Harrow View, The Kodak Site

Transcription

1 Harrow View, The Kodak Site Environmental Statement Document: C-RPT-HVD010 Version 1 LS Harrow Properties Ltd December 2011

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3 Harrow View, The Kodak Site Environmental Statement Document: C-RPT-HVD010 Version 1 LS Harrow Properties Ltd December 2011 Halcrow Group Limited Arndale House, Otley Road, Headingley, Leeds LS6 2UL tel fax halcrow.com Halcrow Group Limited is a CH2M HILL company Halcrow Group Limited has prepared this report in accordance with the instructions of client, LS Harrow Properties Ltd, for the client s sole and specific use. Any other persons who use any information contained herein do so at their own risk. Halcrow Group Limited 2011

4 Harrow View, The Kodak Site Environmental Statement Document history Harrow View, The Kodak Site Environmental Statement LS Harrow Properties Ltd This document has been issued and amended as follows: Version Date Description Created by Verified by Approved by 1 08/01/11 Final V Barraud V Barraud D Harrison

5 Non-Technical Summary Introduction This Non-Technical Summary of the Environmental Statement for the Harrow View, the Kodak site project, has been produced on behalf of LS Harrow Properties Ltd, a wholly owned subsidiary of the Land Securities Property Group, by Halcrow Group Ltd, a CH2M HILL company. This document has been prepared in support of the outline planning application for the proposed mixed use proposed development of the application site in Harrow, north London (NGR TQ146898). This Non-Technical Summary provides a summary of the Environmental Statement which documents the findings of an Environmental Impact Assessment (EIA) of the proposed development. Due to the size (25.4 ha) and nature of the proposed development proposals, an EIA was required by the Council under Schedule 2 10(b) of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (Statutory Instrument No of 2011) The application site The application site is divided into two distinct parcels by a local road (Harrow View). The western parcel (Harrow View West) is currently used for sports, recreation and parking. The eastern parcel (Harrow View East) consists of Kodak s existing factory operations and large areas of cleared brownfield land where industrial buildings have been demolished. Aerial photograph of the application site (within the red line) i

6 The West Coast Main line runs adjacent and to the east of the application site. The surrounding land is generally residential although Headstone Manor, a historic building open to the public, is located to the west of the application site. Headstone Manor is surrounded by its own recreation grounds. Waverley Industrial Park is located to the east of the Harrow View site, which includes Harrow Crown Court. The proposals The proposal is for the comprehensive proposed development and regeneration of the application site for a mix of land uses with associated open space and landscaping, infrastructure, car parking and access roads. The project is expected to be implemented in five phases over approximately seven years. An illustrative land use plan is shown in Figure 1 (other designs may later be considered). The proposed project will include the following: Outline planning application for a comprehensive, phased, mixed use development of land at Harrow View, as set out in the Development Specification. The development comprises the demolition of existing buildings and structures and redevelopment of the site for a mix of uses comprising business and employment uses (within Use Classes B1(a), B1(b), B1(c) and B8); residential dwellings (within Use Class C3); student accommodation (sui generis use); senior living accommodation (within Use Class C3); assisted living care home (within Use Class C2); commercial leisure uses (Use Class D2); community uses (Use Class D1); health centre (Use Class D1); retail and restaurant uses within Use Classes A1, A2, A3, A4 and A5; a primary school (Use Class D1); together with new streets and other means of access and circulation; highway improvements; associated parking, re-profiling of site levels; utilities diversions and connections; open space; landscaping and ancillary development including supporting infrastructure, works and facilities. Alternatives considered Due to the nature of the application site, no alternative suitable locations have been identified for the proposed development. However, through the master planning process, a range of development proposals have been considered for the application site. Various options have been considered and discounted or included within the illustrative masterplan, prior to the identification of the proposals submitted for the outline planning application. The Scope of the Environmental Assessment A scoping assessment was undertaken to identify the scope of the EIA. This considered whether the proposed development could give rise to potential significant environmental effects across the following range of environmental topics as follows: Transport Air quality Noise and vibration Ground conditions Surface water ii

7 Ecology Landscape and visual amenity Socio-economic Cultural heritage and archaeology Waste The EIA Scoping Report (Halcrow 2011a) documents this process and was submitted to the Council in May 2011 for it to consider the scope of the EIA. During this process consultation was also undertaken with the Council officers and a range of statutory consultees to discuss key issues and the scope of the EIA. The EIA was carried out from July to November The process included studying the impact of the proposed development on the environment. Where significant impacts were identified, appropriate actions were designed to reduce the impact to an acceptable level. The full impact assessment is reported in the Environmental Statement and the key findings are highlighted below. Key findings of the Environmental Impact Assessment Transport A Transport Assessment was carried out which shows the number of additional road journeys that will be made as a result of the proposed development when compared to the application site in fully operational industrial use (taken as 2005). The Transport Assessment considered changes both after partial construction of the development (assumed to be 2017) and when it is complete (assumed to be 2021). Traffic surveys of the local roads were carried out as part of the Transport Assessment. The EIA elements of transport included consideration of road severance (e.g. from increased traffic use cutting off access across the road), driver delay, pedestrian delay and pedestrian amenity, changes to levels of fear and intimidation, and likely changes to accident and safety numbers. Impacts of the changes to transport were found to have either a minor adverse or minor beneficial impact (or be not significant). The proposed development includes a number of transport enhancements that will make improvements to the area. These include (amongst others) improved pedestrian and cycle routes around and through the application site and better bus facilities. The Transport Assessment demonstrated that the proposed development would result in an overall reduction in traffic journeys when compared to the fully operational industrial site. Air quality The application site is within an area managed by the Council for air quality. As well as existing data provided by the Council, ten months of air quality monitoring was iii

8 carried out for the project and air quality modelling (i.e. a computer simulation of likely effects) was carried out. The demolition and construction phase of the project is likely to result in the generation of dust which could cause a nuisance to local residents. Therefore measures will be designed to minimise dust nuisance, such as damping down stockpiles of earth and covering loaded trucks. The assessment during operation showed that the overall impact during operation on air quality is likely to be negligible for both existing residents and new residents (as the development is built), even if the Kodak Factory continues to operate on site. Consideration was also given as to the impact of the proposed energy centre, and impacts from this were also found to be negligible. Noise and vibration A noise and vibration survey was undertaken in 2010 for the project and the main existing sources of noise were identified as being trains, road traffic and the operations at the Kodak Factory. During construction significant noise impacts could occur, possibly affecting local residents. Therefore mitigation will be designed to minimise noise impacts. These are likely to include (amongst other actions) the use of the quietest working equipment available and erection of solid fences to provide noise barriers. During operation of the development there is not likely to be a significant noise impact as a result of any changes to traffic flows. Design targets have been identified for noise from new plant (such as that associated with the proposed energy centre) on the application site. Assuming these targets are adhered to, noise impact from plant will not have a significant impact. Noise and vibration impacts on future users of the application site will be reduced by the use of window glazing and detailed consideration of the layout of the development. This is particularly appropriate for development adjacent to the railway line and the main roads in the area (Harrow View and Headstone Drive). With appropriate mitigation in place, all noise and vibration impacts during operation have been identified as being not significant. Ground conditions Investigations of the soil and sub-soil conditions at the application site were carried out. Due to previous industrial uses, a range of soil contaminants were found to occur on the application site. Therefore a range of measures have been designed to prevent these existing contaminants from affecting future users of the application site or the environment. Measures include providing the application site with a covering of inert material and dealing with specific contaminated areas. Impacts from contamination on human health during demolition and construction were also considered and will be managed through the use of Best Practice (e.g. the wearing of appropriate protective clothing). There are also a number of wells on the application site which will require closing before construction starts. iv

9 Water environment There are no streams or rivers on the site, and only one surface drainage ditch on the western boundary of Harrow View West that eventually leads to Yeading Brook. An assessment of flood risk has been carried out for the area. The site is not within a river flood risk area, but surface water flooding could potentially occur as a result of heavy rainfall. To assess this risk a drainage strategy has been developed to ensure the development proposals make sufficient space for water and that properties are adequately protected from the risk of surface water flooding. Biodiversity Ecological surveys were carried out on and near the application site for protected species, including bats, great crested newts and reptiles. No protected species were found. A general ecological survey was also carried out along with a tree survey. The application site is generally not considered to be of significant ecological value. The area could support nesting birds and therefore vegetation will be cleared outside of the nesting season. The creation of habitats associated with the sustainable drainage system and landscape planting will enhance the area for biodiversity. Landscape and visual amenity The landscape of the Harrow View East site is currently dominated by the Kodak factory buildings, including a tall chimney. The landscape of the Harrow View West site is dominated by a large expanse of hard-standing and parked cars. There is also a large area of grassed sports fields surrounded by trees and hedges. Some of the trees on the east side of Harrow View, within the Harrow View East site, are protected with Tree Preservation Orders. Views from Headstone Manor were considered as part of the assessment, along with views from residential properties. Visual impacts on the surrounding area are likely to occur during the construction phases. Mitigation will include maintaining existing screening vegetation and the erection of hoarding to screen the application site at key locations. Once completed, the proposed development will have a significant beneficial impact on the local character of the area, as a result of replacing industrial buildings with the proposed development. The landmark chimney will be retained on the application site as a landscape feature. Socio-economic Kodak operations currently employ approximately 570 staff. The Harrow View site falls into the proposed Harrow and Wealdstone Intensification Area, which is an area designated for increased housing and commercial developments. The application site also benefits from good public transport accessibility. The proposed development will make a significant contribution to the regeneration of Harrow and Wealdstone providing up to 985 new homes (including affordable housing), a new healthcare facility and a primary school. There would be provision of employment space for a net increase of nearly 2,000 jobs on the application site. A number of public parks and play areas would also be created. The proposed project will therefore provide a significant socio-economic benefit to the area. v

10 Cultural heritage and archaeology The proposed development will not directly affect any legally protected sites of historical interest. Headstone Manor, which lies to the west of the application site, is a nationally protected site (Scheduled Monument) and has associated Listed Buildings. The Harrow View West element of the proposed development will result in partially opening up the views to and from Headstone Manor. The Citadel is a World War II bunker on the Harrow View East site. This will be left intact and access will be maintained, although development will take place above and around the structure. The Power House and its associated chimney will also be retained within the new development and will be refitted. Information on its current layout is likely to be recorded as a historical record. The sports pavilion will be demolished and again information on it may be recorded. There is no known archaeology within the application site, but due to the close proximity of Headstone Manor, buried archaeology could occur and there will therefore be taken into consideration during construction. Waste Consideration has been made of the impact of solid waste produced as a result of demolition, construction and operation on the environment. A plan has been prepared to manage construction waste as sustainably as possible, with the promotion of recycling of waste and re-use within the proposed development where possible. Recycling of waste during operation of the development will be optimised through the provision of appropriate areas to sort and store recyclable materials prior to collection. Notwithstanding these measures, West London s waste treatment facilities have the capacity to manage waste produced as a result of the Harrow View proposed development. Cumulative effects Consideration has been made in the EIA of other development that is due to take place within Harrow. An assessment has been carried out of the combined environmental effect of the proposed development and those of other development. No significant cumulative effects have been identified. Conclusions and recommendations In light of the size of the proposed development of the Harrow View site, a comprehensive EIA has been carried out. Impacts have been identified and appropriate mitigation measures either incorporated into the project or proposed for the next stage. There are likely to be some temporary impacts during construction as a result of disruption (such as increased noise, dust and visual impacts). However, during operation the impacts are mainly beneficial, with improved socio-economic benefits, landscaping and improvement to the ground conditions. A separate document will be produced (Construction Environmental Management Plan) that will take forward the actions identified in the Environmental Statement to ensure that the environment is protected during construction. vi

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12 Contents Non-Technical Summary i 1 Introduction Introduction Location of the proposed development Purpose of this ES Structure and content of this ES Context of this ES within the outline planning application Parameter plans and illustrative land use plan 17 2 Context and background Description of the application site Description of the surrounding area Background to the proposed development Strategic planning context Alternatives considered Consultation on the project 27 3 The proposed development Overview of proposed development Development parameters Implementation of the proposed development 38 4 EIA approach and methodology Introduction Scoping the EIA Approach to the EIA Further consultation on EIA process 48 5 Transport Introduction Methodology Legislation and policy Baseline conditions Assessment of impacts during construction Assessment of impacts during operation Mitigation and enhancements Conclusions and statement of residual significance 83 6 Air Quality 84 8

13 6.1 Introduction Methodology Legislation and policy Baseline conditions Assessment of impacts prior to and during construction Assessment of impacts during operation Mitigation measures Conclusions and statement of residual significance Noise and vibration Introduction Methodology Legislation and policy Baseline conditions Assessment of impacts during construction Assessment of impacts during operation Mitigation measures Conclusions and statement of residual significance Ground conditions Introduction Methodology Legislation and policy Baseline conditions Assessment of impacts during demolition and construction Assessment of impacts during operation Mitigation measures Conclusions and statement of residual significance Water Environment Introduction Methodology Legislation, policy and guidance Baseline conditions Assessment of impacts prior to and during construction Assessment of impacts during operation Mitigation measures Conclusions and statement of residual significance Biodiversity Introduction Methodology 204 9

14 10.3 Legislation and policy Baseline conditions Assessment of impacts during construction Assessment of impacts during operation Enhancements Conclusions and statement of residual significance Landscape and Visual Amenity Introduction Methodology Legislation and policy Baseline conditions Assessment of effects on landscape character prior to and during construction Assessment of effects on landscape character during operation Assessment of effects on visual amenity Mitigation measures Conclusions and statement of residual significance Socio-economic Introduction Methodology Legislation and policy Baseline conditions Assessment of impacts during construction Assessment of impacts during operation Mitigation measures Conclusions and statement of residual significance Archaeology and cultural heritage Introduction Methodology Legislation and policy Baseline conditions Assessment of impacts prior to and during site clearance/construction Assessment of impacts during operation Mitigation measures Conclusions and statement of residual significance Waste Introduction

15 14.2 Methodology Legislation and policy Baseline conditions Assessment of impacts prior to and during construction Assessment of impacts during operation Mitigation measures Conclusions and statement of residual significance Cumulative impacts Introduction Scope of the assessment Assessment of potential cumulative effects Impact assessment Consideration of the Harrow and Wealdstone Area Action Plan Conclusions and recommendations Conclusions 309 References 322 List of abbreviations used 326 Figures

16 List of figures (at end of main report unless indicated below) (Note Figures and Appendices are listed by chapter numbers eg Appendix 3.6 is from Chapter 3) 1.1 Application site location plan 1.2 Aerial photograph of the application site (in main report) 1.3 Planning Application Boundary 2.1 Existing site layout 3.1 Illustrative land use plan 3.2 Illustrative residential unit layout 3.3 Buildings demolition and retention 3.4 Zoning and land use 3.5 Principal Public Realm Areas 3.6 Local Play Areas 3.7 Maximum Building Height 3.8 Phasing plan 3.9 Model of proposed development from south 3.10 Model of proposed development from south 3.11 Illustrative Landscape Plan 3.12 Harrow View Recreational Ground Conceptual Drainage and Landscaping Proposals 3.13 Headstone Green Recreational Ground Conceptual Drainage and Landscaping Proposals 5.1 Cycle Network 5.2 Bus stop locations 6.1 Air quality monitoring locations 6.2 Air quality receptor locations 6.3 Traffic links for affected road network 7.1 Noise monitoring locations 7.2 Noise receptor locations 9.1 Surface water features 11.1 Landscape appraisal plan 12.1 Context Map (in main report) 12.2 Indices of Multiple Deprivation 2010 (in main report) 12.3 Education and health facilities (in main report) 12.4 Open space and leisure facilities (in main report) 13.1 Cultural heritage receptors 14.1 Kodak Harrow Site Waste Management (in main report) 12

17 List of appendices (at end of report) (Note Figures and Appendices are listed by chapter numbers eg Appendix 3.6 is from Chapter 3) 4.1 Scoping opinion 4.2 Response to scoping opinion Technical Note 4.3 Scoping responses 4.4 Legislation and policy 6.1 Air quality traffic data 6.2 Air quality modelling methodology 6.3 Air quality model verification 6.4 Diffusion tube results 7.1 Acoustic terminology and introduction to noise 7.2 Baseline noise monitoring report 7.3 Pilkington glass technical data 8.1 Geo-environmental data review Technical Note. 8.2 Geo-environmental Interpretation of ground investigation (for the Harrow View West site only) 10.1 Extended Phase 1 habitat survey report (January 2010) 10.2 Phase 1 habitat survey ground truthing Technical Note 10.3 Bat survey report 10.4 Great crested newt survey report (x 2 reports) 10.5 Reptile survey report 11.1 LVIA methodology 11.2 Photographs 13.1 Cultural heritage desk-based assessment 14.1 Outline SWMP 13

18 1 Introduction 1.1 Introduction This Environmental Statement (ES) has been produced by Halcrow Group Ltd on behalf of LS Harrow Properties Ltd (the applicant), a wholly owned subsidiary company of the Land Securities Property Holdings Limited. This ES has been prepared in support of an outline planning application, to be followed by submission of reserved matters applications pursuant to outline consent, for the proposed mixed use proposed development of the 25.4 ha Kodak site in Harrow, Greater London (NGR TQ146898) the application site (Figure 1.1). This ES documents the findings of an Environmental Impact Assessment (EIA) of the proposed development. Due to the size and nature of the proposed development proposals, an EIA is required by the local planning authority, the Council, under Schedule 2 10(b) of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (Statutory Instrument No of 2011), to support the submission of the outline planning application. In accordance with the statutory requirement to carry out an EIA, the likely significant environmental effects of the proposed development have been assessed, notwithstanding any other terminology used in specific chapters. Socio-economic elements of this Statement have been provided by Quod, the transport elements by Peter Brett Associates (PBA) and the planning policy elements by CBRE. The illustrative masterplan has been developed by BDP Architects and the Energy Strategy by Parsons Brinkerhoff. PPS has carried out Community Engagement for the project. 1.2 Location of the proposed development The application site is located in Harrow, Greater London (Figure 1.1). The application site is divided into two distinct parcels by a well-used, local road (Harrow View), a minor road that connects Harrow to the A4008 (Figure 1.2 and 1.3). The 7.94 ha western parcel (Harrow View West site) currently comprises car parking, a former privately operated leisure centre (Zoom Leisure which closed in September 2011), and private outdoor recreational facilities and private playing fields which are mostly no longer in use (Figure 1.3). The ha parcel to the east of Harrow View (the Harrow View East site) consists of Kodak s existing operations, producing a range of photographic products for the printing and publishing industry, and an area of cleared brownfield land where industrial buildings were demolished in late 2006/2007. A railway line (the West Coast main line) runs adjacent and to the east of the application site and the surrounding area is generally residential. 14

19 Figure 1-2: Aerial photograph of the application site. 1.3 Purpose of this ES The scope and content of this ES has been prepared in accordance with the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (the EIA Regulations). A scoping assessment undertaken in spring 2011, as documented in an EIA Scoping Report (Halcrow 2011a 1 ), determined the scope of the EIA by identifying the likely significant environmental effects of the proposed development across a range of environmental topics. The scope of the EIA has been informed by consultation with the local planning authority, the Council, and other statutory consultees (see Section 4.2 for details), as documented in a formal scoping opinion requested by the applicant and received from the Council in July Further details of this process are provided in Section If two references are for the same year, then a, b, c etc are used in the reference list at the back of the ES to denote which reference this applies to. 15

20 This report records the EIA process undertaken for the proposed development of Harrow View, the Kodak Site, and is submitted parting support of the outline planning application as required under the EIA Regulations. 1.4 Structure and content of this ES This report is structured into the following 16 chapters, supported by figures and appendices. The introductory four chapters describe the context to and reason for the proposed development and provide a description of the proposals and the EIA process. The following 10 chapters present the technical assessments undertaken for each environmental topic. The concluding chapters include an assessment of cumulative effects and highlight the key conclusions and recommendations from the EIA process. Chapter 1: Introduction Chapter 2: Context and background Chapter 3: The proposed development Chapter 4: EIA approach and methodology Chapters 5 to 14: provide the detailed technical assessments of the proposals for each environmental topic: - Chapter 5: Transport - Chapter 6: Air quality - Chapter 7: Noise and vibration - Chapter 8: Ground conditions - Chapter 9: Surface water - Chapter 10: Biodiversity - Chapter 11: Landscape and visual amenity - Chapter 12: Socio-economic - Chapter 13: Archaeology and cultural heritage - Chapter 14: Waste Chapter 15: Cumulative effects Chapter 16: Conclusions and recommendations A Non-Technical Summary (NTS), which summarises the contents of this ES, is also provided at the front of this report and is also available as a standalone document. 16

21 1.5 Context of this ES within the outline planning application his ES is one of several documents prepared in support of the outline planning application for the proposed development. The ES has had regard to the following separate documents: Transport Assessment (PBA, 2011a) and Travel Plan (PBA, 2011b) these provide the basis for Chapter 5 of the ES Heritage Statement (BDP, 2011a) informs the assessment of impacts on cultural heritage described in Chapter 13 Flood Risk Assessment (Halcrow, 2011b) informs the assessment of impacts on surface water described in Chapter 9 Other documents provide additional information relating to the details of the proposed development, the relevant aspects of which are summarised within Chapters 2 and 3 of the ES. These comprise: Planning Statement (CBRE, 2011) Design and Access Statement (BDP, 2011b) Statement of Community Involvement (PPS, 2011) Energy Statement (Parsons Brinkerhoff, 2011). Sustainability Statement (Halcrow, 2011c) Framework Travel Plan (PBA, 2011b) 1.6 Parameter plans and illustrative land use plan The assessments carried out to inform the ES and other documents supporting the outline planning application are based on the parameter plans and these form the basis of the development for which consent is being sought. In certain circumstances, where it has been necessary to use a level of detail beyond that contained in the parameter plans, the layout from the illustrative land use plan has been used as an example of one form of final development which may come forward. All conclusions relate to the parameter plans unless stated otherwise. An illustrative land use plan is included (Figure 3.1) as is an illustrative residential unit layout plan (Figure 3.2). Parameter Plans (relevant to the ES) are included in Figures A description of the development is included in Chapter 3. 17

22 2 Context and background 2.1 Description of the application site The Harrow View East site includes the operational Kodak factory (Figure 2.1). The application site consists of factory, storage and administrative buildings and some cleared areas. There is also a disused Second World War bunker (Air Ministry Building) on the east side of the application site. The following uses occur on the Harrow View East site: offices; research buildings; storage buildings; production buildings; security buildings; and power generation buildings. The Kodak factory employs approximately 560 staff, with shift work taking place. The Harrow View West site includes the following existing/former uses: private car parking (hardstanding) for staff of Kodak Ltd providing space for approximately 500 vehicles; Zoom Leisure centre (which closed in September 2011 for commercial reasons). This was a large private leisure facility that had sports halls, function space, a gym, a golf facility and a bar (Eastman Hall); Kodak Car Club buildings; sports pitches, bowling club (disused), sports pavilion and tennis courts; and rifle range (disused). 2.2 Description of the surrounding area The area surrounding the application site is predominantly residential with some retail elements. The Harrow View East site is bounded by Headstone Drive to the south, and the railway line along its eastern boundary (Figure 2.1). To the west of the Harrow View West site is Headstone Manor, a medieval estate with a manor house which also includes the Harrow Museum and Heritage Centre, and Headstone Manor Recreation Ground. To the north and south of both sites the area is residential with low density (mostly semi-detached) housing. Waverley Industrial Park is located immediately to the east of the Harrow View East site and Harrow Crown Court is to the south-east. Whitefriars First and Middle School (including its playing fields) is located 75m to the east of Harrow View East site (on the east side of the railway line). 18

23 Harrow and Wealdstone Station lies to the south-east of the application site and Headstone Lane Station lies to the north-west. Significant roads in the area include Harrow View and Headstone Drive which, although not A or B-roads, are main distributer roads in the local area. The A409 lies approximately 500m east of the application site (at its closest point) and the A404 lies approximately 1km west of the application site. An extant consent exists for highway works on Harrow View, including the formation of a roundabout to improve access into the Harrow View West and the Harrow View East sites. Consent has been issued to a different developer to deliver up to 43 one and two bedroomed apartments on the application site of the now vacant The Goodwill to All Public House (to the south west of the Harrow View East site) but work has not yet commenced. The effect of other development in the area is considered under the cumulative effects chapter (Chapter 15). 2.3 Background to the proposed development Kodak is currently in the process of scaling down its factory operations at the application site and in late 2006 and 2007 vacated and demolished a number of buildings which were no longer fit for purpose or were surplus to requirements. The longer term strategy is to either consolidate operations in new premises within Harrow View East, as part of the proposed development or to completely vacate the application site and release the land for proposed development. To facilitate the delivery of a viable regeneration proposal, Kodak enlisted LS Harrow Properties as joint venture partners. Proposals to redevelop the Harrow View site for a sustainable mix of uses have emerged over time, largely in response to local need and demand and with accompanying robust evidence to justify the mix and quantum of uses sought. The proposals articulate a vision for the proposed development which has been (and continues to be) informed by key stakeholders. Kodak s operational requirements have also influenced the proposed phasing of the development over a period of 7 years. The strategic planning context and development plan compliance are outlined fully in the Planning Statement prepared by CBRE. 2.4 Strategic planning context Introduction An overview of the adopted and emerging national, regional and local planning policy context, together with other material considerations, for the proposed development has been prepared by CBRE. For the purposes of the EIA, this planning policy overview is high level, focusing on the key planning policies, and the acceptability of the principle of the proposed development on this site. Specific planning policies relating to specific impacts of the proposed development are also considered in each of the other technical chapters of 19

24 the ES where relevant. A full review of the relevant planning policies and guidance is provided in the Planning Statement prepared by CBRE Status of policies Section 38(6) of the Planning and Compulsory Purchase Act 2004 requires applications to be determined in accordance with the proposed Development Plan unless material considerations indicate otherwise. In addition, Section 38(5) of the Act requires that where there is a conflict between development plan policies, the most recently adopted policy takes precedence. The statutory Development Plan that covers the application site comprises: The London Plan (July 2011); and The 'saved' policies of the Harrow Unitary Development Plan (UDP) (2004) Material considerations Other documents relevant to the planning policy context, forming material considerations, include: National PPG Notes and PPSs (various); Draft National Planning Policy Framework; The Mayor s Outer London Commission: Pre-Publication Report (May 2010); Draft Harrow Core Strategy (Submission Version); Harrow and Wealdstone Area Action Plan (AAP) Issues and Options consultation document; London Plan Supplementary Planning Guidance (SPG); Industrial Capacity SPG; Providing for Children and Young People s Play and Informal Recreation; and Supplementary Planning Documents (SPDs) prepared by the Council, including: - Accessible Homes SPD - Access for All SPD - Sustainable Building Design SPD - Residential Design Guide SPD National PPG/Statements National planning policy is set out in a series of Planning Policy Guidance Notes (PPGs) and Planning Policy Statements (PPSs), which represent material considerations for determining all planning applications. The relevant adopted and 20

25 draft planning policy at national level is set out in the following publicly available documents: PPS 1: Delivering Sustainable Development (January 2005); PPS1 Supplement: Planning and Climate Change (December 2007); PPS 3: Housing (June 2011); PPS 4: Planning for Sustainable Economic Growth (December 2009); PPS 5: Planning for the Historic Environment (March 2010); PPS 9: Biodiversity and Geological Conservation (August 2005); PPS 10: Planning for Sustainable Waste Management (March 2011); PPG 13: Transport (January 2011); PPG Note 17: Planning for Open Space, Sport and Recreation (July 2002); PPS 22: Renewable Energy (August 2004); PPS 23: Planning and Pollution Control (November 2004); PPG 24: Planning and Noise (October 1994); PPS 25: Development and Flood Risk (March 2010); PPS 25: Development and Flood Risk Practice Guide (June 2008); Consultation Paper on a new PPS: Planning for a Natural and Healthy Environment (March 2010); and Development Management: Proactive Planning from Pre-Application to Delivery Consultation (December 2009) Emerging national planning guidance A number of changes are proposed to the planning system in the context of the recent Localism Act, including an overhaul of the national level policy framework. A review of national planning policy is currently underway, designed to consolidate policy statements, circulars and guidance documents into a single concise National Planning Policy Framework (NPPF). A consultation draft NPPF document was published by the Department for Communities and Local Government (CLG) in July Regional planning policy Shortly after its election to power, the Coalition Government made clear its intention to abolish Regional Strategies (RSs), although confirmed that the Spatial Development Strategy for Greater London (the London Plan) would not be abolished. The London Plan (July 2011) The London Plan was adopted in July 2011 and formally replaces The London Plan (Consolidated with Alterations since 2004) The London Plan retains the 21

26 fundamental objective of accommodating London s population and economic growth through sustainable development. The policies shown in Table 2.1 have been considered as relevant to the ES Table 2.1: The London Plan relevant policies Policy number and name Policy 2.6: Outer London: Vision and Strategy Policy 2.7: Outer London Economy Policy 2.8: Outer London: Transport Policy 2.13: Opportunity Areas and Intensification Areas Policy 2.17: Strategic Industrial Locations Policy 2.18: Green Infrastructure: The Network of Open and Green Spaces Policy 3.1: Ensuring life chances for all Policy 3.2: Improving health and addressing health inequalities Policy 3.3: Increasing housing supply Policy 3.4: Optimising Housing Potential Policy 3.5: Quality of Design of Housing Developments Policy 3.6: Children and Young People s play and informal recreation facilities Policy 3.7: Large Residential Developments Policy 3.8: Housing Choice Policy 3.9: Mixed and Balanced Communities Policy 3.10: Definition of Affordable Housing Policy 3.11: Affordable Housing Targets Policy number and name Policy 5.5: Decentralised energy networks Policy 5.6: Decentralised energy in development proposal Policy 5.7: Renewable Energy Policy 5.8: Innovative energy technologies Policy 5.9: Overheating and cooling Policy 5.10: Urban greening Policy 5.11: Green roofs and development site environs Policy 5.12: Flood Risk Management Policy 5.13: Sustainable Drainage Policy 5.14: Water Quality and Wastewater Infrastructure Policy 5.15: Water Use and Supplies Policy 5.17: Waste Capacity Policy 5.21: Contaminated Land Policy 6.1: Strategic Approach Policy 6.2: Providing Public Transport Capacity and Safeguarding Land for Transport Policy 6.3 Assessing Effects of Development on Transport Capacity Policy 6.9: Cycling 22

27 Policy number and name Policy 3.12: Negotiating Affordable Housing on Individual Private Residential and Mixed Use Schemes Policy 3.13: Affordable Housing thresholds Policy 3.14: Existing Housing Policy 3.16: Protection and enhancement of social infrastructure Policy 3.17: Health and Social Care Facilities Policy 3.18: Education Facilities Policy 3.19: Sports Facilities Policy 4.1: Developing London s Economy Policy 4.2: Offices Policy 4.3: Mixed Use Development and Offices Policy 4.4: Managing Industrial Land and Premises Policy 4.6: Support for and enhancement of arts, culture, sport and entertainment provision Policy 3.16: Protection and enhancement of social infrastructure Policy 4.7: Retail and Town Centre Development Policy 4.8: Supporting a successful and diverse retail sector Policy 4.9: Small Shops Policy 4.11: Encouraging a connected economy Policy 4.12: Improving opportunities for all Policy 5.1: Climate Change Mitigation Policy 5.2: Minimising Carbon Dioxide Emissions Policy number and name Policy 6.10: Walking Policy 6.12: Road Network Capacity Policy 6.13: Parking Policy 7.1: Building London s Neighbourhoods and Communities Policy 7.2: An Inclusive Environment Policy 7.3: Designing Out Crime Policy 7.4: Local Character). Policy 7.5: Public Realm Policy 7.6: Architecture Policy 7.8: Heritage assets and archaeology Policy 7.9: Heritage-led regeneration Policy 7.13: Safety, security and resilience to emergency Policy 7.14: Improving air quality Policy 7.15: Reducing noise and enhancing soundscapes Policy 7.18: Protecting local open space and addressing local deficiency Policy 7.19: Biodiversity and access to nature Policy 7.20: Geological conservation Policy 7.21: Trees and Woodlands Policy 8.2: Planning Obligations Policy 8.3: Community Infrastructure Levy 23

28 Policy number and name Policy number and name Policy 5.3: Sustainable Design and Construction Local planning policy The Harrow UDP (adopted 2004) sets out the Council s planning policies for land within its administrative area. Following receipt of a Direction from the Secretary of State, 56 policies were permanently deleted from the UDP effective from 27 September The remainder of the policies have been saved for Development Management purposes. The policies of relevance are set out as shown in Table 2.2 Table 2.2: Harrow UDP policies Policy number and name Policy S1: The form of development and pattern of land use Policy SEP5: Structural Features Policy ST3: London-Wide Highway Network Policy SEM1: Development and the Borough s Regeneration Strategy. Policy SEM2: Hierarchy of Town Centres Policy SR2: Cultural, Entertainment, Tourist and Recreational Activities Policy EP11: Development within floodplains Policy EP12: Control of surface water runoff Policy EP13: Culverting and deculverting Policy EP14: Development within Areas at Risk from Sewerage Flooding Policy EP15: Water conservation Policy EP16: Waste management, disposal and recycling facilities Policy EP20: Use of previously developed land Policy number and name Policy T12: Reallocating available roadspace and managing traffic Policy T13: Parking Standards Policy T14: Public car parking Policy of T15: Servicing of new developments Policy of T16: Servicing of new developments Policy H3: New Housing Provision Policy H7: Dwelling Mix Policy H14: Residential institutions. Policy H17: Access for special households with particular needs Policy EM4: New office development Policy EM5: New large scale retail and leisure and other development Policy EM6: Limiting goods sold at out or edge of centre developments Policy EM9: Variety of unit sizes 24

29 Policy number and name Policy number and name Policy EP22: Contaminated Land Policy EM11: Regeneration Areas Policy EP25: Noise Policy EP26: Habitat creation and enhancement Policy EP27: Special protection Policy EP28: Conserving and enhancing biodiversity Policy EP29: Tree masses and spines Policy EP30: Tree preservation orders and new planting Policy EP43: Green Belt and Metropolitan Open Land Fringes Policy EP47: Open Space Policy EP50: Informal areas of open space Policy D4: The standard of design and layout Policy D5: New residential development amenity space and privacy Policy D10: Trees and new development Policy D19: Ancient Monuments Policy D23: Lighting, including floodlighting Policy D25: Shopfronts and advertisements Policy D29: Street furniture Policy D30: Public art and design Policy T6: The transport impact of development proposals Policy EM12: Small industrial units and workshops Policy EM14: Land and buildings in business, industrial and warehousing use Policy EM22: Environmental impact of new business development Policy EM25: Food, Drink and Late Night Uses Policy R4: Outdoor sports facilities Policy R7: Footpaths, Cyclepaths and Bridleways Policy R8: Play areas Policy R11: Protecting arts, culture, entertainment and leisure facilities Policy R13: Leisure Facilities Policy C2: Provision of social and community facilities Policy C7: New educational facilities Policy C8: Health Care and Social Services Policy C16: Access to buildings and public spaces Policy C17: Access to leisure, recreation, community and retail facilities Policy T12: Reallocating available roadspace and managing traffic Policy T13: Parking Standards Policy T14: Public car parking Policy of T15: Servicing of new developments Policy T7: Improving public transport facilities 25

