Air Quality Assessment - March 2020 Oxted Crematorium - Tandridge ...
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Air Quality Assessment
Proposed Crematorium, Sheffield Road, Doncaster
Air Quality Assessment
Oxted Crematorium
March 2020
Report: 9546 v1 Final.docx
3
Date: 30 March 2020 Page 1 of
Air Quality Assessment
Oxted Crematorium
Air Quality Assessment
Oxted Crematorium
March 2020
Horizon Cremation Ltd
Suite 28, Tempus Wharf
London
SE16 4ST
Document Control:
Project no. Project
9546.S Oxted Crematorium
Report No. Ver/rev Written By: Checked by: Authorised by: Date
v.0 Draft H. Parfitt N. Jenkins N. Jenkins 28/02/2020
9546.S
v.1 Final H. Parfitt N. Jenkins N. Jenkins 30/03/2020
This report has been prepared for the exclusive use of the commissioning party and
may not be reproduced without prior written permission from Phlorum Limited.
All work has been carried out within the terms of the brief using all reasonable skill, care
and diligence.
No liability is accepted by Phlorum for the accuracy of data or opinions provided by
others in the preparation of this report, or for any use of this report other than for the
purpose for which it was produced.
Phlorum Limited
Southern Office: Unit 12, Hunns Mere Way, Woodingdean, Brighton, East Sussex, BN2 6AH
T: 01273 307 167 E: info@phlorum.com W: www.phlorum.com
Report: 9546 v1 Final.docx Date: 30 March 2020 Page ii of iii
Air Quality Assessment Oxted Crematorium Contents Figures Figure 1 – Site Location Plan Figure 2 – Construction Phase Receptors Figure 3 – Wind Roses: Charlwood – 2017 - 2019 Figure 4 – Operational Phase Receptors Appendices Appendix A – EPUK and IAQM Significance Criteria Appendix B – IAQM Highly Recommended Mitigation Measures for Low Risk Sites Report: 9546 v1 Final.docx Date: 30 March 2020 Page iii of iii
Air Quality Assessment
Oxted Crematorium
Introduction
1.1 Phlorum Ltd has been commissioned by Horizon Cremation Ltd (“the applicant”)
to undertake an air quality assessment (AQA) for the proposed development of a
crematorium on land north of Oxted Road and east of Barrow Green Road,
Oxted, Surrey in the administrative boundary of Tandridge District Council (TDC).
The National Grid Reference for the centre of the site is 537160, 152020. A site
location plan is included in Figure 1.
1.2 The application site is located on vacant land roughly 1.2km to the west of the
Oxted urban area. The proposed crematorium comprises a ceremony hall with
capacity for 120 people, with car parking facilities for up to 120 vehicles and
associated landscaping works. The facility will be open Monday to Saturday, and
it is anticipated that the crematorium will undertake an average of four to five
services per day, and possibly one or two on Saturday.
1.3 The main pollution sources in the vicinity of the application site are vehicles
travelling on the local road network, primarily the A25 Oxted Road.
1.4 There are no Air Quality Management Areas (AQMAs) in the administrative
boundary of TDC.
1.5 The primary purpose of this AQA is to assess the potential for significant adverse
impacts, in air quality terms, at sensitive receptor locations in the vicinity of the
site. The AQA considers both impacts from the operational and construction
phases of the proposed development.
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Policy Context
The UK Air Quality Strategy (UKAQS)
2.1 The UKAQS1 sets “standard” (AQS) concentrations for a number of key pollutants
which are to be achieved at sensitive receptor locations across the UK by various
“objective” dates.
2.2 For those objectives to which an annual mean standard applies, the most
common sensitive receptor locations used to measure concentrations against
the AQSs are areas of residential housing, since it is reasonable to expect that
people living in their homes could be exposed to pollutants over such a period of
time.
2.3 Schools and children’s playgrounds are also often used as sensitive locations for
comparison with annual mean objectives due to the increased sensitivity of
young people to the effects of pollution (regardless of whether or not their
exposure to the pollution could be over an annual period).
2.4 For shorter averaging periods of between 15 minutes, 1 hour or 1 day, the
sensitive receptor location can be anywhere where the public could be exposed
to the pollutant over these shorter periods of time.
2.5 A summary of the AQSs relevant to this assessment are included in Table 2.1,
below.
Table 2.1 UK Air Quality Standards
Air quality Air quality objective Objective: to
Averaging
Pollutant standard achieve the
Period
(AQS) (μg.m-3) standard by
200 μg.m-3 not to be
1 hour 200 exceeded more than 31 December 2005
Nitrogen dioxide 18 times a year
(NO2)
Annual 40 40 μg.m -3 31 December 2005
50 μg.m -3 not to be
24 hour 50 exceeded more than 31 December 2004
Particulate Matter 35 times a year
(PM10)
Annual 40 40 μg.m -3 31 December 2004
Particulate Matter
Annual 25 25 μg.m -3 2020
(PM2.5)
1 Air Quality Strategy for England, Scotland, Wales and Northern Ireland (Volumes 1 and 2) July 2007.
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2.6 The objectives adopted in the UK are based on the Air Quality (England)
Regulations 20002, as amended, for the purpose of Local Air Quality
Management. These Air Quality Regulations have been adopted into UK law from
the limit values required by European Union Daughter Directives on air quality.
2.7 Obligations under the Environment Act 1995 require local authorities to declare
an AQMA at sensitive receptor locations where an objective concentration has
been predicted to be exceeded. In setting an AQMA, the local authority must
then formulate an Air Quality Action Plan (AQAP) to seek to reduce pollution
concentrations to values below the objective levels. As air quality in Tandridge is
good, TDC has not declared any AQMAs.
National Planning Policy Framework (NPPF)
2.8 The NPPF3, which was updated in February 2019, sets out the Government’s
planning policy for England. At its heart is an intention to promote more
sustainable development. A core principle in the NPPF that relates to air quality
effects from development is that planning should “contribute to conserve and
enhance the natural and local environment”. In achieving this, it states in
paragraph 170 that:
“Planning policies and decisions should contribute to and enhance the natural and
local environment by: […]
preventing 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 […]”.
