overall it is considered that the development does not result in any

unacceptable impacts on the visual resource for the area due to its

established highly industrial character and the very large number of

prominent vertical structures already existing within the surrounding

landscape.


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9 Ecology, nature conservation and biodiversity

9.1 Introduction

This section considers the potential impact of the proposed development on

ecology and nature conservation, both on the site itself and in the

surrounding area.


The site has been completely cleared by the GLA as part of its infrastructure

enabling works for the LSIP.

A breeding bird survey was undertaken in May 2013 by London Conservation

Services to enable discharge of condition 10 of the extant consent. The

survey found no breeding birds within the survey area and concluded that it

was unlikely that there would be any breeding birds as there was an ‘almost

complete absence of suitable nesting habitat’.

The current condition of the site is shown in Figure 8 below; there is limited

ruderal vegetation on the site margins.

Figure 8: Current site condition – November 2013

There are no internationally designated sites (Ramsar, Special Protection

Area, Special Area of Conservation) within 10 km of the proposed


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development. Within 5 km, there are a number of statutory (SSSI and LNR)

designated sites as well as further non-statutory sites (Sites of metropolitan

or borough importance and site of importance for nature conservation

(SINC). Statutory sites within 5 km are shown in Table 27 below.

Table 27: Statutory nature conservation sites within 5 km of the

proposed development

Site name Designation Distance (km)

Ingreborne Marshes SSSI 3.8

Inner Thames Marshes SSSI 3.5

Abbey Wood SSSI 4.2

Beam Valley LNR 2.0

St Peter and St Paul Church Yard LNR 2.1

Crossness LNR 2.2

East Brookend Country Park LNR 4.1

Ingrebourne Valley LNR 4.6

Lesnes Abbey Woods LNR 4.8

Ripple LNR 1.4

Parsloe’s Park Squatts LNR 2.3

Maysbrook Park South LNR 2.3

The Chase LNR 3.5

Rainham Marshes LNR 3.5

Scrattons Park and extension LNR 0.6


9.3.1 Direct impacts – habitat loss / alteration

There will be no direct impacts from the proposed development in terms of

loss / alteration of habitat on site due to the lack of habitats on the site itself.

9.3.2 Indirect impacts - emissions

There is the potential for off-site impacts principally as a result of emissions

to air.

The potential impact on designated sites from the stack emissions has been

assessed in detail in section 6.4.4. The assessment has considered both

emissions of oxides of nitrogen (NOx) and sulphur dioxide (SO2) on a

selection of statutory and important non-statutory sites within a 5 km radius


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as previously agreed with the Environment Agency in accordance with its

guidance (AQTAG06) for nutrient nitrogen and acid deposition.

In all cases, the assessments show that the impact of the proposed

development, in terms of the predicted increments to annual average

concentrations, disposition rates or critical load, is not significant. Where any

critical level is exceeded, this is as a direct result of the prevailing

background concentrations. Given that the impact of the proposed

development on sites within 5 km is insignificant, it is not necessary to

consider potential impact on designated (or candidate) European or

internationally protected sites, the closest of which are more than 10 km

away from the proposed development.

9.3.3 Indirect impacts - shading

In its scoping opinion, LBBD specifically requested that the potential impact

of the proposed development on the Goresbrook and Ship and Shovel Sewer

SINC due to overshadowing be addressed. A series of sunpaths have been

prepared illustrating the shadow cast by the proposed development

throughout the year (Drawing 7487-70-005). The Goresbrook and Ship and

Shovel Sewer SINC runs close to the western and northern boundaries of the

site; the sunpaths clearly show that there is no shadow cast across the SINC

during the summer months (June – September). There is a shadow cast

across the SINC in December but this is not considered to be significant given

that any vegetation in or adjacent to the brook will be dormant at this time of

year anyway.


There will be significant positive impacts from the landscaping scheme that

will be implemented as part of the proposed development (Appendix L).


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The landscape design seeks to augment the urban woodland theme of the

London Sustainable Industries Park and the complementary proposals

recently approved for Plot 5. It consists of the following principal elements:

two to three rows of Extra Heavy Standard tree planting on southern and

eastern boundaries and some taller faster growing trees on a green island

within the site that will serve to filter views of the facility from both within

the park and from Choats Manor Way

shrub planting comprising of species of value to wildlife around the car

park and in the garden area adjacent to the office building

excavation of linear depression to create new damp habitat at eastern end

of the site which will reinforce the similar ecological niche along

established in the Goresbrook corridor

establishment of wildflower species associated with woodland and hedges

and wetter ground in order to encourage a wide range of invertebrates

and assist in the achievement of a BREEAM excellent rating for the

development.

9.5 Conclusion

The site has been cleared ready for development. The landscape plan

continues the GLA’s urban woodland theme and will encompass the creation

of a range of new habitats. Implementation of the proposed development

therefore will provide direct and indirect ecological benefits.


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10 Transport and access

10.1 Introduction

This section assesses the impact of vehicle movements associated with the

proposed development during construction and operation.


The site is currently unoccupied and so there are no vehicle movements at

present. However the site already has planning consent for an identical use

to that proposed.

The approach to assessment of transport-related impacts taken in the EIA,

submitted in relation to the extant consent, was to compare the vehicle

movements from the proposed development with those expected under the

outline consent (ref 04/00524), which allowed the LSIP site to be developed

for B1/B2/B8 uses.

This approach, and its conclusions, were accepted by the GLA / TfL and the

LPA (Thames Gateway Development Corporation / LBBD):

In the stage 1 referral report (ref PDU/2507/01), Transport for London’s

comments note that ‘although the site is currently partly vacant, this

actually represents a reduction of the trip levels anticipated to be

generated by the previous consented use for the site. As a result, TfL

accepts that the development would not have a significant impact on the

local highway network of Transport for London Road Network’.

Para 1.4 of the planning committee report states that ‘in terms of

transport movements to and from the site during both the construction

and operations phase, the conclusions of the Environmental Statement

that the impacts in respect of highway capacity and highway safety are

considered either negligible or moderately beneficial predicated on the


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transport assumption made as part of the extant outline planning

permission are accepted.’

A daily total of up to 86 HGV trips and 70 car trips was estimated to result

from the consented development, which represented a significant reduction

compared with the development consented under 04/00524/OUT.


10.3.1 Construction

Construction of the proposed development would create approximately 50 –

130 temporary jobs (section 3.9). The construction workforce would be

expect to be located close to the site and would be encouraged to use a

common vehicle between a number of workers to reduce vehicle movements.

Parking for construction workers will be provided on-site during construction,

within the development boundary.