30 2.4.8 Emerging planning policy Harrow Local Development Framework The Planning and Compulsory Purchase Act (2004) dictates that Local Planning Authorities must move away from the old system of Local Plans and UDPs towards the preparation of a Local Development Framework (LDF). Once adopted, the LDF will become part of the statutory Development Plan for that administrative area and will effectively replace those UDP policies that have been saved. the Council has commenced the preparation of its LDF. Harrow s LDF will comprise a portfolio of Local Development Documents (LDDs) including a series of Development Plan Documents (DPDs), including a Core Strategy and Harrow and Wealdstone Area Action Plan Harrow Submission Draft Core Strategy (June 2011) Given the advanced stage the Core Strategy has reached, the emerging policies within the Submission Draft Core Strategy can be afforded considerable weight. On the Core Strategy Key Diagram (29), the Harrow View site falls within the Harrow and Wealdstone Intensification Area; the Harrow View East site is identified as a Strategic Industrial Location (SIL) and the western part of the Harrow View West site is identified as Open Space. The emerging policies of relevance to the proposed development of the planning application site within the Submission Draft Core Strategy are set out in Table 2.3, below. Table 2.3: Core Strategy Relevant policies Policy number and name Core Policy 1: Overarching Policy Objectives Core Strategy Policy 1: Managing growth in Harrow Policy CS1B: Local Character Policy CS1D: Local Character Policy CS1E: Local Character Policy CS1F: Open Space, Sport and Recreation Policy CS1G: Open Space, Sport and Recreation Policy CS1I: Housing Policy CS1J: Housing Policy CS1K: Housing Policy number and name Policy CS1N: Economic development and employment Policy CS1: Economic development and employment Policy CS1Q: Transport Policy CS1R: Transport Policy CS1T: Responding to climate change Policy CS1U: Sustainable flood risk management Policy CS1X: Sustainable Waste Management Policy CS1Z: Required infrastructure Policy CS1AA: Required Infrastructure Core Policy 2: Harrow and Wealdstone 26

31 Policy number and name Policy number and name Policy CS1L: Town Centres Harrow and Wealdstone Area Action Plan Issues and Options Consultation Document (May 2011) the Council published a draft Issues and Options consultation document for the Harrow and Wealdstone Intensification Area (designated by the London Plan) on 13 May 2011 for a six week period of public consultation. As an Issues and Options document, this iteration of the AAP represents an early and informal stage of the Plan s preparation. As such, none of the spatial development strategy options referenced carry any commitment of weight. However, the evidence that has been prepared to underpin the emerging AAP is relevant and up-to-date, hence is considered to represent a material consideration of considerable importance to the Harrow View proposals Supplementary Planning Guidance/Supplementary Planning Documents Supplementary Planning Documents (SPD) are used to provide further detail and guidance on the implementation of policies and proposals contained in the existing Harrow Unitary Development Plan (UDP) and future Development Plan Documents. Several SPDs have been developed by Harrow View to help clarify what the Council expects developments to provide and protect, including: Accessible Homes Supplementary Planning Document (SPD) (adopted March 2010); Access For All Supplementary Planning Document (SPD) (adopted April 2006); Sustainable Building Design Supplementary Planning Document (SPD) (adopted May 2009); and Residential Design Guide Supplementary Planning Document (SPD) (adopted December 2010). 2.5 Alternatives considered Due to the nature of the application site, which is in part cleared and ready for development, no alternative suitable locations have been identified for the proposed development. However, through the master planning process, a range of development proposals have been considered for the application site. Various options have been considered and discounted or included within the project, prior to the identification of the proposals described in Section 3 and have been described in the Design and Access Statement (DAS) (BDP, 2011). 2.6 Consultation on the project As part of the masterplanning process the applicant has undertaken a thorough consultation exercise. 27

32 The Council s adopted Statement of Community Involvement (SCI, 2006) confirms that the Council welcomes and encourages pre-application discussions between applicants, their agents, developers or interested parties. Paragraph 6.9 of the SCI explicitly states that for major proposals or applications affecting the wider community, the Council expects the developer to undertake pre-application consultation. Extensive engagement has been undertaken with the Council since the inception of the proposals for the proposed development of the Harrow View site. The nature of this engagement has gradually changed into more formal pre-application engagement, particularly during LS Harrow Properties entered into a formal Memorandum of Understanding (MoU) with the Council on 23 July 2010 specifically in connection with the Kodak Site as it was then known, which sets a vision for the future of the application site and to facilitate the bringing forward of the proposed development proposals through the planning application process. The MoU also formalises LS Harrow Properties and the Council s commitment to enter into a Planning Performance Agreement to manage the process of future planning applications for the Kodak site. In June 2011 LS Harrow Properties entered into a Planning Performance Agreement (PPA) both with the Council and with Transport for London (TfL) to formalise the pre-application stage of engagement in respect of its proposals for Harrow View. The planning proposal within the PPA is for: A sustainable, mixed use scheme for the Kodak site which through enabling development, comprised of residential, retail, commercial and community uses, unlocks the application site s employment generating potential. The principle of which is consistent with the Council s (and other) policies. The PPA explicitly recognises at paragraph 2.3 that: The joint working over the past months has established that Harrow View has the potential to play a significant role in delivering new employment, and enabling residential and other land uses, as well as delivering a number of community benefits and facilitating opportunities elsewhere in the Borough. LS Harrow Properties has continued to engage with the Council Officers, the consultants advising the Council on the Area Action Plan, Design for London and statutory consultees including TfL as part of its comprehensive programme of preapplication discussions under the terms of the PPA. Discussions have also taken place with other departments at the Council including; Housing, Leisure, Transport and Environmental Health. The GLA have been consulted on the proposals. A formal pre-application request was made to the GLA in September 2011 and a meeting with Officers took place on 20th October

33 LS Harrow Properties has also consulted a number of other statutory consultees for pre-application advice including; Sport England, Environment Agency, Metropolitan Police. LS Harrow Properties considers that the opinions and insights of the local community are invaluable when considering a site of the scale of the application site, and hence they have conducted a comprehensive and extensive programme of public consultation exercises, including exhibitions, to provide the local community with the opportunity to comment on the proposals and workshop sessions. The feedback obtained from these has been fed back to and considered by the design team to inform the development of the project. The November 2010 public exhibitions about the future of the application site were attended by over 600 people and over 150 people completed a detailed feedback form. The second stage of the pre-application consultation took place in March Over 100 visitors attended one or more of eight workshop sessions. Most recently, over 800 people visited the second public exhibitions in late June and early July 2011, which showed how the feedback received so far has helped shape the emerging proposals. Details of these events and the associated Stage One, Stage Two and Stage Three Public Consultation Feedback Reports are provided in. In addition to community consultation exercises, the latest information about the proposals can be viewed on the dedicated project website which is updated regularly. 29

34 3 The proposed development 3.1 Overview of proposed development An outline planning application is being made for a comprehensive, phased, mixed use development of land at Harrow View, as set out in the Development Specification. Outline planning application for a comprehensive, phased, mixed use development of land at Harrow View, as set out in the Development Specification. The development comprises the demolition of existing buildings and structures and proposed development of the application site for a mix of uses comprising business and employment uses (within Use Classes B1(a), B1(b), B1(c) and B8); residential dwellings (within Use Class C3); student accommodation (sui generis use); senior living accommodation (within Use Class C3); assisted living care home (within Use Class C2); commercial leisure uses (Use Class D2); community uses (Use Class D1); health centre (Use Class D1); retail and restaurant uses within Use Classes A1, A2, A3, A4 and A5; a primary school (Use Class D1); together with new streets and other means of access and circulation; highway improvements; associated parking, reprofiling of site levels; utilities diversions and connections; open space; landscaping and ancillary development including supporting infrastructure, works and facilities. The above will be carried out together with the creation of new streets and other means of access and circulation, highway improvements, associated parking, reprofiling of site levels, utilities diversions and connections, open spaces, landscaping and ancillary development including supporting infrastructure. An illustrative land use plan (Figure 3.1) was prepared for the application site to illustrate the proposed type and extent of land uses which has been the result of a detailed consultative masterplanning process. As a result of this process a series of key parameters have been defined and associated parameter plans prepared (Figures 3.3 to 3.7). These parameter plans provide the basis for the assessment of significant environmental effects within the EIA. These are described in Section 3.2. It is envisaged that the application site will be developed in phases (to align with Kodak s consolidation and exit from the application site) and hence the planning strategy for the application site involves the submission of reserved matters applications pursuant to outline consent. The possible phases are discussed in Section 3.3 and shown on Figure Development parameters Introduction The key development parameters which provide the basis of the assessment undertaken for this EIA are as shown in Figures 3.3 to 3.7. Further details of each of these parameters are provided in the following sections Land use types 30

35 The proposed development comprises the following proposed land use types and extent (land use classification code is given in brackets e.g. (B1): Development Zones Uses Floorspace/units A B C D Leisure (D1) Retail (A1-A5) Community (D1/D2) Health Centre (D1) Student Housing (sui generis) Residential (C3) Employment (B1) Retail (A1-A5) Employment (B1) Residential (C3) Care home (C2) Residential (C3) up to 1,155 sq m up to 5,125 sq m up to 1,562 sq m up to 2,816 sq m 220 units up to 74 units up to 3,932 sq m up to 875 sq m up to 1,430 sq m up to 129 units up to 5,500 sq m up to 66 units E Employment (B1/B8) up to 8,426 sq m F Café/community (D1/D2) up to 550 sq m G Residential (C3) up to 153 units H Residential (C3) up to 74 units J K L Senior living (C2) Residential (C3) Employment (B1) Residential (C3) Energy centre (sui generis) Car park (sui generis) up to 4,730 sq m up to 32 units up to 1,860 sq m up to 134 units up to 4,950 sq m up to 400 spaces M Employment (B1) up to 16,225 sq m 31

36 Development Zones Uses Floorspace/units N Employment (B1) up to 7,700 sq m P Residential (C3) up to 109 units Q School (D1) up to 3,630 sq m R Residential (C3) up to 59 units S Residential (C3) up to 65 units T Residential (C3) up to 62 units U Residential (C3) up to 128 units There will also be associated parking (including a multi-storey car park with up to 400 spaces), open space, landscaping and ancillary development Proposed phasing schedule It is currently anticipated that the proposed development will be brought forward in five phases over an eight year period, each of which will include the necessary preparatory works and subsequent construction works. A phasing schedule for the proposed development is shown on Figure 3.8 and Table 3.1, below: 32

37 Table 3.1: Proposed phasing of construction Year (March to March) Phase Site Operation Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Receive Outline Planning Approval Enabling Works Construction 1a Southern Site Development 1b Harrow View West Development 1c Southern Site (Kodak Reception Building Etc) Phase 2 Northern Site Development Site clearance and remediation Development Phase 3 Central Site Site clearance and remediation Development 33

38 This phased programme means that different types of activities (constructional and operational) will be undertaken across the application site at any given point in time. This complexity has been considered within the EIA to ensure that impacts on existing and newly introduced receptors are fully considered Access and movement Access Access points for each phase of development are as follows: Phase 1a: access from Headstone Drive for Harrow View East; Phase 1b: access from Harrow View for Harrow View West; Phase 1c: access from Headstone Drive for Harrow View East; Phase 2: access from Harrow View for Harrow View East; and Phase 3: access from both Harrow View and Headstone Drive Movement all modes Parking The development proposals include the creation of a green link through the heart of the application site linking Headstone Manor and Headstone Drive with a new pedestrian/cycle facility. This route opens up a previously closed area, ultimately providing permeability through the application site and linking to the external access network of Headstone Drive, Harrow View and beyond. The crossing facility for the proposed green link is to be in the form of a pedestrian crossing over Harrow View. Pedestrian routes from the application site will link to the local bus stops which are situated within 800m of the application site. Access for vehicular transport will be as shown on Figure 3.5 and will consist of one main route through the Harrow View East site suitable for heavy vehicles and distributor roads suitable for lighter traffic. The Harrow View West site would only have access roads for lighter traffic leading to residential areas. Consideration has been given to design of the street environment within the illustrative masterplan. Shared space principles have been adopted along with promoting an active frontage to increase social interaction and improve public perception of safety. Permeable routes within the application site have been included which link through to the external access network encouraging walking within/to/from the application site through these improved facilities. The corridors adjacent to the application site have been considered in terms of the pedestrian environment and the assessment specifically looks at the routes to the underground station, local bus stops and the nearby High Street of Wealdstone. Cycle routes will be provided within the application site linking with the external access network. Further information on this is given in Chapter 5 and in the Public Realm Strategy of the Design and Access Statement (DAS) (BDP, 2011b). 34

39 The strategy includes elements of designated and undesignated parking along with a multi-storey car park (MSCP) located on the Harrow View East site, providing parking with charges for all the land uses. Spaces for electric charging points and disabled parking have been included in the illustrative masterplan. A Delivery and Service Plan is provided as part of the DAS accompanying the planning application Framework travel plan As part of the planning application, a site wide Framework Travel Plan (FTP) has been developed which includes a number of measures to encourage walking, cycling and public transport use. Those measures include: Provision of a car club on site; Upgrade of existing bus services adjacent to the application site; Upgrade of pedestrian/cycle facilities off site; Provision of pedestrian/cycle infrastructure on site; Parking charges; Parking management; and TravelSmart initiative a marketing tool used to encourage people to travel by modes other than car Infrastructure, utilities and surface water drainage proposals Utilities and services The following works will be required on the existing utilities: Electricity: removal of five high voltage substations within the Harrow View East site; Disconnections/potential abandonment of public foul and surface water sewers (approximately twelve); Disconnections of gas mains at the application site boundaries (1 x medium pressure service and 2 x low pressure services); and Diversions of British Telecommunications cables and/or fibres within the application site; and three British Telecommunications disconnections. New provision will be required for the following: Electricity supply: the local primary substation has sufficient capacity. The project will require extension of the local high voltage network from two connections points on Headstone Drive and Harrow View; Gas: the new supply will be taken from the existing medium pressure gas main along Harrow View; and 35

40 Potable water: replacement will be required of approximately 500m of 6 inch main with an 8 inch main along Harrow View and/or an 8 inch supply from the 16 inch trunk main along Headstone Drive Surface water drainage strategy The proposed surface water drainage strategy for the application site will ensure that, in accordance with Planning Policy Statement 25 (PPS 25) and Environment Agency requirements, a suitable drainage network, including Sustainable Urban Drainage Systems (SUDS) elements, will be installed to reduce future flood risk to both the application site and its surroundings from surface water runoff. Taking into account the constraints of the application site, the proposed surface water drainage strategy comprises attenuation measures to restrict surface water discharge rates to equivalent Greenfield rates. Where possible, surface water runoff will be initially treated using source control techniques such as permeable paving, rooftop attenuation and swales. Site controls such as ponds will then provide attenuation volumes that cannot be achieved using the source control features. Surface water discharge equivalent to Greenfield runoff rates will be conveyed to the public surface water sewer network and existing watercourses (the existing ditch adjacent to the western boundary of Harrow View West) outside the application site. The form, location, and size of the various SUDS facilities needed to achieve the specified discharge rates and attenuation volumes to be accommodated will be determined at the detailed design stage. A conceptual SUDS based drainage layout and preliminary calculations of discharge rates and attenuation volumes are given in the Flood Risk Assessment (FRA), (Halcrow, 2011). The proposed SUDS facilities and associated landscape planting is shown on Figure This has been designed to tie into the future drainage strategy for Headstone Manor Recreation Ground as shown on Figure 3.13, though it should be noted that this is not part of this current planning application Sustainable design principles A Sustainability Statement document has been produced for the Harrow View development (Halcrow, 2011); this document outlines compliance with the current planning requirements for sustainable planning and design, at national, regional and local level. The references include: UK Planning Policy; UK Low Carbon Transition Plan; The London Plan; The London Plan supplementary guidance; Sustainable Community Strategy the Council; and Sustainable Building Design SPD (2009) - the Council. 36

41 In addition to the sustainability checklists included in the mentioned documents, Halcrow have applied sustainability assessment tools in order to identify suitable sustainability strategies for the development: Code for Sustainable Homes (targeting Code 4 for Phases 1A,1B and Code 5 for Phases 1C, 2,3); BREEAM (targeting Very Good rating); and HalSTARTM (Halcrow s comprehensive sustainability tool). The sustainability statement document includes a summary of the strategies taken on board at design stage with reference to specialised studies such as energy strategy, transport, waste and flood risk reports Energy strategy An Energy Strategy has been developed for the Harrow View development in order to comply with the requirements of building regulations, the 2011 adopted London Plan and the emerging Harrow Core Strategy. The energy modelling undertaken by Parsons Brinkerhoff examines two potential supply scenarios: Harrow View development supplied from a single decentralised energy solution (such as a power plant); and The higher density Harrow View East site supplied from a decentralised solution and lower density Harrow View West site supplied from buildingspecific technology (such as air source heat pumps and photovoltaic cells (PV). The outcome of the energy and financial modelling indicates that the preferred solution is for a decentralised energy network-based solution at the Harrow View East site, with building-specific measures at the Harrow View West site. Details on the proposed measures are included in the Energy Strategy (Parsons Brinkerhoff, 2011). In light of the problems that biomass would cause, with respect to air quality, vehicle movements and storage requirements, it has been discounted as an option. The Harrow View East site would therefore have a gas-powered Combined Heat and Power (CHP) plant, supplemented by solar Photo Voltaic cells. The CHP would have approximately 1MW of output. The proposed Energy Centre will be constructed on the ground floor of the Multi Storey Car Park (MSCP). This will consist of a building to house the boilers etc. and a chimney that will be approximately 23m high. The chimney will be located adjacent to the MSCP building which will be approximately 18m high, so the chimney will extend approximately 5m above the MSCP. The Harrow View West site will have an Air Source Heat Pump attached to each building. These small structures will be approximately 1 x 0.5 x 0.4m in size. Each 37

42 building will also have PV units on the roofs and supplemented by further PV units on car park awnings. 3.3 Implementation of the proposed development Introduction The proposed development of the application site will involve a variety of construction activities, including clearance of the existing industrial buildings/structures and the associated infrastructure (roads, services and drainage), remediation of the ground to mitigate risks to human health arising from previous contaminative processes and construction of new buildings/structures and infrastructure associated with the intended land uses. These activities will occur at different times within different areas of the application site according to the proposed phasing plan and phasing programme. The activities described below form the basis for the construction assessments undertaken as part of this EIA in Chapters 5 to 14. It is anticipated that the following primary construction activities will take place during the course of the proposed development. Demolition and site clearance: Demolition of buildings and structures; Removal of sub-structures including basements and foundations and backfilling; Removal of roads, hardstandings, utility services and drainage; and Crushing, grading, sorting and potentially treating site won aggregate replacement, granular and fill materials. Remediation: Excavation to remove localised contamination; Earthworks cut and fill to suit proposed development profiles; Construction of a formal cover system to mitigate human health risks; and Decommissioning of groundwater abstraction wells and groundwater monitoring boreholes Construction of new land uses: Construction of buildings/structures and associated foundations (i.e. pile foundations to multi story car park); and Construction of associated new infrastructure including roads, hardstandings, landscaping, utility services and drainage. These stages are described in more detail below. 38

43 3.3.2 Preparatory works (including demolition and site clearance, remediation and site re-profiling) It is anticipated that the following primary construction activities will take place during the preparatory works phase of the development. Demolition and Site Clearance: Soft Strip: Removal of contaminative and organic materials (asbestos, asphalt, wood etc.) using hand held tools or small mechanical plant. These materials will be sorted, placed in skips and transported off-site for disposal at suitably licensed facilities; Hard Demolition: The buildings and structures (concrete and steel framed) will then be demolished (above and below ground) using long reach tracked machines equipped with hydraulic attachments (excavator buckets, breakers and munchers ). Primary grading and sorting will be undertaken at the point of creation but further crushing, grading and sorting will be carried out at selected site locations to maximise re-use and recovery operations. Any voids formed by the removal of foundation structures and basements will be backfilled with suitable material using track mounted excavators and earthwork compactors; Asphalt road surfaces will be planed off and track mounted machines equipped with excavator buckets and hydraulic breakers used to remove concrete surfacing and sub-base/capping materials as necessary; Vegetation clearance, involving loping of trees, removal of hedges and grubbing up of roots, will be carried out using chain saws and track mounted excavators; Hard arisings from demolition and site clearance will be crushed, screened and graded as appropriate for reuse on site in road and drainage construction, backfill and as marker layers or inert cover materials (see remediation below). Stockpiling of material will be considered to optimise re-use. Where surplus to requirements, recycled materials will be transported off site for use in engineering applications elsewhere. An assessment of the type and quantity of the constituent materials for the application site wide demolitions has been presented in the ES Waste Chapter (Chapter 14); and Vegetative arisings will be chipped for re-use on site in landscaping applications or composted off-site. Remediation: Remediation will comprise the removal of localised contamination hot spots and backfilling with suitable material, using track mounted excavators, dumpers and earthwork compactors, before placement of a formal cover system. Generally the built development, comprising the buildings and paved areas will perform this function. However in gardens, landscaped areas and 39

44 public open space an appropriate thickness of inert cover material (sub-soil and topsoil) known as a capping layer and a marker layer will be required; Construction of cover system will invariably take place concurrently with the new land uses and will involve the use of earth moving equipment (i.e. track mounted excavators, dump trucks, dozers and earthwork compactors) to spread and compact the marker and capping layers; Arisings from hot spot removal will either be removed from site for processing and reuse elsewhere or disposed of to a suitably licensed facility. Subject to the type and quantity of contaminated material to be removed it may be appropriate to remediate the contaminated material and re-use on-site; Prior to placement of the formal cover system above, it will be necessary to carry out earthwork cut and fill to suit the proposed development profiles. This will involve the use of earth moving equipment (i.e. track mounted excavators, dump trucks, dozers and earthwork compactors). Where surplus materials arise these will be transported off site for use in engineering applications elsewhere, subject to their suitability or disposed of to a suitably licensed facility. An assessment of the type and quantity of the constituent materials has been presented in the ES Waste Chapter (Chapter 14); Phase 1a and part of Phase 1b has already undergone demolition and site clearance and partial remediation (i.e. removal of hot spots and partial placement of marker/capping layers). This marker/capping comprises crushed demolition materials derived from an earlier demolition and site clearance programme. However, subject to the detailed site layout design it may be necessary to excavate, stockpile and re-deposit this material. Where surplus materials arise these will be transported off site for use in engineering applications elsewhere (with or without reprocessing). An assessment of the type and quantity of the constituent materials has been presented in the Chapter 14; and A number of currently active and disused groundwater abstraction wells and groundwater monitoring boreholes exist which will require to be decommissioned. These will be backfilled, sealed and capped with concrete. It should be noted that various buildings will be retained on site as shown in Figure 3.3. These include the Air Ministry Building (the bunker), Kodak Power House and chimney and the Reception Building Construction of new land uses Following these preparatory works construction of the intended land uses will progress aligned to the phases and timescales set out in Section This section describes the likely processes and methods/techniques associated with construction of these new land uses. Construction of buildings/structures (concrete and steel framed) and associated foundations (i.e. pile foundations to multi story car park). This will involve the use of vertical and horizontal transportation equipment (i.e. cranes, conveyors, 40

45 dump trucks, lorry mounted pumps, fork lifts, hoists and site dumpers, loaders and lorries), piling rigs (driven or augered), track mounted machines equipped with excavator buckets and hydraulic breakers (i.e. removal of buried obstructions), concrete batching plant, vibrators, compressors, scaffolding and falsework; Construction of associated new infrastructure including roads, hardstandings, public realm, play areas, landscaping, on-site utility services and drainage. This will involve a variety of construction plant, similar to the above and including, graders, vibrating drum compactors, water bowsers, pavers and pneumatic tired rollers; Construction of new site accesses and other highway improvements, services diversions, provision utilities and drainage infrastructure (Phases 1a and 1b/2); and Construction of SUDS facilities, attenuation ponds/basins and habitat creation measures (Phase 1b). The MSCP will go over the bunker, but it is not anticipated that it will be directly impacted by the proposed development. The environmental impacts of construction activities will be managed through a Construction Environmental Management Plan (CEMP) Construction traffic and accesses Construction traffic (HGVs) has been estimated for each phase of the works. This is shown as totals per year and per week in the following table (for one way movement only, figures require doubling for two way traffic): Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Total Enabling Works 5,313 5,313 Phase 1a 2,358 2,358 5,583 Phase 1b 2,358 2,358 4,715 Phase 1c 1,587 1,587 3,174 Phase 2 1,328 1,328 2,701 2,701 8,058 Phase 3 1,328 1,328 2,837 2,837 2,837 11,168 Total per year 5,313 6,477 6,477 5,616 5,616 2,837 2,837 2,837 38,011 41

46 Table 3.2: Construction Traffic (HGVs) Access for works vehicles during construction is planned to be as follows: Phase 1a Existing access off Headstone Drive (main access); Phase 1b Existing Zoom Leisure access off Harrow View new roundabout will have been installed; Phase 1c - Existing access off Headstone Drive (main access); Phase 2 Access via new roundabout off Harrow View; and Phase 3 - Access via new roundabout off Harrow View or existing access off Headstone Drive Operation The proposed mixed use proposed development will become operational in stages as the construction of each of the five phases is completed. Based on the proposed land uses, the principal operational activities will include: Residents living in and travelling to/from their homes (houses, apartments, care home) and using their gardens/communal open space; People working in and travelling to/from the employment units (offices, SME units, storage units, industrial units), retail units (food store, restaurant and non-food retail), the school, and the health, community and leisure facilities (leisure centre, community centre, health centre and care home); People (including residents of the proposed development and the wider community) using and travelling to/from the retail units, and health, community and leisure facilities; Pupils using and travelling to/from the school; Operation, management and maintenance of the buildings, structures and supporting facilities (e.g. car parking) and infrastructure (e.g. road network, drainage system) within the proposed development ; Management and maintenance of the open space zones within the proposed development, including areas of hard and soft landscaping and newly created habitat; and The impacts of these operational activities are assessed, as appropriate, within the technical assessments included in Chapters 5 to

47 4 EIA approach and methodology 4.1 Introduction This EIA has been undertaken in accordance with the EIA Regulations and has involved a number of key stages. Identification of environmental constraints and opportunities within and surrounding the application site to inform the master planning process. This sought to avoid/minimise potentially adverse effects and incorporate opportunities for environmental enhancement within the proposed development proposals. This process was ongoing throughout the EIA and master planning processes; Scoping of the EIA. An initial scoping study of possible environmental effects across a range of potential environmental topics was undertaken, which resulted in the preparation of a formal Scoping Report (Halcrow, 2011a). This was then submitted to the Council in May 2011 in support of a request for a formal Scoping Opinion under the previous EIA Regulations (Schedule 2 10(b) of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999, as amended) which were in force at the time, and additional consultation was undertaken with The Council and other relevant statutory consultees. A formal Scoping Opinion was received from The Council in July 2011 (Appendix 4.1); and Detailed environmental assessment of the proposed development to identify the potentially significant effects and any required mitigation strategies. The findings of this final stage of the EIA are documented within this ES. This chapter describes the overall approach taken for the EIA process, details the findings of the initial scoping process, and describes the overall assessment methodology/framework used for the detailed topic-specific impact assessments. 4.2 Scoping the EIA The scoping process The EIA Scoping Report (Halcrow, 2011a) documents the findings of the initial scoping process. This considered the potential for significant environmental effects resulting from the construction and operation of the proposed development across the following range of environmental topics: Transport; Air quality; Noise and vibration; Ground conditions; Surface water; 43

48 Ecology; Landscape and visual amenity; Socio-economic; Cultural heritage and archaeology; and Waste. Under each topic, potentially sensitive receptors were identified based on an understanding of existing environmental conditions obtained through thorough desk study and field surveys. The likely potential impacts of the proposed development on these receptors were then considered and potential effects were identified. Where it was considered that these effects, whether positive (beneficial) or negative (adverse), could be significant these were taken forward for further consideration within the detailed assessments presented within this ES. A precautionary approach was taken for this scoping assessment to take into account the outline nature of the proposed development proposals and the status of the master planning process at the time of the assessment. Therefore, to accommodate this uncertainty it was assumed that potential environmental issues are scoped in for further consideration during the detailed EIA unless it could be confirmed through appropriate site survey or assessment that specific receptors will not be affected and therefore can be scoped out Conclusions of the scoping process The scoping assessment identified that there were potentially significant issues that required further consideration as part of the detailed EIA for all of the environmental topics considered. These are set out below. However within each topic, specific issues were scoped out as identified below as they were considered unlikely to give rise to significant environmental effects. These were therefore not considered during the detailed EIA process. Based on this scoping assessment, the proposed scope of the EIA was follows: Transport assessment of predicted changes in all modes of transport (including modelling of vehicular traffic) and impacts on the local transport network as a result of the construction and operation of the proposed development. The EIA would summarise the findings of the separate Transport Assessment; Air quality modelling of predicted changes in air quality within the Air Quality Management Area (AQMA) and the effects on identified sensitive receptors as a result of increases in vehicular traffic during the construction (including enabling and demolition works) and operation of the proposed development ; and an assessment of the effects of the existing Kodak operations on new users of the proposed development ; Noise and vibration assessment of predicted changes in noise and vibration levels as a result of increases in vehicular traffic during the construction 44

49 (including enabling and demolition works) and operation of the proposed development and the effects on identified sensitive receptors; and an assessment of the suitability of the application site for residential use; Ground conditions based on existing site assessments and investigations, assessment of the risks relating to the construction and operation of the proposed development to sensitive receptors such as Controlled Waters (surface and ground water), human health and the environment; Surface water consideration of temporary impacts on surface water quality as a result of construction-related activities; assessment of the impacts of the proposed development on surface water drainage and flood risk within and surrounding the application site; and development of a surface water drainage strategy, incorporating SUDS elements. The EIA would summarise the findings of the separate Flood Risk Assessment; Ecology consideration of potential opportunities linked to the habitat creation proposals to be incorporated within the illustrative masterplan. Based on the results of the comprehensive site surveys undertaken, specific consideration of issues relating to any legally protected species was not required (i.e. these issues were scoped out); Landscape, townscape and visual amenity assessment of predicted changes in townscape character and visual amenity (including the views experienced into the application site by the surrounding receptors) as a result of the construction and operation of the proposed development; Socio-economic assessment of impacts arising from the provision of new housing and other uses on-site, and the replacement and/or potential loss of existing on-site uses. Consideration of impacts on employment, the local economy and labour market, the availability of services and community provisions for the existing and new populations resulting from the construction and operation of the proposed development; Archaeology and cultural heritage to supplement the archaeological/cultural heritage desk-based assessment (DBA) completed for the Harrow View West site, a consolidated DBA was prepared to include the Harrow View East site and to identify known features of cultural heritage value and assess the potential for the presence of buried features of value within and surrounding the application site. Based on the DBA, the EIA would consider potential impacts on the setting and presence of known and, as yet, unknown features within and surrounding the application site; and Waste consideration of the type and quantity of waste generated during the construction (including demolition and enabling works) and operation of the proposed development; the resulting management requirements and the capacity of the available infrastructure to receive this waste. A high-level Site Waste Management Plan would be prepared in support of the outline planning application. 45

50 Based on this scoping assessment, the proposed scope of the EIA did not include consideration of the following, as they were considered unlikely to give rise to significant environmental effects, and were therefore scoped out: Transport no adverse significant environmental effects are likely on pedestrians and cyclists and the proposed development presents an opportunity for the provision of more sustainable modes of transport (although due consideration will be made within the Transport Assessment); Surface water no impacts on groundwater resources and quality are anticipated as a result of interactions with surface water; although consideration of effects on groundwater relating to ground contamination will be considered; and Ecology based on the results of the comprehensive site surveys undertaken, specific consideration of issues relating to any legally protected species is not required The scoping opinion Following the internal scoping process, a formal request for a scoping opinion under the EIA Regulations was made in May 2011 to the Council to obtain their views and those of statutory consultees on the proposed scope of the EIA. The EIA Scoping Report (Halcrow 2011a) was provided in support of this request. The scoping opinion provided comments on the proposed scope of the assessment for all topics considered, except for waste. The Council received comments on the scope of the EIA from the following organisations, which were incorporated, as appropriate, within the scoping opinion: Environment Agency; Greater London Archaeology Advisory Service (GLAAS); the Council: Environmental Health; Conservation; Highways and Biodiversity Officers; Harrow Borough Police; Natural England; and Transport for London (TfL). The response received from the Council is provided in Appendix 4.1 and the responses received from other organisations (as listed above) in Appendix 4.3. Following receipt of the scoping opinion, further consultation was undertaken with the Council officers and the statutory bodies from whom comments were received as part of the scoping opinion to discuss specific aspects of their responses and agree an acceptable way forward for the EIA. The agreed way forward from these discussions is documented in Table 1 in Appendix 4.2. Further details of all consultation activities undertaken with statutory and nonstatutory bodies are provided in each of the technical sections. 46

51 4.3 Approach to the EIA Overview The EIA has been based on the development parameters described in Section 3.2 and illustrated on the parameter plans submitted as part of the outline planning application included as Figures 3.3 to 3.7. A consistent approach to the impact assessment has been applied to ensure that the significance of effects prior to and following mitigation is clearly identified. Within this framework the proposed assessment methodologies and associated criteria applied are specific to each environmental topic in accordance with industrystandard procedures and best practice guidance as described in Chapters 5 to 14. The assessment of significance is considered in the context of legislation, policy and development control requirements. A summary of relevant legislation and policy is given in Appendix Impact assessment The proposed staged approach applied to all topic-specific assessments includes the following steps: Identification of the value and/or sensitivity of identified receptors/resources, based on accepted criteria from relevant guidance, awarding values from the following categories: high, medium, low or negligible; Identification and characterisation of potential impacts (i.e. defining their magnitude, extent, nature (e.g. direct/indirect, primary/secondary), duration, reversibility, timing/frequency, and level of confidence in the predictions) to define the identified impacts, whether positive or negative, using the following categories: high, medium, low or neutral/negligible; Assessment of the significance of environmental effects taking into account: (1) the identified value/sensitivity of a receptor/resource; and (2) the magnitude of identified and characterised impacts, and whether adverse or beneficial using a matrix and the assigning the following categories: major, moderate, minor, negligible (see Table 4.1); Identification of measures to avoid, mitigate or compensate for identified adverse effects that would reduce the identified significance of effect; and Assessment of the significance of residual effects, using the criteria/categories identified in the previous steps, taking into account the assumed effectiveness of the proposed mitigation measures. 47