2.9 With regard to assessing cumulative effects the NPPF states the following at
paragraph 180:
“Planning policies and decisions should also ensure that new development is
appropriate for its location taking into account the likely effects (including cumulative
effects) of pollution on health, living conditions and the natural environment, as well
as the potential sensitivity of the site or the wider area to impacts that could arise
from the development.”
2.10 Regarding compliance with relevant limit values and national objectives for
pollutants the NPPF, paragraph 181 states:
“Planning policies and decisions should sustain and contribute towards compliance
with relevant limit values or national objectives for pollutants, taking into account the
presence of Air Quality Management Areas and Clean Air Zones, and the cumulative
impacts from individual sites in local areas. Opportunities to improve air quality or
2 The Air Quality (England) (Amendment) Regulations 2002 - Statutory Instrument 2002 No.3043.
3 Department for Communities and Local Government (DCLG), (2019), National Planning Policy Framework.
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mitigate impacts should be identified, such as through traffic and travel management,
and green infrastructure provision and enhancement. So far as possible these
opportunities should be considered at the plan-making stage, to ensure a strategic
approach and limit the need for issues to be reconsidered when determining
individual applications. Planning decisions should ensure that any new development
in Air Quality Management Areas and Clean Air Zones is consistent with the local air
quality action plan.”
2.11 The NPPF offers a broad framework but does not afford a detailed methodology
for assessments. Specific guidance for air quality continues to be provided by
organisations such as the Department for Environment, Food and Rural Affairs
(Defra), Environmental Protection UK (EPUK) and the Institute of Air Quality
Management (IAQM).
National Planning Practice Guidance (PPG)
2.12 Reference ID 32 (Air Quality) of the National Planning Practice Guidance (PPG)4,
which was updated in November 2019, provides guiding principles on how
planning can take account of the impact of new development on air quality. The
PPG summarises the importance of air quality in planning and the key legislation
relating to it.
2.13 As well as describing the importance of International, National and Local Policies
(detailed elsewhere in this report), it summarises the key sources of air quality
information. It also explains when air quality is likely to be relevant to a planning
decision:
“Whether air quality is relevant to a planning decision will depend on the proposed
development and its location. Concerns could arise if the development is likely to have
an adverse effect on air quality in areas where it is already known to be poor,
particularly if it could affect the implementation of air quality strategies and action
plans and/or breach legal obligations (including those relating to the conservation of
habitats and species). Air quality may also be a material consideration if the proposed
development would be particularly sensitive to poor air quality in its vicinity. […]
“Considerations that may be relevant to determining a planning application include
whether the development would:
Lead to changes (including any potential reductions) in vehicle-related
emissions in the immediate vicinity of the proposed development or further
afield. This could be through the provision of electric vehicle charging
infrastructure; altering the level of traffic congestion; significantly changing
traffic volumes, vehicle speeds or both; or significantly altering the traffic
composition on local roads. Other matters to consider include whether the
4 Planning Practice Guidance (PPG) 32. (2019). Air Quality. https://www.gov.uk/guidance/air-quality--3#history
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proposal involves the development of a bus station, coach or lorry park; could
add to turnover in a large car park; or involve construction sites that would
generate large Heavy Goods Vehicle flows over a period of a year or more;
Introduce new point sources of air pollution. This could include furnaces which
require prior notification to local authorities; biomass boilers or biomass-
fuelled Combined Heat and Power plant; centralised boilers or plant burning
other fuels within or close to an air quality management area or introduce
relevant combustion within a Smoke Control Area; or extraction systems
(including chimneys) which require approval or permits under pollution
control legislation;
Expose people to harmful concentrations of air pollutants, including dust. This
could be by building new homes, schools, workplaces or other development in
places with poor air quality;
Give rise to potentially unacceptable impacts (such as dust) during
construction for nearby sensitive locations;
Have a potential adverse effect on biodiversity, especially where it would affect
sites designated for their biodiversity value.”
2.14 Details are also provided of what should be included within an air quality
assessment. Key considerations include:
Baseline local air quality;
Whether the proposed development could significantly affect local air
quality during construction/operation; and
Whether the development is likely to expose more people to poor air
quality.
2.15 Examples of potential air quality mitigation measures are also provided in the
PPG.
Statutory Guidance for Crematoria
2.16 The Defra Process Guidance Note for Crematoria5 provides guidance on
controlling air emissions from the cremation of human remains.
2.17 The guidance provides emission limit values for various pollutants, which all
crematoria must adhere to. The main pollutants of concern for crematoria are:
nitrogen dioxide (NO2);
particulate matter (PM);
5 Process Guidance Note 5/2 (12) Statutory Guidance for Crematoria, September 2012
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carbon monoxide (CO);
volatile organic compounds (VOCs);
hydrogen chloride (HCl); and
mercury (Hg).
2.18 The crematorium will require an Environmental Permit under the Environmental
Permitting (England and Wales) Regulations 20166. Emissions will need to be
monitored and comply with the emission levels. As a Part B, Local Air Pollution
Prevention and Control (LAPPC), process, the Environmental Permit will be
regulated by the local authority.
Local Planning Policy
2.19 TDC is currently preparing a new Local Plan. Until its adoption, TDC’s Core
Strategy7 and the Tandridge Local Plan Part 2: Detailed Policies are the primary
documents which direct planning in the District. The Core Strategy8 contains no
policy of direct relevance to air quality; however, “Policy CSP 18” states:
“Development must not significantly harm the amenities of the occupiers of
neighbouring properties by reason of overlooking, overshadowing, visual intrusion,
noise, traffic and any other adverse effect.”
2.20 The Local Plan Part 2 contains policies of relevance to air quality, these include
“DP7: General Policy for New Development”, which states:
“Amenity: The proposal does not significantly harm the amenity of neighbouring
properties by reason of pollution (noise, air or light), traffic, or other general
disturbance;”
2.21 “DP22: Minimising Contamination, Hazards & Pollution” states:
“Air Pollution
H. Development will be permitted provided it would not:
1. Have an adverse impact on health, the natural or built environment or amenity of
existing or proposed uses by virtue of odour, dust and/or other forms of air pollution;
or
2. Be likely to suffer unacceptable nuisance as a result of proximity to existing sources
of odour, dust and/or other forms of air pollution.”