HGV deliveries during the construction period will vary dependent on the

activities on site with larger numbers of deliveries, estimated to be up to 20 /

day, associated with earthworks and foundations. At other times, HGV

deliveries will be approximately 2 – 5 / day. There will also be approximately

20 oversized loads associated with key items of the process equipment.

Movement of oversize loads would be coordinated with the local highway

authority.

It is anticipated that construction traffic will not exceed the levels associated

with the operational phase which is discussed in the following section.

10.3.2 Operation

Assessment methodology

The methodology used for predicting the impact of the proposed development

on transport is set out below.


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The same approach as that undertaken in relation to the extant consent has

been followed i.e. vehicle movements from the proposed development will be

compared with those expected under the extant consent (ref

10/00287/LBBD), which allows the site to be developed for use as an energy

generation facility.

There are four principal changes from the development permitted under the

extant consent that have an impact on vehicle movements:

Waste to be treated at the facility will increase to 180,000 tonnes / year

from 120,000 tonnes / year.

Waste will be delivered and residual waste exported in bulk HGVs resulting

in a higher payload / vehicle (assumed to be 20 tonnes / HGV rather than

10 tonnes / HGV).

Metals will be exported from the facility for further recycling / processing

resulting in an additional stream.

Employee numbers are increased over that assumed in the extant consent

from 35 to 55 staff in total. Of these 55, 45 staff will be employed in

production across either two or four shifts, dependent on the specific role,

and 10 non-production staff, who would work general office hours.

There is no change proposed to delivery hours i.e. deliveries will be accepted

between the hours of 07:00 – 22:00 Monday – Friday and 07:00 – 17:00 on

Saturdays, over the equivalent of 304 days / year (six days / week excluding

bank holidays).

All other assumptions are the same as in the assessment submitted for the

extant consent e.g. all staff assumed to drive to work, HGV movements


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spread evenly throughout allowed delivery hours, no backfilling of vehicles

etc22.

Table 28 below summarises the vehicle movements associated with deliveries

of waste and export of residual materials / recyclables under the extant

consent and the proposed scenarios.

Table 28: Operational HGV movements – extant and proposed

Parameter Extant consent Proposed

Waste (in) Ash (out) Waste (in) Ash (out) Recyclables (out)

Tonnes 120,000 10,980 180,000 25,900 8,600

Tonnes / HGV 10 11 20 20 20

Deliveries / year 12,000 1,000 9,000 1,295 430

Total 13,000 10,725

Table 29 below summarises the vehicle movements associated with staff

journeys to and from work for the extant consent and the proposed

amendment. The four shift system in operation for production staff means

that there will be a maximum of 47 staff on site in any 24 hour period.

Table 29: Staff vehicle movements – extant and proposed

Time Extant consent Proposed

In Out In Out

05:00 - 06:00 9 16

06:00 - 07:00 8 6

07:00 - 08:00

08:00 - 09:00 9 10

09:00 - 10:00

10:00 - 11:00

11:00 - 12:00

12:00 - 13:00

13:00 - 14:00 9 15

14:00 - 15:00 9 16

15:00 - 16:00

22 It is likely that some backfilling of vehicles will occur, which will reduce the number of HGV movements.

However, it is not possibly to accurately quantify the amount at this stage and so to ensure a conservative

and robust assessment, it is assumed that no backfilling will take place.


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Time Extant consent Proposed

In Out In Out

16:00 - 17:00

17:00 - 18:00 9 10

18:00 - 19:00

19:00 - 20:00

20:00 - 21:00

21:00 - 22:00 8 6

22:00 - 23:00 9 15

Total 35 35 47 47

Summary

Table 30 below shows the overall vehicle trips for both the extant consent

and proposed operations. It can be clearly seen that the proposed change to

the tonnage treated has no significant impact on vehicle movements and in

fact, total number of HGV movements is reduced compared with the extant

consent owing to the use of larger vehicles.

The report of the Director of Planning for the extant consent stated in para

1.4 that ‘in terms of transport movements to and from the site during both

the construction and operations phase, the conclusions of the Environmental

Statement that the impacts in respect of highway capacity and highway

safety are considered either negligible or moderately beneficial predicated on

the transport assumptions made as part of the extant outline planning

permission are accepted’. Furthermore, in para 9.57, the Council’s ‘Transport

Development Management team and TfL … accept that the development

would not have a significant impact on the local highway or the TfL road

network’.

Therefore, given that the vehicle movements associated with the extant

consent do not have a significant impact, it can be concluded that the similar

number of movements associated with the proposed development will have

no impact either, particularly as the HGV movements associated with the

proposed development are lower than in the extant consent; the increase of


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8 trips / day overall is due to the increased number of employees resulting in

assumed additional car trips.

It is important to note that the assessment assumes that all employees drive

to work on their own. Census travel to work data referred to in the

accompanying draft travel plan (Appendix F), indicate that it is more likely

that around 20 staff would drive to work, two would be a passenger in a car /

van, 19 would use public transport, four walk, and one each travel by

motorcycle and bicycle.

Environmental Statement for proposed energy generation facility on Plot 2, London Sustainable Industries Park 134

Table 30: Predicted traffic flows – staff and HGVs for extant consent and proposed operations

Time

Extant consent vehicle movements Proposed vehicle movements

Staff Commercial Total Staff Commercial Total

In Out In Out In Out Total In Out In Out In Out Total

Cars HGV All vehicles Cars HGV All vehicles

05:00 - 06:00 9

9 0 9 16

16 0 16

06:00 - 07:00

8

0 8 8

6

0 6 6

07:00 - 08:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

08:00 - 09:00 9

2.9 2.9 11.9 2.9 14.8 10

2.4 2.4 12.4 2.4 14.7

09:00 - 10:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

10:00 - 11:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

11:00 - 12:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

12:00 - 13:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

13:00 - 14:00 9

2.9 2.9 11.9 2.9 14.8 15

2.4 2.4 17.4 2.4 19.7

14:00 - 15:00

9 2.9 2.9 2.9 11.9 14.8

16 2.4 2.4 2.4 18.4 20.7

15:00 - 16:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

16:00 - 17:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

17:00 - 18:00

9 2.9 2.9 2.9 11.9 14.8

10 2.4 2.4 2.4 12.4 14.7

18:00 - 19:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

19:00 - 20:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

20:00 - 21:00

2.9 2.9 2.9 2.9 5.8

2.4 2.4 2.4 2.4 4.7

21:00 - 22:00 8

2.9 2.9 10.9 2.9 13.8 6

2.4 2.4 8.4 2.4 10.7

22:00 - 23:00

9

0 9 9

15

15 15

Total 35 35 43.5 43.5 78.5 78.5 157 47 47 35.3 35.3 82.3 82.3 165


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135


10.4.1 Introduction

The assessment in section 10.3 above has demonstrated that vehicle

movements associated with the proposed development are very similar to

those under the extant consent; whilst assumed employee trips are slightly

higher, HGV movements are reduced. As vehicle movements under the extant

consent had no significant impact on the existing network (section 10.3.2)

there are therefore no specific mitigation measures required with respect to

vehicle movements.