52 Table 4.1: Impact significance based on the sensitivity or value of receptors and the magnitude of impact Magnitude Sensitivity/Value High Medium Low High Major Moderate/Major Moderate Medium Moderate/Major Moderate Minor/Moderate Low Minor/Moderate Minor Negligible/Minor Neutral/Negligible Negligible/Minor Negligible/Minor Negligible Assessment of cumulative/in-combination effects Consideration has also been given to the potential for cumulative effects, both in terms of different types of impact on a specific receptor resulting from the proposed development, and impacts affecting receptors resulting from the implementation of both the proposed development and other nearby development proposals. The assessment also considered any interactions between the residual environmental effects identified under each specific environmental topic. This cumulative effects assessment identified if any additional, potentially synergistic, effects could arise or if the significance of identified residual effects could change when the interactions between environmental topics are considered. The proposed approach undertaken included the following steps: A request to the Council in August 2011 for details of any relevant development proposals that are not included within the defined baseline conditions (i.e. committed developments that have already received planning consent but have yet to be implemented) in the vicinity of the application site, the potential effects of which may interact with those of the proposed development; Review of the information received from the Council to identify any potential interactions between these development proposals and the proposed development, and the identification of potentially sensitive receptors; and Identification of whether the predicted residual effects of the proposed development on the identified sensitive receptors change when considered in combination with the additional proposals (for example, impacts on the AQMA as a result of the predicted combined changes in vehicular traffic). 4.4 Further consultation on EIA process The consultation process for the scoping stage has been described in Section above. Further consultation has also been carried out on specialist elements of the ES with the following organisations/officers: 48

53 the Council - Biodiversity Officer, Environmental Health Officer and Highways Officer; Greater London Archaeological Advisory Service (GLAAS) Archaeological Advisor; and Environment Agency Planning Liaison Officer. This is reported in more detail within each of the technical chapters as appropriate (Chapters 5-14). At the request of the Council, further consideration has been made of the Area Action Plan (AAP) for Harrow and Wealdstone. This is discussed further in Chapter

54 5 Transport 5.1 Introduction This chapter addresses the likely significant environmental effects of the proposed development with respect to transport issues. It assesses and quantifies the potential environmental effects of the person trips and traffic that may be generated by the development, and considers the effects on the wider transportation network for all modes walking, cycling, public transport and on the highway. The access arrangements for the development for all modes are also considered. A Transport Assessment (TA) report has been submitted in support of the planning application for the application site. The scope and assessment methodology adopted within the TA, and used for this assessment, was subject to a consultation process with the Council, as highway authority, and Transport for London prior to the submission of the planning application and has been agreed with these authorities. It is intended that this chapter provides the reader sufficient information to understand any potentially significant traffic and transport effects of the proposed development, but should further information/detail be required then reference can be made to the TA. 5.2 Methodology Scope of assessment The analysis within this chapter has been prepared in accordance with Guidelines for the Environmental Assessment of Road Traffic (Institute of Environmental Assessment, 1993). The guidance suggests the following topics should be considered: Noise; Vibration; Visual Effects; Severance; Driver Delay; Pedestrian Delay; Pedestrian Amenity; Fear and Intimidation; Accidents and Safety; Hazardous Loads; Air Pollution; Dust and Dirt; 50

55 Ecological Effects; and Heritage and Conservation Effects. Many of these topic areas are considered within separate chapters in the EIA. These include the chapters on Noise and Vibration, visual effects are considered within Landscape and Visual Amenity, hazardous loads within the chapter on Waste, dust and particulate deposits in the Air Quality chapter, ecological effects within Biodiversity and heritage and conservation issues within Archaeology and Cultural Heritage. The topics considered in this chapter are based on information derived in the Transport Assessment on the number of additional trips on the network as a result of the proposed development. The consideration relates to two future year scenarios that are representative of a worst case mid-state development and the end-state development Assessment methodology for transport assessment The indicative delivery of the development is shown to be phased in five sections as illustrated on Figure 3.8. From a transport perspective, no connection through Harrow View East is provided until the final phase (phase 3). Hence, the distribution of trips up to the completion of phase 2 has a different pattern to the end state. The completion of phase 2 has therefore been selected as the worst case interim position. An opening year of 2017 for the first four phases of development and an opening year of 2021 for the complete development has been assessed, as agreed with Highway Officers during the scoping of the Transport Assessment. No allowance has been made for construction traffic in 2017 as this would be less than the existing operational traffic flows which have been included. Phases 1a, 1b, 1c and 2 have two separate vehicular access points into Harrow View East site, and phase 3 allows for a link between the two vehicular access points through the application site. For clarity, phases 1a and 1c gain access from the south, via Headstone Drive, whilst phase 2 gains access from the west via Harrow View. Phase 1b lies on the western side of Harrow View and gains access from it. The assessed traffic flows are based on the planning application parameters which have been capped for the various land uses. Therefore, the traffic flows assume an accumulation of development quantum through phases 1-2. The remainder of the development quantum up to the maximum cap for each particular land use is released in phase 3. Traffic counts were undertaken on a typical weekday (Tuesday 24th May 2011) to gain an understanding of the existing local traffic patterns for the peak hours (see Appendix 5.1 for survey information). The junctions covered by the survey data were identified as part of the scoping process for the Transport Assessment. Survey data was collected for two peak periods on the highway network between hours and hour periods. In addition, a survey was also 51

56 undertaken on a Saturday 9th July 2011 for Headstone Drive/Harrow View between the hours of The surveyed traffic movements were fully classified as cars, Light Goods Vehicles (LGVs), Heavy Goods Vehicles (HGVs) split between Other Goods Vehicles 1 (OGV1) (2 and 3 axles rigid vehicles and transit vans over 3.5 tonnes) and OGV2 (4 or more axles rigid vehicles, 3 or more axles articulated and other goods vehicles with trailers), Buses, Motorcycles and Pedal Cycles. Queue lengths were also noted every 5 minutes on all surveyed junction approach arms. In addition, it was recognised that it was important to verify that the typical weekday chosen did represent typical flows on the network during the peak periods. Therefore automatic traffic counters (ATCs) were placed on Harrow View and Headstone Drive within the vicinity of the application site which collected a weeks worth of traffic data, and confirmed that the detailed counts were representative Background traffic It has been agreed with Highway Officers that factoring of the observed turning movements would be appropriate to provide an assessment of the effects of traffic growth, and hence derive future year background traffic turning movements for assessment purposes. The two future year scenarios were therefore defined as follows: Opening year of phases 1a-c and 2 (2017) this considers all occupied development when there is no through route within the Harrow View East site. Opening year of phases 1a-c, 2-3 (2021) this considers all occupied development when there is a through route within the Harrow View East site. The observed background flows have been increased using growth factors extracted from Tempro software. This software contains data provided by the Department for Transport (DfT) for traffic forecasting purposes. The software takes account of future development planned for Harrow in terms of the number of new jobs created and houses to be provided. Since the traffic generation associated with the development has been included explicitly in the assessment, the inputs to the Tempro software were adjusted to avoid double-counting of future growth. Pre-existing Trips For the purpose of assessment, it is correct to take account of the trips that could be generated in any case from the existing uses on the application site. The actual effects of the planned development will be defined by the difference between the existing uses and the planned development trips. This methodology has been agreed with the Council and TfL as part of the scoping exercise for the Transport Assessment. Therefore trip generation rates for the previous lawful land uses on the application site have been extracted from the Trip Rate Assessment Valid for London (TRAVL) database for the weekday peak hours of and The database holds survey results for development sites in London relating to specific land uses. 52

57 The information extracted was filtered for location, Public Transport Accessibility Level (PTAL) rating and year so as to provide a suitable trip rate for a similar site. The trip rate has been applied to the pre-existing land use quantum to provide trip generation for all modes e.g.vehicles, public transport users etc. During the last 5 years, the Kodak site has been in a state of transition as the redevelopment potential has been discussed, the existing operations moved around on the application site and the general operation has wound down. Therefore, it was deemed appropriate to set the baseline assumptions for the purposes of assessment on the operations in 2005, as the highway network accommodated this level of development. A substantial proportion of Harrow View lies within the Wealdstone preferred industrial location, which is identified in the London Plan as a strategic industrial location (SIL). London Plan Policy 2.17 affords SILs strategic protection as London s main reservoirs of industrial and related capacity. Within the Harrow UDP, Harrow View East falls within an Industrial and Business Use Area. Should proposals come forward for an industrial use on all or part of Harrow View, there is unlikely to be an objection in principle to the proposed use given its strategic designation. During 2005 the total floor areas at the application site were 173,729sqm2 as confirmed by Kodak. The split of land uses was 26,013m2 office space and 147,716m2 industrial buildings. The vehicle trip rates for land uses office and light industrial were extracted as follows: Table 5.1: TRAVL trip rates - vehicles AM Peak PM Peak Saturday (11-12) Arrivals Departures Arrivals Departures Arrivals Departures Applying the agreed vehicle trip rates to the quantum of pre-existing gross floor area (GFA) provides the following vehicle trip generation to/from the Kodak site: Table 5.2: TRAVL trip generation - vehicles Land Use AM Peak PM Peak Saturday (11-12) Arrival s Departure s Arrival s Departure s Arrival s Departure s Office Light Industr ial The vehicle trip generation has been distributed between the Harrow View West and Harrow View East sites in accordance with the ratio of parking spaces on the two 53

58 sites. The Harrow West site had 811 parking spaces and the Harrow View East site had 461 parking spaces in This equates to 64% of trips arriving/departing from the Harrow West site and 36% of trips arriving/departing from the Harrow View East site. The trips have then been distributed onto the external highway network in accordance with observed survey data Committed development Committed development traffic flows relate to sites that have planning permission but have not yet been built. There was only one site identified by the Council s Highway Officer and so these flows have been extracted from the Transport Assessment relating to Pinner House (planning refs. P/0596/08/3904 Appeal, P/0596/08/CFU Final and P/0035/10 Final) Baseline traffic The baseline traffic flows are estimated through the addition of the background traffic flows to the committed traffic flows as well as the pre-existing flows associated with the Kodak site. These flows were used as the baseline to which the impact of the development is compared. The flows associated with this scenario are known as do minimum Development trip rates For the purpose of assessment trip generation rates for the various land uses included in the development proposals have been extracted from the Trip Rate Assessment Valid for London (TRAVL) database for weekday peak hours of , and Saturday The trip rate has then been applied to the development quantum to provide the trip generation for the modes of travel available to and from the application site. This included private vehicles, walking, cycling and public transport including buses, railways and the Underground. It was agreed with TfL and the Council that sites within the database were selected for outer London with a PTAL score of 2-4, for surveys undertaken from the Year However, some land uses did not have sufficient data and so the filter of data was altered these are identified in the trip rate table below. Trip rates have been extracted for the various land uses on the application site except for the community centre. It has been agreed through the scoping exercise for the TA that the community centre will not attract external trips. The remaining proposed land uses have been considered against the most appropriate TRAVL classifications and are shown in the following table. The quantum assessed is based on the development description included in the planning application and has been converted to GFA for use in calculating the trip generation. The quantum is illustrated below: 54

59 Table 5.3: Land use quantum and TRAVL description Land use Quantum Units TRAVL land use Leisure Centre 1155 Sqm GFA Health Centre 2253 Sqm GFA Care home 7905 Sqm GFA D2 Health Clubs and Sports Centre s D1 Health Service C2 Residential Care Food store/non food retail/restaurant/cafe 4800 Sqm GFA A1 Supermarket Student Accommodation 220 Units C3 Residential Residential Harrow View East Residential Harrow West 671 Units C3 Residential 314 Units C3 Residential Primary School 630 Pupils D1 Non residential school Office/light industrial/storage Sqm GFA B1 Office The TRAVL vehicle trip rates have been extracted for the weekday peak period and Saturday and are shown below: Table 5.4: TRAVL vehicle trip rates TRAVL land use (per 100sqm unless otherwise stated) AM ( hrs) PM ( hrs) Saturday (11-12hrs) Arrivals Departures Arrivals Departures Arrivals Departures Leisure Centre Health Centre Care home Food store Residential (per unit)

60 TRAVL land use (per 100sqm unless otherwise stated) Primary School AM ( hrs) PM ( hrs) Saturday (11-12hrs) Office * *Note: The trip rate for the PM arrivals of the office/light industrial/storage land uses relates to the worst case trip rate for light industrial. This provides a robust assessment of the employment land uses Development trip generation The trip rates gathered from TRAVL have been combined with the proposed on site development quantum to give an associated trip generation for the proposed development. Vehicle trip generation is shown as follows: Table 5.5: Vehicle trip generation Vehicle Trip Generation AM ( hrs) PM ( hrs) Saturday (11-12hrs) Arrivals Departures Arrivals Departures Arrivals Departures Leisure Centre Student Accommodation Health Centre Care home Food store Residential Harrow View East Residential Harrow View West Primary School Office Development trips delivery and servicing Trip rates relating to HGVs have been extracted for B1 light industrial to represent the large proportion associated with this particular land use. It is assumed that the number of large service vehicles associated with the retail and restaurant elements of 56

61 the proposed development will be insignificant during the peak hour period. Therefore, it was not appropriate to make any allowance for these vehicles in the junction modelling. The HGV trip rates for the B1 light industrial land use have been applied to the quantum of proposed development, and both the trip rate and associated traffic generation for the peak hours is shown in the following table: Table 5.6: HGV TRAVL trip rates and trip generation B1 Light Industrial AM ( hrs) PM ( hrs) Saturday (11-12hrs) Arrivals Departures Arrivals Departures Arrivals Departures Trip rate Trip generation Mode shift adjustment The scale of the development and comprehensive mix of uses means that a number of trips will be completed wholly within the application site, or constitute existing trips that are already on the network and that will divert as a consequence of the development. It is correct to make an adjustment for these and this has been agreed with TfL and the Council s Highway Officer. The following lists the nature of the adjustments and the percentage to be applied to the vehicular traffic generation: Mixed Use - a reduction to car trips of 20% to all land uses to take account of the mixed nature of the application site. Retail Pass-by and Diverted Trips - 37% pass-by trips is applied to the traffic generation related to the food store during the evening peak hour and 11% during Saturday between In addition, a more modest pass by of 10% has been assumed relating to the other retail units and restaurant. The Primary School will attract local trips from the development itself as well as the surrounding residential areas. On this basis it is anticipated that there would be very few vehicular trips and of those a large proportion is expected to be linked trips to work. Since the school requirements are uncertain at this time and the catchment is unknown, a worst case scenario of a 45% reduction factor has been applied to the trip rates for the school to take account of the linked trips. Applying the reduction factors above to the traffic generation suggests the following trips for each land use: 57

62 Table 5.7: Vehicle trip generation with adjustments TRAVL land use AM ( hrs) PM ( hrs) Saturday (11-12hrs) Arrivals Departures Arrivals Departures Arrivals Departures Leisure Centre Student Accommodation Health Centre Care home Food store Residential Harrow View East Residential Harrow View West Primary School Office Traffic Distribution The proposed traffic generated by the development proposals has been distributed onto the local highway network based upon the observed traffic movements recorded during on site surveys conducted on 24th May For phases 1a-c, and 2, there are two discrete points of access for the Harrow View East site and one point of access for the Harrow View West site. In the final phase (phase 3), the two points of access to the Harrow View East site would be joined by a through route which would be intended for local traffic and designed accordingly. The proposed phasing for the development is shown in Figure 3.8 and illustrates the following: phase 1a would access from Headstone Drive for the Harrow View East site; phase 1b would access Harrow View for the Harrow West site; phase 1c would access from Headstone Drive for the Harrow View East site; phase 2 would access from Harrow View for the Harrow View East site; and phase 3 would access both Harrow View and Headstone Drive; 58

63 Since phase 3 enables a through route it is likely that there will some alterations to existing traffic movements along Harrow View/Headstone Drive as well as changes to access for the land uses in phase 1-2 as this traffic uses the side roads. It should be noted that the connecting route has been designed so as not to encourage through traffic. However, it is acknowledged that, depending on the congestion at the Harrow View/Headstone Drive, there may be some vehicles that seek to route through in the peak hours. Therefore, the following assumptions have been applied to phase 3 which have been agreed with Highway Officers: 100% of development traffic heading northbound along Harrow View from Phases 1a and 1c would use the through route and then the enabling roundabout junction onto Harrow View (as would the return journey back); 20% of development traffic from Phase 1b that would be heading south along Harrow View would use the through route in the application site and then turn left at the Harrow View / Headstone Drive junction to continue south (S), the remaining 80% would use the enabling roundabout on Harrow View and head south straight through the Harrow View/Headstone Drive junction. Since there is a no right turn from Harrow View (S) then this assumption has not been applied to the return journey; 100% of development traffic from Phase 1b that would be heading east along Headstone Drive would use the through route in the application site (as would the return journey back); 100% of development traffic from Phase 1b that would be heading east along Headstone Drive would use the through route (as would the return journey back); 5% of development traffic from Phase 1b that would be heading south along Harrow View would use the through route, and the remaining 95% would head south along Harrow View. Since there is no right turn from Harrow View (S) then this assumption has not been applied to the return journey; and 20% of the background traffic that is travelling southbound along Harrow View and turning left to go eastbound along Headstone Drive is assumed to reroute through the application site and the reverse for the return journeys With development traffic flows The with development traffic flows are calculated based upon the addition of the baseline traffic flows, and the proposed development traffic flows. The pre-existing flows associated with the Kodak site are removed as this scenario assumes the application site is redeveloped. However, to remain robust the existing flows associated with Kodak at present have been included in the phase 1a-2 scenario. The flows associated with this scenario are known as do something. Junction capacity analysis was undertaken for the local highway network during the peak hours using DfT standard computer modelling software. This comprises an assessment of the traffic flows for the present day, how these may change over time with consented development flows included (known as do nothing scenario) and 59

64 the effect of adding the proposed development traffic to this (known as do something scenario). For the purposes of the EIA the links between the junctions have been considered as follows: Link A Courtenay Avenue between A410 and Long Elmes Link B Long Elmes (east (E)) between A409 High Road and Harrow View Link C Harrow View between Long Elmes and enabling roundabout Link D Long Elmes (west (W)) between Headstone Lane and Harrow View Link E Harrow View between enabling roundabout and Headstone Drive Link F Headstone Drive between existing/proposed vehicular site access and Harrow View Link G Harrow View between Headstone Drive and A4005 Greenhill Way Link H Headstone Gardens between Pinner View and Harrow View Link I/M Headstone Drive (W) between Princes Drive and existing/proposed vehicular site access Link J Hailsham Drive from Headstone Drive Link K Headstone Drive (W) between Ellen Webb Drive and Princes Drive Link L Princes Drive between Headstone Drive and Kings Way Link N Cecil Road between Headstone Drive and Tudor Road Link O Headstone Drive (E) from Ellen Webb Drive Link P Ellen Webb Drive between Cecil Road and High Street Link Q High Street between Ellen Webb Drive and Palmerstone Road Link R Mason Avenue between The Bridge and Byron Road Link S The Bridge between Ellen Webb Drive and A409 Link U Station Road between A404 Pinner Road and Pinner View Link V/AB A404 Pinner Road between Station Road and Headstone Road Link W Imperial Drive between A404 Pinner Road and Alexandra Avenue Link X A404 Pinner Road between Station Road and George V Avenue Link Y Headstone Road (north (N)) between A404 Pinner Road and Harrow View Link Z Greenhill Way between Headstone Road and A409 Station Road 60

65 Link AA Headstone Road (south (S)) between A404 Pinner Road and College Road Particular attention has been given to the operation of the Harrow View/Headstone Drive junction which has been identified by The Council as a current constraint on the highway network and of local concern Assessment methodology for EIA elements of the transport assessment The assessment methodology for the EIA elements of the transport assessment are described under the assessment of impacts during operation (Section 5.6) below Significance criteria The significance criteria of the net development environmental impact for each topic considered is based on the magnitude (or scale) of the change as well as the sensitivity (or importance) of the receptor affected. In terms of the magnitude of change, Guidelines for the Environmental Assessment of Road Traffic suggest that there is a mixture of subjective assessment (where no thresholds are available for comparison) and quantitative assessment where absolute figures are provided based on research. Further information will be provided as each topic is considered in the assessment of impacts sections later in this chapter. Categories of receptor sensitivity have been defined from the principles set out in the Guidelines for the Environmental Assessment of Road Traffic, including the following: The need to identify particularly groups or locations which may be sensitive to changes in traffic conditions; The list of affected groups and special interests set out in the guidance; The identification of links or locations where it is felt that specific environmental problems may occur; and Such locations would include accident blackspots, conservation areas, hospitals, links with high pedestrian flows etc. These have been used to outline in broad terms the sensitivity of receptors to traffic for the categories identified in this chapter, although in detail, each receptor assessed may have a different sensitivity to each specific effect. Although not specifically identified within the guidelines as being sensitive for these categories it has been assumed that individual residential and employment areas have low sensitivity. This is on the basis that the land uses listed in the guidance are for specific institutions/areas which are likely to have high levels of pedestrian activity along with a large element of vulnerable users. High sensitivity receptors include: Schools, colleges and other educational institutions; 61

66 Retirement/care homes for the elderly or infirm; Roads with no footway that may be used by pedestrians; and Accident blackspots. Medium sensitivity receptors include: Hospitals, surgeries and clinics; Parks and recreation areas; Shopping areas; and Roads with narrow footway that may be used by pedestrians. Low sensitivity receptors include: Open spaces; Tourist/visitor attractions; Historical buildings; and Churches and other places of worship. The magnitude of effects and receptor sensitivity has then been compared to estimate the significance of the effect, as set out in the table below. As there are no published standard criteria, the table below includes a range of criteria to allow the specific characteristics of each effect to be considered on an individual basis, within the structure of the receptor/magnitude approach. Table 5.8: Significance Criteria Magnitude Sensitivity of Receptor High Medium Low High Major Major/ Moderate Moderate/ Minor Medium Major/Moderate Moderate Minor Low Moderate Moderate/Minor Minor/Insignificant Neutral/Negligible negligible negligible negligible 5.3 Legislation and policy Relevant legislation and policy to transport is described in Appendix

67 5.4 Baseline conditions This section describes the existing transport network surrounding the application site for all modes, including current highway conditions Walking and cycling At present, employees of Kodak can access Harrow View East from Harrow View via a secure pedestrian access point. Pedestrians and cyclists can access Harrow View West via the all modes entry/exit point on Harrow View. In the recent past, when the application site operated at its full capacity there were two other dedicated pedestrian access points located on Headstone Drive for Harrow View East. Footways are available alongside the local highway network to make the journeys to the town centre and local underground station, as is typical for an urban area within London. Pedestrian crossing facilities have also been incorporated in the traffic signal controlled junction at Harrow View with Headstone Drive. However, these facilities are informal and require pedestrians to judge when to cross through the gaps in the traffic. The local town centre of Wealdstone is approximately 0.6 km away, which is within a short walk of the application site (approximately minutes). A review of pedestrian facilities was carried out using the TfL tool; Pedestrian Environment Review System (PERS). This allocates a score for various considerations along a route or over a crossing point, in an aim to record the conditions for pedestrians near the application site. The scores are then grouped into red, amber or green, with red meaning that there are issues that need to be addressed through to green which has negligible issues. Overall, the PERS audit found that conditions and facilities for pedestrians in the vicinity of the application site are average to good; and whilst elements of some of the routes, links and crossings were awarded amber and red scores within the assessment (for such things as deviation from the desire line, limited number of rest points and effective widths), all achieved an overall score of green. A number of small scale improvements would improve the environment for pedestrians such as improving the provision of dropped kerbs and tactile paving along Sandridge Close and trimming overhanging vegetation along Harrow View and Headstone Drive. The application site lies adjacent to the local cycle network which runs along Harrow View and Headstone Drive to the south of Harrow View East. These cycle routes can be accessed using any of the application site access points and connect the town centre to the south via the London Cycle Network Plus (LCN+). The cycle network is shown on Figure Bus services There are a number of bus stops in close proximity to the application site located on both Headstone Drive and Harrow View. 63

68 The bus stops on Harrow View are located close to the existing Zoom Leisure site access and at the junction of Harrow View/Headstone Drive. These bus stops are shown on Figure 5.2. The Zoom Leisure stop for the northbound bus service is located in a lay-by with no shelter and for the southbound service is located on the roadside with a shelter. The stops at the Harrow View/Headstone Drive junction incorporate shelters on the roadside for passengers waiting for the northbound and southbound service along Harrow View. The bus stops on Headstone Drive are located close to the existing eastern access of the Kodak Factory site and the junction of Headstone Drive/Harrow View. Both of these stops also have roadside shelters. A summary of bus services available from Harrow View and adjacent Headstone Drive bus stops is as follows: Table 5.9: Bus Services Bus Information Bus Service H9 circular service around Harrow start/finish at Harrow bus station H10 clockwise circular route around Harrow starting/finishing at Harrow bus station Operation Monday-Friday Every 30 minutes from (hours); 4 services between ; 8-12 minutes during the day; every 30 minutes in the evening until Saturday Two services between ; 3 services between ; every 9-12 minutes during the day; every 20 minutes between ; every 30 minutes until Sunday 3 services per hour during the day; 2 services per hour from Monday Friday 3 services operate between ; every 8-10 minutes during ; 3 services between ; every 30 minutes until 0104 Saturday 2 services between 0600 and 0800; 4 services per hour between ; every 9-12 minutes during the day until 1900; 2 services per hour operate from 2000 until Sunday 2 services per hour until 0900 from 0634; 3 services per hour between ; 2 services per hour in the evening until

69 Bus Information H14: Hatch End/St Thomas Drive Northwick Park Hospital H14: Northwick Park Hospital - Hatch End/St Thomas Drive Monday-Friday 4 services operated from ; a bus every 8-12 minutes between ; 4 services an hour operate in the evening until Saturday 3 services an hour between ; 4 services between ; 9-13 minutes between ; evening service until 0008 operates every 15 minutes. Sunday 3 services operate per hour between ; 4 services an hour between ; 3 services an hour until Monday-Friday 2 services operate between ; 4 services operate between ; every 8-12 minutes; buses every 7-10 minutes; 5 services between ; every 15 minutes until Saturday 2 services operate between ; 3 services operate between ; every 8-12 minutes between ; services every 15 minutes from Sunday 3 services per hour between ; 4 services per hour between ; 3 services between National Rail Services can be accessed from two locations within the vicinity of the application site. The nearest location is Harrow and Wealdstone rail station, which lies approximately 800m to the east of the application site and provides rail services operated by London Midland Trains and London Overground. The London Midland Train service that is provided operates between Birmingham, Rugby, Northampton and London Euston stations. The following table sets out the services available: 65

70 Table 5.10: Rail Services Harrow and Wealdstone station National Rail Information Harrow and Wealdstone station Services London Euston station Milton Keynes Rugby/Birmingham Times Weekday: 6 services in the AM peak; 5 services returning in the PM peak Weekends: Operates regular services through the day every 20 minutes Weekday: 4 services in the AM peak; 3 services returning in the PM peak Weekends: Operates regular services through the day hourly on Saturday and half to one hourly on Sunday Weekday: 2 services late evening during the week Weekends: Infrequent direct services National Rail Services are also available from Harrow-on-the-Hill rail station. This station lies approximately 1.8km to the south of the application site and provides rail services operated by Chiltern Railways. The rail service that is provided operates between Aylesbury and London Marylebone stations. The following table summarises the service availability: Table 5.11: Rail Services Harrow-on-the-Hill station National Rail Information Harrow-on-the-Hill station Services London Marylebone Station Times Weekday: 2 services in the AM peak; 2 services returning in the PM peak Weekends: Operates regular services through the day every 30 minutes on Saturday and Sunday 66

71 National Rail Information Harrow-on-the-Hill station Aylesbury Weekday: 2 services in the AM peak; 3 services returning in the PM peak Weekends: Operates regular services through the day every 30 minutes on Saturday and every hour on Sunday There are two underground lines within the vicinity of the application site the Bakerloo line and the Metropolitan line. The nearest underground station is Harrow and Wealdstone station, which is the termination point for the Bakerloo line. It is approximately 800m to the east of the application site and provides services to the centre of London approximately every 8-12 minutes during the peak hours hours Monday Friday with a slightly reduced service outside of these peak hours and at weekends. The Harrow and Wealdstone underground station also provides a London Overground service between Watford Junction and Euston Station which runs approximately every 20 minutes during the peak periods hours Monday-Friday with a slightly reduced service outside of these peak hours and at weekends. The Metropolitan line can be accessed from either the North Harrow underground station, which lies approximately 1.3 miles to the west of the application site, or the Harrow-on-the-Hill underground station, which lies approximately 1.8km to the south of the application site Highways Headstone Drive is a single carriageway road with a 30mph speed limit. The road is wide in the vicinity of the application site (approximately 9.2m). It has a predominantly built-up frontage (except for the section on the Harrow View East site side which has limited existing access onto this corridor) with residential properties set back from the road allowing off road parking. There are also local shops located at the junction of Headstone Drive/Harrow View fronting onto wide footways with service access available to the rear. There are a number of local residential streets which form simple priority junctions with Headstone Drive, and which create a local grid network allowing vehicles to permeate through to major corridors. Cycle facilities are available along Headstone Drive, which is marked by advisory cycle lanes on both sides of the carriageway. In addition there are parking restrictions along Headstone Drive in the form of double and single yellow lines that create an unobstructed corridor for vehicles and cyclists during peak times. The corridor has width constraints under the rail bridge prior to the Cecil Road/High Street priority junctions that can create conflict with cyclists/car drivers. 67

72 The corridor is flanked by footpaths on both sides of the carriageway that vary between 1.8m-2.3m. Crossing points are available over Headstone Drive at strategic locations in the form of zebra crossings. Harrow View is a dual carriageway along the length of the Harrow View West site, which then narrows to a single carriageway. The single carriageway section in the vicinity of the Harrow View East site is fairly wide (approximately 8.5m in width) and is subject to a 30mph speed limit. The corridor has some active frontage where residential properties exist set back from the carriageway. Some on street parking occurs in this section as the houses do not have private driveways. However, along the length of the application site there is very little frontage activity with few points of access. There are parking restrictions along the corridor (except for outside the residential housing to the north of the application site) in the form of single yellow lines. The corridor is flanked by lit footways on both sides of the carriageway which vary from 1.8m 2.3m. These are consistent with an urban environment such as this location. There are four main strategic routes from the application site, the A409 to the east, the A410 to the north, the A404 to the west, and the A312 to the south. These can be accessed via Harrow View and/or Headstone Drive. A number of junctions have been considered in detail within the assessment as the extent of discernible impact was considered to be most likely to occur at these locations. These comprise the following: Harrow View/Site Access this is the proposed access to both the Harrow View East and the Harrow West sites and already has planning permission; Headstone Drive/Site Access this is the proposed access to the Harrow View East; Courtenay Avenue/Long Elmes traffic signalised junction to the north of the application site; Harrow View/Headstone Drive traffic signalised junction to the south of the application site; Headstone Drive/Princes Drive roundabout layout to the east of the application site; Headstone Drive/Ellen Webb Drive/Cecil Road Cecil Road and Headstone Drive form priority junctions onto Ellen Webb Drive within close proximity of each other. Headstone Drive is for access only to local retail with some parking facilities available; The Bridge/Ellen Webb Drive traffic signalised junction; Pinner Road (A404)/Station Road/Imperial Drive traffic signalised junction; and 68

73 Headstone Road/Greenhill Way (A4005) traffic signalised junction Accident analysis Crash data was provided by the Council for the last 5 years for all junctions surveyed and the links in between. None of the junctions had a fatal accident, although some did have serious accidents. However, no discernable trends were detected that suggested that any of the junctions had a particular safety problem that needed to be addressed. It is considered unlikely that the traffic generated by the development would exacerbate or initiate an accident problem at any of the junctions that were subject to the assessment as the predicted traffic generation is lower than the pre-existing uses Receptors The effect of traffic flows arising from the development has been defined on each of the identified links, and considered with regard to the receptors that are located alongside the link. The following receptors have been identified adjacent to the links that comprise the study area and have been evaluated as follows (link locations are shown on Figure 6.3): Link A: Low sensitivity residential Link B: Low sensitivity residential, and medium sensitivity GP and Dental surgeries Link C: Low sensitivity residential Link D: Low sensitivity residential, and medium sensitivity local shops, and high sensitivity primary school Link E: Low sensitivity residential, and medium sensitivity local shops Link F: Low sensitivity residential and local businesses Link G: Low sensitivity residential and local businesses, and medium sensitivity GP and Dental surgeries Link H: Low sensitivity residential and local businesses Link J: Low sensitivity employment area Link K: Low sensitivity residential Link L: Low sensitivity residential Link M: Low sensitivity residential and local businesses, medium sensitivity local shops and NHS clinic Link N: Low sensitivity residential and employment area Link O: Low sensitivity local businesses, and medium sensitivity local shops 69

74 Link P: Medium sensitivity rear of retail units, and station car park Link Q: Low sensitivity local businesses, and medium sensitivity shopping area Link R: Low sensitivity local businesses, and medium sensitivity shopping area Link S: Low sensitivity local businesses, and medium sensitivity shopping area Link U: Low sensitivity residential, and medium sensitivity local shops Link V: Low sensitivity residential and employment area, medium sensitivity local shops, GP and dental surgeries and high sensitivity college Link W: Low sensitivity residential and employment area, medium sensitivity shopping area, and high sensitivity colleges (Regent College and International School of Business Studies) Link X: Low sensitivity residential, local businesses and place of worship, and medium sensitivity shopping area Link Y: Low sensitivity residential and local businesses, and medium sensitivity local shops Link Z: Low sensitivity residential and employment area, and medium sensitivity shopping area Link AA: Low sensitivity residential and employment area 5.5 Assessment of impacts during construction Construction of the development is anticipated to commence in accordance with the phasing diagram referred to at Figure 3.8. It is anticipated that the development will be subject to greater detail in respect of the routing strategy along with logistics and mitigation measures. These would be included in a Construction Management Plan which would form a condition as part of the planning application. For the purposes of understanding construction traffic effects, an estimate has been undertaken to consider the overall number of vehicles for the proposed development. This takes into account the demolition works as well as the construction of buildings/infrastructure on the application site. The maximum volume of weekly trips is not likely to exceed 270 two-way movements comprising 135 in and 135 out (see Table 5.12). These trips will be spread throughout the day, as they will be made up of materials deliveries, off site disposal and other trips related to the management of the construction process. The likelihood is that construction vehicle movements will predominantly be controlled by the Construction Management Plan to be outside of 70