6 Environmental Permitting (England and Wales) Regulations SI 2016/1154
7 TDC (2008). Tandridge District Core Strategy
8 TDC (2014). Tandridge Local Plan Part 2: Detailed Policies (2014-2029)
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2.22 The emerging Local Plan9, which was submitted to the Planning Inspectorate in
January 2019, contains policy of relevance to air quality. Given the emerging Local
Plan is at an advanced stage, it is assumed that it will be given some material
consideration in the determination of planning applications. “Policy TLP46:
Pollution and Air Quality” states:
“All development proposals must be located and designed to not cause a significant
adverse effect upon the environment, the health of residents or residential amenity by
reason of pollution to land, air or water, or as a result of any form of disturbance
including, but not limited to noise, light, odour, heat, dust, vibrations and littering.
New residential development located near to existing uses that generate pollutant,
noise, odour or light will be expected to demonstrate that the proposal is compatible,
and will not result in unacceptable living standards.
Planning conditions may be used to manage and mitigate the effects of pollution
and/or disturbance arising from development. Where required, conditions limiting
hours of construction, opening hours and placing requirements on applicants to
submit further proposal details will be implemented in order to ensure impacts on the
environment and residential amenity are kept within acceptable limits and where
possible reduced.
Air Quality
Development will be supported where it would not result in the national Air Quality
Objectives (32) being exceeded; and it would not lead to a significant deterioration in
local air quality resulting in unacceptable effects on human health, local amenity or
the natural environment.
Proposals for new development should reflect the requirements of the Council's Air
Quality Impact Assessments (2018) and any subsequent update, as well as air quality
conditions developed by Surrey Air Alliance. Proposals should also be in accordance
with the Local Transport Plan and its supporting, Air Quality Strategy, Low Emissions
Transport and Electric Vehicle Strategies, and be cognisant of policy TLP36: Ashdown
Forest SPA, where relevant.”
2.23 The Surrey Transport Plan Electric Vehicle Strategy10, Low Emission Transport
Strategy11 and Travel Planning Strategy12 set out Surrey County Council’s (SCC)
aims, objectives and preferred approaches for promoting a modal shift away
from single occupancy car use, as well as a move toward low emission vehicles.
9 TDC (2019) Our Local Plan: 2033 (Regulation 22 submission)
10 SCC (2018) Surrey Transport Plan, 2011-2026 Low Emissions Transport Strategy
11 SCC (2018) Surrey Transport Plan, 2011-2026 Electric Vehicle Strategy
12 SCC (2011) Surrey Transport Plan: Travel Planning Strategy
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Assessment Methodology
Guidance
3.1 Defra’s Local Air Quality Management Technical Guidance (LAQM.TG (16)13 has been
followed to undertake this assessment.
3.2 Guidance published by the IAQM14 on the Assessment of Dust from Demolition and
Construction was also used when assessing the construction phase of the
proposed development. The Greater London Authority (GLA) Supplementary
Planning Guidance15 on The Control of Dust and Emissions during Construction and
Demolition has also been referred to, which, although primarily intended for use
in London, is considered best practice guidance for the UK. It details a number of
mitigation measures that should be adopted to minimise impacts of dusts and
fine particles.
3.3 In addition, the latest Environmental Protection UK (EPUK) & IAQM guidance on
Planning for Air Quality’16 has been referred to for the operational phase
assessment. The criteria used to determine the significance of impacts from road
traffic were derived from this guidance, and have been included in Appendix A.
3.4 Finally, the IAQM’s Guide to the assessment of air quality impacts on designated
nature conservation sites (2019) 17 has been referred to.
Consultation
3.5 Initial contact was made with TDC’s Environmental Health Officer (Air Quality) in
February 2020 to discuss the development and the proposed scope of work.
TDC’s EHO agreed with methodology in principal but requested that the
assessment:
Refer to Annex F of Environment Agency H1 guidance to assess the
significance of impact from the cremator; and
Include an assessment of PM2.5.
3.6 The EA’s H1 guidance has been replaced by joint Defra and EA guidance18, which
has been followed in this assessment.
13 Defra.(2018). Part IV of the Environment Act 1995, Environment (Northern Ireland) Order 2002 Part III, Local Air Quality
Management, Technical Guidance LAQM. TG(16). London: Defra.
14 IAQM. (2014). Guidance on the assessment of dust from demolition and construction.
15 Greater London Authority. (2014). The Control of Dust and Emissions During Construction and Demolition.
16 EPUK & IAQM. (2017). Land-Use Planning & Development Control: Planning For Air Quality.
17 IAQM. (2019). A guide to the assessment of air quality impacts on designated nature conservation sites.
https://iaqm.co.uk/text/guidance/air-quality-impacts-on-nature-sites-2019.pdf
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3.7 Furthermore, the EHO recommended the AQA include a detailed dispersion
modelling assessment of both cremator and road traffic emissions, so that the
combined impact of these sources could be assessed at discreet receptors.
3.8 As the proposed development’s traffic generation is low (i.e. below commonly
used criteria to screen out detailed assessment), it was argued that a detailed
assessment of road traffic would not be necessary. It was agreed that the initial
results of the cremator assessment would be shared prior to submission of the
AQA to allow them to make an informed opinion on the requirements of the
scope.
3.9 The results presented in Section 6 were shared with the EHO on the 27th
February 2020, by email. On the 28th of February a response was received and no
further request for a traffic modelling assessment was made.
Baseline Air Quality
3.10 The baseline air quality conditions in the vicinity of the site are established
through the compilation and review of appropriately sourced background
concentration estimates and local monitoring data, detailed below.
Background maps (UK-AIR)
3.11 Defra provides estimated background concentrations of the UKAQS pollutants
on the UK Air Information Resource (UK-AIR) website19. These estimates are
produced using detailed modelling tools and are presented as concentrations at
central 1sq.km. National Grid square locations across the UK. These were
updated in May 2019 and are based on monitoring data from 2017.