However, a number of policies at national, regional and local level (e.g. NPPF

policy 4, London Plan policies 6.3 and 6.9 and Barking and Dagenham DPD

policies BR10 and BR11 (section 4.3.3)) require measures to reduce the need

to travel where possible and encourage travel by more sustainable means;

mitigation measures with respect to more sustainable transport options are

discussed below.

10.4.2 Waterborne transport

The residual waste to be treated at the proposed development will come from

a number of locations within the east and north London area. It is not

practicable therefore to consider transport by water during the operation of

the development.

The possibility of bringing in materials by river during the construction phase

will be reviewed with shortlisted contractors during the procurement process.

10.4.3 Cycle parking

Twenty secure, covered cycle parking spaces will be provided in two locations;

adjacent to the office entrance and close to the materials reception building as

shown on drawing 7487-70-003.


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136

10.4.4 Electric cars

Dedicated parking spaces and charging points for four electric cars, with

passive provision provided in a further two spaces will be provided as shown

on drawing 7487-70-003.

10.4.5 Shuttle service

TGW2E has committed to the provision of a minibus shuttle service to / from

Dagenham Dock station at appropriate times of day to be agreed once the

facility is operational.

10.4.6 Travel plan

A draft travel plan has been produced which is included in Appendix F. The

travel plan cannot be finalised until the development is operational and the

preferred travel modes of staff and their journeys are known. The travel plan

will be finalised within six months of the development becoming operational

and submitted to LBBD for approval.

10.5 Conclusion

The vehicle movements associated with the proposed development are very

similar to those under the extant consent, which were found to have no

significant impact on the local highways or TfL road network. HGV movements

are reduced but employee car movements are slightly higher reflecting the

increased number of jobs. Employee vehicle movements have also been

calculated on a worst case basis assuming all employees drive; in reality staff

will use a number of transport modes and the travel plan is specifically

targeted at reducing single person car journeys to and from the site.


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137

11 Geology, ground conditions and land quality

11.1 Introduction

Existing ground conditions under the proposed development have been

characterised through numerous desktop and intrusive investigations on the

site and the surroundings, the findings of which have been previously

submitted to LBBD in support of earlier planning applications for the site.

Most recently, a Phase 1 desk-based assessment was undertaken by TGW2E

(Appendix G) and submitted to LBBD to discharge condition 22a of the extant

consent, which states that:

No development approved by this permission shall be commenced prior to a

contaminated land assessment and associated remedial strategy, together

with a timetable of works, being submitted to the Local Planning Authority for

approval:

a) The contaminated land assessment shall include a desk study to be

submitted to the Local Planning Authority for approval. The desk study

shall detail the history of the site uses and propose a site investigation

strategy based on the relevant information discovered by the desk study.

The strategy shall be approved by the Local Planning Authority prior to

investigations commencing on site.

Following approval of the Phase 1 desk study, TGW2E has undertaken a site

investigation in accordance with the assessment methodology approved by

LBBD. The assessment has included relevant sampling and analysis and

production of a revised conceptual model. The Phase 1 and Phase 2

assessments are contained in Appendix G and Appendix H respectively and

the findings are summarised in this chapter.


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138


11.2.1 Previous contaminative uses

The site itself and the wider area have been developed over approximately the

last 100 years for a range of uses including rail sidings, sewage treatment

plant and most recently as a depot during construction of the Channel Tunnel

Rail Link. A number of historic landfills have been identified within 250m of

the site boundary but these are not considered to pose a significant risk to the

site.

11.2.2 Ground conditions

BGS borehole records at the site confirm the presence of Made Ground to

depths of between 1.5m and 3m depth over soft alluvial clays and peat

typically to 6m depth. Sand and Gravel consistent with River Terrace Deposits

were noted to depths of around 10 to 12m overlying the silt and clay of the

Lambeth Beds.

11.2.3 Groundwater

The recorded permeability of the drift geology is moderate to very low

reflecting the variability of the Alluvium and underlying sand and gravels.

Permeability of the solid geology is identified as moderate to very low

reflecting the variability of the Lambeth Beds which are inter-bedded sands.

The site does not lie within outside any source protection zone and there are

no groundwater abstraction wells within 2000m of the site.

The site is shown as being at very high risk of groundwater flooding. This is

likely to be due to the potential for near surface groundwater within the

Alluvium. As site levels appear to have been raised as part of land reclamation

works this risk is considered a lower risk more likely to be associated with

underground structures, which can be addressed through design.


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139

11.2.4 Hydrology

The closest surface main watercourse to the site is the Gores Brook located

10m from the northern and western boundary of the site. The Gores Brook

flows from the north to the south and discharges into the River Thames. A

drain is present 15m E of the site flowing along the site boundary and

discharging in to the Gores Brook.

A review of the Environment Agency’s flood maps indicate that the proposed

site lies within Flood Zone 3.

There are no licensed surface water abstractions within 250m of the site.

11.2.5 Coal mining search

No coal or other mining activity is identified below or close to the site.

11.2.6 Ground Workings

No active ground workings have been identified within 250m of the site.

A number of historic surface extractions have been identified within 250m of

the site; all are considered low / no risk.

11.2.7 Radon

The Groundsure Report indicates that no radon precautions are necessary.

11.2.8 Summary

The site is considered to be of moderate sensitivity for the following reasons:

The end purpose is for commercial / industrial use.


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140

The bedrock is classified as a Principal Aquifer, however this is overlain by

a secondary aquifer.

The site is situated outside of a Source Protection Zone.

There are no ecological sensitivities on site or adjacent to the site.

There are no groundwater abstractions on site or adjacent to the site.


11.3.1 Preliminary conceptual model

The conceptual site model (CSM) is a dynamic representation of the site, to be

refined and developed at each stage of the site investigation process.

The conceptual site model contains three principal elements:

Source - probable or actual contaminants; their nature and location.

Receptor– existing and, within reason, foreseeable targets, on or off-site,

which the source may affect.

Pathway – the means by which the source and the receptor may come into

contact.

Where a source – pathway – receptor pollutant linkage is envisaged, an

estimation of the risk posed by this linkage can be made. Should any one of

the three elements (source, pathway or receptor) be absent, then there is no

risk. Table 31 presents the preliminary conceptual model for the site in its

existing state.