75 sensitive hours such as school drop off/pick up times and peak hours so that operatives can avoid congestion periods. The construction vehicle numbers associated with each phase and based on the likely phased eight year construction period, are assessed as follows: Table 5.12: Construction vehicle numbers Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Tota l Enabling Works 5,313 5,313 PHASE 1A 2,358 2,358 5,583 PHASE 1B 2,358 2,358 4,715 PHASE 1C 1,587 1,587 3,174 PHASE 2 1,328 1,328 2,701 2,701 8,058 PHASE 3 1,328 1,328 2,837 2,837 2,837 11,168 Total 5,313 6,477 6,477 5,616 5,616 2,837 2,837 2,837 38,011 Per Week The following topics have been considered in relation to the construction phases: Severance The guidelines in the Manual of Environmental Appraisal suggest a range of indicators for determining the significance of severance. Changes in traffic flow of 30%, 60% and 90% are regarded as producing slight, moderate and substantial changes in severance respectively. The change in daily traffic flow between the 2017 and 2021 do minimum scenarios and with construction traffic included suggests changes of less than 30%. Therefore, the magnitude is considered negligible. Driver delay The junction capacity tests undertaken in the TA for the do minimum and do something future year scenarios of 2017 and 2021 illustrate that there is congestion during the peak hours. This is not unusual for an urban outer London region. The results also show that the ratio of the traffic flow to the oretical capacity of the junction (RFC value), which is a measure of the residual available capacity of the junction, is smaller in the do something scenario when compared to the do nothing scenario for both future years, or are predicted to operate within acceptable parameters. Therefore, the effect of the traffic flows with the development in place is to reduce the level of congestion and delay at the assessed junctions. 71

76 Since the number of construction vehicles are considerably less than the development flows contained in the do something scenario, then the available capacity would be even higher when compared to the do nothing scenario. Therefore, there is an overall improvement for the capacity of the highway links and junctions during the construction period when compared to the do nothing scenario and so the magnitude is considered low beneficial. Pedestrian delay It is advised in the guidance that assessors use judgement to determine whether pedestrian delay is a significant impact. The guidance highlights changes in the volume, composition or speed of traffic may affect the ability of people to cross roads. As already advised there is a negligible change in traffic flows during the construction phases. Therefore, the magnitude is considered as negligible. Pedestrian amenity This topic is described in the guidance as relative pleasantness of a journey. The guidelines suggest that the significance of changes in pedestrian amenity would be where the traffic flow (or its lorry component) is halved or doubled. As already mentioned, there is a negligible change in traffic flows during the construction phases. Therefore, the magnitude of significance is considered as negligible. Fear and intimidation The guidelines highlight that the impact is dependent on the volume of traffic, its HGV composition, its proximity to people or the lack of protection caused by such factors as narrow pavement widths. During the construction phase there will be an increase of heavy goods vehicles, however the magnitude of overall traffic will be less than the baseline, which therefore suggests a magnitude of significance of negligible. Accidents and safety - Despite the addition of construction traffic a net reduction in traffic is predicted compared to the pre-existing use on the application site, suggesting a magnitude of low beneficial. In summary, the following table lists the receptors and the environmental impact based on the receptor sensitivity and magnitude: 72

77 Table 5.13: Environmental Impact for each receptor during construction Receptors (neither beneficial or adverse) Severance (neither beneficial or adverse) Driver delay (Beneficial) Pedestrian delay (neither beneficial or adverse) Pedestrian amenity (neither beneficial or adverse) Fear and intimidation (neither beneficial or adverse) Accidents and safety (beneficial) Link A (low (L)) negligible minor/ insignificant negligible negligible negligible minor/ insignificant Link B (low and medium (M)) negligible Minor/ insignificant (L); Moderate/ minor (M) negligible negligible negligible minor/ insignificant (L): moderate/ minor (M) Link C (low) negligible minor/ insignificant negligible negligible negligible minor/ insignificant Link D low, med and high) negligible minor/ insignificant (L); Moderate/ Minor (M); Moderate (H) negligible negligible negligible minor/ insignificant (L); Moderate/ Minor (M); Moderate (H) Link E (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) Link F (low) negligible Minor/ insignificant negligible negligible negligible Minor/ insignificant Link G (low and med) negligible Minor/ Insignificant (L); Moderate/ minor (M) negligible negligible negligible Minor/ Insignificant (L): Moderate/ minor (M) Link H (low) negligible Minor/ insignificant negligible negligible negligible Minor/ insignificant 73

78 Receptors (neither beneficial or adverse) Severance (neither beneficial or adverse) Driver delay (Beneficial) Pedestrian delay (neither beneficial or adverse) Pedestrian amenity (neither beneficial or adverse) Fear and intimidation (neither beneficial or adverse) Accidents and safety (beneficial) Link I/M (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) Link J (low) negligible Minor/ insignificant negligible negligible negligible Minor/ insignificant Link K (low) negligible Minor/ insignificant negligible negligible negligible Minor/ insignificant Link L (low) negligible Minor/ insignificant negligible negligible negligible Minor/ insignificant Link N (low) negligible Minor/ insignificant negligible negligible negligible Minor/ insignificant Link O (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) Link P (med) negligible Moderate/ Minor negligible negligible negligible Moderate/ Minor Link Q (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) Link R (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) 74

79 Receptors (neither beneficial or adverse) Severance (neither beneficial or adverse) Driver delay (Beneficial) Pedestrian delay (neither beneficial or adverse) Pedestrian amenity (neither beneficial or adverse) Fear and intimidation (neither beneficial or adverse) Accidents and safety (beneficial) Link S (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) Link U (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) Link V/AB low, med and high negligible Minor/ Insignificant (L); Moderate/ Minor (M); Moderate (H) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M); Moderate (H) Link W low, med and high negligible Minor/ Insignificant (L); Moderate/ Minor (M); Moderate (H) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M); Moderate (H) Link X (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) Link Y (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) 75

80 Receptors (neither beneficial or adverse) Severance (neither beneficial or adverse) Driver delay (Beneficial) Pedestrian delay (neither beneficial or adverse) Pedestrian amenity (neither beneficial or adverse) Fear and intimidation (neither beneficial or adverse) Accidents and safety (beneficial) Link Z (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible negligible Minor/ insignificant (L); Moderate/ Minor (M) Link AA (low) negligible Minor/ insignificant negligible negligible negligible Minor/ insignificant 5.6 Assessment of impacts during operation The existing potential as well as historic use of the application site is an intensive industrial use and so the net effect in traffic flows during the assessment periods is a reduction in traffic. Hence, this assessment quantifies the change and allows the appraisal at these locations in terms of overall performance in the future, with and without development at Kodak. The following topics have been considered in relation to the operational phases, and in the context of the future years of 2017 and 2021 as follows: Severance The guidelines in the Manual of Environmental Appraisal suggest that there are a range of indicators for determining the significance of the relief from severance. Changes in daily traffic flow of 30%, 60% and 90% are regarded as producing slight, moderate and substantial changes in severance respectively. The change in daily traffic flow between the baseline and the proposed development traffic is below 30%. Therefore, the change in severance is below 30% and so relates to a magnitude of negligible. Driver delay - Capacity assessments have been completed for the junctions detailed below using appropriate junction modelling software as follows: The proposed Harrow View/site access, Headstone Drive/Princes Drive, Headstone Drive/Ellen Webb Drive/Cecil Road and the redesign of the Harrow View/Headstone Drive roundabout junctions have been assessed using the ARCADY software - a computer modelling program that allows the performance of roundabouts to be analysed. Courtenay Avenue/Long Elmes, The Bridge/Ellen Webb Drive, Pinner Road (A404)/Station Road/Imperial Drive, Harrow View/Headstone Drive and Headstone Road/Greenhill Way (A4005) traffic signalised junctions have been analysed using the Linsig software - a computer modelling program that allows the performance of traffic signal junctions to be analysed. 76

81 The proposed Headstone Drive/site access priority junction has been assessed using the PICADY software - a computer modelling program that allows the performance of priority junctions to be analysed. Information on the operation of the local junctions has been taken from the modelling exercise undertaken as part of the Transport Assessment. The results highlight that spare capacity increase at the local junctions when the with development scenario is compared to the baseline scenario, or junctions are predicted to operate within the maximum theoretical capacity, in all future years, at all junctions. On this basis, the magnitude of significance is considered low beneficial for both future year scenarios. Pedestrian delay It is advised in the guidance that assessors use judgement to determine whether pedestrian delay is a significant impact. The guidance highlights changes in the volume, composition or speed of traffic may affect the ability of people to cross roads. There is a negligible change in traffic flows when comparing the baseline conditions with the proposed development conditions. Therefore, the magnitude of significance is considered as negligible. Pedestrian amenity This topic is described in the guidance as relative pleasantness of a journey. The guidelines suggest that the significance of changes in pedestrian amenity would be where the traffic flow (or its lorry component) is halved or doubled. There is a negligible change in traffic flows due to the proposed development. In addition the proposals include for the creation of a green link increasing the permeability of the application site and area as a whole. Therefore, the significance is considered as negligible. Fear and intimidation The guidelines highlight that the impact is dependent on the volume of traffic, its HGV composition, its proximity to people or the lack of protection caused by such factors as narrow pavement widths. During operation it is predicted that traffic flows will generally go down in comparison to the base line which therefore suggests the magnitude of significance to be low beneficial. Accidents and safety The guidelines suggest making a simple statistical assessment of the likely increase or decrease in the number of accidents resulting from changes in traffic flows and composition. There is a negligible change in traffic flows due to the proposed development when compared to the baseline. Therefore, it is not considered that the development would lead to any increase in accidents or decrease in safety and so the significance is considered as negligible. In summary, the following table lists the receptors and the environmental impact based on the receptor sensitivity and magnitude: 77

82 Table 5.14: Environmental Impact for each receptor during operation Receptors Severance (neither beneficial or adverse) Driver delay (Beneficial) Pedestrian delay (neither beneficial or adverse) Pedestrian amenity (neither beneficial or adverse) Fear and intimidation (Beneficial) Accidents and safety (neither beneficial or adverse) Link A (low) negligible Minor/ Insignificant negligible negligible Minor/ Insignificant negligible Link B low: med: negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M negligible Link C (low) negligible Minor/ Insignificant negligible negligible Minor/ Insignificant negligible Link D low, med and high) negligible Minor/ Insignificant (L); Moderate/ Minor (M); Moderate (H) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M); Moderate (H) negligible Link E (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M negligible Link F (low) negligible Minor/ Insignificant negligible negligible Minor/ Insignificant negligible Link G (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M negligible Link H (low) negligible Minor/ Insignificant negligible negligible Minor/ Insignificant negligible 78

83 Receptors Severance (neither beneficial or adverse) Driver delay (Beneficial) Pedestrian delay (neither beneficial or adverse) Pedestrian amenity (neither beneficial or adverse) Fear and intimidation (Beneficial) Accidents and safety (neither beneficial or adverse) Link I/M (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M negligible Link J (low) negligible Minor/ Insignificant negligible negligible Minor/ Insignificant negligible Link K (low) negligible Minor/ Insignificant negligible negligible Minor/ Insignificant negligible Link L (low) negligible Minor/ Insignificant negligible negligible Minor/ Insignificant negligible Link N (low) negligible Minor/ Insignificant negligible negligible Minor/ Insignificant negligible Link O (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible Link P (med) negligible Moderate/ Minor negligible negligible Moderate/ Minor negligible Link Q (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible Link R (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible 79

84 Receptors Severance (neither beneficial or adverse) Driver delay (Beneficial) Pedestrian delay (neither beneficial or adverse) Pedestrian amenity (neither beneficial or adverse) Fear and intimidation (Beneficial) Accidents and safety (neither beneficial or adverse) Link S (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible Link U (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible Link V/AB low, med and high negligible Minor/ Insignificant (L); Moderate/ Minor (M); Moderate (H) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M); Moderate (H) negligible Link W low, med and high negligible Minor/ Insignificant (L); Moderate/ Minor (M); Moderate (H) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M); Moderate (H) negligible Link X (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible Link Y (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible 80

85 Receptors Severance (neither beneficial or adverse) Driver delay (Beneficial) Pedestrian delay (neither beneficial or adverse) Pedestrian amenity (neither beneficial or adverse) Fear and intimidation (Beneficial) Accidents and safety (neither beneficial or adverse) Link Z (low and med) negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible negligible Minor/ Insignificant (L); Moderate/ Minor (M) negligible Link AA (low) negligible Minor/ Insignificant negligible negligible Minor/ Insignificant negligible 5.7 Mitigation and enhancements As the significance criteria for both construction and operation related to the development is minor to insignificant there are no mitigation measures required or proposed as a consequence of the assessment. However, there are to be a number of enhancements included as part of the development proposals to encourage residents and occupiers to consider other modes of transport rather than rely on single occupancy private cars. The proposed development complies with National and Regional Policies in transport terms, as it has mixed land uses which provide employment, residential, retail and leisure facilities within a short walk of each other. In addition, a green link is to be included through the heart of both parts of the application site enabling a new pedestrian/cycle facility linking Headstone Manor to the west and Wealdstone Town Centre to the east. The application site is located close to bus stops on Harrow View and Headstone Drive for existing local bus services (H9, H10 and H14) and is within a short walk (approximately 10 minutes) of the underground system. In terms of parking, the proposals include for some provision that is dedicated to each land use, but also provide additional areas that are for shared use and may be subject to usage charges to help to redress the balance between use of the car and other modes. A Transport Assessment report and Framework Travel Plan document accompanies the planning application and will make provision for measures that will influence travel mode choice away from car ownership and reliance on the single user car. The development proposals for the Harrow View West and East sites are in accordance with a number of the goals set out within the Local Implementation Plan 2 LIP2, for example, through the creation of a green link through the heart of the application site linking Headstone Manor and Headstone Drive. This route opens up a previously closed area, ultimately providing permeability through the application site linking to the external network of Headstone Drive and Harrow View. Permeable 81

86 pedestrian routes from the application site will link to the local bus stops which are situated within 800m of the development area. The proposals provide cycle routes within the application site and linking with the external network. In terms of the wider area, the proposals include off site works to provide new off road shared cycle/pedestrian links along the frontage of the application site on Harrow View and Headstone Drive. The mixed land use development is located within the Intensification Area which is defined as a growth area in the Core Strategy as it is well connected and provides ready access to many day-to-day facilities Site access Harrow View Harrow View will provide access for vehicles to and from the Harrow View East and Harrow View West sites. Initially this will provide access for phases 1b and 2, and then for all phases when a through route is provided at phase 3. This access will be in the form of a roundabout junction, which already has planning permission. The junction has been designed to allow for proposed development of the application site and has been approved by the local highway authority. Footways are incorporated within the design to allow access for pedestrians into both parts of the application site adjacent to the carriageway. However, the main pedestrian link between both parts of the application site is via the green link proposed through the heart of the application site. The crossing facility for the proposed green link is to be in the form of a tiger crossing or zebra crossing over Harrow View. This green link crossing is to be located approximately half way between the proposed roundabout and Victor Road on Harrow View. The location can be seen at the parameter plans provided with the application (Figures ). Bus services operate along Harrow View and Harrow View East has been designed to allow for re-routing of the operation through this site if this becomes a viable option in the future. However, it is anticipated that the existing service will remain along the Harrow View corridor as the application site is within a 5 minute walk of the local bus stops Site access Headstone Drive The vehicular access onto Headstone Drive is to be in the form of a simple priority junction. Initially this will serve phases 1a and 2 until it is connected through the application site in phase 3 to the Harrow View access. A dedicated access point for pedestrians and cyclists would be onto Headstone Drive via the green link. The access to the green link would be opposite Walton Road on Headstone Drive. Walking and cycling routes in the area will be enhanced by the provision of new routes through the development which will provide attractive, safe and direct connections, both within and through the application site linking to the external network. 82

87 As part of the proposal the following off site schemes are included: Shared cycle/pedestrian off road route adjacent to the frontage of Harrow West; Shared cycle/pedestrian off road route adjacent to the frontage of Headstone Drive; and Informal crossing points over Harrow View for the green link through the application site and near to Victor Road/Harrow View road junction. 5.8 Conclusions and statement of residual significance The assessment demonstrates that the environmental impact for the construction period of the study area is negligible for all topics considered except driver delay and accidents and safety. These two topics show a beneficial impact between minor and moderate depending on the sensitivity of the receptor..therefore, mitigation is not proposed. The assessment demonstrates that the environmental impact for the operational period of the study area is negligible for all topics considered except driver delay and fear and intimidation. These two topics show a beneficial impact between minor and moderate depending on the sensitivity of the receptor..therefore, mitigation is not proposed. As stated earlier, the existing potential use of the application site is an intensive industrial use and so the net effect in traffic flows during the assessment periods is a reduction in traffic. Due to this fact, there is not predicted to be any residual effects as a result of the development. 83

88 6 Air Quality 6.1 Introduction This chapter presents an assessment of the air quality issues that have the potential to result from the construction and operation of the proposed development. The application site clearance and construction phase of the proposals have the potential to result in temporary air quality impacts due to the emission of dust and emissions from haulage vehicles. The operational phase of the proposed development may lead to a change in traffic on the local road network, and this has the potential to affect air quality due to a change in vehicular emissions. There are also proposals for an energy centre on the application site, which will affect air quality at existing receptors and receptors on the application site. Application site receptors will also be exposed to Kodak factory emissions during the early phases of the development. Furthermore, the application site will introduce residential receptors within an AQMA, where air pollutant concentrations could be in excess of air quality objectives. This chapter describes the baseline and future air quality within the vicinity of the application site. The construction assessment focuses on the air quality impacts of dust and haulage vehicles in the construction phase. The operational assessment focuses on the air quality impacts of traffic and the energy centre associated with the development. The exposure of proposed residential receptors to vehicular pollutants and pollutants associated with Kodak factory and proposed energy centre operations are also assessed. 6.2 Methodology Scope of assessment The air quality assessment has addressed the air quality issues highlighted in the Scoping Report (Halcrow, 2011) and scoping opinion from the Council. The assessment has involved the following key elements: Assessment of existing air quality through a review of the Council s Air Quality Review and Assessment documents and air quality data within the vicinity of the development; A diffusion tube monitoring survey undertaken by Halcrow Group Ltd to define air quality in the vicinity of the proposed development; Identification of receptors that are likely to be sensitive to changes in air quality resulting from the construction and operation of the proposed development; Semi-quantitative assessment of the effect of the construction phase in terms of the potential for dust complaints and air quality impacts from haulage vehicles; 84

89 Quantitative assessment of the effect of the operational phase on local air quality based on road traffic emissions and emissions from the proposed energy centre; and Quantitative assessment of air quality on the application site, taking into account Kodak factory emissions Assessment methodology a) Construction phase Potential impacts The construction phase is likely to affect local air quality through the generation and subsequent deposition of construction dust. Dust deposition on windows, properties, and cars can result in complaints through surface soiling. The amount of dust generated from construction activities depends on: the type of materials handled; the length and scale of operation; the type of activities performed on site; the weather conditions; and the effectiveness of dust suppression measures. Furthermore, the perception of dust from surface soiling is determined by factors such as (Office of the Deputy Prime Minister, 2005): the colour contrast between the dust and the surface on which it settles; the nature of the illumination of the surface; the presence of a nearby clean reference surface against which comparisons can be made; the personal experience and expectation of the observer; and adverse publicity influencing the expectation of the observer. The above factors mean that it is not possible to reliably predict the number of dust complaints that will occur during the construction phase of the proposed development. However, it is possible to estimate the distance from dust-generating activities over which dust complaints may occur. Studies of dust impacts from quarrying, waste disposal and construction operations indicate rapid fall-off in downwind dust concentrations with increasing distance from the source due to particle dispersion and deposition. Large and heavy particles fall out closer to the source than finer and lighter particles. Particles greater than 30µm in size tend to comprise the greatest portion of dust emitted by dust generating activities and these particles are the most visible and therefore the most likely to generate complaints. Particles of this size deposit largely within 100m of sources, and as such, potential 85

90 dust impacts on local air quality have been considered at all sensitive receptors within 100m of proposed construction activities within the application site boundary. The London Councils Best Practice Guidance (London Councils, 2006) has been used to define the risk of dust nuisance impacts occurring during construction. The risk of dust nuisance is based on the size of the construction site, the number of buildings constructed and the location of sensitive receptors. These guidelines are outlined in Table 6.1, and can be used to define the level of dust mitigation that is likely to be required during construction. Table 6.1: Construction Site Evaluation Guidelines Category Low Risk Sites Medium Risk Sites High Risk Sites Criteria Development of up to 1,000m2 of land and; Development of 1 to 10 properties and; Potential for emissions and dust to have an infrequent impact on sensitive receptors. Development of between 1,000 and 15,000m2 of land and; Development of 10 to 150 properties and; Potential for emissions and dust to have an intermittent or likely impact on sensitive receptors. Development of over 15,000m2 of land or; Development of over 150 properties or; Potential for emissions and dust to have significant impact on sensitive receptors. The construction of the proposed development may also affect air quality following emissions from haulage vehicles. The number of haulage vehicle movements expected to result from the construction phase has been compared against Design Manual for Roads and Bridges (Highways Agency, 2007) and Environmental Protection UK (2010) criteria. According to the criteria, an increase in HGVs of less than 200 per day is not expected to result in significant air quality impacts. Sensitive Receptors For construction dust, potentially sensitive receptors are defined as: One or more locations where the effect of dust emissions associated with construction activities may result in complaints. Impact Significance The significance of construction dust impacts cannot be classified using the normal procedure employed in EIA as it is not possible to predict the magnitude or significance of potential impacts (i.e. the concentrations of construction dust in the atmosphere or predict the amount of dust deposits leading to complaints). Rather, if dust impacts result in a complaint then the impact is significant; if no complaints arise then the impact is not significant. 86

91 b) Operational Phase Potential impacts The proposed development could have the following operational impacts: A change in air quality at existing receptors due to emissions from development associated traffic; A change in air quality at existing receptors due to emissions from the proposed energy centre; and Introduction of receptors on the application site to the emissions outlined above, as well as emissions from the Kodak factory operations. The receptors will be located in an AQMA where air pollutant concentrations could be in excess of air quality objective values. These potential air quality impacts have been considered as outlined in the methodology below. The approach adopted has been approved by Paul Hargreaves (Environmental Health Officer the Council) following consultation with Stephen Pyatt (Senior Air Quality Consultant, Halcrow Group Ltd), and has been formulated to address the air quality issues highlighted in the Scoping Report (Halcrow, 2011) and scoping opinion from the Council. The assessment of operational air quality impacts considers nitrogen dioxide (NO2) and particulate matter smaller than 10 (PM10) and 2.5 (PM2.5) micrometers, since these are the main pollutants likely to be affected by development associated road traffic and energy centre emissions. Harrow AQMA has also been declared for NO2 and PM10, with the likelihood that concentrations may exceed air quality objective values on the application site. These pollutants comprise a background and local component. The background concentration is determined by regional, national and international emissions, and often represents a significant proportion of the total pollutant concentration. The local component is determined by local pollutant sources (such as roads, and chimney stacks). Predicted local concentrations have been combined with the predicted background component when calculating a total concentration that can be compared against the human health based criteria set in EU and UK legislation. Background and local pollutant concentrations have been established following the methodology outlined in this section. Background Pollutants Background pollutant concentrations are spatially and temporally variable throughout the UK. Background concentrations of nitrogen oxides (NOx), NO2, PM10 and PM2.5 representative of the study area have been established for the base year (2010) and opening year scenario for the development (2015). Background pollutant concentrations have been obtained from the Defra (Department for Environment, Food and Rural Affairs) website. The proposed development is expected to be fully operational by There are five phases to the development as shown on Figure 3.8. As described in Section 3.2.3, phase 1a and 1b will be complete by 2015, phase 1c by 2016, phase 2 by 2017 and 87

92 phase 3 by As a worst case, the air quality assessment has assumed that all the phases will be operational in This approach has been adopted as air quality is expected to improve year on year as a result of the introduction of cleaner vehicle technologies in future years. The background pollutant concentrations used in this assessment are presented in Table 6.2. Monitoring at a number of background locations were undertaken as part of this assessment. The average annual equivalent background NO2 concentration measured during the monitoring survey was 27.7µg m -3 (Table 6.14), which is slightly lower than the 2010 background NO2 concentration predicted by Defra (30.8 µg m -3 ). Defra background values have been used in the assessment as a worst-case approach. Table 6.2: Background Pollutant Concentrations Year NOx (µg /m 3 ) NO2 (µg /m 3 ) PM10 (µg /m 3 ) PM2.5 (µg /m 3 ) The background concentrations were adjusted following the methodology in Defra (2009) to ensure that the sources modelled in the assessment were not double counted in the background concentrations. Local Road Traffic Component The traffic contribution to local pollutant concentrations has been predicted using the dispersion model ADMS (Roads). The model uses detailed information regarding traffic flows on the local road network together with meteorological data to predict pollutant concentrations at specific locations selected by the user. A detailed description of the road traffic air quality modelling undertaken is outlined in Appendix 6.2 and is summarised below for completeness. The following scenarios have been considered in this assessment: 2010 Base year; 2015 Opening year Do-Minimum plus traffic associated with committed development in the study area including Pinner House; and 2015 Opening year Do-Something - Development traffic plus traffic associated with committed development in the study area including Pinner House. Traffic data used for the assessment is presented in Appendix 6.1. The Do-Something situation for the opening year includes development associated traffic from all five phases. This is a worst case approach, since air quality is expected to improve in future years in response to the introduction of increasingly stringent vehicle emission standards. The proposed development is located in an AQMA. Following Environmental Protection UK guidance Development Control: Planning for Air Quality (2010), because 88

93 traffic associated with the proposed development is likely to affect air quality where air pollutants are above objective levels, the following criteria have been used to define roads considered in the air quality assessment: Roads with a traffic change in Annual Average Daily Traffic (AADT) flow of 5% or more as a result of the development; and Roads with a change in Heavy Duty Vehicle AADT flow of 200 or more as a result of the development. Base year air quality predictions allow the modelled pollutant concentrations to be verified against monitoring data. Pollutant concentrations predicted in the opening year Do-Minimum and Do-Something scenario have been compared to ascertain the impact of the proposed development on local air quality. Road-traffic concentrations were verified against monitoring data from the Council and monitoring data collected as part of this assessment in order to determine whether the predicted values required adjustment. This verification process is outlined in Appendix 6.3. Local Energy Centre Component The energy centre will be located on the ground floor of the proposed multi-storey car park, in the north east part of the application site. It is anticipated that the energy centre will comprise of a gas engine Combined Heat and Power (CHP) unit and three Low Temperature Hot Water (LTHW) boilers, although the three boilers would provide resilience, with only one boiler ever in operation alongside the CHP unit. No biomass boilers are expected to be used by the energy centre. Stack, building and emission parameters for the proposed energy centre have been provided by Parsons Brinckerhoff. The height of the multi-storey car park is assumed to be 18m, with surrounding buildings 10m tall. Table 6.3 shows the stack parameters for the energy centre. The emission parameters (at Standard Temperature and Pressure) for the CHP unit and the LTHW boiler are shown in Table 6.4. Table 6.3: Stack Parameters Approx OS Location Height (m) Diameter (m) , Note: It is anticipated that the stack would be comprised of three circa 0.6m flues, which have been assumed to be contained in a single stack. Table 6.4: Emission Parameters Source Efflux Velocity (m 3 /s) Temperature ( C) NOx Emission (g/s) PM10 Emission (g/s) CHP Unit

94 Source Efflux Velocity (m 3 /s) Temperature ( C) NOx Emission (g/s) PM10 Emission (g/s) LWHW Boiler The energy centre has been considered in the ADMS (Roads) dispersion model using the industrial source function and year 2009 meteorological data from Heathrow Airport. Although this is not as robust approach as using an industrial source dispersion model such as AERMOD, it does provide an indication of the levels of NO2 and PM10 likely to result from the energy centre. This approach was agreed with the Council. The model was used to predict annual mean NOx and PM10. For 1-hour mean NO2, the 99.8th percentile of all one hour mean values throughout each year was output from the model. This value corresponds with the 18th largest hourly mean value throughout the year, and so a value less than 200 µg m -3 would indicate that the 1- hour mean AQS objective for NO2 would not be exceeded. For 24-hour mean PM10, the 90th percentile of all 24-hour mean values throughout the year was predicted, corresponding with the 35th largest 24-hour mean value throughout the year. A value less than 50 µg m -3 would indicate that the 24-hour mean AQS objective for PM10 would not be exceeded. Opening year (2015) background values were combined with the contribution from the proposed energy centre. The background concentrations are representative of annual mean values, and while following Defra (2009) guidance, it is considered appropriate to combine the concentrations with 24-hour mean PM10, it is not appropriate to combine 1-hour mean NO2 concentrations to an annual average background concentration. The approach outlined in Defra (2009) (Ref 10.8) was adopted when predicting 1-hour mean NO2, which involved multiplying the background NO2 concentration by a factor of two and applying the resulting value to the short term concentration modelled. Following Defra (2009) it has been assumed that 100% NOx is oxidised to NO2. The 100% conversion efficiency has been assumed for both annual mean and 1-hour mean NOx, and these assumptions are a worse case scenario for the production of NO2. Local Kodak Factory Component Under the current proposed phasing of the development (see Section 3.2.3), the Kodak factory could be operational for a short period of time whilst other parts of the application site become occupied. The air quality impact of Kodak factory operations on application site receptors has been assessed here based on emissions data obtained from the Environment Agency and Kodak Harrow. Sensitive Receptors Potentially sensitive receptors during the operational phase of the proposed development have been defined according to Defra (2009) as: 90

95 Locations where members of the public are likely to be regularly present and are likely to be exposed for a period of time appropriate to the averaging period of the relevant air quality objective. The air quality objectives/limit values most relevant to this assessment are annual mean objectives for NO2, PM10 and PM2.5. Sensitive receptors in the context of these air quality objectives will include building façades of residential properties, schools, hospitals, care homes etc. Sensitive receptors have been identified at locations representative of worst-case public exposure. It should be noted that particular care has been taken to identify sensitive receptors alongside junctions, where vehicular speeds are likely to be lower, and vehicle emissions greater than in free flowing driving conditions. The 13 existing receptors modelled and assessed as part of this assessment are presented in Figure 6.1. Table 6.5 shows the grid reference of the modelled receptors. Table 6.5: Existing Receptors Receptor X-coordinate Y- coordinate R R R R R R R R R R R R R New receptors that would be introduced as a result of the proposed development were also considered. Air quality was predicted along a transect of receptors located on either side of Harrow View, corresponding with the proposed location of residential uses. The location of development receptors modelled as part of this assessment are presented in Table 6.6 and shown in Figure 6.1. Receptors NR1 and NR6 are closest to Harrow View and represent a receptor on the boundary of the proposed 91

96 development. Receptor NR11 was located close to the junction of Harrow View and Headstone Drive and is representative of the worst-case pollutant concentrations on the application site. Other parts of the development that border the existing road network will be of commercial use, and are therefore not classed as sensitive receptors. Table 6.6: Application Site Receptors Receptor X-coordinate Y- coordinate NR NR NR NR NR NR NR NR NR NR NR Impact Significance The significance of air quality impacts is dependent upon both the magnitude of change in air pollutant concentrations in relation to air quality objective/limit values and absolute pollutant concentrations in relation to air quality objective/eu Limit Values. Descriptors for magnitude of change and significance have been formulated by the Institute of Air Quality Management and are shown in Table 6.7 and Table 6.8. The use of these descriptors is recommended for the assessment of the significance of air quality impacts in EPUK (2010) and these descriptors have been adopted in this assessment. Table 6.7: Definition of Magnitude of Change for NO 2, PM 10 and PM 2.5 Magnitude of Change Annual Mean NO2/PM10 Annual Mean PM2.5 Days PM10 >50 µg m-³ Large +/- > 4 µg m-³ +/- >2.5 µg m-³ +/- > 4 days Medium +/- 2 4 µg m-³ +/ µg m-³ +/- 2 4 days 92

97 Magnitude of Change Annual Mean NO2/PM10 Annual Mean PM2.5 Days PM10 >50 µg m-³ Small +/ µg m-³ +/ µg m-³ +/- 1 2 days Imperceptible +/- <0.4 µg m³ +/- <0.25 µg m-³ +/- <1 day Table 6.8: Air Quality Impact Significance for Changes to Annual Mean Pollutant Concentration at a Receptor (Based on Annual Mean NO 2 and PM 10) Absolute Concentration in Relation to Objective /Limit Value Change in Concentration Small Medium Large Increase with Scheme Above Objective/Limit Value With Scheme Slight Adverse Moderate Adverse Substantia l Adverse Just Below Objective/Limit Value With Scheme (100 to 90% of Objective) Slight Adverse Moderate Adverse Moderate Adverse Below Objective/Limit Value With Scheme (90 to 75% of Objective) Negligible Slight Adverse Slight Adverse Well Below Objective/Limit Value With Scheme (< 75% Objective) Negligible Negligible Slight Adverse Decrease with Scheme Above Objective/Limit Value Without Scheme Slight Beneficial Moderate Beneficial Substantia l Beneficial Just Below Objective/Limit Value Without Scheme (100 to 90% of Objective) Slight Beneficial Moderate Beneficial Moderate Beneficial Below Objective/Limit Value Without Scheme (90 to 75% of Objective) Negligible Slight Beneficial Slight Beneficial Well Below Objective/Limit Value Without Scheme < 75% Objective) Negligible Negligible Slight Beneficial Separate criteria to those described in Table 6.7 and Table 6.8 have been used to assess the significance of new exposure introduced on the application site. Table 6.9 sets out the significance criteria described in the EPUK (formerly the National Society for Clean Air) guidance document Development Control: Planning for Air Quality (EPUK, 2006) for the assessment of new exposure. 93