3.12 Being background concentrations, the UK-AIR data are intended to represent a
homogenous mixture of all emission sources in a particular grid square location.
Concentrations of pollutants at various sensitive receptor locations can,
therefore, be calculated by modelling the emissions from a nearby pollution
source, such as a busy road, and then adding this to the appropriate UK-AIR
background datum.
Local Monitoring
3.13 TDC monitoring data are also considered an appropriate source for establishing
baseline air quality, and the most recent available data from TDC’s 2019 air
quality annual status report20 have been included and assessed.
18 https://www.gov.uk/guidance/risk-assessments-for-your-environmental-permit
19 Defra: UK-AIR. www.uk-air.defra.gov.uk
20 TDC (2019) Air Quality Annual Status Report, 2019.
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Construction Phase Assessment
3.14 The construction phase of the proposed development will involve a number of
activities that will produce polluting emissions to air. Predominantly, these will be
emissions of dust. As such, the IAQM’s guidance 14 has been followed to assess
the potential risk of adverse impacts on human and ecological receptors during
this phase.
3.15 The guidance suggests that where a human receptor is located within 350m
(50m for ecological receptor) of a site boundary and/or 50m of a route used by
construction vehicles, up to 500m from the site entrance, a risk assessment
should be undertaken.
3.16 High sensitivity receptors are considered to be most at risk when located within
20m of a works area. Figure 2 shows receptors that could be sensitive to dust
that are located within 350m of the boundary of the site.
3.17 The Multi Agency Geographic Information for the Countryside (MAGIC) website21,
which incorporates Natural England’s interactive maps, has been reviewed and
has identified no statutory ecological receptors within 50m of the site boundary
or within 50m of any routes used by construction vehicles on the public highway,
up to 500m from the site entrance. As such, based on distance alone it can be
concluded that construction dust will have no significant impact on statutory
ecological receptors.
Construction Dust Impacts Significance Criteria
3.18 The IAQM guidance suggests Demolition, Earthworks, Construction, and Trackout
should all be assessed separately to determine the overall significance of the
construction phase.
3.19 In the IAQM dust guidance the first step in assessing the risk of impacts is to
define the potential dust emission magnitude. This can be considered ‘Negligible’,
‘Small’, ‘Medium’ or ‘Large’ for each of the construction stages. Whilst the IAQM
provides examples of criteria that may be used to assess these magnitudes, the
large number of potential variables means that every site is different and
therefore professional judgement must be applied by what the IAQM refer to as
a “technically competent assessor”. The construction phase assessment therefore
relies on the experience of the appraiser.
3.20 As such, attempts to define precisely what constitutes a negligible, small,
medium or large dust emission magnitude should be treated with caution.
Factors such as the scale of the work, both in terms of size and time, the
construction materials and the plant to be used must be considered.
21 Natural England and MAGIC partnership organisations. Multi Agency Geographic Information for the Countryside.
http://www.magic.gov.uk/
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3.21 The second step is to define the sensitivity of the area around the construction
site. As stated in the IAQM guidance:
“the sensitivity of the area takes into account a number of factors:
the specific sensitivities of receptors in the area;
the proximity and number of those receptors;
in the case of PM10, the local background concentrations; and
site-specific factors, such as whether there are natural shelters, such as trees,
to reduce the risk of wind-blown dust.”
3.22 Based on these factors, the area is categorised as being of ‘Low’, ‘Medium’ or
‘High’ sensitivity.
3.23 When dust emission magnitudes for each stage and the sensitivity of the area
have been defined, the risk of dust impacts can be determined. The IAQM
provides a risk of impacts matrix for each construction stage. The overall
significance for the construction phase can then be judged from the construction
stages assessed. Again, this is subject to professional judgement, but often the
highest risk stage will predominate in influencing the overall level of risk.
Construction Traffic and Machinery
3.24 Combustion exhaust gases from diesel-powered plant and construction vehicles
accessing the application site will also be released. However, the volumes and
periods over which these releases will occur are unlikely to result in any
significant peaks in local air pollution concentrations and therefore this has been
scoped out of the assessment.
Operational Phase – Traffic Emissions
Vehicle Emissions
3.25 Vehicle emissions will arise from the combustion of fossil fuels in vehicle engines
and their subsequent release to atmosphere via tailpipe exhausts. The most
significant pollutants released by cars and other vehicles are oxides of nitrogen
(NO2/NOx) and fine particulate matter (PM10 and PM2.5). Releases of carbon
monoxide (CO) and some volatile hydrocarbons (e.g. benzene and 1,3-butadiene)
are of less significance and are not assessed further in this report.
3.26 As it is elevated annual mean concentrations of NO 2 and PM10 that have resulted
in the declaration of most AQMAs across the UK, these are the pollutants of most
concern and they have therefore been the focus of this air quality assessment.
PM2.5, which is a smaller fraction of particulate matter, has also been considered.
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Existing Receptors
3.27 The latest EPUK & IAQM planning guidance9 provides indicative thresholds for
changes in traffic flows which would require a detailed air quality assessment.
These are changes in 24-hour average annual daily traffic (AADT) flows of:
>100 light duty vehicles (LDV) and/or;
>25 heavy duty vehicles (HDV) when within or adjacent to an AQMA; and
changes of 500 LDV or 100 HDV elsewhere.
3.28 Changes below these thresholds can be reasonably considered to have an
insignificant impact on air quality.
3.29 Information provided by Systra, the transport consultants for the project,
indicates that the proposed development will generate 372 vehicle movements
per day (1 HDV).
3.30 The proposed development’s traffic generation rates are also below the IAQM’s
criterion for requiring further assessment on designated sites of nature
conservation (i.e. an increase of 1000 LDV / 200 HDV on a road, in-combination
with committed developments).
3.31 Considering the above, a detailed assessment of road traffic on human and
ecological receptors has been scoped out, as no significant impacts would be
expected.