Table 31: Preliminary conceptual model

Source Location Exposure

pathway

Potential

receptor

Probability of

exposure

Details

Human health

Metals Former sewage

works

Ingestion and

dermal

Construction

workers

Dismissed Normal PPE will

address risk

Site users Negligible No

contamination

identified

Hydrocarbons Oil storage

tanks

Ingestion,

dermal and

inhalation

Construction

workers


address risk

Site users Negligible No

contamination

identified


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pathway

Potential

receptor

Probability of

exposure

Details

Heavy metals

(lead TP703)

Made ground Ingestion,

dermal and

inhalation

Construction

workers


address risk

Site users Low Remediation in

soft landscape

areas

recommended

Hydrocarbons,

metals and

asbestos


dermal and

inhalation

Construction

workers

Dismissed Normal

construction

PPE will

address risk

under CDM

Site users Negligible No significant

sources

identified

Hydrocarbons

and metals

Unforeseen

contamination

Ingestion,

dermal and

inhalation

Construction

workers

Dismissed Normal

construction

PPE will

address risk

under CDM

Site users Low Discovery

strategy

Ground gas Made ground

and landfill

Inhalation and

explosive

Construction

workers

Low No confined

entry likely

Site users Low Characteristic

situation 2

Groundwater

Hydrocarbons

and metals

Potential

spillage on site

Vertical

migration

Groundwater Negligible DQRA shows no

significant risk

Surface water

Hydrocarbons

and metals

Potential

spillage on site

Horizontal

migration

Watercourses Negligible DQRA shows no

significant risk

Environmental receptors

On site contaminants Ingestion,

dermal and

inhalation

Ecology Dismissed No ecological

designations

Direct Archaeology Dismissed No receptor

Direct Geology Dismissed No sensitive

receptor

Phytotoxic Woodland Dismissed No receptor

Phytotoxic Crops Dismissed No source

Ingestion,

dermal and

inhalation

Livestock Dismissed No source

Building services

On site contaminants Direct Historic

building

Dismissed No receptor

Direct Proposed

buildings

Dismissed No significant

source

Permeate into

pipework

Water pipes Dismissed No significant

source


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11.3.2 2013 site investigation

The full report is contained in Appendix H with key findings summarised in this

section.

The site works comprised eight trial pits (TP1 – TP8) and seven cable

percussive boreholes (BH1 – BH7) and were undertaken between 16st and 31st

July 2013. Groundwater and gas monitoring wells were installed within the five

of boreholes. Locations of all exploratory holes are shown on Drawing

CRM.035.006.D.003 in Appendix H.

Contamination samples were generally taken within the upper 1m as this

material is likely to have been impacted by potential spillage and leakage

associated with the previous industrial use. In addition, samples were taken

from soils showing evidence of contamination and also samples from below

areas of potential contamination.

Four return visits were undertaken to monitor ground gas and measure depth

to groundwater. During one of the visits, groundwater samples were taken

from the boreholes with the wells.

Ground conditions

The site investigation confirmed the published geology and identified the

following strata:

Made ground

Alluvium

Terrace Gravels

Lambeth beds

Thanet sands

Groundwater was encountered within all exploratory holes.


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Visual and olfactory evidence of contamination, black staining in the made

ground, was encountered in TP3, TP5, BH5 and BH7 with black staining at a

greater depth in the Lambeth Beds encountered in BH4 and BH6.

11.3.3 Risk assessment

A Tier I risk assessment has been undertaken using available and current

screening values for human health and where appropriate controlled waters.

The risk assessment is undertaken based on the findings of the preliminary

conceptual model given in Table 31. Based on the contamination testing and

Tier I assessment a revised Conceptual Model has been prepared, which is

given in Table 31 below.

Where significant risks are identified remedial measures are recommended.

Human health

Assessment of the risks to human health has been undertaken by comparing

the soil quality data from both the current (2013) investigation and analyses

previously undertaken by others, with reference values obtained from the

Contaminated Land Exposure Assessment (CLEA), Soil Guideline Values (SGV)

and General Acceptance Criteria (GAC). A summary table of the reference

values is included in Appendix H.

Where an exceedance is identified the risk is assessed by considering the

sensitivity of the proposed development and the potential pathway. As the

site is to be developed as an Energy Recovery Facility it is considered that

commercial values are applicable.

The soil quality analyses from all studies only show exceedances above the

reference values for a commercial end use as shown in Table 32 below.


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Table 32: Locations where reference values exceeded

Location / depth / study Determinand GAC (mg/kg) Concentration (mg/kg)

Enzygo 2013

TP4A at 0.35m Lead 590 2136

BH2 at 0.30 – 0.50m Lead 590 610

PBA 2007

TP703 2.40m Lead 590 7222

ESI 2007

69316 2.50m Arsenic 640 1028

ES1 2010

TP22 0.80m (off site) Lead 590 930

Asbestos fibres, confirmed as chrysotile, were detected in two locations (TP3

and TP5) at a depth of 0.40 m.

The elevated lead and arsenic are considered to originate from ash and clinker

within the made ground and are only considered to pose a risk where they can

be exposed to site users. Encapsulation below hardstanding will effectively

break the source pathway-receptor scenario.

Controlled waters

A detailed quantitative risk assessment (DQRA) was undertaken in 2010, the

results of which are summarised in Appendix H. The DQRA showed no

significant risks to controlled waters although identified a possible impact from

ammoniacal nitrogen, probably resulting from the former sewage treatment

works, which could impact controlled waters after 500 years. It is considered

that capping the site with hardstanding as part of the proposed development

will reduce water ingress and therefore reduce the potential impact from this

ammoniacal nitrogen.

Groundwater concentrations measured in samples collected during the 2013

investigation have been compared against threshold concentrations derived


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from the 2010 DQRA or reference values23 as appropriate. An assessment of

likely risk has then been made based on a source-pathway-receptor model.

Determinands were generally below the respective limits and most are below

screening values with the exception of the results given in Table 33 below.

Table 33: Elevated groundwater concentrations recorded in 2013

study Location Determinand Threshold (mg/l) Concentration (mg/l)

BH2 Anthracene 0.02 0.03

BH5 Anthracene 0.02 0.03

BH6 Zinc 254 300

There were no elevated concentrations of anthracene or zinc measured in soil

samples collected from these boreholes.

Ash was noted in the made ground in BH6 which may account for the elevated

zinc concentration. BH6 is located on the southeast of the site away from

Gores Brook and boreholes located nearer the brook did not record elevated

zinc concentrations indicating that it is unlikely that the zinc will migrate to the

brook. Moreover, any groundwater entering the brook will be significantly

diluted and so the exceedance of the EQS in groundwater at BH6 is not

considered to have any significant impact on surface water quality.