98 Table 6.9: Air Quality Significance of Effects for Introduction of New Exposure Absolute Concentration at New Properties in Relation to Objective Number of New Properties Exposed to Concentration >500 Above Objective Slight Adverse Moderate Adverse Substantial Adverse Very Substantial Adverse Below Objective but not Well Below Negligible Negligible Slight Adverse Slight Adverse Well Below Objective Negligible Negligible Negligible Negligible Well Below Objective = < 75% of the objective level Consultation The air quality assessment methodology outlined above has been agreed with the Council following several telephone conversations between Stephen Pyatt (Senior Air Quality Consultant, Halcrow) and Environmental Health Officers at the Council. The assessment of road traffic air quality impacts, and the approach used to assess the impact of Kodak factory emissions on future receptors was agreed with Paul Hargreaves (Environmental Health Officer, the Council). The methodology used to assess the impact of energy centre emissions, and the traffic scenarios used to assess road traffic air quality impacts were agreed with Patrick Legg (Environmental Health Officer, the Council). 6.3 Legislation and policy An analysis of legislation and plans relevant to the assessment is included in Appendix 4.4. The air quality legislation most relevant to the assessment is summarised in Table The policy documents most relevant to the assessment are outlined below: The London Plan: Spatial Development Strategy of Greater London (2011); Mayor of London s Air Quality Strategy (2010); London Borough of Harrow Air Quality Action Plan (2004); and Planning Policy Statement 23: Planning and Pollution Control (2004). 94

99 Table 6.10: Air Quality Objectives and EU Limit Values for NO 2, PM 10 and PM 2.5 Air Quality Objectives and European Directives for the protection of human health Air Quality Objectives EU Limit Values Pollutant Concentrat ion Averaging Period Compliance Date Concentration Compliance Date NO2 200 µg m-3 1-hour mean (not to be exceeded more than 18 times per year) 31 December µg m-3 (18 exceedances) 1 January µg m-3 annual mean 31 December µg m-3 1 January 2010 PM10 50 µg m-3 24-hour mean (not to be exceeded more than 35 times per year) 31 December µg m-3 (35 exceedances) 1 January µg m-3 annual mean 31 December 2004 PM µg m-3 annual mean 1 January µg m-3 1 January µg m-3 1 January Baseline conditions Harrow Council air quality review and assessment The Council has declared its entire borough as an AQMA due to exceedances of the annual mean objective for NO2 and the daily mean objective for PM10. The exceedance of the air quality objectives are due to road traffic emissions. An Air Quality Action Plan (AQAP) was prepared for Harrow in 2009, which aims to reduce the volume of road traffic and congestion in the borough. Details of the AQAP are summarised in Section Harrow Council air quality monitoring data There are two principal methods used for measuring air quality; either using passive sampling techniques such as diffusion tubes, or through the use of sophisticated continuous monitoring equipment. The Council monitors NO2 across the borough from four diffusion tube sites and two continuous monitoring stations. Diffusion tubes are less accurate than continuous monitoring stations and tend to over read concentrations. In order to account for this, diffusion tubes are collocated with continuous monitoring stations, and the results from each method compared to obtain a bias adjustment factor to apply to the diffusion tube reading. 95

100 The closest diffusion tube sites to the application site are located on the grounds of St John Fisher School and Harrow Arts Centre, approximately, 1.5km west and 1.5km north of the proposed development, respectively. Both sites are representative of urban background NO2, and bias adjusted annual mean NO2 concentrations obtained from each tube are shown in Table Concentrations have been bias adjusted by the Council using national bias adjustment factors. The other diffusion tube sites are located over 2.5km from the application site and are unlikely to be representative of air quality within the vicinity of the proposed development. Table 6.11: Bias Adjusted Urban Background Annual Mean NO 2 (µg m -3 ) Location OS Grid Reference Objective St John Fisher School, Melrose Road , Harrow Arts Centre, Uxbridge Road , Table 6.11 shows that urban background annual mean NO2 concentrations at the two diffusion tube sites were well below annual mean air quality objective values from 2006 to The closest continuous monitoring station to the application site is located on Pinner Road, approximately 1.1km south west of the proposed development (see Figure 6.2). The station is representative of roadside air quality, and monitors PM10 as well as NO2. Annual mean NO2 and PM10 concentrations measured from the station are shown intable The other continuous monitoring station is located in Stanmore, over 3.5 km north east of the application site, and is unlikely to be representative of air quality within the vicinity of the proposed development. Table 6.12: Annual Mean NO2 and PM 10 (µg m -3 ) at the continuous monitoring station on Pinner Road. Location Pinner Road OS Grid Reference , Pollutant Objective NO PM Exceedances of air quality objective values highlighted in bold Table 6.12 shows that annual mean NO2 concentrations were above the annual mean objective at the continuous monitoring station on Pinner Road from 2006 to However, annual mean PM10 concentrations were well below annual mean objective values over the same period. Table 6.13 shows the number of hours above the exceedance limit for NO2 and the number of days above the exceedance limit for PM10 recorded by the continuous 96

101 monitoring station. The number of exceedances recorded was below the hourly mean objective for NO2 (18 exceedances permitted per year) and the daily mean objective for PM10 (35 exceedances permitted per year) between 2006 and Table 6.13: Number of Exceedances of Short-term Objectives for NO 2 and PM 10 at the continuous monitoring station on Pinner Road Location Pinner Road OS Grid Reference , Pollutant Objective NO PM The air quality monitoring undertaken by the Council suggests that background pollutant concentrations are likely to be below air quality objective values. Roadside NO2 concentrations exceed annual mean objectives at the Pinner Road site. Since it is likely that annual mean NO2 concentrations are in excess of the annual mean objective value alongside roads within the vicinity of the proposed development, Halcrow Group Ltd undertook a diffusion tube survey on roads within the vicinity of the application site. The survey is described in Section Halcrow Group air quality monitoring data Halcrow carried out diffusion tube monitoring of NO2 from 18 locations, which included the application site and roads within the vicinity of the proposed development. Sampling was carried out for a period of approximately 10 months, with mean concentrations derived for each monthly period. The monitoring data was used to support and verify the results of the air quality modelling. The diffusion tube monitoring sites used by Halcrow are shown in Figure 6.1, and a short description of the location of each monitoring site is presented in Table Table 6.14: Halcrow Diffusion Tube Monitoring Sites and Bias Adjusted Annualised NO 2 Concentrations (µg m -3 ) Site ID Site Type OS Grid Reference Location Details NO2 (µg/m³) 1 Roadside , Pinner Road Station Road Crossroads 2 Roadside , Southfield Park Junction with Station Road 3 Roadside , Pinner View Parkside Way Crossroads Roadside , Headstone Gardens Roadside , Headstone Drive

102 Site ID Site Type OS Grid Reference Location Details NO2 (µg/m³) 6 Roadside , Headstone Drive/Hailsham Drive Mini-Roundabout 7 Roadside , Cecil Road Junction with Headstone Drive 8 Roadside , Headstone Drive/Princes Drive Mini-Roundabout Background , Kodak Factory Site South Background , Kodak Factory Site North Roadside , Harrow View South of Victor Road 12 Roadside , Harrow View North of Victor Road Roadside , Courtney Avenue Background , Downing Close Background , Zoom Leisure Tennis Court (Triplicate 1) Background , Zoom Leisure Tennis Court (Triplicate 2) 17 Background , Zoom Leisure Tennis Court (Triplicate 3) 18 Background , Zoom Leisure Sports Ground Roadside , Headstone Lane Roadside , George V Avenue- Headstone Lane Crossroads 51.5 Note: Roadside sites are located within 5m of the kerb of a busy road. Background sites are distanced from sources. Exceedances of annual mean objective are highlighted in bold. Diffusion tubes were provided and analysed by Gradko International Ltd and were prepared using the 20% TEA/water preparation method. The diffusion tubes were attached to lampposts at a height of 2 to 3m above the ground. Tubes were labelled, and kept refrigerated in plastic bags prior to and after exposure and the exposure times for each tube were recorded. 98

103 The monthly diffusion tube results are presented in Appendix 6.4. The monitoring was undertaken from June 2010 to May Continuous monitoring data was interrogated. In order to determine how representative the results are of annual mean 2010 values (corresponding with the assessment base year scenario). The nearest Automatic Urban Rural Network (AURN) site to the proposed development is North Kensington. Year 2010 annual average concentrations from the AURN monitor were compared to the average concentration the monitor obtained between June 2010 and May 2011 (corresponding with the Halcrow Group monitoring period). Table 6.15: Annual Mean and Monitoring Period Average Concentrations Site Annual Mean 2010 (µg/m³) Average Concentration June 2010 to May 2011 (µg/m³) Ratio Kensington North Table 6.15 shows that the annual mean 2010 concentrations obtained from the AURN monitor are within 2% of those obtained over the period corresponding with the Halcrow diffusion tube monitoring survey. This analysis suggests that the average concentrations monitored at the diffusion tubes are likely to be representative of annual mean 2010 concentrations. Diffusion tubes were not co-located with a continuous monitoring station during this monitoring survey. Bias adjustment factors were obtained from the UWE Review and Assessment website and applied to the NO2 concentrations obtained (0.92 Bias Adjustment for Gradko 20% TEA in Water 2010). Triplicate tubes were used at the HVW site in order to examine the precision of the monitoring (i.e. the ability of the measurements to be consistently reproduced). The precision reflects both the laboratory s performance in preparing and analysing the tubes, as well as the handling of the tubes in the field. The Coefficient of Variation (CV) provides a measure of precision, and was calculated for the tubes using the AEA_DifPAB_v02 tool prepared for LAQM and available from Defra. The tube precision was found to be good during all months where triplicate results were collected. The annualised bias adjusted diffusion tube results are presented in Table 6.14, which shows that there are currently exceedances of the annual mean NO2 AQS Objective alongside roads (these locations are not however representative of relevant exposure) within the vicinity of the proposed development. The exceedances were measured at roadside sites, with the highest concentrations being measured at junctions as a result of slow moving traffic. The highest concentration was measured at site 20 (51.5µg m - ³) which is located on the junction of Headstone Lane and George V Avenue (A404). Monitoring undertaken on the application site (Sites 9, 10, 14, 15, 18 and 12) recorded concentrations below the AQS objective. Site 11 is located on the boundary of the application site, and the NO2 concentration measured at this location exceeded the annual mean AQS Objective. It should be noted however, that this location is not representative of public exposure since application site receptors will be located further from the carriageway than the diffusion tube. 99

104 6.4.4 Baseline concentrations at receptors The monitoring data outlined above has been used to calibrate/verify the results of the ADMS (Roads) dispersion model. Model results were compared with monitoring data and then adjusted. The model was then used to predict concentrations at the sensitive receptors selected for the assessment. The base year adjusted annual mean NO2, PM10 and PM2.5 concentrations predicted at each of the sensitive receptors shown in Figure 6.2 are presented in Table Table 6.16: Base Year Air Quality Modelled at Existing Receptors (µg/m³) Receptor NO2 (µg/m³) PM10 (µg/m³) No of 24 Hour PM10 Exceedances PM2.5 (µg/m³) Objective R R R R R R R R R R R R R Exceedances of air quality objective values highlighted in bold Annual mean NO2 concentrations at receptors R1, R3, R8 and R12 are predicted to be in excess of the AQS Objective in the base year. These receptors are all located close to junctions and are affected by the highest traffic flows in the study area. There are no predicted exceedances of AQS objectives for PM10 or PM2.5 at receptors. 6.5 Assessment of impacts prior to and during construction The construction phase of the proposed development has the potential to generate dust, which may deposit on property and cars causing soiling and discolouration and can result in complaints through amenity loss or perceived damage. 100

105 It is currently anticipated that the proposed development will be brought forward in five phases over an eight year period, each of which will include the necessary preparatory works and subsequent construction works. Most dust is likely to be generated in the early stages of each phase during demolition and earthwork activities. Dust will also be generated by processes such as the handling and stockpiling of soils and broken/crushed concrete and plant/vehicle movements on unmade surfaces. The total area of the proposed construction site is 25.4 ha (254,000 m 2 ). From Table 6.1, the construction phase can be classed as High Risk in terms of the potential for significant air quality impacts to arise without mitigation. Table 6.17 shows the likely significance of construction impacts at receptors without mitigation. Table 6.17: Impact Significance of Construction, Without Mitigation Receptor Value Magnitude of Impact Significance (without mitigation) Existing Receptors Within AQMA N/A High Risk of Significant Impact Application Site Receptors Within AQMA N/A High Risk of Significant Impact Due to the factors outlined in the construction phase methodology section, it is not possible to predict the impact magnitude or significance of potential dust impacts. Dust impacts would however, be expected to be restricted to within 100m of the application site perimeter due to particle dispersion and deposition effects. Properties most sensitive to dust impacts are located alongside roads that border the application site, specifically, along Cecil Road, Headstone Drive, Harrow View, Victor Road, Pinner Park Avenue and Pinner Park Gardens. The phasing of the development will also mean that some application site receptors are introduced within 100m of dust generating activities associated with subsequent development phases. The construction phase of the proposed development may also affect air quality following emissions from haulage vehicles. Table 6.18 shows the annual total and average daily number of two-way haulage movements expected during each year of construction. Table 6.18: Two Way HGV Movements during Construction Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Year 7 Year 8 Total 10,626 12, AADT According to DMRB (Highways Agency, 2007) and Environmental Protection UK (2010) air quality guidance, an increase in AADT flow of 200 or less for Heavy Goods Vehicles is not expected to be significant in relation to impacts on local air quality. 101

106 Based on this guidance, no significant air quality impacts would be expected to arise from haulage vehicle movements during each year of construction. Air quality impacts from the tracking out and re-suspension of dust will also be reduced through the mitigation measures outlined in Section 6.7. Dust impacts are likely to be temporary and not persist beyond completion of construction. Furthermore, dust impacts will be episodic and only likely to occur when conditions are right for dust emissions to occur (e.g. dry and windy) and dust mitigation measures are not being effective. The combination of these conditions is unlikely to occur regularly throughout the construction period. Adverse air quality impacts during construction are therefore likely to be infrequent and short-term and with the application of dust mitigation to ensure that best practice measures (BPM) are being employed (see Mitigation Measures), any adverse impacts will be minimised. 6.6 Assessment of impacts during operation Road traffic emissions ADMS (Roads) was used to predict the impact of development associated traffic on concentrations of NO2, PM10 and PM2.5 at existing receptors and at receptors introduced on the application site. Modelled road traffic concentrations were adjusted based on the verification process outlined in Appendix 6.3, and were combined with the Defra background concentrations to calculate the total concentration at receptors. The location of the receptors considered in the assessment is shown in Figure 6.2. Nitrogen Dioxide at Existing Receptors Table 6.19 shows the annual mean NO2 concentrations predicted at existing receptors in the opening year (2015) with and without the development. The impact significance, defined according to Table 6.8, is also shown. Table 6.19: Total Predicted Annual Mean NO 2 (µg/m 3 ) and Significance of Change at Existing Receptors Receptor Do Minimum (DM) Do Something (DS) DS - DM Impact Significance AQS Objective R Negligible R Negligible R Negligible R Negligible R Negligible 102

107 Receptor Do Minimum (DM) Do Something (DS) DS - DM Impact Significance R Slight Beneficial R Negligible R Slight Beneficial R Negligible R Negligible R Negligible R Negligible R Negligible Table 6.19 shows that annual mean NO2 concentrations are not predicted to exceed the annual mean objective at any receptor in either the Do-Minimum or Do- Something scenario. All receptors experience a decrease in pollutant concentrations as a result of the proposed development. The reduction in NO2 is attributable to a decrease in traffic relative to the Do-Minimum scenario (which assumed that the proposed application site was operating at the same scale as the operations in 2005, as agreed with the relevant authorities (the Council and Transport for London)). The predicted change in NO2 concentrations is of slight beneficial significance at receptors R6 and R8, and is of negligible significance at all other receptors. Particulate Matter at Existing Receptors Opening year annual mean PM10 and PM2.5 concentrations predicted at existing receptors are respectively shown in Table 6.20 and Table Table 6.20: Modelled Annual Average PM 10 (µg/m 3 ) and Significance of Change at Existing Receptors Receptor Do Minimum (DM) Do Something (DS) DS - DM Impact Significance AQS Objective R Negligible R Negligible R Negligible R Negligible R Negligible 103

108 Receptor Do Minimum (DM) Do Something (DS) DS - DM Impact Significance R Negligible R Negligible R Negligible R Negligible R Negligible R Negligible R Negligible R Negligible Table 6.20 and Table 6.21 shows that annual mean PM10 and PM2.5 concentrations are predicted to be below annual mean AQS objectives at existing receptors in the Do- Minimum and Do-Something scenario. The number of exceedances of the daily objective is also predicted to be well below the AQS objective at all receptors in the opening year. The impact significance, defined according to Table 6.8, is predicted to be negligible for PM10 and PM2.5 at all receptors. Table 6.21: Modelled Annual Average PM 2.5 (µg/m 3 ) and Significance of Change at Existing Receptors Recept or Do Minimum (DM) Do Something (DS) DS - DM Impact Significance AQS Objecti ve R Negligible R Negligible R Negligible R Negligible R Negligible R Negligible R Negligible R Negligible R Negligible 104

109 Recept or Do Minimum (DM) Do Something (DS) DS - DM Impact Significance R Negligible R Negligible R Negligible R Negligible Air Quality at New Receptors The proposed development will introduce residential receptors within Harrow AQMA. Opening year annual mean NO2, PM10 and PM2.5 concentrations have been predicted across the application site. Table 6.22 presents the results of this assessment for receptors NR1 to NR11. Table 6.22: Modelled Pollutant Concentrations at Proposed Application Site Receptors Receptor NO2 (µg/m³) PM10 (µg/m³) PM2.5 (µg/m³) AQS Objective NR NR NR NR NR NR NR NR NR NR NR Table 6.22 illustrates that none of the proposed receptors will be located in locations that exceed AQS Objectives. This is also supported by the baseline monitoring that was undertaken, which showed that the annual mean NO2 objective was only exceeded at kerbside locations. All new receptors experience levels of particulates that are well below the AQS objective, and only a few proposed receptors experience levels of NO2 which are not well below the objective (well below defined as <75% of objective). Based on Table 6.9, the impact significance of exposure to air pollutants is expected to be negligible for application site receptors. 105

110 6.6.2 Energy centre emissions NO2 and PM10 concentrations attributable to the proposed energy centre have been predicted using dispersion modelling and compared against AQS objectives. The maximum incremental increase in pollution and the maximum total pollutant concentrations modelled across the application site (including background component) are presented in Table Table 6.23: Maximum Predicted Concentrations on the Application Site Pollutant AQS Objective Max Incremental Max Total NO2 200 µg.m th Percentile of Hourly Mean 10 µg.m µg.m µg.m -3 Annual Mean 0.8 µg.m µg.m -3 PM10 50 µg.m -3 90th Percentile of 24- Hour Mean 0.9 µg.m µg.m µg.m -3 Annual Mean 0.2 µg.m µg.m -3 Table 6.23 demonstrates that no AQS objective is predicted to be exceeded on the application site as a result of emissions from the proposed energy centre. The increase in pollution at existing receptors is predicted to be well below the incremental values shown in Table 6.22, and is imperceptible, corresponding with negligible significance. The total concentrations presented in Table 6.23 do not include the road traffic local pollutant contribution. Assuming, as a worst-case, that the maximum incremental increase in NO2 and PM10 were to occur at the application site receptor with the greatest road traffic plus background concentration, as shown in Table 6.22 (receptor NR11), the impact would be of negligible significance. The impact of energy centre emissions is therefore expected to negligible at all application site receptors Kodak Factory emissions Under the current proposed phasing of the development (see Section 3.2.3), the Kodak factory could be operational for a short period of time whilst other parts of the application site become occupied. The main pollutants associated with the factory process are SO2, NOx and PM10. Kodak operates under a permit which is enforced by the Environment Agency. Figure 6-1a and Figure 6-2b show the permitted SO2 and NOx emissions and the emissions associated with the factory operations between 1992 and The data has been obtained from Kodak Harrow. The figure shows that emissions from the factory are well below permitted levels and have continued to decline year on year over this time period. 106

111 Harrow Site SO 2 Emissions SO2 Emissions / t Figure 6-1a: Kodak Factory SO 2 Emissions between 1992 and 2008 SO2 Emissions / t/mm 2 Consent Emissions Emissions per unit Harrow Site NO x emissions NOx Emissions / t Figure 6-2b: Kodak Factory NO x Emissions between 1992 and NOx Emissions / t/mm 2 consent actual per unit According to the Environment Agency website, less that 1 tonne of PM10 was emitted during 2009, which is well below levels which would require reporting to the Environment Agency. Because SO2, NOx and PM10 emissions are well below permitted levels, it is unlikely that objectives would be exceeded on the application site. Furthermore, the air quality monitoring for NO2 undertaken on the application site indicated that the concentrations were below the annual mean air quality objective (other than at a roadside location, which does not correspond with relevant exposure). No further consideration of Kodak factory emissions has been undertaken for this assessment, as they are not considered to be significant Summary of operational impacts 107

112 Table 6.24 summarises the impact magnitude and significance of the operational phase without mitigation. The impact magnitude and significance are based on the overall impacts across all receptors, taking into consideration traffic, energy centre and Kodak factory emissions. Table 6.24: Impact Significance of Operation, Without Mitigation Receptor Value Magnitude of Impact Significance (without mitigation) Existing Receptors Within AQMA Small Negligible Application Site Receptors Within AQMA N/A Negligible 6.7 Mitigation measures During construction In order to mitigate against significant air quality effects at receptors, Best Practice Measures (BPM) should be adopted. These measures should include techniques such as those outlined in The control of dust and emissions from construction and demolition (London Councils, 2006) and Control of dust from construction and demolition activities (Building Research Establishment, 2003). The development has been classified as a High Risk site in terms of the potential for the construction phase to impact on receptors. According to London Councils (2006), the following mitigation measures should be implemented at High Risk sites: Site planning erect solid barriers to site boundary; no bonfires; plan site layout machinery and dust-causing activities should be located away from sensitive receptors where possible; ensure all site personnel are fully trained; responsible person to be on site during working times to maintain logbook and carry out site inspections; hard surface site haul routes; and install real time dust monitors. Construction traffic All vehicles to switch off engines no idling vehicles; Wheel washing at the exits from construction areas where there is a potential for dust and mud to be carried on to the highway; 108

113 All loads entering and leaving site to be covered; No site runoff of water or mud; On-road vehicles to comply with set emission standards; All non road mobile machinery to use ultra low sulphur tax exempt diesel where available and to be fitted with appropriate after treatment from the approved list; Minimise movement of construction traffic around site; and Hard surfacing and effective cleaning of haul roads and appropriate speed limit around site. Demolition works Use water as dust suppressant; Cutting equipment to use water as suppressant; Use enclosed chutes and covered skips; and Wrap buildings to be demolished. Site activities Minimise dust-generating activities; Use water as dust suppressant where applicable; Cover, seed or fence stockpiles to prevent wind whipping; Re-vegetate earthworks and exposed areas; and If applicable, ensure concrete crusher or concrete batcher has permit to operate. With the adoption of BPM as specified above, the potential impacts of dust during the construction phase can be significantly reduced During operation The air quality assessment has determined that the proposed development will lead to an improvement in air quality due to a reduction in road traffic (based on the traffic flows generated by Kodak Harrow of the application sites operations in 2005, as agreed with the Council). Therefore, the development does not conflict with the Council Air Quality Action Plan. One of the objectives of the air quality action plan in relation to this type of development is: All medium/large development schemes to be designed to maximise integration of different modes, with pedestrian, cyclist and public transport user priority over the car. The framework travel plan for the proposed development which is described in more detail in the transport assessment (PBA, 2011) is provided to accompany the planning application and has considered: 109

114 Provision of a car club on site; Upgrade of existing bus services adjacent to site; Upgrade of pedestrian/cycle facilities off site; Provision of pedestrian/cycle infrastructure on site; Parking charges; Parking management; and TravelSmart Initiative this is a marketing tool used to encourage people to travel by modes other than car. The framework travel plan will therefore encourage walking, cycling and public transport use. In addition, the mixed use nature of the development will reduce the need to travel with leisure and retail facilities available within a short walk/cycle for local residents and employees at and surrounding the application site. 6.8 Conclusions and statement of residual significance The application site clearance, and construction phase is likely to generate dust which, if unmitigated, has the potential to cause complaints at properties in close proximity to dust generating activities. However, with the adoption of Best Practice Measures complaints should be avoidable and the effects of dust from the construction phase will be temporary. The operational air quality impact of road traffic associated with the development and emissions from the energy centre have been established on the application site and at existing receptors using detailed dispersion modelling. The assessment has determined that the overall operational air quality effects of traffic associated with the development would be of negligible significance at existing receptors and at receptors introduced on the application site as part of the proposed development. The impacts of energy centre emissions are also determined to be of negligible significance. No AQS objective would be exceeded as a result of the proposals. The assessment has also determined that Kodak factory operations undertaken alongside the early development phases would be unlikely to lead to exceedances of air quality objectives on the application site. 110

115 Table 6.25: Significance of residual effects identified during the construction and operation of the proposed development following the implementation of mitigation measures Receptor Summary description of impact Significance of potential effect prior to mitigation Proposed mitigation Residual significance Construction Existing Receptors Emissions of construction dust. Emissions from haulage vehicles. High risk of significant dust impacts. Haulage vehicle emissions of negligible significance. Adoption of Best Practicable Means (BPM) including water suppression and erection of hoardings around site boundary. Medium/low risk of significant dust impacts Application Site Receptors Emissions of construction dust. Emissions from haulage vehicles. High risk of significant dust impacts. Haulage vehicle emissions of negligible significance. Adoption of Best Practicable Means (BPM) including water suppression and erection of hoardings around site boundary. Medium/low risk of significant dust impacts Operation Existing Receptors Emissions from traffic associated with the operation of proposals Overall Negligible Travel Plan to reduce development traffic Overall Negligible Emissions from energy centre on application site Application Site Receptors Emissions from traffic Emissions from energy centre on application site Emissions from Kodak Factory Overall Negligible None Overall Negligible 111

116 7 Noise and vibration 7.1 Introduction There is a potential for noise impacts to arise from activities during both the construction and operational phases of the proposed development. In general terms, the potential construction noise impacts are temporary while any operational impacts are considered to be permanent. It is to be expected on a project of this type and scale that the construction phase will involve a wide range of activities and potential temporary noise impacts. However, the principal noise impacts are considered likely to arise from demolition of existing structures, earthwork activities, installation of site infrastructure, roads and services and construction of new buildings. During the operational phase of the development, changes in road traffic noise levels have the potential to be the principal noise impact on the existing noise environment both within and outside the application site. 7.2 Methodology As the application site will be redeveloped in phases, consideration has been given as to whether the demolition and construction activities of the later phases may impact on occupied new dwellings in the earlier phases. The planned phasing programme is as follows (Figure 3.8): Phase 1a: March 2013 March 2015 new development construction, with first occupancy assumed in March 2014; Phase 1b: March 2013 March 2015 new development construction, with first occupancy assumed in March 2014; Phase 1c: March 2015 September 2016 new development construction, with first occupancy assumed in March 2016; Phase 2: March 2013 March 2015 clearance and remediation; March 2015 March 2017 new development construction. First occupancy assumed in March 2016; and Phase 3: March 2015 March 2017 clearance and remediation; March 2017 March 2020 new development construction. First occupancy assumed in March Based on this programme, operational activities at Harrow View East will have finished before any new dwellings are occupied, therefore there would not be any operational impacts of the existing Kodak factory operations on any new dwellings. However, there will be noise impacts from on-going construction phases on new residential receptors in all Phases. 112

117 7.2.1 Scope of assessment The scoping assessment consisted of a desk based review of the application site and surrounding land uses. The review considered that the application site is predominantly affected by a mix of road, rail and industrial noise (Halcrow, 2011a). The scoping stage identified the following key tasks to be undertaken as part of the assessment of noise and vibration impacts at the EIA stage: Consultation with the Environmental Health Department (EHD) at the Council to agree the scope and nature of the baseline noise and vibration surveys completed in 2010 and the proposed assessment methodologies to be employed are acceptable for the EIA; Identification of the noise-sensitive existing and future receptors within the application site and the surrounding area; Assessment of predicted noise levels at existing and future sensitive receptors during the construction phase(s) of the proposed development; Assessment of predicted noise levels at existing potentially sensitive local existing receptors, which have the potential to be affected by changes in road traffic noise levels following the proposed development; Assessment of measured and predicted noise and vibration levels on future users of the application site; Assessment of the proposed energy centre and any future plant and services to be located on or within proposed new buildings; Determination of the significance of the noise impacts associated with the construction and operational phases of the proposed development; Provision of proposals for mitigation measures, where appropriate, in order to minimise any potential negative impacts arising from and on the development; and Prediction of residual impacts, which may remain following implementation of mitigation measures. The scoping opinion received from the Council in July 2011 confirmed that the baseline noise and vibration surveys completed in 2010 and provided as part of the EIA Scoping Report and the proposed assessment methodology were acceptable (see Appendix 4.1 and Appendix 4.2 for details) Assessment methodology a) Baseline monitoring A baseline noise and vibration survey was undertaken in early The results are summarised in Section 7.4 and the full survey report is provided in Appendix 7.2. The noise and vibration survey locations monitored are reproduced in Figure 7.1. The 113

118 main existing sources of noise identified included the railway line on the eastern boundary, road traffic and noise from existing operations at Harrow View East. Noise and vibration surveys were undertaken over a typical mid-week period during both day and night time hours at several locations within and around the application site. Long term noise measurements over 24-hour periods were undertaken at seven locations, and vibration at one location. Several short term noise measurements of particular noise sources associated with the existing factory operations were also undertaken on an ad-hoc basis, and vibration measurement from the railway line. The relevant longer-term noise measurement results and vibration measurement results are reported below, and all of the measurement locations are indicated in Figure 7.1. b) Assessment of construction-related impacts The assessment of construction-related impacts follows the guidance provided by British Standard 5228 (BS5228) Noise and Vibration Control on Construction and Open Sites (2009). This is the British Standard methodology for the prediction of construction noise and vibration, and provides guidance on methods of predicting and measuring noise and assessing its impact on those exposed to it. BS5228 provides suitable methods for the calculation of noise from construction activities, including basic information regarding noise levels from a range of construction equipment. Guidance is also provided for the identification of the significance of noise levels from surface construction activity. Significance can be considered in relation to fixed limits, or alternatively in considering the potential change in the ambient noise level as a result of the construction noise. For this assessment, construction noise has been considered quantitatively to establish the likely occurrence of potentially significant noise levels. The magnitude of construction noise impacts is calculated following the procedures in BS5228. An absolute noise level from the various construction activities is calculated, and the level of construction noise is considered against a site-specific significance criteria that is derived as explained below. A significance criterion is developed from noise measurements of existing ambient noise levels taken at the nearest noise sensitive receptors to the application site. BS5228 considers sensitive receptors to include: residential housing; hotels and hostels; buildings in religious use; buildings in educational use and buildings in health and/or community use. The measured ambient noise level is rounded to the nearest 5dB(A), and considered against the Threshold values in Table 7-1, reproduced from BS5228. Depending on the measurements of existing noise levels, the sensitive receptor(s) would be allocated into Category A, B or C, and the subsequent threshold value applies. The predictions of total noise from construction, including the ambient noise level, are compared to the threshold value(s). If the total noise level exceeds the appropriate category threshold value, then a significant effect is deemed to occur and further consideration of noise mitigation or control should be made. Table 7.1: Threshold of Significant Effect from Construction Works at Dwellings 114

119 Assessment category and threshold value period (LAeq) Threshold value, in decibels (db) Category AA) Category BB) Category CC) Night-time ( ) Evenings and weekends Daytime ( ) and Saturdays ( ) A) Category A: Threshold values to use when ambient noise levels rounded to the nearest 5 db are less than these values. B) Category B: Threshold values to use when ambient noise levels rounded to the nearest 5 db are the same as category A values. C) Category C: Threshold values to use when ambient noise levels rounded to the nearest 5 db are higher than category A values. c) Assessment of operational impacts The key operational noise impacts identified with respect to the operation of the application site are: Potential increase in road traffic noise at existing sensitive receptors located outside the application site due to changes in traffic flows following the completion of the development; Potential impacts from existing and possibly increased road traffic noise on future occupiers of the application site that may be sensitive to noise that include: residential dwellings (that include a residential care home and senior living accommodation), student housing, a school, a health centre and employment uses; Potential impacts from existing railway noise and vibration on future occupiers of the application site; and Potential impacts on future residents due to noise from existing activities within the Waverley Industrial Estate at Hailsham Drive to the south east of the application site. Potential impacts on existing and future sensitive receptors from the proposed energy centre and any fixed building services from within the proposed development. The key guidance documents referenced in the assessment methodology for operational noise impacts are listed below, and outlined in more detail in Appendix A4. Design Manual for Roads and Bridges, Volume 11, Section 3, Part 7 (DMRB), Noise and Vibration, 2008; 115

120 Calculation of Road Traffic Noise (CRTN), 1988; Planning Policy Guidance note 24 (PPG24), Planning and Noise, 1994; British Standard 8233 (BS8233): Sound Insulation and Noise Reduction for Buildings Code of Practice, 1999; World Health Organisation (WHO): Guidelines for Community Noise, 1999; Building Bulletin 93 (BB93): Acoustic Design of Schools ; Health Technical Memorandum (HTM 08-01): Acoustics, 2008; British Standard 6472 (BS6472): Guide to evaluation of human exposure to vibration in buildings (1Hz to 80Hz), 2008; British Standard 4142 (BS4142): Rating industrial noise affecting mixed residential and industrial areas,1997; and Noise Impact Assessment Guidelines, Institute of Acoustics and Institute of Environmental Management and Assessment, 2006 Draft Update. Assessment of road traffic noise The calculations of predicted road traffic noise resulting from the proposed development are based on the assessment of predicted traffic flows undertaken as part of the Transport Assessment prepared separately in support of the outline planning application by Peter Brett Associates (PBA), and summarised in Chapter 5 of this ES. Data has been provided for the scheme opening year and the year of completion of each phase. The traffic data used for the noise assessment is presented in Tables 7-2 and 7-3 below. The Without Scheme traffic data is in Table 7-2 for a scenario where the proposed development does not go forward and assumes traffic from the existing factory and office uses. The With Scheme traffic data assumes the closure of the existing factory and offices, and the Harrow View proposed development is occupied as planned. The Pinner House development is also assumed to be completed and operational in the With Scheme traffic data. Traffic flows are provided by Phase, and for the year of each phase completion. The Road Links are indicated in Figure 6.3 provided as part of the transportation assessment. In the absence of measured or modelled traffic speeds, the road speed limit is used for all roads. A speed limit of less than 50mph applies to all roads, therefore following CRTN guidance a speed of 50kph is used in the noise calculations. 116