Operational Phase – Cremator Emissions
3.32 In order to determine the effect on local air quality from the operation of the
cremator, a dispersion model has been used to predict pollutant concentrations
across the local area. The model used was Atmospheric Dispersion Model
Software (ADMS 5), which is a new generation Gaussian plume dispersion model
produced by the Cambridge Environmental Research Centre (CERC). This model
has been validated and approved by the Defra for use as an assessment tool to
assess the dispersion of pollutants from point sources.
3.33 The major emissions from cremators are NO2/NOx, CO, PM, Hg and non-methane
volatile organic compounds (NMVOCs). As such, these pollutants have been the
focus of this assessment.
Emission Rates and Model Inputs
3.34 Worst-case emission rates (based on emission limits) have been obtained from
the Defra Statutory Guidance on Crematoria5. Full details of emission rates and
model parameters are provided in Table 3.1, below.
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Table 3.1: ADMS-5 Model Inputs
Stack Parameter Value
Exit Velocity (m/s) 15
Volumetric Flow Rate (m3/hr) 2270
Temperature (˚C) 140
Stack Diameter (m) 0.225
Stack Height Above Ground Level (m) 7.9
Stack Location (O.S. x, y) 537163, 152050
Building Height (m) 6.4
NOx Emission Rate (g/s)** 0.15
CO Emission Rate (g/s)* 0.042
PM Emission Rate (g/s)* 0.008
SO2 Emission Rate (g/s)* 0.029
Mercury Emission Rate (g/s)* 0.000021
HCI (g/s)* 0.013
Organic Compounds (benzene) (g/s)* 0.008
Notes: *Derived from emission concentration limits from Statutory Guidance for Crematoria5
multiplied by flow rate. **Derived from emission concentration limits from a crematorium of
similar size.
3.35 It is worth noting that cremation equipment is likely to be significantly ‘cleaner’
than the emission rates set out above. The Scottish Environmental Protection
Agency (SEPA) monitors the performance of cremators in Scotland. It judged the
performance of the cremator fitted in Horizon’s first crematorium on the Clyde
Coast which opened in June 2018 to be ‘Excellent’ after an unannounced
inspection in August 2018.
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Meteorological Data
3.36 Detailed, hourly sequential, meteorological data are used by the model to
determine pollutant transportation and levels of dilution by the wind and vertical
air movements. Three years of meteorological data used in the model were
obtained from Charlwood meteorological station, as it was considered to provide
the most representative data of similar conditions to the application site. The
meteorological data used for this assessment were from 2017, 2018 and 2019.
The meteorological data used in this assessment are shown in Figure 3. The
surface roughness applied to the model study area and meteorological station
was 0.3m, to reflect their rural/agricultural settings.
Conversion Ratios for NOx to NO2
3.37 Environment Agency guidance22 has been followed when estimating NO2
concentrations from modelled NOX concentrations. It suggests a phased
approach when considering the ambient ratios of NO 2: NOX, which are:
Screening scenario: 50% and 100% of the modelled values should be
used for short-term and long-term average concentration,
respectively. That is, 50% of the predicted NO X concentrations should
be assumed to convert to NO2 for short term assessments and 100%
of the predicted NOX concentrations should be assumed to convert to
NO2 for long-term assessments;
Worst Case Scenario: 35% and 70% of the modelled NOX process
contributions should be used for short-term and long-term average
concentration, respectively. That is, 35% of the predicted NO X
concentrations should be assumed to convert to NO 2 for short-term
assessments and 70% of the predicted NOX concentrations should be
assumed to convert to NO2 for long-term assessments; and
Case Specific Scenario: Operators are asked to justify their use of
percentages lower than 35% for short-term and 70% for long-term
assessments in their application reports.
3.38 For the purposes of this assessment, the screening scenario conversion ratios
have been used whereby it was assumed that 50% of short term average NO x
concentrations and 100% of long-term average NOx concentrations were
converted to NO2.
Crematorium Emissions Significance Criteria
3.39 The significance of impacts from the cremator flue is determined in terms of
Defra’s “Risk assessment for environmental permitting”18. The significance of
impacts is considered both in terms of the:
22 Environment Agency (2006) ‘Conversion ratios for NO X and NO2’.
https://webarchive.nationalarchives.gov.uk/20140328232919/http://www.environment-
agency.gov.uk/static/documents/Conversion_ratios_for__NOx_and_NO2_.pdf
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Process Contribution (PC): the impact of direct, additional emissions
associated with the new processes only, and
Predicted Environmental Concentration (PEC): the impact associated
with combined PC and existing background pollutant concentrations.
Initial Screening Stage (Step 1)
3.40 The Defra guidance states the significance of impacts should be assessed in a
multi-stepped approach. In the first instance, the impact of the PC for a
particular pollutant is not considered significant if:
the long term PC at a sensitive receptor isAir Quality Assessment
Oxted Crematorium
Assessment Criteria
3.46 Environmental Assessment Levels (EALs) provide hourly and annual limits for
various pollutants. Where pollutants are already covered by AQS in the UKAQS,
the EALs mirror these. The EALs for the pollutants of relevance to the proposed
cremator are included in Table 3.2 below.
Table 3.2: Air Quality Standards and Environmental Assessment Levels
Pollutant Concentration Limits Averaging Period
Air Quality Objectives
40μg.m -3 Annual Mean
NO2
200μg.m-3 1 hour Mean
40μg.m -3 Annual Mean
PM10
50μg.m -3 24 hour mean
CO 10mg.m -3 8 hour rolling mean
VOCs* 5μg.m-3 Annual Mean
Environmental Assessment Levels
Polychlorinated Dibenzo-p-Dioxins
No EAL given -
and Furans (PCDD/F)
20mg.m -3 Annual Mean
Hydrogen Chloride (HCI)
750mg.m-3 1 hour mean
0.25μg.m-3 Annual mean
Mercury
7.5μg.m-3 1 hour mean
*Assumed to be benzene, as a worst case pollutant.
Sensitive Receptors
3.47 The closest sensitive receptors to the cremator stack are shown on Figure 4 and
are detailed in Table 3.3 below. Relevant high sensitivity receptors were
identified in all directions. All receptors were modelled at “breathing height”,
which is by convention 1.5m above ground level.