Risk to the aquifer is dismissed as the concentration is below drinking water

standards.

No sources of anthracene were noted in the boreholes and no other

polyaromatic hydrocarbons (PAH) concentrations exceed threshold values.

It is likely that the minor exceedance by anthracene may be a result of

residual water impact following previous remediation works and that

23 Fresh water Environmental Quality Standards (EQS), UK drinking water Standards (DWS) and World

Health Organisation (WHO) values for drinking water


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anthracene has been identified as a potential exceedance due to its very low

EQS value. Again, as groundwater entering Gores brook will be significantly

diluted, the marginal exceedance for anthracene is not considered to have any

significant impact on surface water quality.

The installation of hardstanding / buildings over 84% of the site, together with

the proposed drainage system will eliminate the potential for future surface

water percolation into the underlying materials and groundwater.

As a previous remediation exercise has been carried out and the chemicals

identified have only been encountered in isolated pockets and the exceedances

have not been encountered in groundwater closer to the receptor it is

considered that the residual EQS exceedances identified in the groundwater

are not migrating to the receptor.

It is therefore considered that these residual determinants will naturally

attenuate into the surrounding ground before reaching the receptor.

Ground gas

Where potential risk from ground gas has been identified from the preliminary

conceptual model and the intrusive ground investigation works, the results of

the monitoring are compared against relevant gas screening values24. From

this analysis, the Characteristic Situation is identified and remedial measures

proposed as appropriate.

When assessing the risk and type of remedial measures appropriate,

consideration is given to the likely construction of the development, the nature

of the gas posing a risk and the nature of the likely source.

Given the presence of peaty materials and as carbon dioxide concentration

was recorded above 5% during a number of visits consideration has been

24 CIRIA Report 665


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given to increasing the gas risk situation. However, due to the absence of

measurable gas flow and the nature of carbon dioxide, which is heavier than

air, there is not considered to be a significant risk that gas can enter buildings.

Therefore, it is considered that Characteristic Situation 1 still applies and no

special precautions are required.

11.3.4 Revised conceptual model

The preliminary conceptual model (Table 31) has been revised in the light of

the findings of the site investigation and the risk assessment discussed in

section 11.3.3 above. The revised conceptual model is given in Table 34

below.

Table 34: Revised conceptual model


pathway

Potential

receptor

Probability

of exposure

Details

Human health

Metals Former

sewage works

Ingestion

and dermal

Construction

workers

Low Remediation

recommended

Site users

Hydrocarbons Oil storage

tanks

Ingestion,

dermal and

inhalation

Construction

workers

Dismissed No exceedance of GAC

values

Site users

Heavy metals

(lead TP703)


dermal and

inhalation

Construction

workers

Low Remediation

recommended

Site users

Hydrocarbons,

metals and

asbestos


dermal and

inhalation

Construction

workers

Dismissed No exceedance of GAC

values

Site users

Hydrocarbons

and metals

Unforeseen

contamination

Ingestion,

dermal and

inhalation

Construction

workers

Dismissed Normal construction PPE

will address risk under

CDM

Site users Low Discovery strategy

Ground gas Made ground

and landfill

Inhalation

and

explosive

Construction

workers

Dismissed Characteristic situation

1

Site users

Groundwater

Hydrocarbons

and metals

Potential

spillage on site

Vertical

migration

Groundwater Negligible DQRA shows no

significant risk.

Concentrations below

DWS

Surface water

Zinc BH6 Horizontal

migration

Watercourses Dismissed Source away from

surface watercourse.

Any ingress will be

diluted below EQS.

Capping site will reduce

potential migration.


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pathway

Potential

receptor

Probability

of exposure

Details

Anthracene BH2 and BH5 Horizontal

migration

Watercourses Dismissed No source noted. Slight

exceedance of EQs only.

Any ingress will be

diluted below EQS.

Capping site will reduce

potential migration.

Environmental receptors

On site contaminants Ingestion,

dermal and

inhalation

Ecology Dismissed No ecological

designations

Direct Archaeology Dismissed No receptor

Direct Geology Dismissed No sensitive receptor

Phytotoxic Woodland Dismissed No receptor

Phytotoxic Crops Dismissed No source

Ingestion,

dermal and

inhalation

Livestock Dismissed No source

Building services

On site contaminants Direct Historic

building

Dismissed No receptor

Direct Proposed

buildings

Dismissed No significant source

Permeate

into

pipework

Water pipes Dismissed No significant source


The proposed development utilises hard landscaping, which will provide a

barrier between future site users and any contamination present within the

underlying soils effectively breaking the source-pathway-receptor model.

As concentrations of determinands where the primary pathway is inhalation

have not been detected above the relevant GAC value the risk from indoor

inhalation can be dismissed.

There is a low risk to construction workers from concentrations of lead, arsenic

and potential asbestos fibres in the soil; these risks should be addressed by

the Contractor under its Construction Stage Health and Safety Plan, as

required by the Construction, Design and Management (CDM) Regulations.


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These measures are likely to include:

Management of the construction works to limit access to potentially

contaminated soils by construction staff.

Securing the site to prevent access by unauthorised people and

requirements for site induction for site staff.

Use of a clean area with appropriate welfare facilities.

Management of dust through control of any bulk earthworks operation and

where necessary wetting down.

Use of appropriate PPE.

Remedial measures to protect controlled waters are not considered necessary

following the assessment of the results. It is recommended that the

hardstanding is utilised to manage future surface water ingress to the site

thereby reducing potential migration of groundwater into the surface

watercourses. This will provide environmental betterment through

construction.

It is recommended that surface water samples are collected from Gores Brook

for analysis to confirm that there are no adverse impacts on surface water

quality prior to and following the construction works. Samples should be

collected as follows:

one sample up-stream of the site

one sample adjacent to the site

one sample down-stream of the site.

If unforeseen contamination is encountered during construction works such as

localised spillage outside the areas investigated an Environmental consultant

will be available on a ‘call out’ basis to undertake an assessment of risk. If

‘unforeseen contamination’ is encountered, the discovery strategy will be to

remove the source as it is likely to be very limited in extent.


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11.5 Conclusion

The small number of pollutant linkages that exist will be removed through the

installation of hardstanding on site. There are no significant risks to human

health for the site’s end users once the development is completed. Potential

risks to workers during construction will be addressed through appropriate

working procedure and equipment.


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12 Water resources

12.1 Introduction

Assessment of impact on water resources – hydrology, hydrogeology, flood

risk and drainage was initially scoped out of consideration (Appendix A) on the

basis of the findings of the previous EIA and the fact that the proposed

changes in terms of the new technology / layout would not affect these

findings.