121 Table 7.2: Without Scheme Traffic Data Road Link hr AAWT %HGV 18hr AAWT %HGV 18hr AAWT %HGV 18hr AAWT %HGV A Courtenay Ave (north (N) of Long Elmes) B Long Elmes (east (E) of Courtenay Ave) C Courtenay Ave (south (S) of Long Elmes) D Long Elmes (west (W) of Courtenay Ave) E Harrow View (N of Headstone Drive) F Headstone Drive (between Harrow View and Rokeby Rd) G Harrow View (S of Headstone Drive) H Headstone Drive (W of Harrow View) I Headstone Drive (E of Rokeby Rd) J Hailsham Drive K Headstone Drive (between Hailsham Drive and Cecil Rd) L Princes Drive

122 M Headstone Drive (W of Hailsham Drive) N Cecil Road O Canning Road P Ellen Webb Dive (S of Canning Rd) Q High Street R Masons Avenue S The Bridge T Ellen Webb Drive (N of The Bridge) U Station Road V A404 Pinner Road (E of Station Rd) W Imperial Drive X A404 Pinner Road (W of Station Rd) Y Headstone Road Z Greenhill Way A A A B Headstone Road A404 Pinner Road (W of Headstone Rd)

123 Table 7.3: With Scheme Traffic Data by Phase Link 2015 Phase 1A 2015 Phase 1B 2016 Phase 1C 2017 Phase Phase 3 18hr AA WT %H GV 18hr AA WT %H GV 18hr AA WT %H GV 18hr AA WT %H GV 18hr AA WT %H GV A B C D E F G H I J K L M N O P Q R S T U V W X

124 2015 Phase 1A 2015 Phase 1B 2016 Phase 1C 2017 Phase Phase 3 Y Z AA AB In England and Wales, the standard method for predicting traffic noise levels is given in the Calculation of Road Traffic Noise (CRTN) The index used to characterise traffic noise in CRTN is the LA10, 18-hour. This is the average of the 18-hourly A-weighted sound pressure level exceeded for 10% of the time over the period 0600 to 2400 hours on a normal weekday. The DMRB Volume 11, Section 3, Part 7, HD 213/11, Noise and Vibration, 2011 provides guidance on the assessment of noise and vibration effects from all road projects. This includes guidance on what a significant impact is in terms of road traffic noise. A change of 1dB LA10,18-hour is the minimum change that can be detected by the human ear in the short term. (e.g. between Without Scheme and With Scheme on the opening of the development). Where there are not expected to be significant changes in the traffic speeds or composition of the traffic flow, a change in 18-hour AAWT of 25% or more increase, or a 20% decrease or more is approximately equivalent to a change of 1dB(A). The assessment applies the scale of impact magnitude provided by the DMRB for the consideration of any change in road traffic noise between the Without Scheme and With Scheme scenarios. The scale of impact magnitude differs, depending on whether a comparison is being undertaken in the short or long term. The short-term is usually considered to be the same year, and the long-term comparison is usually considered to be over a 15-year period. The table is reproduced here, in Table 7.4. Table 7.4: Scale of Magnitude of Noise Impact from Road Magnitude of Impact Short-Term (same year) Noise Level Change db(a) Long-Term (future year) Noise Level Change db(a) No Change 0 0 Negligible 0.1 to to 2.9 Minor 1 to to 4.9 Moderate Impact 3 to to 9.9 Major impact 5 or more 10 or more 120

125 Assessment of existing road traffic and railway noise on future receptors In assessing the suitability of the application site for proposed new residential development, reference will be made to guidance provided by Planning Policy Guidance Note 24 (PPG24) Planning and Noise (1994). In assessing the magnitude of impact for the proposed new sensitive receptors on the application site, suitable design goals have been set for both outside amenity spaces and internal spaces from external noise sources. It should be noted that the detailed acoustic design of each of the proposed building types/uses is outside of the scope of the application and the EIA, and the assessment presented is broadly based on acoustic principles. For residential receptors an assessment is undertaken in accordance with PPG24. In cognisance of the guidance provided within both BS 8233 Sound Insulation and Noise Reduction for Buildings Code of Practice (1999) and the World Health Organisation (WHO) 'Guidelines for Community Noise (1999), the following design goals are proposed: - Internal noise in rooms does not exceed 30dB LAeq between the hours of 2300 and 0700 hours, and individual noise events should not normally exceed 45dB LAmax,f; and - Internal noise in rooms does not exceed 35dB LAeq between the hours of 0700 and 2300 hours. For external amenity spaces, including gardens, balconies and terraces, the WHO guidelines is considered and the following design goal is proposed: - The sound pressure level in outdoor living areas should not exceed 55 db LAeq,T. It can be difficult to achieve WHO guidelines for external spaces within London, and where it is not possible to achieve this level, then the assessment must demonstrate that reasonable measures have been taken to reduce external noise levels as far as possible. This approach corresponds with the findings of National Physical Laboratory report CMAM 16, which states that these levels can be unachievable in London, given the transportation infrastructure that is in place. In considering the proposed new school in Phase 2, the guidance within BS8233, WHO and Building Bulletin (BB93) Acoustic Design of Schools were considered and the following design goals are proposed: - Internal noise in classrooms and teaching areas should not exceed 35dB LAeq,30min during school hours; and - External noise at the boundary of the school playground and sports fields should not exceed 55dB LAeq,30min; Appropriate design goals for the health centre is taken from Health Technical Memorandum (HTM 08-01) Acoustics, are proposed as follows: 121

126 - Noise in consulting rooms should not exceed 40dB LAeq,1-hour; and - Noise in waiting areas should not exceed 50dB LAeq,1-hour; The design goals for the proposed offices are taken from BS8233, and proposed as follows: - Internal noise in cellular offices should range between 40-50dB LAeq,T; - Internal noise for executive office or meeting room should range between 35-40dB LAeq,T; and - Internal noise for open plan offices should range between 45-50dB LAeq,T. Assessment of existing railway vibration The noise and vibration measurement survey report (Appendix 7.2) included measurement, and subsequent interpretation of vibration adjacent to the railway. Given the low magnitude of vibration measured, the report concluded that there would be a low probability of adverse comment from vibration from the railway. This is therefore not considered further. Assessment of industrial and plant noise The assessment of noise impacts within the existing Waverley Industrial Estate, the energy centre and any proposed fixed building services and plant items has been carried out with reference to British Standard 4142 (BS4142) Rating industrial noise affecting mixed residential and industrial areas. As noted in Section A in Appendix 4.4 the likelihood of complaint from noise of an industrial nature is assessed by comparing the specific noise level (or if the noise contains an identifiable acoustic feature, the rating noise level) with the measured background noise level. The likelihood of noise provoking complaints is assessed by subtracting the background noise level from the rating noise level. BS4142 states: "A difference of around 10dB or higher indicates that complaints are likely. A difference of around 5dB is of marginal significance. A difference of minus 10dB is a positive indication that complaints are unlikely." Assessing Significance The significance of all identified noise impacts (as outlined above) is established based on Guidelines for Noise Impact Assessment produced by the Institute of Acoustics/ Institute of Environmental Management and Assessment Joint Working Party. The first draft was published in 2002, and subsequently updated in A ratified version of the 2006 draft was due for publication at the end of 2008, and is expected in the near future. The 2006 draft of the Guidelines recommends establishing impact magnitude and significance based on reasoned judgement considering both objective and subjective factors. The scale presented in Table 7.5 is provided within the 2006 draft guidance as 122

127 an example, and is expected to be provided within the forthcoming Guidelines to describe the range of noise impacts on people. This scale has been used for this assessment to determine the magnitude of significance for all aspects of the proposed development. In order for the semantic descriptors to align with the assessment of impact significance provided in Section 4.4.2, alternative descriptors have been added in brackets. Table 7.5: Generic Scale of Noise Impact on People Perception Impact Semantic Descriptor Significance Not noticeable None No Impact Not Significant Noticeable Non intrusive Noise can be heard, but does not cause any change in behaviour, e.g. turning up volume of television; speaking louder; closing windows. Can slightly affect the character of the area but not such that there is a perceived change in the quality of life Slight (Negligible/Minor) Not significant Noticeable Intrusive (see note) Noise can be heard and causes small changes in behaviour, e.g. turning up volume of television; speaking louder; closing windows. Potential for non awakening sleep disturbance. Affects the character of the area such that there is a perceived change in the quality of life Moderate (Minor/Moderate) Significant Noticeable Disruptive (see note) Causes a material change in behaviour, e.g. avoiding certain activities during periods of intrusion. Potential for sleep disturbance resulting in difficulty in getting to sleep, premature awakening and difficulty in getting back to sleep. Quality of life diminished due to change in character of the area Substantial (Moderate/Major) Significant 123

128 Perception Impact Semantic Descriptor Significance Noticeable Physically Harmful Significant changes in behaviour and inability to mitigate effect of noise leading to psychological effects, e.g. regular sleep deprivation/awakening; loss of appetite, significant, medically definable harm, e.g. noise induced hearing loss Severe (Major) Significant Note: There may be a case of defining an intrusive or even a disruptive impact as being not significant if the noise only occurs on a very small number of occasions per year. In considering construction-related effects, where the total noise level is predicted to be above the threshold value set out in Table 7-1, a significant impact is deemed to have occurred and the magnitude of significance is applied using professional judgement based on the description in the Impact column provided in Table 7-5. In considering the various operational effects, professional judgement is used to determine significance based on the magnitude of the change (where applicable), whether a design goal is achieved (where applicable) and the guidelines in Table Consultation The scoping opinion received from the Council in July 2011 with respect to noise and vibration, and the baseline survey report, confirmed that the proposed approach was acceptable 7.3 Legislation and policy A detailed analysis of relevant guidance and policy is provided in Appendix 4.4. Key plans and policies include: Greater London Authority, The London Plan 2011 Spatial Development Strategy for Greater London, July 2011; Greater London Authority, Sounder City - The Mayor s Ambient Noise Strategy (2004); The saved policies within the adopted Harrow Unitary Development Plan (UDP) (July 2004); Harrow Draft Sustainable Building Design Supplementary Planning Document (SPD); and Planning Policy Guidance Note 24 (PPG24), Planning and Noise (1994). The London Plan is a spatial Development Strategy for London. In terms of noise it promotes a range of actions to achieve the wider environmental sustainability of 124

129 London that include the reduction of noise pollution. The transport, spatial and design policies set out in the plan will be implemented in order to reduce noise and support the objectives of the Mayor s Ambient Noise Strategy. Policy 7.15 is concerned with reducing noise and enhancing soundscapes. In terms of planning, development proposals should seek to reduce noise by minimising existing and potential adverse noise impacts, separate new noise sensitive development from major noise sources, wherever practicable, and promote new technologies and improved practices to reduce noise at source. The Mayor s Ambient Noise Strategy Sounder City focuses on reducing noise through better management of transport systems, better town planning and better design of buildings. This means minimising noise on roads and railways, being more aware of where noisy activities are sited and protecting housing, schools, waterways and open spaces. Policies 69 and 70 of the Strategy specifically relate to new development, and require a noise assessment to be carried out for sites where noise levels are above a certain level as specified in PPG24. Such assessment must also demonstrate that potential noise issues are addressed to ensure a satisfactory standard of noise in and around the development. Additionally, the strategy stipulates that any adverse noise impacts from proposed development must be minimised both within, and in the vicinity of, the development. The key policy within the Harrow UDP with regards to noise is EP25. Policy EP25 relates to noise and sets out ways to minimise noise and vibration disturbance. The Council will take into account noise and vibration levels likely to result from or affect a proposal and will require noise, vibration and disturbance to be minimised. This can be achieved through: design, layout and orientation of buildings; planting and landscaping; use of noise screens; insulation; enclosing or screening plant and equipment; controlling times of operation; vibration suppression; and other appropriate measures. Policy EP25 further states that development proposals that would lead to unacceptable levels of noise, vibration or disturbance will be refused. The focus of the Harrow Draft SPD Sustainable Building Design is to ensure that the Council will encourage developments that are more sustainable. With respect to noise the sustainability outcomes sought are to reduce unacceptable noise so that noise- 125

130 sensitive land uses or developments are not impacted by noise or vibration generating developments or land uses. With respect to new developments, proposals should suit the existing location and take into account potential impacts on existing noise-sensitive receptors that include residential dwellings, hotels, day care centres and health facilities, schools, libraries and places of worship and also natural habitats where biodiversity can also be sensitive to noise. Noise generating activities should be identified, and mitigation should be considered and incorporated early in the design process. Recommendations are made for early considerations in design in respect of noise that include; internal layout of building(s) to reduce the occupant s exposure to noise nuisance; design of building services to mitigate potential noise nuisance; existing external sources of noise; and the impact that proposed developments may have on neighbouring noise-sensitive receptors. With regards to noise from construction activities, the SPD notes that noise is unavoidable, but that the contractor has a responsibility to ensure that inconvenience and disruption to neighbours is kept to a minimum where possible. PPG24 sets out the Government s policies on noise-related planning issues in England. The document gives guidance to local authorities in England on the use of their planning powers to minimise the adverse impact of noise without placing unreasonable restrictions on development. 7.4 Baseline conditions Measured baseline noise and vibration levels a) Long-term noise measurements Table 7.6 presents a summary of the longer term daytime and night-time survey results from the baseline noise and vibration measurement survey undertaken in February and April Daytime noise levels at 24-hour locations are presented as 16-hour ( hours) measurements, whilst night-time data are presented as 8- hour ( hours) values at each relevant location. Table 7.6: Summary of Long Term Measured Noise Levels, Free-field Location Date Time Period Measured Noise Level db LAeq, T LA90,T LA10,T LAmax LT1 11/02/10 to 12/02/ & LT2 10/02/10 to 11/02/ &

131 Location Date Time Period Measured Noise Level db LAeq, T LA90,T LA10,T LAmax LT3 10/02/10 to 11/02/ & LT4 08/02/10 to 09/02/ & /02/10 to 10/02/ & LT5 08/02/10 to 09/02/ & /02/10 to 10/02/ & LT6 11/02/10 to 12/20/ & LT7 11/02/ At LT1 (adjacent to the railway line) the main nearby noise source is the railway line. The average measured LAeq,T for the day and night time periods were 74dB and 73dB respectively. At measurement locations LT2 (Harrow View) and LT4 (Headstone Drive) road traffic was the main noise source, from Harrow View and Headstone Drive respectively. Measured levels of road traffic noise in the daytime period at LT2 and LT4 were 66dB LAeq at both locations, and 59dB LAeq during the night time period at both locations. At location LT4 monitoring was undertaken for 48-hours, and the measurement results were consistent between the two 24-hour periods. At measurement location LT3 (Hailsham Drive), noise from road traffic was noted in the distance, but the main noise sources were noted to be the air conditioning units associated with buildings on Hailsham Drive. The average measured LAeq,T for the day and night time periods were 56dB and 51dB respectively. 127

132 At measurement location LT5 (Central Area) no particular noise sources were noted, just general noise from activities within Harrow View East. Noise measurements were undertaken at this location across 48-hours, and the measurement results are consistent between the two 24-hr periods. The average measured LAeq,T for the day and night time periods were 60dB and 59dB respectively. It is considered that the measured noise levels during the day and night time periods are similar due to the 24-hour working of the Kodak Factory. At measurement locations LT6 and LT7 (both Harrow View West) no particular noise sources were noted, other than road traffic and rail noise in the distance. The daytime noise measurements were consistent at both locations at 51-52dB LAeq,T. The nighttime measurement at location LT6 was 45dB LAeq,T. b) Vibration survey The vibration survey recorded continuous vibration dose values (VDVs) over a 24 hour period from 22 April 2010 at a measurement location adjacent to the railway line (Figure 7.1). Readings were used to calculate 16-hour day time and 8-hour night time vibration levels for comparison with criteria in British Standard 6472 (BS6472) Guide to evaluation of human exposure to vibration in buildings (1Hz to 80Hz) (2008). The results of the vibration survey undertaken in April 2010 are summarised in Table 7.7. Table 7.7: Summary of Vibration Monitoring Data Period Measured Vibration Dove Values ms-1.75 Longitudinal Axis (x) Transverse Axis (y) Vertical Axis (z) Daytime Nighttime Measured levels of vibration from the railway line are well below the BS6472 standards presented in Table A-5 in Appendix A for adverse comment in residential buildings. Therefore, there would be a low probability of adverse comment due to vibration from the railway for residential buildings. The effects of vibration from the railway line on development adjacent to the railway line is therefore not considered further. 7.5 Assessment of impacts during construction As noted in the introduction to this Chapter, the construction phases are planned to start in March 2013, and to continue over five phases for a total period of seven years to March There will be continuous construction activity in various areas of the application site over this period. The detailed construction methods are not known at this time, and therefore, the assessment presented is based on typical construction phases and activities. In order 128

133 to provide an indication of the potential impacts of this phase, key construction activities which may arise as a result of the proposed development have been identified as follows: Demolition and Clearance; Site preparation and Remediation; New Construction: - Piling - Concreting - Lifting. Construction activities associated with developments of this type and scale have the potential to result in significant noise impacts depending on the proximity of existing sensitive receptors to the works, the need for significant earth moving and use of heavy plant and machinery and the prevailing noise climate at the receiver. The greatest noise-related impacts are likely to occur during any initial demolition, breaking out and earthworks stages when the application site is being cleared and the ground prepared/excavated. Once this is complete, it is considered that the construction activities associated with the construction of new building envelopes should give rise to lower noise emissions. There will also be a temporary increase in the number of HGVs on the local road network accessing the application site during the construction phase(s). Information is provided in Table 3.2 in Section of the ES as to the number of HGV movements expected to access the application site throughout the construction period. The number will vary, depending on the phase(s) under construction, from 118 up to way HGV movements per week. The HGVs will access the application site using points on Headstone Drive and Harrow View, although the exact haul routes are not defined Construction activities The assessment of construction activities is based on potential noise levels from a selection of typical construction plant that may be used, and the calculation of noise levels back to different distances, which may reflect noise levels at local receptors. Table 7.8 presents details of typical plant and equipment which could reasonably be used during the development programme, and the corresponding noise levels taken from tables within BS5228. It should be noted that the plant noise levels presented are indicative and the actual plant selected for use may be quieter or noisier in its operation. It should also be noted that this list considers the main items of plant and is not exhaustive. 129

134 Table 7.8: Construction Plant Noise Levels Activity Plant Sound Power Level (db LWA) Sound pressure level (db LAeq) 10m 20m 50m 100m 250m Demolition & Clearance Breaking up Concrete Breaking up Brick Foundations Loading Dump Truck Dumping Rubble Breaking and spreading Rubble Breaker Mounted on Wheeled Backhoe Breaker Mounted on Excavator Tracked Excavator Articulated Dump Truck Tracked Excavator Crushing Concrete/ Rubble Tracked Crusher Site Preparation & Remediation Clearing Site Dozer (20T) Ground Excavation/ Earthworks Tracked Excavator (40T) Loading Lorries Wheeled Loader Distribution of Material Dump Truck (Tipping Fill) Rolling and Compaction Vibratory Roller Piling Pre-cast Concrete Piling Hydraulic Hammer Rig Concreting 130

135 Sound pressure level (db LAeq) Mixing Concrete Concrete Mixer Truck Pumping Concrete Concrete Mixer Truck Poker Poker Vibrator Lifting Large Crane Wheeled Mobile Telescopic Crane (400t) Small Crane Mobile Telescopic Crane (50t) The predictions have been undertaken at set distances from the boundary of each phase of construction works (see Figure 7.2), which have been selected to represent the following closest sensitive receptors to the application site: During Phase 1a there are existing residential receptors located approximately 22m to the south, across Headstone Drive. In Phase 1b, there are existing residential receptors located within approximately 35m to the north on Pinner Park Avenue, and within 5-10m of the southern site boundary on Downing Close, Sidney Road, Edward Road and Fairfield Drive. In Phase 1c, there are existing residential receptors located approximately 22m to the south across Headstone Drive and approximately 80m to the west across Harrow View. There may also be some new residential receptors within the areas of Phases 1a and 1b, based on first occupancy beginning in these phases in March The new residential receptors in Phases 1a and 1b may be located within approximately 20m and 180m respectively of construction works in Phase 3. During Phase 2, there are existing residential receptors located within approximately 5m and 35m of the northern site boundary on Harrow View and Pinner Park Gardens respectively. There may also be some new residential receptors within the areas of Phases 1a, 1b and 1c, based on first occupancy in these phases in March 2014 and March The new residential receptors in the areas of Phases 1a, 1b and 1c may be located within approximately 160m, 50m and 20m respectively of construction works occurring in Phase 2. During Phase 3, there are existing residential receptors located approximately 175m to the north, 60m across Headstone Drive to the south and approximately 45m across Harrow View to the west. There may also be some new residential receptors within the areas of the earlier Phases 1a to 2, based on first occupancy 131

136 in March 2014 for Phases 1a and 1b and March 2016 for Phases 1c and 2. The new residential receptors in Phases 1a, 1c and 2 may be located within approximately 20m of construction works occurring in Phase 3. Receptors in Phase 1b may be within approximately 80m. The area of Phases 1, 1c, 2 and 3 (Harrow View East) is approximately 530m from north to south and 370m across. Phase 1b (Harrow View West) is more uniformly 300m from north to south and 260m across. For some receptors intervening obstructions, such as existing and new buildings, are likely to provide a degree of noise screening. Where there is screening from construction activities at a given receptor the simplified approach for attenuation as detailed within BS5228 has been used. If there is a barrier or topographical feature between a source and receiver an approximate attenuation of 5dB can be assumed when the top of the plant is just visible at the receiver, and an attenuation of 10dB can be adopted when the source is completely hidden. For the purposes of this assessment a conservative 5dB barrier attenuation for topography and intervening buildings has been assumed for all receptors. The noise levels calculated at a range of distances from each individual item of plant have been based upon hard reflective ground between source and receiver. During the various construction phases, it will usually be the case that more than one type of plant item will be operating at the same time. In order to provide an indication of combined noise levels during each of the stages of construction summarised in Table 7-8 the noise emission from each of the items of plant listed against each activity in Table 7-8 have been combined. The combined noise levels at the same reference distances from the application site boundary are presented in Table 7.9. Table 7.9: Combined Potential Noise Levels of Typical Construction Activities (db) Activity Sound pressure level (db LAeq) 10m 20m 50m 100m 250m Demolition & Clearance Site Preparation & Remeditioan Piling Concreting Lifting The measurements of existing ambient noise levels are used to determine the threshold value for significant impacts from construction noise. The baseline noise 132

137 measurements and resultant threshold categories and threshold values for locations on the application site boundaries are presented in Table Table 7.10: Construction Phase Impact Significance Threshold Values (from BS5228) Measurement Location Measured LAeq,T db Category Threshold Value (Daytime) LT2 (East of Phase 2, west and north of Phases 3, 4 and 5) LT4 (South of Phases 1, 3, 4 and 5) 66 B B 70 LT5 (Central site area) 60 A 65 LT6 (North and South of Phase 2) 52 A 65 The total noise level is the combined predicted noise from construction activities (Table 7.9) and the measured ambient noise level (Table 7.10). A comparison of the total noise level against the category threshold value shown in Table 7-10 from the baseline noise measurements is presented in Table

138 Table 7.11 Where the total noise level is less than the threshold category value then the impact is not significant. Where the total noise level exceeds the threshold category value, then a significant impact is deemed to have occurred. Where a significant impact occurs, the impact significance is assigned taking account of the criteria in Table 7.5, together with professional judgement. This does not consider any additional mitigation measures that may be put in place during the phases of construction. 134

139 Table 7.11: Construction Phase Impact Significance Construction Phase Receptor Position Ambient Noise Level LAeq db Total Noise Level LAeq db BS5228 Threshold Value (Daytime) Predicted Impact Significance Demolition & Clearance Site Preparation & Remediation Piling Concreting Lifting LT LT LT LT LT LT LT LT LT LT LT LT LT LT LT LT LT LT LT LT Moderate Adverse Moderate Adverse Moderate Adverse Moderate Adverse Moderate Adverse When construction activities are occurring at the closest locations (i.e. the application site boundaries) to each group of receptors, be they existing or proposed future dwellings, then the BS5228 daytime threshold values are predicted to be exceeded. The impacts of the construction of the various phases on existing and proposed new noise sensitive receptors are as follows: During Phase 1a, the closest noise sensitive receptors are approximately 22m across Headstone Drive from the application site boundary. When the various 135

140 construction activities are occurring at the southern site boundary, noise levels will be above the BS5228 threshold value at receptors across Headstone Drive; During Phase 1b, the closest noise sensitive receptors are within approximately 5-10m of the southern site boundary, and 35m of the northern site boundary. When the various construction activities are occurring at the northern and southern site boundaries, noise levels will be above the BS5228 threshold value at the closest residential dwellings; In Phase 1c, the closest noise sensitive receptors are within approximately 22m of the southern site boundary, and 80m to the west of the phase boundary. When the various construction activities are occurring at the southern site boundary, noise levels will be above the BS5228 threshold value at receptors across Headstone Drive; During Phase 2, the closest noise sensitive receptors are approximately 5-35m from the north boundary. When the various construction activities are occurring at the northern site boundary, noise levels will be above the BS5228 threshold value at the closest residential dwellings; and In Phase 3, the closest noise sensitive receptors are approximately 45m to the west across Harrow View. When the various construction activities are occurring at the western site boundary, noise levels will be above the BS5228 threshold value at receptors across Harrow View. In all phases, when the various construction activities are occurring within the application site phased areas, and located more than 50m from either existing or new noise sensitive receptors (with the exception of demolition and piling), the threshold values will be met. In the case of demolition and piling, the threshold values are met when these activities occur in excess of 100m and 60m respectively from existing or new sensitive receptors Construction Traffic There will be a temporary increase in the numbers of HGVs using the surrounding road network to access the application site during the construction phases. Haul routes are not yet defined, but the main access points for construction traffic will be on Harrow View and Headstone Drive. There are expected to be from 118 up to way HGV movements per week during the construction phases. Assuming that the number of HGV movements per week is evenly distributed across five week days there may be up to 54 HGV 2-way movements per day using Harrow View or Headstone Drive. The baseline traffic data for the first year of construction on these routes is reproduced in Table An indication of the overall change in vehicle movements and number of HGVs on these routes is also included, assuming the maximum of 54 2-way HGV movements per day on all sections of Harrow View and Headstone Drive. 136

141 Table 7.12: Without Scheme Traffic Data Road Link 2015 Without Scheme Add 2015 During construction HGVs 18hr No. %H 18hr No. % AAWT HGV GV AA HGV HGV WT E Harrow View (N of Headstone Drive) F Headstone Drive (between Harrow View and Rokeby Rd) G Harrow View (S of Headstone Drive) H Headstone Drive (W of Harrow View) I Headstone Drive (E of Rokeby Rd) K Headstone Drive (between Hailsham Drive and Cecil Rd) M Headstone Drive (W of Hailsham Drive) There would be an increase in total traffic flows of less than 0.5% with the additional HGV movements associated with the construction phases. When considering permanent changes in road traffic flow (in accordance with DMRB) an increase in total vehicle flow (18-hr AAWT) of +25% is the minimum threshold advised to lead to a change of 1dB to road traffic noise levels. A change of less than 1dB is considered to not be noticeable, and as such an increase in total flow of <1% would not be expected to result in any increase to road traffic noise levels. There is no similar published advice in any standards or guidance with respect to changes in number of HGVs alone, or for the assessment of temporary changes in road traffic flows for construction schemes. It is also noted that when they pass by a fixed position HGVs are higher in noise level than cars. Nonetheless, the numbers of additional HGV movements per day during the construction phase are low, and there is not expected to be a noticeable change in total road traffic noise levels from construction traffic during the construction phases Construction noise summary Based upon the qualitative judgements in Section it would be appropriate to consider measures to reduce noise during the construction phase to fall within the 137

142 threshold values outlined in Table 7-10, or any other limits that may be imposed by the Council. Potential mitigation measures are discussed in Section Typically, it is likely that the closest local residential receptors will be particularly sensitive to short term construction noise impacts given their proximity to the application site. However, the extent to which construction noise is audible or considered significant by an individual receiver will be dependent on the position of the construction activity on the application site, which will move close to and further away from each receptor as the development progresses. Existing local noise sources will also be a significant factor in whether construction noise is audible at local sensitive receptors. With respect to the receptors close to Harrow View and Headstone Drive an influential factor will be the level and composition of all road traffic at the time when the construction works are being undertaken. There is not expected to be any noticeable change in overall road traffic noise levels as a result of additional HGV movements on the local road network during the construction phase. Table 7.13: Significance of effects identified during construction of prior to the implementation of mitigation measures Receptor Summary description of impact Magnitude of impact Significance of potential effect Existing dwellings located at the various site boundaries Construction Noise Moderate Adverse Significant Proposed new dwellings located in the Phases Construction Noise Moderate Adverse Significant Existing receptors close to the local road network Construction Traffic Noise Negligible Not Significant 7.6 Assessment of impacts during operation Impacts of road traffic noise As described in Section the assessment of noise impacts resulting from the traffic anticipated to be generated from the proposed development is based on the traffic data provided by PBA from the TA as summarised in Tables 7.2 and 7.3. Table 7.14 provides the % change in traffic flow when considering each phase against the Without Scheme scenario for the same year. The final column presents the % change in a comparison of the completed development (i.e. all phases in operation including Phase 3) against the Without Scheme situation in

143 Table 7.14: Percentage Change in Road Traffic Flows Road Link 2015 Phase 1a 2015 Phase 1b 2016 Phase 1c 2017 Phase Phase Base/ 2021 Phase 3 A Courtenay Ave (N of Long Elmes) B Long Elmes (E of Courtenay Ave) C Courtenay Ave (S of Long Elmes) D Long Elmes (W of Courtenay Ave) E Harrow View (N of Headstone Drive) -12.1% -11.1% -10.7% -7.1% - 9.1% -5.3% -4.8% -4.7% -3.2% - 3.4% -16.2% -14.8% -14.4% -9.7% % -3.0% -2.7% -2.6% -1.8% - 1.9% -20.8% -19.1% -18.6% -13.0% % -4.1% +2.5 % -7.2% +4.4 % % F Headstone Drive (between Harrow View and Rokeby Rd) -6.0% -5.7% -3.7% -2.7% - 9.5% -4.6% G Harrow View (S of Headstone Drive) H Headstone Drive (W of Harrow View) -16.5% -15.1% -14.9% -10.0% - 9.8% -6.8% -6.5% -5.1% -3.7% - 4.0% -4.9% +1.3 % I Headstone Drive (E of Rokeby Rd) -5.8% -5.4% -3.5% -3.1% +0.2 % +5.7 % J Hailsham Drive -2.6% -2.4% -1.8% -1.4% - 1.0% +5.1 % K Headstone Drive (between Hailsham Drive and Cecil Rd) -4.9% -4.6% -3.3% -2.6% - 2.6% +3.0 % L Princes Drive -3.7% -3.5% -2.6% -2.1% - 1.8% +4.1 % 139

144 Road Link 2015 Phase 1a 2015 Phase 1b 2016 Phase 1c 2017 Phase Phase Base/ 2021 Phase 3 M Headstone Drive (W of Hailsham Drive) -6.3% -6.0% -4.3% -3.4% - 3.3% +2.0 % N Cecil Road -3.2% -3.0% -2.1% -1.7% - 1.5% O Canning Road -1.5% -1.4% -0.9% -0.6% - 1.1% +4.5 % +5.0 % P Ellen Webb Dive (S of Canning Rd) -4.0% -3.8% -2.7% -2.1% - 1.8% +4.1 % Q High Street -2.8% -2.7% -1.9% -1.4% - 1.3% R Masons Avenue -3.3% -3.2% -2.2% -1.7% - 1.7% S The Bridge -3.0% -3.0% -2.4% -2.2% - 2.1% +4.7 % +4.2 % +3.9 % T Ellen Webb Drive (N of The Bridge) -3.9% -3.8% -2.7% -2.1% - 2.1% +3.7 % U Station Road -7.9% -7.5% -5.9% -4.4% - 4.6% +0.3 % V A404 Pinner Road (E of Station Rd) -4.7% -4.7% -4.6% -4.6% - 4.4% +0.6 % W Imperial Drive -4.9% -4.6% -3.7% -2.7% - 2.8% +2.6 % X A404 Pinner Road (W of Station Rd) -3.9% -3.8% -3.7% -3.5% - 3.5% +2.0 % Y Headstone Road -14.2% -12.9% -12.7% -8.5% - 6.6% Z Greenhill Way -2.4% -2.2% -2.2% -1.6% - 1.3% -1.5% +4.4 % A A Headstone Road -6.3% -5.6% -5.5% -3.3% - 2.5% +3.0 % A B A404 Pinner Road (W of Headstone Rd) -7.9% -7.2% -7.2% -5.0% - 3.9% +1.6 % 140

145 There are no road links where significant increases in road traffic flows of greater than 25% increase are identified. Decreases of approximately 21% are identified on Harrow View (north of Headstone Drive) in Phase 1A. A decrease of approximately 1dB may therefore be experienced on this section of road in these phases. When comparing changes in road traffic flows for each phase against the Without Scheme scenario for the same year, a decrease in road traffic flows on all road links is predicted. When comparing the completion of Phase 3 against the Without Scheme scenario in 2015 there are some increases in road traffic flows of up to +5.7% at twenty-two of the road links, and reductions at the remaining road links. Calculations of road traffic noise have been made for each link, at a reference distance of 10m from the edge of each link and at a first floor window 4m above ground, to enable consideration of road traffic noise changes between the Without Scheme and With Scheme scenarios. Table 7.15 presents the Without Scheme results, and Table 7.16 presents the With Scheme results. Table 7.15: Without Scheme Road Traffic Noise, L A10,18-hour db Road Link A Courtenay Ave (N of Long Elmes) B Long Elmes (E of Courtenay Ave) C Courtenay Ave (S of Long Elmes) D Long Elmes (W of Courtenay Ave) E Harrow View (N of Headstone Drive) F Headstone Drive (between Harrow View and Rokeby Rd) G Harrow View (S of Headstone Drive) H Headstone Drive (W of Harrow View) I Headstone Drive (E of Rokeby Rd) J Hailsham Drive

146 Road Link K Headstone Drive (between Hailsham Drive and Cecil Rd) L Princes Drive M Headstone Drive (W of Hailsham Drive) N Cecil Road O Canning Road P Ellen Webb Dive (S of Canning Rd) Q High Street R Masons Avenue S The Bridge T Ellen Webb Drive (N of The Bridge) U Station Road V A404 Pinner Road (E of Station Rd) W Imperial Drive X A404 Pinner Road (W of Station Rd) Y Headstone Road Z Greenhill Way A A Headstone Road A B A404 Pinner Road (W of Headstone Rd) Table 7.16: With Scheme Road Traffic Noise, L A10,18-hour db 142