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Table 3.3: Modelled Receptors
Receptor UK Grid Reference
ID Descriptor X Y
R1 Residential, Tandridge Hill Lane 536969.6 152037.7
R2 Residential, Tandridge Hill Lane 536980.9 152099.5
R3 Residential, Tandridge Hill Lane 536980.4 152191.6
R4 Residential - Old School House, A25 537317.6 151921.9
R5 Residential, Tandridge Hill Lane 537007.1 152353.7
R6 Residential, Tandridge Priory, Barrow Green Rd 537685.8 152312.7
R7 Residential - The Pheasantry 537794.2 151548.6
R8 Residential, Jackass Lane 537156.8 151271.6
R9 Residential, Nagshall Farm, A25 536470.4 151760.9
Note: Grid references are indicative as the model layout is based on Ordnance Survey base
mapping
Ecological Receptors
3.48 The closest designated sites to the application site are the Godstone Ponds Site
of Special Scientific Interest (SSSI) and the Woldingham & Oxted Downs SSSI;
both are located over 1km away.
3.49 The proposed development is within an SSSI Impact Risk Zone. Natural England
guidance states that any planning application within an SSSI Impact Risk Zone
which includes combustion is considered to have the potential to impact the SSSI.
3.50 The Ecological Assessment provides Natural England’s discretionary advice for a
similar Horizon Cremation scheme in 2018, as follows:
“Our SSSI impacts risk zone dataset indicates that indirect, adverse impacts in relation
to air quality may occur in relation to designated sites. A suitable assessment of
impacts upon air quality is therefore required as part of any planning proposal.
The designated sites needing consideration as part of the air quality assessment will
be dictated by a number of criteria (see steps below) but initial screening is based on
distance. The variables for this screening step in the process comprise the energy
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requirements for the crematorium and the distance to the designated site(s). We
would advise that the following criteria are applied:
Up to 20MW energy requirement – Assess impacts on any designated sites
within 500m
20-50MW energy requirement – Assess impacts on designated site within 2km
In excess of 50MW energy requirement – Assess impacts on European sites
within 10km
For those designated sites falling within the distances quoted above (according to
your assessment of the crematorium’s energy requirements) the submitted air quality
assessment should address (but not be limited to):
Are the designated site’s notified / designated feature sensitive to the hazard?
What are the appropriate critical levels and critical loads for the features?
Is the magnitude of the effect likely to be significant?
Is the ‘process contribution’ greater than the relevant threshold alone?
Consider existing background levels - Is the ‘predicted environmental
concentration’ above the relevant threshold?”
3.51 The total electrical requirement of proposed cremator at full load is expected to
be 57kVA and the total natural gas requirement will be 586kW (0.586MW). The
combined power requirement is therefore much less than Natural England's
minimum threshold for concern for air quality effects.
3.52 Based on this, is not considered likely that the proposed development will give
rise to significant changes in air quality that would result in increased adverse
effects on the SSSI habitats and no further assessment has been undertaken.
3.53 Ecology Solutions also identified several non-statutory sites close to the
application site (e.g. potential Site of Nature Conservation Importance and
Ancient Woodland). Being non-statutory receptors, the PC at these receptors
would have to be greater than 100% of the environmental standard to potentially
be significant. Considering the results in Section 6, the risk that this might occur
is considered to be negligible and no significant impacts are predicted at these
non-statutory sites.
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Baseline Air Quality
4.1 This chapter is intended to establish prevailing air quality conditions in the
vicinity of the application site.
UK-AIR Background Pollution
4.2 The UK-AIR predicted background pollution concentrations for NO 2, PM10 and
PM2.5 for 2017 to 2022 are presented in Table 4.1. These data were taken from
the central grid square location closest to the application site (i.e. grid reference:
537500, 152500).
Table 4.1: 2017 to 2022 background concentrations of pollutants at the
application site
Predicted background concentration (μg.m-3) Air quality
Averaging standard
Pollutant
Period concentration
2017 2018 2019 2020 2021 2022
(μg.m-3)
NO2 15.2 14.6 14.0 13.3 12.7 12.2 annual mean 40
PM10 15.5 15.3 15.1 14.9 14.8 14.6 annual mean 40
PM2.5 10.3 10.2 10.0 9.8 9.7 9.6 annual mean 25
4.3 The data in Table 4.1 show that annual mean background concentrations of NO 2,
PM10 and PM2.5, in the vicinity of the application site between 2017 and 2022,
were predicted to be well below their respective AQSs.
4.4 The data show that in 2020, NO2, PM10 and PM2.5 concentrations are predicted to
be below their AQSs by 67%, 63% and 61% respectively. As such, annual mean
background concentrations are likely to be well below the respective AQSs at the
application site and surrounding uses.
4.5 Concentrations of all pollutants were predicted to decline each year. These
reductions are principally due to the forecast effect of the roll out of cleaner
vehicles, but also due to UK national and international plans to reduce emissions
across all sectors.
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Local Sources of Monitoring Data
4.6 Local air quality monitoring is considered an appropriate source of data for the
purposes of describing baseline air quality.
Automatic Monitoring
4.7 TDC does not undertake continuous (automatic) monitoring in the District.
Non-Automatic Monitoring
4.8 TDC operates an extensive non-automatic, NO2 diffusion tube monitoring
network and the most recent available monitoring data for diffusion tubes
located within 4km of the application site are included in Table 4.2.
Table 4.2: Monitoring data from TDC NO2 diffusion tubes
Distance NO2 annual mean concentration (μg.m-3)
from the
Monitor Type
application
site (km) 2016 2017 2018
TD10 R 2.0 - - 32.0
TD11 R 2.0 - - 33.4
TD5 R 2.0 - - 28.8
TD34 UB 2.3 21.6 20.3 19.7
TD32 R 2.5 23.1 22.0 22.9
TD9 UB 2.5 20.0 17.4 17.8
TD28 R 2.7 30.1 27.8 29.8
TD30 UB 3.4 22.4 21.8 22.8
Note: “R” = roadside, “K” = kerbside. Bold denotes exceedance of the 40μg.m-3 AQS.