LBBD agreed that there was no need for a new FRA to accompany the

application on the basis that the mitigation measures described in the previous

assessment and included in condition 21 of the extant consent have been

incorporated into the design of the proposed development and will be complied

with for the life of the development.

However, Thames Water, in its response to LBBD during the scoping process,

expressed a concern that the network may be unable to cope with demand

and requested that the following issues be considered:

The proposed development’s demand for water supply and network

infrastructure both on and offsite

The proposed development’s demand for sewage treatment and network

infrastructure both on and offsite

The surface water drainage requirements and flood risk of the development

both on and offsite

Piling methodology and its potential impact on neighbouring utility services.

These specific issues raised by Thames Water are addressed in this section.


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The ground conditions including groundwater and hydrology have been

described in section 11.2. The site is at high risk of groundwater flooding due

to the potential for near surface groundwater within the Alluvium.

The site does not lie within outside any source protection zone and there are

no groundwater abstraction wells within 2000m of the site.

The closest surface main watercourse to the site is the GoresBrook located

close to the northern and western boundary of the site. The GoresBrook flows

from the north to the south and discharges into the River Thames.

There are no licensed surface water abstractions within 250m of the site.

A review of the Environment Agency’s flood maps indicate that the proposed

site lies within Flood Zone 3.

There is currently no drainage infrastructure on the site.


12.3.1 Construction

Specific impacts on water resources during construction of the proposed

development may include:

Pollution of ground waters caused by improper handling and disposal of

construction site wastewater.

Spillage or infiltration of oils, fuels, and hydraulic fluids etc from plant

maintenance and refuelling areas onto ground.

The production of wastewater with potentially high particulate loads which

may require treatment prior to disposal.


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Piling methodology

The proposed development will utilise precast driven piles, which will only

have a localised effect on the surrounding ground. The buildings and

equipment foundations that are to be piled are all within the site, a minimum

of 5m away from the site boundary; there will therefore be no impact on any

services outside the site.

12.3.2 Operation

Water supply

Detailed discussions with Essex and Suffolk Water to date have not identified

any concerns with respect to provision of a water supply to the site.

The flood risk assessment undertaken by Price and Myers in relation to the

whole LSIP identifies that the site of the proposed development is already

above the minimum build level of 1.625m AOD agreed with the Environment

Agency. A maximum rate of surface water discharge has been set at 6l/s/ha

for all storm conditions. Surface water will be collected on site by traditional

below ground drainage systems with incorporated attenuation tanks designed

for the various storm conditions and finally discharged into the estate drainage

system at the two site entrances provided by the GLA as part of the overall

LSIP development.

Waste water

Waste water from the proposed development site will be collected by

traditional below-ground gravity drainage systems and prior to discharge into

the estate drainage system at the two site entrances provided by the GLA as

part of its infrastructure enabling works. The maximum discharge

requirement of 5l/s and specified chemical content has been agreed with the

GLA. TGW2E understands that the GLA is currently in negotiation with

Thames Water to improve the downstream foulwater drainage system and


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pumpstation to meet the requirements from all of the existing and proposed

developments on the LSIP.

Drainage design

The proposed drainage strategy is shown in Drawing MA9580/200 and has

been designed in accordance with the FRA for the LSIP undertaken by Price

and Myers (report dated 29 January 2010) and the Surface Water

Management Strategy for Plot 2 undertaken by MMI Civils in relation to the

extant consent (report dated February 2010).

Key elements of the drainage design area as follows:

Discharge limited to greenfield surface water run-off rate of 6l/s/ha.

Infiltration-based drainage methods are not feasible due to the highly

variable and unpredictable percolation characteristic combined with the

high water table.

The SUDS strategy is based on attenuated surface water to final discharge

into public sewer incorporating rainwater harvesting for use on site where

possible.

1890m3 of underground storage will be installed, located as shown on

Drawing MA8605/200 to provide sufficient storage for 1 in 100 year event.

An additional 300m3 storage will be provided for rainwater harvesting

subject to enduser requirements.


12.4.1 Construction

The mitigation measures described below are based on best practice detailed

in the Environment Agency’s Pollution Prevention Guidelines (PPGs), and

anticipated construction techniques and will be incorporated into the

Construction Environmental Management Plan (section 3.9).


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Surface water runoff

Site surfaces should be compacted to help reduce the amount of surface water

soaking into the ground and the amount of silty water that has to be dealt

with.

Open stockpiles of materials and areas of exposed, unmade ground will be

minimised. Stockpiles of construction materials (e.g. aggregates sand and fill

materials) should be covered with tarpaulin or a silt fence constructed using a

suitable geotextile, as a matter of course, but particularly during rainstorms.

Plant and wheel washing

All vehicles and plant will be cleaned if necessary, before leaving the

construction site, to ensure that no earth or mud etc is deposited on the road.

Wheel washers and plant washing facilities will be securely constructed with no

overflow and the effluent will be contained for proper treatment and disposal.

Fuel and oil storage

All fuel and oil will be stored on an impermeable base within a bund and

secured. The base and walls will be impervious to the material stored and of

an adequate capacity. Drip trays will be used under compressors, pumps,

motors and any redundant plant and during refuelling.

When plant maintenance is carried out on site, used oil should be stored in a

bunded area for collection. Oil and fuel filters should also be stored in a

designated bin in a bunded area for separate collection.


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12.4.2 Operation

Leaks and spillages

The majority of potential operational-related impacts have been minimised or

eliminated through the design of the proposed development which means that

all operations will take place in enclosed buildings with appropriately designed

water treatment plant.

Fuel storage and filling areas will be permanently bunded during operation to

ensure any spillages are contained and can be dealt with accordingly. Design

of tanks and bunds will be in accordance with the requirements of the Oil

Storage Regulations (2001) and the guidance given in Environment Agency

Pollution Prevention Guideline 2 – above ground oil storage tanks.

Flooding

The drainage strategy, which includes water storage to be provided on site

and discharge rates to be restricted, means that the site is not at increased

risk of flooding, nor will it increase the flood risk elsewhere.

Regulatory requirements

All discharges to controlled waters from the proposed development will be in

accordance with either an Environmental Permit or discharge consent. All

trade effluent discharged to foul sewer will be in accordance with a trade

effluent consent issued by the statutory sewerage undertaker.

12.5 Conclusion

The principal potential impact on water resources from the proposed

development is in relation to its location in an area of high flood risk.

However, implementation of the mitigation measures described in the LSIP

FRA and summarised in this section mean that the site will not be at increased

risk of flooding once developed, nor would it increase the risk of flooding

elsewhere.


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13 Energy and sustainability

13.1 Introduction

The efficiency of the proposed development has been calculated using the

GLA’s prescribed methodology for energy statements25.