147 Road Link 2015 Phase 1A 2015 Phase 1B 2016 Phase 1C 2017 Phase Phase 3 Change 2015 Base/ 2021 Phase 3 A B C D E F G H I J K L M N O P Q R S T U V W X Y

148 Road Link 2015 Phase 1A 2015 Phase 1B 2016 Phase 1C 2017 Phase Phase 3 Change 2015 Base/ 2021 Phase 3 Z AA AB The final column of Table 7.16 above shows the change in LA10,18-hour db for the comparison of road traffic noise levels in the 2015 Without Scheme scenario against the 2021 Phase 3 scenario, when all works are completed and the proposed development is fully occupied. The largest increase in levels of road traffic noise is predicted to be +0.4dB, which would be an imperceptible change of negligible magnitude in accordance with DMRB (Table 7.4), and therefore Not Significant in accordance with Table Impacts of existing road traffic and railway noise The key existing noise sources affecting the entire application site is road and rail traffic, primarily on Harrow View and Headstone Drive and the railway line that passes the eastern boundary of the application site from the north to the south-east. Given this, when assessing the suitability of the application site for residential enduse in accordance with PPG24, the rail traffic noise source Noise Exposure Category (NEC) values have been referenced for location LT1, and road traffic noise source NEC values (Table A-1 in Appendix 4.4) for locations LT2 to LT7. In this assessment, care homes are considered to be a residential receptor. Proposed new residential receptors are highlighted in Figure 7.2. Table 7.17: PPG24 NECs across the application site Measurement Location Period Measured Noise Level LAeq,T (db) PPG24 NEC LT1 Daytime 74 C / D Night-time 73 D LT2 Daytime 66 C Night-time 59 C LT3 Daytime 57 B Night-time 51 B LT4 Daytime 66 C Night-time 59 C 144

149 Measurement Location Period Measured Noise Level LAeq,T (db) PPG24 NEC LT5 Daytime 60 B Night-time 59 C LT6 Daytime 52 A Night-time 45 A / B LT7 Daytime 51 A During the night time measurements the level of 82 db LAmax (slow) was exceeded at measurement location LT1, and not exceeded at measurement locations LT2 to LT6. Where this level is exceeded regularly several times in one hour over night the location should be treated as being in NEC C. The categories presented in Table 7-17 are not affected by the LAmax, as measurement locations LT1 is in NEC D as a result of the day and night time average measurement results. At LT1, the main noise source is rail traffic, and this area of Harrow View East falls into NEC D. PPG24 contains the following advice for Local Authorities with regard to residential development that falls within NEC D: Planning permission should normally be refused. The illustrative masterplan as indicated in Figure 3.1 indicates a mix of employment uses adjacent to the railway line, which will also form a barrier between the railway line and proposed new residential development towards the central areas of Harrow View East (LT3 and LT5). At LT2 and LT4 road traffic is the main noise source, and these areas of the application site fall into NEC C. With respect to residential development within NEC C, PPG24 advises that; Planning permission should not normally be granted. Where it is considered that permission should be given, for example because there are no quieter sites available, conditions should be imposed to ensure a commensurate level of protection against noise. At measurement locations further removed from the railway line and road noise sources, measured levels were lower. At LT3, LT5, LT6 and LT7 the measurement results were within NEC B, and NEC A for some periods of the day. For NEC B the following advice is provided by PPG24: Noise should be taken into account when determining planning applications and, where appropriate, conditions imposed to ensure an adequate level of protection against noise. However, even when falling within NECs C or D, it is possible to incorporate mitigation measures within the design of new residential buildings in order that development can take place. Recommended mitigation measures that will achieve suitable WHO and BS8233 internal noise levels, as set out in the design goals in Section 7.2.2, are discussed in Section

150 Table 7-18 presents the noise measurement results for those locations closest to those proposed new noise sensitive receptors that are not residential dwellings, including proposed new offices. The relevant design goals set out in Section are presented, with an indication of the margin by which they would be exceeded. For the health centre in Phase 1a and offices in Phases 1a and 1c located on Headstone Drive, measurement results from Measurement Position LT4 are used. For the school in Phase 2, the measurement results at LT2 are considered, measured next to Harrow View. For offices in Phases 2 and 3 measurement results for Location LT1 are used for those that will face towards the railway line, and LT3 for the opposite facades, facing away from the railway line. Table 7.18: Non-residential Noise Sensitive Receptors Design Goals db Measured Outdoor Noise Level LAeq,T db Exceeds Design Goal Health Centre, inside waiting rooms (LAeq,1-hr) Health Centre, inside Consulting Rooms (LAeq,1-hr) School, Inside Classrooms (LAeq,30min) School, Outdoor at boundary of playground and sports fields (LAeq,30min) Offices, Phases 1 and 3 (LAeq,T) to 31 Offices, Phases 4 and 5 Facing Railway Line (LAeq,T) Offices, Phases 4 and 5 Facing away from Railway Line (LAeq,T) to to 22 Table 7.18 indicates that, based on the outdoor measurements, the stated design goals for the various non-residential end uses are not met. The only design goal relevant to outdoor spaces is for the school playground/sports fields.table 7.18shows that the design goal of 55dB LAeq,30-min is exceeded by 11dB, based on measurements at LT2. BS8233 advises that an open window can be expected to provide 10-15dB noise attenuation for indoor spaces from outdoor noise levels. When considering this, the margin by which the indoor design goals are exceeded is reduced. It is considered that the appropriate design of the layout and building envelope of each end use would result in suitable internal noise levels with appropriate 146

151 mitigation. The potential measures to achieve this are discussed in broad terms in the Section It is not considered appropriate at this stage to assign magnitude or significance criteria to the assessment of the potential impact on future site users. Rather, it is considered more appropriate to consider and identify suitable mitigation measures that will result in future uses of the application site achieving the appropriate design goals. Mitigation measures are discussed in Section Impacts of industrial and plant noise An assessment of the potential noise impacts from the existing Waverley Industrial Estate (to the south-east of the application site), the proposed Energy Centre (within the multi-storey car park see Figure 7.2) and also any proposed fixed building services and plant items associated with office/commercial development has been carried out with reference to BS4142. a) Impacts of Waverley Industrial Estate The baseline noise survey includes measurements at the boundary of Waverley Industrial Estate with the application site (LT3). Measurement observations advise that the main source of noise is from air conditioning units associated with the buildings within the Industrial Estate. Measured levels of LAeq,T adjacent to Waverley Industrial Estate (LT3) range between db (1-hour) in the daytime and db (5-minute) at night. Measured background noise levels measured at LT3 are also used in the assessment presented below, as the levels measured here are lower than at the other central site location of LT5. Measured levels of LA90,T range between 47-56dB (1-hour) in the daytime and 44-56dB (5-minute) at night. The closest proposed new residential dwellings are in phase 1A (student housing) and phase 3, and will be located approximately 10m from Waverley Industrial Estate. The distance attenuation provided by 10m distance from the measurement position (1m from source) can be assumed to be 20dB. Table 7.19 provides the BS4142 assessment for the nearest proposed dwellings to air conditioning units at Waverley Industrial Estate. Assessments are provided for both the day and night-time periods, although it is not known whether the units operate in night-time hours. A +5dB acoustic feature correction is also added to the measured level to allow for any tonal component from the air conditioning units, and to derive the rating level. Table 7.19: BS4142 Assessment for Waverley Industrial Estate Description Daytime (1-hr reference period) Night-time (5- min reference period) Measured Specific Noise Level LAeq,T db

152 Description Daytime (1-hr reference period) Night-time (5- min reference period) Distance Correction Acoustic Feature Correction Rating Level Measured Background Level, LA90,T db Excess of Rating Level over Background db(a) Conclusion -2-2 Less than Marginal Significance and more than Complaints not Likely The assessment indicates that the rating level of noise from existing air conditioning units within Waverley Industrial Estate at the closest proposed new residential receptors in Phase 1A and 3 would be 2dB below measured background levels in both the day and the night-time periods. This indicates that the air conditioning units are unlikely to be heard at the residential receptors. In terms of BS4142, the assessment is below Marginal Significance and above Complaints not Likely. In terms of the criteria provided in Table 7.3, the magnitude and significance is therefore considered to be No Impact and Not-Significant. b) Impacts of proposed energy centre and fixed building services plant The preferred location for the proposed new energy centre is on the ground floor of the proposed multi-storey car park on the eastern boundary of Harrow View East, adjacent to the northern boundary of Waverley Industrial Estate. The energy centre is likely to consist of CHP (Combined Heat and Power) with district heating, although other options are also under consideration. Assuming that the option for CHP is selected, a combination of plant will be required. The plant requirements may include a gas engine with gas boilers, a thermal store and electric chillers. The Energy Statement (Parsons Brinkerhoff, 2011) considers six different plant and equipment configurations for natural gas CHP, and also discusses other options, such as ground source heat pumps, biomass CHP, liquid bio-fuel CHP, photo-voltaic panels and air source heat pumps. Given that the likely configuration of the energy centre and associated equipment to be installed are not confirmed at this stage, it is not practical to undertake noise calculations of potential impacts from any plant to be installed. Instead this assessment recommends appropriate noise limits to be achieved at the nearest noise sensitive receptors from all aspects of the energy centre operations. There are also likely to be fixed building services plant items associated with the commercial elements of the proposed development, for example air conditioning units associated with the offices or food store. The locations, type, number and 148

153 associated noise emissions from any fixed building services plant items are not known at this stage, therefore an assessment of future noise emission levels from these source(s) is not possible at this stage. The delivery yard of the Food Store is another area that has the potential to result in noise disturbance, through the use of plant items and also deliveries. A conservative approach is adopted following the principals of BS4142 that the energy centre and any other operational plant and also delivery areas, should be designed to achieve a rating level that is at least below existing levels of background noise levels (LA90), and where practicable up to 10dB below the existing background noise levels (LA90). Based on the measurement results from locations on the application site boundary, and locations representative of new residential development within the application site, Table 7.20 below sets out the suggested noise limits at sensitive receptors in terms of a rating level LAR,T for daytime (0700 to 2300 hours) and night-time (2300 to 0700 hours) periods from the energy centre, and any other operational building services or plant. Table 7.20: Recommended Noise Limits for Fixed Building Services Plant Items, Free-field (db) Measurement Location Period Measured LA90,T db Acoustic Feature Correction db(a) Recommended LAR, T db at Residential Receptors LT2 Daytime Night-time LT3 Daytime Night-time LT4 Daytime Night-time LT5 Daytime Night-time LT6 Daytime Night-time The above limits should be achieved at residential receptors by the total noise emission level from all permanent fixed building services plant items (including the energy centre), and delivery areas. Due allowance should be made for the additive effects of noise, and individual plant items may need to be designed to a lower level to ensure that the overall limit is achieved. 149

154 During detailed design particular attention should be paid to those proposed new residential dwellings that are attached to the food store and located above retail premises, and also the student housing block. Where possible, noise sensitive rooms should not be placed adjacent to any fixed building services associated with the food store. Delivery areas should also be designed to be located away from these receptors, where possible. Table 7.21 shows the effects of the operation of the development prior to the implementation of mitigation. Table 7.21: Significance of effects identified during the operation of the proposed development prior to the implementation of proposed mitigation measures Receptor Summary description of impact Magnitude of impact Significance of potential effect Existing Sensitive Receptors bordering the application site Changes in road traffic flows and resulting noise Negligible Not Significant Future noisesensitive receptors in Phase 3 Waverley Industrial Estate No Impact Not Significant Future Noise- Sensitive Receptors Energy centre and new plant permanent fixed plant items Negligible (if design goals are met) Not Significant 7.7 Mitigation measures During construction During the construction phase of the proposed development, impacts of moderate adverse significance might be anticipated at a number of identified noise-sensitive receptors when assessed without mitigation measures in place, although this is highly dependant upon the type and location of the construction works that will be undertaken. It may be appropriate for the Contractor to undertake a full noise assessment when more detailed information regarding likely construction activities and plant usage become available. This will enable any specific requirements for noise and vibration mitigation to be incorporated, to achieve the construction phase threshold values indicated in Table 7-10 (or any alternative requirements imposed by the Local Authority). Guidance on noise and vibration management and mitigation is provided in BS5228 Part 1, Section 61 of the Control of Pollution Act 1974, also in CIRIA document C650 (2005) Environmental Good Practice on Site (Second Edition). Notwithstanding further detailed assessment, it is always recommended that Best Practicable Means be employed to minimise construction impacts, including, for example the following: 150

155 careful selection of working methods and programme; selection of quietest working equipment available e.g. electric/battery powered equipment, which is generally quieter than petrol/diesel powered; use of regularly maintained and appropriately silenced equipment; shutting down of equipment when not in use, i.e. maintain a no idling policy ; positioning of equipment behind physical barriers, i.e. existing features, hoarding or purpose built acoustic barriers; directing noise emissions from plant, including exhausts or engines, away from sensitive positions; handling of all materials in a manner which minimises noise, including minimising drop heights into hoppers and lorries; switching all audible warning systems to the minimum setting required by the health and safety executive, and using banksmen as an alternative to audible alarms wherever practicable; planning the routes and times of deliveries to minimise nuisance to local communities; reminding all site employees of their obligation to minimise noise on site by the use of signs and site inductions; and, engaging in community liaison to explore ways of minimising noise impacts and increasing local tolerance to noise. Preparation of a Construction Environmental Management Plan (CEMP) for reference throughout the construction phase would also assist in identifying potential impacts and provide specific mitigation measures where considered necessary. Following detailed identification and implementation of appropriate mitigation measures during the works, a reduced noise impact at identified noise-sensitive receptors may be anticipated during worst-case construction activities During operation a) Existing sensitive receptors bordering the application site An impact magnitude of Negligible has been identified for all receptors surrounding the application site with respect to changes in road traffic noise. Mitigation measures do not therefore need to be considered for this noise source. b) Future sensitive receptors within the application site When undertaking an assessment of possible mitigation measures, the measured noise levels at each of the monitoring locations are considered in order to confirm that the internal and external noise design goals can be achieved. Analysis of the measured noise levels has been undertaken in order to provide guidance regarding the level of noise attenuation required for the proposed new dwellings. 151

156 Table 7.22 presents outline levels of attenuation required for dwellings at the boundaries of the application site, and other sensitive receptors within the application site, corresponding to the measurement locations. The final column presents the amount of attenuation required in order for the recommended internal noise levels for the various design goals to be met. Table 7.22: Attenuation Levels Required for Internal Design Goals Location Measured Outdoor Noise Level (db LAeq, T) Internal Noise Level Goal (db LAeq, T) Noise Attenuation Required (db) LT2 Daytime Night-time LT3 Daytime Night-time LT5 Daytime Night-time LT6 Daytime Night-time LT7 Daytime LT4 - Health Centre, inside waiting rooms (LAeq,1-hr) LT4 - Health Centre, inside Consulting Rooms (LAeq,1-hr) LT2 - School, Inside Classrooms (LAeq,30min) LT4 - Offices, Phases 1 and 3 (LAeq,T) LT1 - Offices, Phases 4 and 5 Facing Railway Line (LAeq,T) LT3 - Offices, Phases 4 and 5 Facing away from Railway Line (LAeq,T) to to to

157 The minimum attenuation provided by a partially open window would be 10dB(A). This would reduce the internal noise levels from external noise sources by 10dB, and correspondingly reduce the amount of noise attenuation required (for internal spaces). For open plan offices in phases 2 and 3 facing away from the railway line, this would be enough reduction to meet the internal design goal of 45-50dB. However at all other locations the design goals would not be met, therefore further options for mitigation need to be considered. Table 7.23 presents the amount of attenuation required for any gardens or external spaces, based on the ground-floor results at the assessment locations, in order to achieve the design goal of 55dB LAeq,T. Table 7.23: Attenuation Levels Required for Internal Design Goal for Residential Receptors Location Measured Outdoor Noise Level (db LAeq,T) Noise Level Goal (db LAeq,T) Noise Attenuation Required (db) LT LT LT LT LT LT N/A LT N/A School (LT2) The use of noise barriers can reduce the noise level at sensitive receptors by reducing sound propagation. To be most effective, noise barriers must be either located very close to the source (i.e. the road) or to the receiver (i.e. the dwellings). The use of noise barriers as boundary fencing around the perimeter of the application site would reduce noise levels in any garden areas bordering the road and at the façade of sensitive receptors. Table 7.24 provides an indication of the level of attenuation that can be achieved from the use of boundary fencing for receptors at different set-back distances from the roadside. Noise attenuation provided by boundary fencing reduces once the receptor position is above the height of the fence, and therefore tends to have a lesser effect at receptor heights above the first floor window. The levels of attenuation indicated in the table below are presented for a ground floor height of 1.5m and a first floor receptor height of 4m. Table 7.24: Level of Noise Attenuation from Road Traffic Noise Sources Provided by Boundary Fencing 153

158 Distance (m) Road Edge to Barrier Barrier to Receptor Barrier Height (m) Receptor Height (m) Attenuation db The use of boundary barriers would reduce noise levels from road traffic in gardens, external spaces and also the level of noise entering sensitive receptors. There will not be external spaces adjacent to the railway line (LT1), and there are no dwellings proposed adjacent to Headstone Drive (LT4). The illustrative masterplan indicates that dwellings located adjacent to Harrow View road (LT2) will be orientated such that garden areas will be located to the rear of the dwellings. Therefore, the buildings themselves will act as noise barriers, and these garden areas would therefore be expected to achieve, or be close to, the design goal of 55dB LAeq,T at most locations. At garden locations within the application site, and at the school, measured noise levels are up to 5dB above the design goal of 55dB. Given that these measurements were undertaken during a period of operation of the existing Kodak Factory, which will not be present once the development is constructed and operational, it is considered that noise levels would be slightly lower. Considering the noise attenuation that will be provided by new buildings at the application site boundaries from the road and rail traffic, actual noise levels in garden areas and the school playground are expected to be close to the design goal of 55dB LAeq,T. At some locations the use of boundary barriers alone would not be sufficient to achieve the design goals for internal spaces, assuming open windows. Boundary barriers will also not be appropriate for all locations around the application site. Where boundary barriers are not sufficient to meet the design goals for internal noise levels with a window open, mitigation in the form of glazing can also be considered. 154

159 The sound reduction performance requirement for glazing at specific locations will apply to the overall performance of the external building fabric envelope. However, the glazing and any ventilation units are typically the weakest link in the overall sound reduction performance of the external building fabric. As such, the performance requirements can be assessed based upon appropriate glazing/ventilator specifications at this stage in the absence of detailed building elevation designs. The assessment is based on single figure performance data, which have been corrected to allow the typical frequency content of road traffic noise. The resultant measured noise attenuation, in decibels, gives a very useful guide to the in-situ sound reduction performance of the window for situations where various sources of noise dominate. The performance index relevant to traffic noise is Rw+Ctr. The RW component is an indication of the sound reduction performance to a random white noise source, and the addition of the Ctr is an indication of the sound reduction performance to noise sources with a strong low frequency component, such as road traffic. Appendix 7.3 contains a product sheet for Pilkington OptiphonTM, which is a specialist glass for the reduction of noise. The final column of the data tables in Appendix 7.3 indicates the sound reduction performance of each product in terms of the Rw+Ctr. The nomenclature used to describe the glazing units is in the form of X/Y/Z; where X and Z are glass thicknesses (mm) and Y is the depth of the air gap (mm) separating the two panes of glass. For the example product of Pilkington OptiphonTM assumed to be provided for some units in Table 7.25, X is the thickness of a pane of standard Pilkington K glass in mm, Y is the thickness of the air gap (which in this case may be anything between 6 to 20mm), and Z is the thickness of a pane of Pilkington OptiphonTM in mm. Without considering any attenuation that may be provided by boundary barriers, the products appropriate for all the noise monitoring locations and building types are presented in Table In the case of residential receptors, the highest value required between day and night-time periods is presented. Note that the inclusion of glazing units in these tables is based on manufacturers data for specific units; other units with a similar sound reduction performance will be equally valid. Due allowance should be made for on-site variations from the manufacturer s declared values, which are typically based on laboratory tests. Table 7.25: Noise Attenuation/Glazing requirements Location Attenuation Required Sound Reduction Rw+Ctr db Potential Glazing Unit LT2 Residential /6 to 20/ OptiphonTM/6 to 20/6.8 OptiphonTM LT3 Residential /6 to 20/4 155

160 Location Attenuation Required Sound Reduction Rw+Ctr db Potential Glazing Unit LT5 Residential /6 to 20/4 LT6 Residential /6 to 20/4 LT7 Residential /6 to 20/4 LT4 Health Centre Waiting Rooms LT4 Health Centre Consulting Rooms LT2 School Classrooms /6 to 20/ /6 to 20/ OptiphonTM/6 to 20/12.8 OptiphonTM LT4 Offices Phases 1 and 3 LT1 - Offices, Phases 4 and 5 Facing Railway Line to /6 to 20/ /6 to 20/ OptiphonTM/6 to 20/6.8 OptiphonTM 25 4/6 to 20/ OptiphonTM/6 to 20/12.8 OptiphonTM LT3 - Offices, Phases 4 and 5 Facing away from Railway Line 7 to /6 to 20/4 It should be noted that the attenuation levels indicate in the Table 7.25 are based upon windows remaining shut. Where this is the case, PPG24 advises that alternative means of providing ventilation and control of summertime temperatures should be provided. The Building Regulations on ventilation recommend that habitable rooms in dwellings have background ventilation. Trickle ventilators can provide this, and sound attenuating types are available. Where sound insulation requirements preclude opening windows for rapid ventilation and cooling, acoustic ventilation units incorporating fans are available for insertion in external walls; these can provide sound reduction comparable with domestic secondary glazing. Where appropriate, the preferred choice of ventilation is through the use of natural ventilation openings such as trickle vents, air-bricks and passive ventilation devices. Such ventilators can be used to meet the requirements of the Building Regulations Approved Document F for background ventilation. The future occupants would then have the option of having windows open or closed. 156

161 The Building Research Establishment (BRE) has published an Information Paper on the acoustic performance of such passive ventilation systems. IP4/99: Ventilators: Ventilation and Acoustic Effectiveness (October 1999) details a study into the sound reduction performance of fourteen different window mounted trickle ventilators and seven different through-wall passive ventilators. The measured sound reduction performance, after taking into account flanking sound paths (i.e. sound paths that do not travel directly through the vent) and the effective area of the ventilator, are given in Table 7.26 below. Table 7.26: Range of Measured Sound Reduction Performance of Passive Ventilators, With Vents Open and Corrected for the Effective Area of the Ventilator db(a) Window Mounted Trickle Vents (open) Passive Through-Wall Ventilators (open) From 14 to 40dB (depending on model) From 30 to 46dB (depending on model) Note: Figures corrected for effective area of ventilator It can be seen from the above figures that passive through-wall ventilators are available that meet the requirements of the Building Regulations Approved Document F for background ventilation and also provide a sound reduction performance that meets or exceeds that predicted to be required from the glazing elements. However, as for the glazing specifications, it may be possible to reduce the specification of ventilators used at potentially less sensitive rooms or elevations, whilst maintaining the required internal design goal. This could be assessed further at the detailed design stage. The above assessments of glazing and ventilation are based on the assumption that the most sensitive rooms, such as bedrooms and living rooms, are located on the most exposed elevation of the dwellings adjacent to the main roads. If the internal layout of the residential dwellings are such that sensitive rooms face away from the main noise sources, then the requirements for acoustic glazing and ventilation could be reconsidered. c) Industrial and Plant Noise The impacts of existing noise from the Waverley Industrial Estate on new residential dwellings were identified as Not-Significant. Mitigation measures do not therefore need to be considered. Assuming that the design targets presented in Table 7-20 for any new fixed services or plant items and delivery areas are achieved, the impact magnitude will be Negligible. No mitigation measures are therefore considered for this noise source. d) Summary of mitigation Noise measurements and preliminary calculations have revealed that with appropriate mitigation in the form of suitably orientated properties, noise barriers and suitably specified glazing and ventilation, or a combination of these measures, 157

162 appropriate internal and external noise levels can be achieved at residential dwellings and other noise sensitive receptors within the proposed development. In the first instance, the internal layout of residential dwellings should be carefully considered, and where possible oriented so that the most sensitive rooms, e.g. bedrooms and living rooms, face away from the main noise sources, which are the boundary roads and railway line. Where noise sensitive rooms will face towards the main noise sources, suitable glazing and ventilation should be provided to achieve internal design goals. Where possible, gardens should also be oriented away from main roads to minimise the impact of road traffic noise levels on outdoor spaces. The following specific mitigation principles should be applied at the detailed design stage for the following specific uses: For new residential properties facing Harrow View an overall reduction of 31dB is required for internal spaces through a combination of noise barrier boundary fencing and suitably specified glazing and ventilation. It is assumed that gardens will be located to the rear of dwellings directly adjacent to Harrow View; For new residential properties within Phases 1a, 1c, 2 and 3 (LT3 and LT5) an overall reduction of 30dB is required for internal spaces through a combination of noise barrier boundary fencing and suitably specified glazing and ventilation; For new residential properties within Phase 1b (LT6 and LT7) an overall reduction of 27dB is required for internal spaces through a combination of noise barrier boundary fencing and suitably specified glazing and ventilation; For the proposed new health centre in Phase 1c a reduction of 16dB for waiting rooms, and 26dB for consulting rooms is required for internal spaces through the use of suitably specified glazing and ventilation; For the proposed new school a reduction of 36dB is required for classrooms through the use of suitably specified glazing and ventilation; For the proposed new offices in Phases 1b and 1c facing Headstone Drive, a reduction of 26-31dB is required for executive offices or meeting rooms, 16-26dB for cellular offices or 16-21dB for open plan offices with the use of suitably specified glazing and ventilation; For the proposed new offices in Phases 2 and 3 facing towards the railway line, a reduction of 35-40dB is required for executive offices or meeting rooms, 25-35dB for cellular offices or 25-30dB for open plan offices with the use of suitably specified glazing and ventilation; For the proposed new offices in Phases 2 and 3 facing away from the railway line, a reduction of 7-17dB is required for executive offices or meeting rooms, 7-17dB for cellular offices or 7-12dB for open plan offices with the use of suitably specified glazing and ventilation; and 158

163 For the proposed new residential dwellings that are attached to the food store and located above retail premises, and also the student housing block, noise sensitive rooms should not be placed adjacent to any fixed building services and delivery areas should also be designed to be located away from noise sensitive rooms, where possible. Notes on the above Predictions It is important to note that the predicted internal noise levels presented are based upon the direct sound field within the room. Internal reverberant noise levels cannot be assessed at this time, as any prediction remains highly dependant upon the volume of absorption within the completed rooms (due to surface finishes and individual furnishings) and the size of the receiving room façade. However, as referenced in the technical reference document Sound Control for Homes 2, in a typically furnished domestic room, these factors will have relatively little effect on the final predicted internal noise level, and can therefore be assumed to have little effect on the outcome of a preliminary assessment. The internal layout and dimensions of the proposed rooms, the relative areas of glazing to brickwork and the exact nature of the external building fabric materials will all affect the internal noise levels. A more detailed assessment of glazing sound reduction performance should be undertaken once these details are known, prior to procuring the glazing units, so that a detailed 1/3 octave band sound reduction specification may be produced. 7.8 Conclusions and statement of residual significance Following detailed identification and implementation of appropriate mitigation measures during the construction phase, and the implementation of a suitable CEMP, the overall temporary noise impact at noise-sensitive receptors (both existing and future) would not be expected to exceed Moderate Adverse Significant. There is no significant change in road traffic noise levels as a result of the development. The change is of a negligible magnitude, which is Not Significant. A series of mitigation principles are outlined in Section for the detailed design stage. If these are adhered to and the design goals for the proposed development are 2 Building Research Establishment (BRE) and Construction Industry Research and Information Association (CIRIA), Sound Control for Homes,

164 met, then the significance of effects on proposed new sensitive receptors will be Not Significant. If the recommended noise limits for the energy centre and any new fixed building services and plant items outlined in Table 7-20 are adhered to then the impact from these parts of the development will be Not Significant. Table 7.27: Significance of residual effects identified during the construction and operation of the proposed development following the implementation of mitigation measures Receptor Summary Description of Impact Significance of Potential Effect Proposed Mitigation Residual Significance Construction Existing dwellings located at the application site boundaries Construction noise Moderate Adverse (Significant) CEMP and Best Practice Measures Moderate adverse (Significant) Proposed new dwellings located in Phases 1a, 1b and 1c within the application site Construction noise Moderate adverse (Significant) CEMP and Best Practice Measures Moderate adverse (Significant) Existing receptors close to the local road network Construction Traffic Noise Negligible (Not Significant) CEMP and Best Practice Measures Negligible (Not Significant) Operation Existing sensitive receptors bordering the application site Changes in road traffic flows and noise Negligible (Not Significant) None Negligible (Not Significant) Future noise sensitive receptors within the application site Existing road and rail noise - Glazing recommendations and design principles (including orientation and noise fences) Negligible Significant) (Not 160

165 Receptor Summary Description of Impact Significance of Potential Effect Proposed Mitigation Residual Significance Future noisesensitive receptors in Phase 3 within the application site Waverley Industrial Estate No Impact (Not Significant) None No Impact (Not Significant) Future noisesensitive receptors within the application site Energy centre and new plant permanent fixed plant items and deliveries - Design Targets (Table 1-20) Negligible Significant) (Not 161

166 8 Ground conditions 8.1 Introduction This chapter addresses the impact of the proposed development on the existing ground conditions, geology and hydrogeology of the application site. In particular it addresses potential issues in relation to ground hazards including both contamination and any associated influence upon the ground engineering for the proposed development upon Controlled Waters (principally the Yeading Brook and a chalk aquifer underlying the application site) and upon human health. This chapter describes the methods used to identify the baseline ground conditions (in so far as this is suspected or known from the studies and investigations that have been carried out to date) at the application site and in the surrounding area. Potential impacts are identified, the need for mitigation measures has been addressed and consideration is given to residual impacts. 8.2 Methodology Scope of assessment The assessment of ground conditions has involved the review and collation of available information pertaining to the current condition of the soils and groundwater on site. This information has been used to characterise baseline conditions for the application site. The information has been reviewed in the context of the proposed development to evaluate direct and indirect impacts. The standards applicable to the assessment are described in Section Sources of baseline data The assessment is based upon the baseline data obtained from the following sitebased assessments and investigations undertaken to date for the application site: Additional Phase I and Phase II Environmental Assessments were carried out by Aspinwall and Dames and Moore on behalf of Kodak Ltd in October 1990, September 1993 and August 1996; Phase I Environmental Site Assessment was carried out by Conestoga-Rovers and Associates (UK) Ltd for the Harrow View East and Harrow View West sites in March 2003 on behalf of Kodak Ltd. This was followed by Phase II Environmental Assessments in December 2003, October 2006 and April 2008 and a programme of ground water quality monitoring between 2004 and 2010; the Council commissioned Geotechnical and Environmental Associates to carry out a contamination investigation of the southern portion of the Harrow View East site in March 2006; 162

167 Site Validation Assessments were carried out by Conestoga-Rovers and Associates (UK) Ltd in January 2008 following demolition works in 2006 and 2007 involving the removal of approximately 35 no. buildings; A review of these existing reports was carried out by Halcrow in April 2010 and summarised in a Halcrow Technical Note (reference: C-TCN-HVD001- Rev1 Geo-environmental Data Review); and Ian Farmer Associates undertook further ground investigation of the Harrow View West site in August 2010 to supplement the Conestoga et al 2008 investigations, and in particular to provide geotechnical data for foundation engineering assessment. A geo-environmental interpretation of the ground investigation site was carried out by Halcrow in February 2011 and is the subject of a Halcrow Technical Note (Ref: C-TCN-HVD005-Rev 1). A summary of the above listed reports is provided in Appendix Assessment criteria An assessment of the significance of the proposed development on ground conditions and water resources is made by comparing the existing geology, ground, and hydrogeological conditions to the expected condition of these media post development, and how these may impact sensitive or valued receptors. To enable this, the sensitivity and value of each of the identified receptors has been evaluated using the criteria presented in Table 8.1. Table 8.1: Criteria for Assessing Value of Receptor Value of Receptor High Medium Criteria Receptor of international or national importance Medium value receptors are considered to be of regional significance. Possible Receptors Human Health (future site users, construction/maintenance workers, site neighbours) Major (Principal) aquifer in the underlying Chalk Groundwater protection zone Soils and geology (including Sites of Special Scientific Interest (SSSI)) Watercourse (including riparian ecosystems). Minor Aquifer (i.e. Alluvium occurring in the application site) Non-potable water resource Soils and geology (including Regional Important Geological Sites) 163

168 Value of Receptor Low Negligible Criteria Low value receptors are considered to be of district or local significance Value of receptor of insignificant or no value Possible Receptors Building fabric Services fabric Undesignated soils and geology In Table 8.2 the definition of minor, moderate and major significance is subjective for impacts to both ground conditions and groundwater resources. However, the context of the guidance and legislation used in this assessment is described in Section 8.3. Criteria used to assess the magnitude of the impact on geology and groundwater and the magnitude of the impact of potentially contaminated land within this assessment are identified in Table 8.2, Table 8.3 and Table 8.4. Table 8.2: Criteria for Assessing Magnitude of Impact of Development on Geology and Soils Magnitude of Identified Impact Major Moderate Minor Negligible Definition of Geology and Soils Criteria Any impact on an internationally or nationally designated site, such as an SSSI, designated or proposed on the basis of geological interest, that is located within or immediately adjacent to the scheme limits. Impact on a significant area of high quality or rare soil type located within or immediately adjacent to the scheme limits. Impact on a significant or active mineral resource, such as an open-cast mine or quarry, that lies within the limits that would be sterilized by the proposed development. Impact on a locally designated or proposed site of geological interest, such as Regionally Important Geological Sites (RIGS), that is located within or adjacent to the scheme limits. Impact on any area of high quality or rare soil type located within or immediately adjacent to the scheme limits. An identified but unexploited mineral resource that would be sterilised by the development. Damage to soils within the limits. Impact on any other prominent but undesignated geological feature. In addition impact on a potential mineral resource or poor quality soil close to the limits that may be affected by the development. Impact on any other site of geological interest that is in the vicinity of the limits but would not be affected by the development. Also any mineral resource in the vicinity of the limits that would not be affected by the development. 164