4.9 The data in Table 4.2 show that annual mean concentrations of NO2 at monitored
locations, in the vicinity of the application site have been consistently below the
40μg.m-3 AQS since 2016.
4.10 The highest concentration was recorded at TD11 in 2018, where a concentration
16.5% below the AQS was recorded. TD11 is, however, located in Godstone at a
roadside location and is, therefore, not considered to be representative of
conditions in the vicinity of the site.
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4.11 Urban background concentrations of NO2 in the study area were at least 43%
below the AQS in 2018. As the application site is not located in an urban area, the
‘urban background’ concentrations recorded in Godstone and Oxted are not
considered to be representative of background conditions across the application
site.
4.12 The data in Table 4.2 show that there is no discernible decline in NO2
concentrations in the study area and that concentrations fluctuate between
years.
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Construction Phase Assessment
5.1 The construction phase of the proposed development will involve a number of
activities that could produce polluting emissions to air. Predominantly, these will
be emissions of dust.
5.2 The estimates for the dust emission magnitude for demolition, earthworks,
construction and trackout below are, where appropriate, based on estimates
from experience on similar schemes for the client, and the professional
experience of Phlorum consultants.
Potential Dust Emission Magnitude
Demolition
5.3 The application site is currently undeveloped. As such, there are no existing
structures and demolition is not considered further in this assessment.
Earthworks
5.4 The site area exceeds the IAQM’s threshold descriptor for a ‘Large’ site in the
context of earthworks (10,000m2). However, it is estimated that less than 20,000
tonnes of earth is to be moved, which is considered ‘Small’ with reference to the
IAQM guidance.
5.5 Considering the above, the potential dust emission magnitude during
earthworks is considered to be Medium with reference to IAQM descriptors.
Construction
5.6 During construction, activities that have the potential to cause emissions of dust
might include concrete batching, sandblasting and piling; however, it has not
been stated that these are anticipated for the proposed development.
Stockpiling and the general handling of construction materials also have the
potential to lead to dust emissions, particularly during dry, windy conditions.
5.7 The prospective building materials are reinforced concrete, structural steel,
timber, brick/block and proprietary cladding and glazing, which have a low to
medium potential for dust emission.
5.8 The volume of the proposed building is expected to be less than 25,000m3 which
falls into the IAQM’s ‘Small’ category.
5.9 Overall, the potential dust emission magnitude for the construction stage is
considered to be Medium, to ensure a conservative approach.
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Trackout
5.10 Construction traffic, when travelling over soiled road surfaces, has the potential
to generate dust emissions and to also add soil to the local road network. During
dry weather, soiled roads can lead to dust being emitted due to physical and
turbulent effects of vehicles.
5.11 As well as the type of road surface, the number of daily HDV accessing the site is
used to determine dust emission magnitude during construction: 50 Large. The number of HDVs accessing the site is expected to
be less than 10, falling into the ‘Small’ IAQM category.
5.12 Overall, the potential dust emission magnitude for the trackout phase is
considered to be ‘Small’ with reference to IAQM guidance.
Potential Dust Emission Magnitude Summary
5.13 A summary of the potential dust emission magnitude as a result Earthworks,
Construction and Trackout activity, discussed above, is listed in Table 5.1 below.
Table 5.1: Dust Emission Magnitude for the construction activities, based on
the IAQM’s guidance
Activity Dust Emission Magnitude
Earthworks Medium
Construction Medium
Trackout Small
Sensitivity of the Area
5.14 Having established the potential dust emission magnitude for each phase of the
project, the sensitivity of the area must be considered to establish the
significance of effects. The effect of dust emissions depends on the sensitivity of
each receptor. High sensitivity human receptors include residential dwellings,
schools and hospitals.
5.15 Within distances of 20m of the site boundary there is a high risk of dust impacts,
regardless of the prevailing wind direction. Up to 100m from the construction
site, there might still be a high risk, particularly if the receptor is downwind of the
dust source.
5.16 With the exponential decline in dust with distance from dust generating
activities, it is considered that for receptors more than 350m from the site
boundary, the risk is negligible. Furthermore, the risks at over 100m only have
the potential to be significant in certain weather conditions, e.g. downwind of the
source during dry periods.
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5.17 The approximate number of high sensitivity human receptors in the vicinity of
the application site is detailed in Table 5.2 below, with distance buffers shown in
Figure 2.
Table 5.2: Approximate number of High Sensitivity Receptors in the vicinity
Distance to Approximate number
Receptor Details
site (m) of receptorsAir Quality Assessment
Oxted Crematorium
5.21 Overall, the proposed development is considered to be Low Risk for nuisance
dust soiling effects, negligible risk for ecology, and Low Risk for PM 10 health
effects, in the absence of mitigation.
Site Specific Mitigation
5.22 The GLA guidance15, which is used as a benchmark for developments across the
UK, suggests a number of mitigation measures that should be adopted in order
to minimise impacts from dusts and fine particles. The vast majority of these
suggestions can be considered as general good practice. Appropriate measures
that could be included in the construction of the proposed development include:
ideally cutting, grinding and sawing should not be conducted on-site
and pre-fabricated material and modules should be brought in where
possible;
where such work must take place, water suppression should be used
to reduce the amount of dust generated;
skips, chutes and conveyors should be completely covered and, if
necessary, enclosed to ensure that dust does not escape;
any excess material should be reused or recycled on-site in
accordance with appropriate legislation;
developers should produce a waste or recycling plan;
following earthworks, exposed areas and soil stockpiles should be re-
vegetated to stabilise surfaces, or otherwise covered with hessian or
mulches;
stockpiles should be stored in enclosed or bunded containers or silos
and kept damp where necessary;
hard surfaces should be used for haul routes where possible;
haul routes should be swept/washed regularly;
vehicle wheels should be washed on leaving the site;
all vehicles carrying dusty materials should be securely covered; and
delivery areas, stockpiles and particularly dusty items of construction
plant should be kept as far away from neighbouring properties as
possible.