A BREEAM pre-assessment has also been undertaken which identifies

indicative credits that can be achieved and also the target standard achieved

in each category and overall.


The existing baseline in relation to energy and sustainability is essentially one

where the waste to be treated by the proposed facility is sent to landfill.


13.3.1 BREEAM rating

The BREEAM pre-assessment is included in Appendix I and demonstrates that

the proposed development should achieve an ‘excellent’ rating. The

assessment will be developed further as detailed design proceeds.

13.3.2 Energy assessment

The energy assessment (Appendix J) investigates the use of passive energy

efficiency measures, the use of Combined Heat and Power and further

complimentary Low / Zero Carbon Generating Technologies (LZCGTs) to

reduce regulated CO2 emissions associated with energy consumption within

the proposed development to a level 40% below the current Target CO2

emission rate as set out in Part L2 of the Building Regulations.

25 Energy planning: GLA guidance on preparing energy assessments – September 2013


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The following benchmarks are considered in relation to the ‘Lean’, ‘Clean’ and

‘Green’ target benchmarks set out in Policy 5.2B of the London Plan.

Lean – Reducing demand through passive energy efficiency measures

Clean – Consideration of CHP / district heating and mandatory

incorporation of heat export / district heating infrastructure where feasible.

Green – Consideration of renewable technologies (complimentary to CHP)

The energy strategy, and influencing factors, can be summarised as follows:

There is a clear commitment to reduce regulated CO2 emissions to a level

below that required within Part L of the 2010 Building Regulations through

energy demand reduction measure, ie through maximising passive energy

efficiency measures (these measures are discussed further in Appendix J).

Further to maximising energy efficiency measures the building will make

use of electricity generated by the proposed development itself to provide

all building heating and electricity.

In line with Policy 5.17B of the London Plan, the ‘Carbon Intensity’ for

electricity generated by the development has been calculated. This figure

has been confirmed as -629g CO2/kWh, which is considerably below the

‘Carbon Intensity Floor’ of 400g CO2/kWh as set out in Policy 5.17B of the

London Plan.

As such electricity supplied to the building from the plant itself has been

defined as Carbon Neutral within this assessment, i.e. a CO2 emission Rate

of 0.0 kg.CO2/kWh.

Table 35 and Table 36 below summarise the carbon dioxide savings at each

stage of the hierarchy. It can be seen that the proposed development exceeds

Part L2 of the 2010 Building Regulations by passive energy efficiency

measures alone.


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Incorporating the savings from energy generation reduces building CO2

emissions by approximately 80% relative to the part L 2010 target emission

rate (TER) and therefore the proposed development exceeds the target in

Policy 5.2 of the London Plan.

Table 35: Carbon dioxide emissions after each stage of the energy

hierarchy

Hierarchy Carbon dioxide emissions (tonnes CO2 / year)

Regulated Unregulated

Baseline building: Building Regulations

2010 Part L compliant development

33.92 1.194

Lean – after energy demand reduction 28.95 1.194

Clean – after CHP 6.53 1.185

Green – after renewable energy 6.53 1.185

Table 36: Regulated carbon dioxide savings from each stage of the

hierarchy

Hierarchy Regulated carbon dioxide savings

Tonnes CO2 / year %

Savings from energy demand 4.97 14.64

Savings from CHP 22.42 77.45

Savings from renewable energy 0.00 0

Total cumulative savings 27.39 80.75

Total target savings 13.57 40

Annual surplus 13.82


The proposed development meets the policy requirements with respect to

BREEAM and energy efficiency and so no specific mitigation measures are

required.

13.5 Conclusion

The results of the BREEAM assessment and energy assessment summarised in

this section demonstrate that the proposed development meets the

requirements to achieve a BREEAM excellent rating and to achieve a 40%

improvement on 2010 Building Regulations.


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14 Socio-economic and health

14.1 Introduction

This section considers the prevailing socioeconomic environment in the area

and identifies the key impacts that the proposed development will have in

terms of environment, social and community impacts.

Information in this section has been drawn from a range of publicly available

sources, which are referenced as appropriate.


14.2.1 The London Borough of Barking and Dagenham

The borough was formed in 1965 by the London Government Act (1963) as

the London Borough of Barking and renamed the London Borough of Barking

and Dagenham in 1980.

Census data show that the population was approximately 165,000 in 1961,

falling to a low of 146,000 in 1991. Over the last twenty years the population

has increased significantly to 186,000 (2011 census).

Barking and Dagenham has traditionally been known for its strong

manufacturing sector. In recent years manufacturing employment has

declined, to be replaced by a more service-based economy. However,

manufacturing still accounts for 16% of employment in the Borough,

compared with just 4% across London as a whole. Table 37 below shows a

breakdown of employment by sector in the Borough26.

26 http://www.nomisweb.co.uk/reports/lmp/la/2038431874/report.aspx


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Table 37: Employment by sector in Barking and Dagenham

Employment sector Number of jobs Employees (%)

Manufacturing 7,400 16.3

Construction 2,000 4.5

Services 36,000 79.1

Distribution, hotels and restaurants 11,100 24.4

Transport and communications 4,200 9.1

Finance, IT, other business activities 6,000 13.3

Public administration, education and health 12,600 27.7

Other services 2,100 4.5

The Barking and Dagenham Joint Strategic Needs Assessment27 published in

October 2013, identifies that some 12,370 residents have been claiming out of

work benefits (Incapacity Benefit and Employment Support Allowance, lone

parents, Job Seekers Allowance/unemployment) for 1 year or more. This

figure represents 10.4% of the working age population, compared with 7.3%

London-wide.

Over the last 10 years the rate in the borough has consistently been at least

3% higher than the figure for London.

In Barking and Dagenham only 62.9% of working age people (aged 16-64) are

in employment. Over 8400 residents would need to move into work to ensure

convergence with the London employment rate (69.5%).

The Barking and Dagenham workforce is relatively low skilled and the borough

has much lower proportions of qualified adults at every level compared with

London or England although the borough is improving at a faster rate than

national or regional averages.

The Index of Multiple Deprivation (IMD) provides a means of ranking areas

(lower super output areas (LSOA)) in terms of the multiple extent of

27 http://www.barkinganddagenhamjsna.org.uk/Documents/JSNA2013-all.pdf


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deprivation experienced by people living in that area. There are 38 separate

indicators organised across seven distinct domains which address

employment, income, health deprivation and disability, living environment,

crime, education skills and training, and barriers to housing and services.

These indicators are then combined and ranked to provide indicators at

borough level.

When considering the population weighted average of the combined scores for

the LSOAs, Barking and Dagenham is ranked 22nd out of 326 local authorities

in England, which places it in the top 7% most deprived boroughs in England.

When considering the population weighted average of the combined ranks for

the LSOAs, Barking and Dagenham is ranked 8th out of 326 local authorities in

England, which places it in the top 3% most deprived boroughs in England.

In 2007, the Borough had 13 LSOAs ranked within the 10% most deprived in

England. In 2010, this figure had reduced to 11. The entire borough lies

within the worst 50% LSOAs in the country.

Barking and Dagenham has been awarded Beacon Status for tackling climate

change, has a Low Carbon Zone and forms part of the East London Green

Enterprise District.

14.2.2 Thames Ward

Thames Ward is the largest, but the lowest populated, ward in the Borough

with 9,425 residents28. It has the highest proportion of 16 – 74 year olds

employed in manufacturing industries. There were 400 unemployment

claimants in the ward in September 2010.

28http://www.barkingdagenhampartnership.org.uk/facts-figures/Documents/Thames.pdf


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Of the 11 LSOAs ranked within the 10% most deprived in England, three of

them (1974, 2420 and 2801) lie in Thames Ward. The rest of Thames Ward is

within the 30% most deprived LSOAs in the country.

14.2.3 The London Sustainable Industries Park

The aim of the London Sustainable Industries Park (LSIP) is to create the UK’s

largest concentration of environmental industries and technologies.

The vision is for a closed loop system, with businesses delivering waste to

energy projects, combined heat and power schemes, recycling and

reprocessing facilities, and renewable energy technologies. This system

enables businesses to develop synergies with their neighbours, maximise

resource efficiency and innovation and minimise waste.


14.3.1 Employment opportunities

There will be significant direct employment opportunities as a result of the

construction of the facility. Levels of employment will vary throughout the

construction period dependent on the activities on site. However, it is likely

that employees will range between 50 - 130 per day during the first 12 – 15

months of construction and a maximum of 50 employees per day during the

remaining six – nine months. Peak levels of employment are likely to be

associated with concrete works and building of the superstructure and internal

works.

It is anticipated that some 55 permanent jobs will be created at the facility

when operational.

Operational positions would include jobs for engineers, managers and

administrators, control room operators, skilled and semi-skilled tradesmen and

general workers.


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There will also be a number of indirect employment opportunities for e.g.

support services, equipment and materials and catering suppliers as a result of

the proposed development both during construction and operation.

TGW2E has committed to work with LBBD to maximise the number of

positions filled from the local community and has met with the Group Manager

- Economic Development and Sustainable Communities to explore ways in

which the opportunities can be maximised.

TGW2E has also met with key staff at Barking and Dagenham College and has

agreed to work in partnership with the college to develop a bespoke

apprenticeship scheme for the proposed development, specifically in relation

to mechanical and electrical engineering maintenance for the development

once operational. TGW2E hopes that it will be possible to accommodate 5 – 6

apprentices.

Further specialist training would be given as appropriate, providing

opportunities for employees to increase their skills.

The contractor selected for the construction of the facility will also be required

to enter into a commitment to take on local apprentices.

TGW2E has also entered into a Memorandum of Understanding with the

Sustainability Research Institute of the University of east London to work

together to identify potential end uses for the residual material arising from

the process.

The proposed development therefore has the potential for a considerable

positive impact on local employment.


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14.3.2 Ongoing community liaison and engagement

The design of the facility includes a visitor / education area in the office

building. TGW2E is happy to offer opportunities for pre-arranged visits from

local schools and colleges. Updates and news about the facility will also be

posted on the website.

14.3.3 Other effects

The assessments in sections 5, 7, and 11 have demonstrated that the

proposed development will have no adverse impact on health arising from

emissions to air, noise or contaminated land.

There will be no adverse odour impacts from the proposed development as all

waste handling operations will take place indoors and all exhaust air from the

waste-handling area will be passed through carbon filters to remove any

odours (section 3.7).

Internal handling of all wastes and residues means that there will be no

windblown litter as a result of the proposed development. However, as a

proactive measure, staff will be required to walk the perimeter of the site at

regular intervals and to remove any wind-blown litter promptly.

Finally, the proposed development will bring a major derelict site back into

use. The expected lifespan of the facility is twenty – thirty years. The site will

be principally laid to hardstanding and so it is not anticipated that any

remediation will be required during decommissioning. In any case, it is a

requirement of the permitting process (section 3.8) that a site closure report

be produced which demonstrates that the site is in the same condition at the

end of operations as at the start.


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There are no specific mitigation measures required for potential socio-

economic or health impacts.

14.5 Conclusion

Barking and Dagenham Council’s vision for the year 2020 is ‘to build

communities and transform lives’. One of its three key priorities is to:

‘Increase prosperity for all by encouraging the development of a well-educated

and skilled workforce, increasing access to jobs, supporting existing

businesses to grow and attract new investment’.

The proposed development will directly contribute to this key priority by

bringing a new employer to the area that will provide jobs and training

opportunities in one of the more deprived areas of the borough. As one of the

larger sites to be developed in the LSIP, it will also directly contribute to the

success of the LSIP itself.


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15 Conclusion

The proposed development relates to an energy generation facility at the

London Sustainable Industries Park in Dagenham.

The principle of development of an energy generation facility on this site is

fully established and has already been subject to rigorous examination and

assessment through the process of determination of the extant consent.

This Environmental Statement has assessed the potentially significant

environmental effects of the proposed development and demonstrated that:

The proposed development is in accordance with European, national,

regional and local policy.

The proposed development would have no significant adverse effects on air

quality.

The proposed development would not have a significant impact on

background noise levels.

There are no significant soil and groundwater associated with the

development.

The proposed development is in an area at risk of flooding but the

mitigation measures implemented will mean that the site itself is not at

significant risk of flooding nor would it increase the risk of flooding

elsewhere.

The proposed development would not have a significant adverse visual

impact.

There are no significant transport impacts as a result of the proposed

development; travel and deliveries and servicing plans will also be

developed.

The proposed development is highly energy efficient and exceeds the

requirements of the London Plan with respect to energy efficiency.

The proposed development achieves a BREEAM rating of excellent.


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The proposed development would have no significant adverse effects on

ecology and nature conservation; implementation of the proposed

landscape design would have a positive impact on the biodiversity potential

of the site.

The proposed development would have a positive socio economic impact

through the creation of 55 permanent jobs during operation, including

apprenticeships and training opportunities, as well as temporary jobs

during construction.

The proposed development would reduce greenhouse gas emissions.

The National Planning Policy Framework states that LPAs should approve

applications for renewable or low carbon energy developments unless material

conditions dictate otherwise and provided the impacts are (or can be made)

acceptable.

The proposed development would provide low carbon energy and this

environmental impact assessment has demonstrated that impacts are

acceptable.

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