5.23 In addition, the IAQM lists recommended mitigation measures for low, medium
and high Dust Impact Risks. The highly recommended mitigation measures for
Low Risk sites have been included in Appendix B of this report.
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Residual Effects
5.24 After the implementation of the mitigation measures listed above and in
Appendix B, the impact risk for each stage of the construction programme will be
reduced and the residual significance of impact for the construction phase is
expected to be negligible.-
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Operational Phase Assessment
Crematorium Assessment
6.1 Results from the ADMS assessment of emissions from the cremator stack are
presented below. In relation to the short-term EALs, the worst-case assumption
has been made that the cremator plant will run continuously and at 100%
capacity. This will not be the case, but it allows potential worst-case atmospheric
conditions to be considered in the model.
6.2 For the annual mean (long term) EALs, a more realistic approach has been
undertaken. This assessment has considered that the cremator will operate for
2,500 hours per year, which represents the 9am to 5pm working day, Monday to
Friday (excluding bank holidays).
Screening Stage 1
6.3 It should be reiterated that for all pollutants, the significance of impact is
determined first against the thresholds in Screening Stage 1 (whereby PC isAir Quality Assessment
Oxted Crematorium
Maximum PC
Predicted
Pollutant Averaging Period EAL/AQS
at Receptor
PC (μg.m-3) % of EAL
PM2.5 Annual Mean 0.1 0.0 25μg.m
CO Rolling 8 hour mean 0.0 0.0 - 10,000μg.m-3
VOCs
Annual Mean 0.0 0.1 R3, R5 5μg.m-3
(Benzene)
Annual Mean 0.0 0.1 R3, R5 20μg.m -3
Hydrogen
Chloride
1 hour mean 2.2 0.3 R3 750μg.m-3
Annual Mean 0.0 0.0 -- 0.25μg.m-3
Mercury
1 hour mean 0.0 0.0 -- 7.5μg.m-3
Note: Any apparent discrepancies are due to rounding.
6.5 The data in Table 6.1 show that maximum short-term (1 hour, 8 hour running
and 24 hour maximum mean) and long-term PCs at all receptors in the study
area are below the thresholds of Screening Stage 1. As such, no further
assessment is required, and the impact of cremator emissions can be considered
to be insignificant.
Cumulative impacts
6.6 With regard to cumulative impacts with road traffic emission, the maximum
increase in annual mean NO2 and PM10 predicted at any human receptor due to
cremator emissions was 0.2μg.m-3 (0.4% with reference to the AQS) and
0.0μg.m-3 (0.2% with reference to the AQS), respectively.
6.7 Existing sensitive receptors in the vicinity of the application site are all located at
a distance of greater than 10m from a road. The diffusion tubes with the highest
concentrations in the baseline assessment were located within 2.4m of the road.
Given that pollution concentrations tend to exponentially decline with distance
from roads23, it is considered likely that air quality at existing receptors in the
vicinity of the site is likely to be good (i.e. less than 75% of the AQS).
23
Laxen,D & Marner B (2008) NO2 Concentrations and Distance from Roads
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6.8 As such, large increases in NO2, PM10 and PM2.5 would be required to have, even,
a slight impact (i.e >6% increase with reference to AQS).Given that the proposed
development will not significantly increase traffic flows and the marginal
increases caused by cremator emissions, it is considered highly unlikely that
there would be significant adverse impacts caused by the cumulative impact of
road and cremator emissions.
Mitigation
6.9 As the proposed development will have no significant impact on air quality, no
mitigation is required to make the scheme acceptable in air quality terms.
However, to better align the mitigation proposal with SCC Local Transport Plan
and associated strategies, the proposals include:
1 dual header electric vehicle charge point; and
cycle racks and changing facilities.
6.10 In addition to the above, the proposed development includes several measures
that will minimise emissions associated with heating and powering the
development. These include:
Photo-voltaic (PV ) cells on roof;
The recycling of heat from cremator (subject to MEP design); and
Insulation standards in exceedance of Building Regulations
requirements.
6.11 Finally, it should be noted that the area has been identified as needing a
crematorium. As such, it is likely that there would be a regional reduction in
vehicle miles (and emissions) overall due to shorter distances travelled by
vehicles currently travelling to crematoria further afield.
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Discussion
7.1 A detailed air quality assessment was required to consider the potential impacts
of a proposed Crematorium on land north of Oxted Road and east of Barrow
Green Road, Oxted.
7.2 As air quality in Tandridge District is good and TDC has not declared any AQMAs.
Data from local monitoring and the UK-AIR suggest that concentrations across,
and in the vicinity, of the application site are likely to be well below the key AQSs
for NO2, PM10.and PM2.5.
7.3 The construction phase of the proposed development could give rise to
emissions that might cause some dust soiling effects on adjacent uses. However,
by adopting appropriate mitigation measures to reduce emissions and their
potential impact, there should be no significant residual effects, complying with
the requirements of the NPPF.
7.4 The proposed development is anticipated to generate, on average, 372 vehicle
trips a day; this falls below an EPUK and IAQM screening criterion for requiring a
detailed traffic assessment. As such, it was concluded that traffic generated by
the proposed development would have no significant impact on air quality.
7.5 A detailed dispersion model has also been used to predict maximum emissions
from the cremator flue, and hence the potential adverse impact, on the nearest
existing sensitive receptor locations in proximity to site. The dispersion
modelling assessment followed the precautionary principle and it was assumed
that the cremator would emit at the emission limit values set out in Defra’s
Process guidance note for Crematoria.
7.6 The results of the cremator assessment show that maximum pollutant impacts
are well below environmental assessment levels and no further assessment is
required, as impacts are not significant.
7.7 Given the site’s rural location, and the marginal increases in pollution
concentrations caused by the cremator, the risk that there would be significant
adverse impacts caused by the combined impact of road and cremator
emissions was considered to be negligible.
7.8 With regard to mitigation, the proposed development includes a host of green
measures designed to promote more sustainable forms of transport and reduce
emissions. These include the provision of one dual header EV charge point, cycle
racks, changing facilities, PV cells on the roof and standards of insulation that
exceed Building Regulations.
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