169 Table 8.3: Criteria for Assessing Magnitude of Impact of Development on Groundwater Magnitude of Identified Impact Major Moderate Minor Negligible Definition of Groundwater Criteria Where construction and/or operation would result in considerable impact on a water resource of high quality. Where construction and/or operation would result in a limited impact on a water resource of high quality; or a considerable reversible impact on a water resource of moderate quality which would not necessarily result in the land meeting the definition Contaminated Land under Part 2A of the Environmental Protection Act, 1990 Where construction and/or operation would result in a limited, very short or highly localised impact on a water resource of high quality (e.g. used for a potable water resource); or a limited (by extent, duration or magnitude) impact on a water resource of moderate quality (e.g. used for agricultural/industrial abstraction); or a considerable (by extent, duration or magnitude) impact on a water resource of low quality (e.g. heavily polluted groundwater). Where construction and/or operation would not result in deterioration in water quality of an aquifer or where there is no significant groundwater resource in the vicinity of the development. Table 8.4: Criteria for Assessing Magnitude of Impact of Contaminated Land on Development Magnitude of Identified Impact Major Definition of Contaminated Land Criteria Previous or ongoing activities on or near to a site where severe harm to a defined receptor is very likely. Site investigation data indicating contamination on many sites affected by current or former uses. Quantitative or qualitative risk assessment data estimating a significant likelihood of adverse effects from exposure to pollutants in the environment. Loss of the special characteristics of water resources. Change to General Quality Assessment (GQA) grade, pollution of potable source, severe flood risk, loss of fisheries. Any pollution inside Zone 1 (Inner Source Protection Zone) or of a groundwater protection zone of special interest. 165

170 Magnitude of Identified Impact Moderate Minor Negligible Definition of Contaminated Land Criteria Previous or ongoing activity where harm to a defined receptor is possible but severe harm is unlikely. Site investigation data indicating moderate contamination. Quantitative or qualitative risk assessment data estimating medium risk of adverse effects from exposure to pollutants in the environment. Impact on water resources. Reduction in the production of fisheries, moderate changes insufficient to reduce water quality. Any pollution that takes up to 400 days to travel to a groundwater abstraction borehole or 25% of the total catchment area, (Zone 2, Outer Source Protection Zone). A site within or adjacent to the works for which a contaminating potential is a possibility, but where it is considered very unlikely that any contamination would affect the environment surrounding the scheme during construction or operation. No mitigation measures would be proposed at this stage, but careful observation would be required during construction and action. Greenfield site or previous or ongoing activities where harm to a defined receptor is unlikely. Site investigation data indicating significant contamination is unlikely. Quantitative or qualitative risk assessment data estimating low likelihood of adverse effects from exposure to pollutants in the environment. Minor impact, insufficient to affect the use or characteristics of the water resource. The assessment of effect presented in this chapter considers the value of individual receptors, the magnitude of the impact on the receptor and the consequent significance of the effect both before and following the application of appropriate mitigation measures. The identification of significance is summarised in Table 8.5. Table 8.5: Significance of Effects of Assessments Value of Receptor High Medium Low Negligible Magnitude of Impact Major Adverse Moderate Adverse Minor Adverse Major effect Moderate effect Moderate effect Moderate effect Minor effect Minor effect Minor effect No effect Minor effect Minor effect No effect No effect 166

171 Value of Receptor Negligible No effect No effect No effect No effect Minor Beneficial Minor effect Minor effect No effect No effect Moderate Beneficial Moderate effect Moderate effect Minor effect No effect Major Beneficial Major effect Moderate effect Minor effect Minor effect Consultation A briefing meeting was held with the Environment Agency (EA) in January 2010 to introduce the proposed development and determine potential key issues including those in relation to Controlled Water resources, which might be at risk from any contamination within the application site. Subsequently, the EA confirmed its position in response to the Scoping Report that preceded this report; that response is copied in Appendix Legislation and policy Assessment of the project is in accordance with a number of key pieces of legislation and guidance, as follows: Part IIa Environmental Protection Act 1990 The legislative framework governing the definition of contaminated land is contained within Part IIa of the Environmental Protection Act Contaminated land is assessed and managed in accordance with the Contaminated Land Report 11-Model Procedures for the Management of Land Contamination (EA, 2004). There are four possible grounds for determination of Contaminated Land (from Section 78a(2) of the Environmental Protection Act 1990), namely: i) significant harm is being caused; ii) there is a significant possibility of significant harm being caused; iii) pollution of Controlled Waters is being caused; iv) pollution of Controlled Waters is likely to be caused. For the purposes of Part IIa, Controlled Waters are considered a receptor. A significant pollutant linkage must be identified before the Local Authority can make the judgement that land appears to be contaminated land because of pollution of Controlled Waters being caused or likely to be caused Contaminated Land Exposure Assessment (CLEA) 167

172 The proposed development is of mixed use, the application site corresponds with the CLEA model for a Commercial and Residential (with and without plant uptake) site. For human health risk assessment, chemical test results were assessed using published Soil Guideline Values (SGV) and General Assessment Criteria (GAC) for commercial land use (ref. EA, 2009 and Nathanail et al, 2009). A published SGV for lead is not currently available, therefore the SGV for a commercial site end use, which was withdrawn in 2008 was used for initial screening purposes only. Risk to Controlled Waters was assessed using Environmental Quality Standards (EQS). Where EQS values were not available for certain substances UK Drinking Water Standards (DWS) are used Planning Policy Statement 23 (PPS23) Planning Policy Statement 23: Planning and Pollution Control, (PPS23) advises that the assessment of baseline and future conditions should include the impacts of development, and whether or not it would create unacceptable cumulative damage to the environment. Contamination of land may threaten public health and safety, the natural environment, the built environment and economic activities, through its impacts on the users of the land, and on neighbouring users. It remains the responsibility of the landowner/developer to identify land affected by contamination and to ensure that appropriate remediation is undertaken to secure a safe development. PPS23 Annex 2: Development on Land Affected by Contamination gives brief details of the roles of the different parties in the development process, on the relationship between planning control and the contaminated land regime and on the requirements and good practice in dealing with these issues through planning control. The Government s current approach to existing contaminated land is to encourage land to be used safely and economically, striking a balance between risks and the need to restore Brownfield sites to beneficial use. The Suitable for Use approach is adopted by regulators for existing contamination where site conditions are assessed in relation to intended use of the application site after the application of any necessary mitigation. Other relevant contaminated land-related legislation and guidance includes: Remedial Targets Methodology, EA, 2006a; CL:AIRE The Definition of Waste: Development Industry Code of Practice; Guidelines for Environmental Risk Assessment and Management, Department of Environment, Trade and the Regions (DETR) and EA (2000); and Groundwater Policy: Protection and Practice (GP3) Other relevant planning documents Other relevant planning-related documents include: 168

173 Planning Policy Statement 9: Biodiversity and Geological Conservation, (PPS9) (2005); Planning Policy Guidance 14: Development on Unstable Land, (PPG14) (1990); and The London Plan, Baseline conditions Geology, soils and groundwater There are no geological SSSIs or RIGS in or near the proposed development site. The previous Phase I and Phase II studies of the application site indicated that the underlying geology comprises, in descending order, Made Ground with a bedrock of the London Clay, the Lambeth Group and the Chalk bedrock. In the Harrow View West site, and associated with Yeading Brook (west branch) which aligns with the western site boundary, there are sporadic deposits of alluvial clay underlain by some sand and gravel. The Chalk bedrock constitutes a Secondary A aquifer to the south and west of the application site. This underlies the Harrow View West site to the west and south and the south eastern fringe of the Harrow View East site. Elsewhere the stratum is unproductive. There are records for nine groundwater abstraction wells on the application site, four of which have been decommissioned in consultation with the EA. There are also a number of groundwater monitoring wells which will also require decommissioning once no longer required. The London Clay and Lambeth Group are non productive strata and therefore are not at risk of groundwater contamination. There are a number of historical water wells in the application site that abstracted groundwater from the Chalk for use as process water; the current quality of that water does not suggest the presence of any contamination of the Chalk aquifer by substances originating from the application site. The nearest surface water feature to the application site is a drainage ditch (known in this report as western boundary ditch) that lies adjacent to the western boundary of the Harrow View West site. Yeading Brook (west branch) lies about 120m west of the western boundary of the application site. The Victor Road branch of Yeading Brook is a surface water sewer that flows under Harrow View road and Victor Road before discharging into Yeading Brook Potential for contamination The current retained (see Section 2.1 for details) and former uses of the Harrow View East site with contaminative potential include film manufacture and coating, waste water treatment (silver recovery), silver-bearing effluent drains, power generation, engineering, waste handling and materials storage. Potential contaminative 169

174 substances used and stored on the Harrow View East site may have included developing agents, fixing agents, stabilising chemicals, bleaches and oil/hydrocarbon products. Accordingly, metals, chlorinated solvents and hydrocarbons may be present in the application site. The current use of the Harrow View West site is primarily for recreational purposes and car parking with a sports field and a leisure complex, a car club and disused rifle range. These uses could also result in the presence of contaminants such as metals and oil/hydrocarbons. It must be noted that because buildings were still present during the investigations listed in Section it was not possible to investigate potential contaminants that may be present below the buildings within the existing Harrow View East site. It is therefore possible that previously unidentified contamination may be present under these buildings; this situation is common in Brownfield development and is usually managed and controlled by means of a specific Condition on planning, which would likely be additional ground investigation and assessment of these areas prior to construction. For the Harrow View East site, within the areas for which data is available a few isolated hotspots were recorded where concentrations of some substances exceeded the commercial end-use Soil Guideline Values (SGV). These included lead, barium, benzo(a)pyrene and trichloroethene, which were predominantly encountered at shallow depths (<1m). The maximum depth of a recorded commercial end-use exceedance was 1.5m. Exceedances of the more sensitive residential with plant uptake SGV were more prevalent across the application site. These included: Arsenic; Barium; Lead; Nickel; Vanadium; Benzo(a)anthracene; Benzo(a)pyrene; Benzo(b)fluoranthene; Benzo(k)fluoranthene; Chrysene; Dibenzo(a,h)anthracene; Indeno(1,2,3-cd)pyrene; Naphthalene; Phenanthrene; 170

175 TPH aromatic C21-C35; TPH aromatic C35-C44; Benzene; Trichloroethene; Tetrachloroethene; and Total PCB congeners. These were predominantly recorded at shallow depths (<1m), with occasional deeper exceedances up to 2m below ground level. Additionally, the area around the old silver recovery sumps (north of Building 40), where ingress of groundwater was observed during cleaning operations (CRA, phase 2 report, 2003) was tested for shallow (only) soil samples ( m bgl in BHB10, BHB11 and BHB12) and a silver concentration of 210 mg/kg was recorded in BHB11, north/north east of the sumps. However, no residential GAC has been computed for risk to human health from silver in soils. In summary, the contamination investigations carried out at both the Harrow View East and West sites have identified a range of contaminants. This data has been reviewed against current Soil Guideline Values (SGV) and the guidance laid out in CLR 11 for risk to human health for both commercial and residential with plant uptake land uses. The dataset, the quantitative criteria used and further details on the exceedances encountered are presented in Halcrow s geo-environmental data review (covering the entire application site) in Appendix 8.1 and geo-environmental Interpretation of ground investigation (for the Harrow View West site only) attached as Appendix 8.2. Groundwater monitoring was undertaken at several locations within the application site between July 2003 and January 2010, and further monitoring was undertaken as part of the supplementary Harrow View West site investigation in August This monitoring recorded some exceedances of the freshwater Environmental Quality Standard (EQS) and the UK Drinking Water Quality Standard (2000) for antimony, boron, manganese, selenium, vanadium and total petroleum hydrocarbons (TPH) in the shallow groundwater beneath the Harrow View West site. Ground gas monitoring was undertaken in the Harrow View West site as part of the ground investigation in August 2010 the results of which are likely to be representative of the application site as a whole. These indicate in accordance with CIRIA guidelines a Characteristic Situation 1 ( very low risk ), meaning that buildings will not require ground gas protection. Nevertheless, given the Brownfield status of the Harrow View West site, a precautionary amount of ground gas/vapour protection to buildings may be volunteered. Testing was carried out upon soil samples to provide an initial assessment of whether soils contain agents likely to attack concrete. The results were compared against guidance laid out in BRE Special Digest 1. The initial assessment indicated DS-1 class and AC-1s. However, the naturally occurring London Clay underlying the 171

176 application site is likely to contain sulphates and sulphides, so further assessment would be required to confirm the above indications. The following receptors sensitive to any potential contamination risks (as summarised in Table 8.1) within the application site include: Soils and geology; Human Health - New residential/site users o Residential with gardens o Residential without gardens o Commercial - Existing neighbouring residents - Demolition/construction workers - Existing residents surrounding the application site; Controlled waters - Surface waters Yeading Brook - Groundwater Secondary A Aquifer; The wider environment e.g. ecological resources on and in close proximity to the application site; and Building fabric Geotechnical considerations The Made Ground present within the application site is expected to have been placed in an uncontrolled manner and the alluvium (where present) comprises soft silt/clays and loose silt/sands; as such neither are likely to provide acceptable founding conditions without ground improvement. The underlying London Clay, Lambeth Group and Chalk are all known generally to provide a satisfactory formation for the support of appropriately designed foundations, subject to the identification and treatment of any soft spots that can be present in the near surface weathered horizons of these materials. 8.5 Assessment of impacts during demolition and construction This presents a review of the demolition and construction processes for the proposed development and the potential impacts on ground conditions at the application site. Full details of the demolition and construction processes are given in Section 3.3. However the demolition and construction activities relevant for the assessment within this chapter include: 172

177 Demolition of existing buildings on site; Removal of existing infrastructure, including underground services, drains and roads; Decommissioning of five currently active/disused uncapped groundwater abstraction wells; Remediation of contamination (where required); Earthworks and site levelling where required, including the construction of capping layer in soft landscaped and garden areas; Construction of new infrastructure; including roads and utilities; and Excavation of ground and construction of building foundations. The potential impacts arising from demolition of the existing site and during construction would include: a) Creation of airborne dust potentially containing asbestos and/or metals and during demolition/construction creating risks to construction/demolition workers. The works are likely to phased, therefore also creating potential risks posed to residents/end users of completed areas of development (e.g. Phases 1a, 1b and 1c during the demolition/remediation and construction activities required for Phases 2 and 3); b) Construction/demolition workers coming into contact with hydrocarbons, metals and asbestos by dermal contact; c) The creation of pathways for the mobilisation of contaminants from within the Made Ground during excavation of ground and from pilling through the ground. This would include pathways from any existing uncapped abstraction wells and monitoring wells within the application site; d) Release of oils and hydrocarbons from plant and machinery into the ground. Potential leaching of contaminants from the soil, and in to groundwater and surface waters. The significance of each of these effects identified are summarised in Table 8.6. Table 8.6: Significance of effects identified during the Demolition/ construction of the proposed development prior to the implementation of mitigation measures Receptor Value Summary description of impact Magnitude of impact prior to mitigation Significance of potential effect prior to mitigation Humans (residents) High Residents inhaling dust-borne asbestos and metals Moderate Moderate Adverse Effect 173

178 Receptor Value Summary description of impact Magnitude of impact prior to mitigation Significance of potential effect prior to mitigation Human Health (construction/ Demolition workers) High Construction/ demolition workers coming into contact with hydrocarbons. metals and Asbestos by dermal contact or inhalation Moderate Moderate Adverse Effect Controlled Waters (Principal Aquifer and Secondary A aquifer) High Abstraction and monitoring wells and piles becoming pathways for contaminant migration to the Principal and secondary A aquifer Major Major Adverse Effect Controlled Waters (Surface waters, i.e Yeading Brook) Mediu m Direct run off to surface waters (leading to Yeading Brook), particularly, oils and hydrocarbons Major Moderate Adverse Effect Geology and Soils (no RIGS, no SSSI) Negligi ble No impact identified Negligible No Effect 8.6 Assessment of impacts during operation This section presents a review of the operational processes for the proposed development and the potential impacts on ground conditions at the application site The primary operational activities will include: Residents living in their homes and using their gardens; Humans using or working in the employment units, community and leisure centre, a school, large food store and smaller local retail units; and Further development and/or maintenance of the development, involving intrusive excavation. For the purposes of this assessment, the potential impacts arising from the operational site are considered in terms of the following receptors. Note that for the assessment of operational impacts the human health receptors have been further sub- 174

179 classified in terms of their proposed end use of the application site and the potential exposure to contaminants. a) Human health: residential houses with gardens; b) Human health: residential houses and flats without gardens and for areas of soft landscaping accessible by the public; c) Human health: commercial workers in employment units, community and leisure centre, large food store and smaller local retail units; d) Controlled waters; and e) Building fabric. Potential impacts on these receptors are identified and described below Human health: residential with gardens (i.e. possible plant uptake of contaminants): Direct contact with, ingestion or inhalation of metals and organics (e.g. hydrocarbons, solvents, oils, PAH), particularly in gardens and from homegrown fruit and vegetables; Exposure to ground gas and vapours following construction; Direct contact, ingestion or inhalation of metals and organic substances (e.g. hydrocarbons, solvents, oils, PAH) within landscaped areas; and Potential risks to residents/end users of completed phases of the proposed development (i.e. Phases 1a, 1b, 1c) resulting from the generation of airborne dust potentially containing asbestos and metals during demolition/construction activities for later phases (i.e. Phases 2 and 3) Human health: residential without gardens (ie no possibility of plant uptake of contaminants): Exposure to ground gas and vapours following construction; Direct contact with, ingestion or inhalation of metals and organic substances (e.g. hydrocarbons, solvents, oils, PAH) within landscaped areas; and Potential risks to residents/end users of completed phases of the proposed development (i.e. Phases 1a, 1b, 1c) resulting from the creation of airborne dust potentially containing asbestos and metals during demolition/construction activities for later phases (i.e. Phases 2 and 3) Human health: commercial: Exposure to ground gas and vapours following construction; Direct contact with, ingestion or inhalation of metals and organic substances (e.g. hydrocarbons, solvents, oils, PAH) within landscaped areas; and Potential risks to residents/end users of completed phases of the proposed development (i.e. Phases 1a, 1b, 1c) resulting from the creation of airborne dust 175

180 potentially containing asbestos and metals during demolition/construction activities for later phases (i.e. Phases 2 and 3) Controlled Waters: Surface waters Yeading Brook Surface run-off of contaminants into storm drains in commercial areas leading to Yeading Brook; and The creation of pathways and the mobilisation of contaminants via service ducts and drains on a site-wide basis, particularly during the removal of old drains Building and service fabric Aggressive ground conditions upon buried concrete (i.e. the degradation of inappropriately specified concrete by naturally occurring sulphates); and Water supply pipes made of inappropriately specified materials (e.g. plastic) being laid through soil contaminants and the associated risk that water supplies may be tainted or contaminated as a result because of permeation of contaminants through the pipe material. The sensitivity of each receptor and the significance of the effects of the impacts listed above are identified and summarised in Table 8.7 Table 8.7: Significance of effects identified during the operation of the proposed development prior to the implementation of proposed mitigation measures Receptor Value Summary description of impact Magnitude of impact prior to mitigation Significance of potential effect prior to mitigation Humans (Residential without gardens) and Humans working in commercial Units High High Exposure to Ground gas and vapours Direct contact, ingestion, inhalation of metals and organics (e.g. hydrocarbons, solvents, oils, PAH) within landscaped areas. Moderate Moderate Moderate Adverse Effect Moderate Adverse Effect High Residents potentially inhaling dust borne asbestos and metals from areas of the application site still under phased construction Moderate Moderate Adverse Effect 176

181 Receptor Value Summary description of impact Magnitude of impact prior to mitigation Significance of potential effect prior to mitigation Humans living in houses with gardens only (Residential with plant uptake) High Direct contact, ingestion, inhalation of metals and organics (e.g. hydrocarbons, solvents, oils, PAH), particularly in gardens and from home grown fruit and vegetables Moderate Moderate Adverse Effect Controlled Waters (Surface Waters: Yeading Brook and Secondary aquifer (alluvium) Medium Medium Surface run off of contaminants into drains in Commercial areas The creation of pathways and the mobilisation of contaminants via drains on a site wide basis to surface waters Negligible Negligible No Effect No Effect Controlled Waters (Principal aquifer in the Chalk) High Mobilisation of contaminants by pilling and via existing wells on site wide basis to surface waters Moderate Moderate Adverse Effect Building Fabric Low Aggressive ground conditions upon concrete and Moderate Minor Adverse Effect High Water supply pipes being buried through contamination and the risk of water supplies potentially being contaminated. Moderate Moderate Adverse effect The operational phase of the proposed development is likely to reduce the impact to the environment compared to those possible impacts from the application sites 177

182 current land use. In the long term the proposed development will benefit from the application of the requirements of the Government s Contaminated Land Exposure Assessment (CLEA) processes for the identification, management and control of land that may be contaminated. Accordingly, there will not be any additional risk to human health, Controlled Waters and the wider environment, and there should be a positive impact from the remediation of any contaminants identified and removed. 8.7 Mitigation measures During construction and demolition During demolition and construction the following mitigation measures for each identified receptor would need to be applied. a) Human health: residents in surrounding areas located outside the application site and in areas of the application site which have been completed as part of any phased development (i.e. Phases 1a, 1b and 1c) The risk posed to existing neighbouring residents would be from dust potentially containing asbestos and/or metals during demolition and construction. This could be easily mitigated through the use of best practice measures in accordance with current Health and Safety Executive (HSE) guidance. These measures include the use of dust suppression measures, particularly in any areas where asbestos or metals have been previously identified. Dust suppression measures would include the use of dampening down ground with water sprays and wheel washes for site vehicles leaving site. Also sheeted scaffolding and enclosed working for particular elements would be carried out. Additional control measures could include air monitoring within and outside demolition/construction areas. b) Human health: demolition/construction workers The potential for exposure of construction workers to contaminants via dermal contact, ingestion or inhalation can be mitigated through the use of appropriate safe method of work (e.g. dust suppression, minimisation of manual handling) and hygiene measures (e.g. provision of appropriate personal protective equipment and washing facilities) during construction works. c) Controlled Waters: Principal aquifer (Chalk), Secondary A aquifer (alluvium) and Yeading Brook Action is required to ensure that existing abstraction wells and monitoring wells on the application site do not become a potential pathway for contaminants to enter the Principal and/or Secondary A aquifer below the application site; Each well would need to be first located and decommissioned, or otherwise protected. This would require consultation with the EA to determine the most appropriate decommissioning method. A number of the wells have been decommissioned already, although it is anticipated that further decommissioning of these may need to be considered. To ensure that piling does not create contaminant pathways, pilling should be carried out in accordance with current EA guidance and the use of CFA piles. 178

183 In order to mitigate for release of oils and hydrocarbons from plant and machinery into soil, groundwater and Yeading Brook (surface water), the contractor would be required to adhere to appropriate best practise including EA Pollution Prevention Guidelines (PPG) to ensure the groundwater and surface waters are protected during construction works. Examples of best practice would include the bunding of oil tanks, the use of drip trays beneath oil tanks, engines, gearboxes and hydraulics and an emergency spillage action plan. It should be noted that the likelihood of the migration of contaminants into the aquifer is considered low due to up to 9.8m of low permeability London Clay beneath the application site During operation The identified risks to/impacts on sensitive receptors during the operation of the proposed development, as identified in Section 8.6, are proposed to be mitigated as described below. a) Human health - Residents and site users Ground gas and vapours: Ground gas monitoring carried out within the Harrow View West site, indicated Characteristic Situation 1 ( very low risk ), which does not require any gas protection measures. However, there is currently no gas monitoring data for the Harrow View East site where the previous investigations have identified the inhalation of gases and vapours (from VOCs and SVOCs) present within the Made Ground as a contaminant pathway. It is therefore recommended that further ground investigation and monitoring be undertaken to determine ground gas conditions across the Harrow View East site prior to any works taking place. Should mitigation be required, then this could consist of appropriate gas/vapour protection measures within buildings in accordance with guidance laid out in CIRIA 659, combined with source-removal of contaminants where this is also needed for the protection of human health and/or Controlled Waters. Contact, ingestion, inhalation of metals and organics: Any risks of direct contact with, ingestion or inhalation of metals and organics, particularly within gardens and landscaped areas, would require mitigation. These potential contaminant pathways will be automatically severed in areas of structures or hard standing. Accordingly, additional ground investigation and assessment may be required within the Harrow View East site where buildings are still present and where there are existing gaps within the assessment data. The provision of a cover system in accordance with guidance in Buildng Research Establishment (BRE) Report 465 and in consultation with the local authority will likely be required. This may typically consist of a marker/hard-dig layer and a suitable thickness of inert cover material to prevent significant contact between existing ground and end users of the application site. Generally, the structural development of the application site (including roads and any areas of hard standing) will provide this function and the formal cover system is expected to be required in areas of gardens and open space only. The existing coverage of crushed material across much of the southern areas of the Harrow View East site can be taken as the marker layer, although it may be necessary to reduce the thickness of this (and/or of 179

184 the underlying potentially contaminated material) in order to create headspace for a second inert cover layer, which may need to be up to 1m thick. The cover layer may comprise, at least in part, the subsoil and topsoil requirements for garden/open space/landscaped areas. All soils imported to the application site will need to be validated as being chemically suitable with concentrations of contaminants below the identified site specific targets. All topsoil (whether imported or site-won) will need to be similarly compliant in addition meeting BS 3882 specifications. Although unlikely, optional remediation of localised contaminants may be carried out to reduce the scope and extent of the cover system and/or to mitigate any identified impacts on nearby Controlled Waters, principally the Yeading Brook. b) Building Fabric In order to prevent aggressive attack on buried concrete structures, all such structures will need to be designed in accordance with BRE Special Digest 1. The London Clay presents naturally aggressive conditions for buried concrete, (i.e. high sulphate concentrations causing an acidic ph which reacts adversely with concrete) which will be similarly mitigated. Where contamination has been identified, all potable water pipes should be nonplastic and be laid in lined trenches which are backfilled with clean imported fill material and should be carried out in consultation with the appropriate local water supply company. 8.8 Conclusions and statement of residual significance Any identified pollutant impacts on human health are expected to be capable of being satisfactorily mitigated by established engineering processes. These processes may include providing the application site with an inert cover system and, within structures and buildings, gas/vapour protection measures may be required following additional gas monitoring and assessment in the Harrow View East site. Additionally, remediation of localised contaminants may be carried out to reduce the scope and extent of the cover system and/or to mitigate any identified impacts on nearby Controlled Waters, principally, Yeading Brook. Risks to Controlled Waters due to the marginal exceedances identified are considered to be low and remediation is not likely to be recommended as the costs are likely to outweigh any benefits. Impacts on human health during demolition/construction will be mitigated through the use of best practice and appropriate operating procedures in accordance with current HSE and EA guidance. Impacts on Controlled Waters during demolition/ construction would need to be mitigated by use of best practice as outlined in the EA Pollution Prevention Guidelines (PPGs). The existing abstraction wells, where not already adequately decommissioned, would need to be first located and then decommissioned. Any existing monitoring wells on the application site would also need to be decommissioned. The decommissioning would require consultation with the EA to determine the most appropriate decommissioning method in accordance with EA standard guidelines. To ensure that piling does not create contaminant pathways, 180

185 pilling should be carried out in accordance with current EA guidance and the use of CFA piles. Impacts upon building fabric are considered to be low provided the mitigation outlined in Section is applied. In the long term the proposed development will benefit from the application of the requirements of the Government s Contaminated Land Exposure Assessment (CLEA) processes for the identification, management and control of land that may be contaminated. Accordingly, there will not be any additional risk to human health, Controlled Waters and the wider environment, and there should be a positive impact from the remediation of any contaminants identified and removed. Following the implementation of the proposed mitigation measures, the residual impacts on the ground conditions and contamination during the construction phases of the proposed development are anticipated to be No Effect Following the implementation of the proposed mitigation measures, the residual impacts on the ground conditions and contamination during the operational phases of the proposed development are anticipated to be No Effect to Moderately Beneficial Effect depending on the receptor. The significance of the residual effects identified is shown in Table 8.8. Table 8.8: Significance of residual effects identified during the construction and operation of the proposed development following the implementation of mitigation measures Receptor Summary description of impact Significance of potential effect prior to mitigation Proposed mitigation Residual significance Construction Humans (residents) Residents potentially inhaling dust borne asbestos and metals Moderate Adverse Effect Dust suppression measures and/or air monitoring No Effect Humans (Construction/ Demolition workers) Construction/demol ition workers coming into contact with hydrocarbons. metals and Asbestos by dermal contact or inhalation Moderate Adverse Effect Appropriate operating procedures and hygiene measures No Effect Controlled Waters (aquifer) Abstraction wells, monitoring wells and piles becoming pathways for contaminants to Aquifer Major Adverse Effect The location and appropriate decommissioning of wells and use of CFA piles. No Effect 181

186 Receptor Summary description of impact Significance of potential effect prior to mitigation Proposed mitigation Residual significance Controlled Waters (Surface waters) Direct run off to surface waters (Yeading Brook) No Effect None required No Effect Geology and Soils Operational No impact identified No Effect None required No Effect Humans Site Wide, including Humans (Residential without gardens) and Humans working in commercial Units Exposure to Ground gas and vapours Direct contact, ingestion, inhalation of metals and organics (e.g. hydrocarbons, solvents, oils, PAH) within landscaped areas. Moderate Adverse Effect Moderate Adverse Effect Further Ground Investigation and/or gas protection measures Appropriate cover layer on gardens and landscaped areas of the application site. No Effect Moderately Beneficial Effect Residents inhaling dust-borne asbestos and metals from areas of the application site still under phased construction Moderate Adverse Effect Dust suppression measures and/or air monitoring No Effect 182

187 Receptor Summary description of impact Significance of potential effect prior to mitigation Proposed mitigation Residual significance Humans living in houses with gardens only (Residential with plant uptake) Direct contact, ingestion, inhalation of metals and organics (eg hydrocarbons, solvents, oils, PAH), particularly in gardens and from home grown fruit and vegetables Moderate Adverse Effect Appropriate cover layer gardens and landscaped areas of the application site. Moderately Beneficial Effect Controlled Waters Surface run off of contaminants into drains in Commercial areas The creation of pathways and the mobilisation of contaminants via drains on a site wide basis to surface waters No Effect None Required No Effect No Effect None Required No Effect Building Fabric Aggressive ground conditions upon concrete Minor Adverse Effect Structures should have been designed in accordance with BRE Special Digest 1 No Effect Water supply pipes being buried through contamination and the risk of water supplies potentially being contaminated. Moderate Adverse effect Pipes should be non plastic and laid in lined trenches with clean backfill in consultation with local water company guidelines No Effect 183

188 9 Water Environment 9.1 Introduction This section describes the water environment within and surrounding the application site and the likely significant impacts on it during construction and operation of the proposed development. Mitigation measures that will be incorporated into the proposed development, together with any additional mitigation measures for the construction phase, are proposed to minimise the impact of the scheme on the water environment. Issues relating to groundwater quality are covered in the Ground Conditions chapter (Chapter 8). Key issues relating to groundwater which may influence surface waters are included in this section. 9.2 Methodology Scope of assessment This section of the EIA considers the impacts upon the water environment which includes the hydrology (both low and high flows) and water quality of the proposed development. Impacts of flooding are considered within this chapter in relation to the hydrology impacts and the interactions with water quality. The study area for the water environment has been defined by the area directly affected by the development and any areas beyond which are considered to be within the zone of influence. A separate Flood Risk Assessment (FRA) and Conceptual Sustainable Urban Drainage (SUDS) Strategy (Halcrow, 2011) have been prepared in support of the outline planning application and are referred to and summarised within this chapter. No impacts on groundwater resources and quality are anticipated as a result of interactions with surface water. The consideration of effects on groundwater relating to ground contamination is considered primarily within the Ground Conditions chapter (Chapter 8). Enquiries with Thames Water have established that the local foul sewerage network has sufficient capacity to serve the needs of the development and consequently foul sewerage provision is not considered further in this assessment. Similarly enquiries with regards to the storm water sewerage network have established that there are no capacity issues assuming that discharge rates do not exceed those of the Kodak operation. The Environment Agency has advised that surface water discharge rates are to be limited to Greenfield rates which will require flows to be attenuated on site. This will result in a significant reduction in overall discharge rates and hence a reduction in the sewer flooding risk in the local area. The proposed scope of this assessment is set out in the EIA Scoping Report (Halcrow, 2011) and includes an assessment of impacts upon water quality during construction and impacts upon hydrology and flood risk during operation of the development. A 184

189 scoping opinion was received from the Council in July 2011 (Appendix 4.1). The response referred to issues which are to be considered including: flood risk and the need for an FRA and its content; the use of Sustainable Urban Drainage Systems (SUDS); and the identification and details of mitigation measures and enhancements. Appendix 4.2 has been produced by Halcrow in response to the scoping opinion which identifies how the points raised have been addressed in the appropriate documents. These issues have influenced the preparation of the FRA and the SUDS Strategy and hence, the content of this assessment Data sources A desk based study has been undertaken to identify the baseline environment from which receptors have been identified. Features of the existing environment are discussed below in section 9.4. The desk study has been compiled using information from the following sources: aerial photographs [ water quality data, Environment Agency (EA) [ Kodak Harrow Flood Risk Assessment (Halcrow, December 2011); Harrow Borough Environmental Summary Fact sheet, EA, 2010; and Thames River Basin Management Plan, EA Impact assessment methodology The assessment methodology follows the framework presented in Section 4 whereby, after establishing the existing conditions and identifying receptors of the water environment, the value of these receptors has been established. The criteria used to establish the value of receptors is shown in Table 9.1. Impact types and risks, which have the potential to have a beneficial or adverse impact on a sensitive receptor have been identified. The criteria used to identify the magnitude of an impact are shown in Table 9.2. Following this the level of significance of any predicted effects has then been determined. An assessment has been made of the residual impacts the proposed development could have on hydrology and water quality. Impact assessment prediction has taken into account the proposed mitigation measures to be incorporated into the proposed development where significant effects are identified (i.e. the inclusion of SUDS). As noted above, impacts from flood risk are subject to assessment elsewhere and therefore are not included in the tables below. 185

190 Table 9.1: Water Environment guidance criteria for estimating the value of environmental receptors and resources Value High Medium Low Criteria A water resource which is of high quality and highly sensitive to change. More specifically, a surface water resource of pristine or near pristine water quality, where water quality is not significantly affected by anthropogenic factors, and where water quality does not affect the diversity of species of flora and fauna. Includes sites with international and European nature conservation designations with water-dependent ecosystems: e.g. Special Protection Area, Special Area of Conservation, Ramsar Site and EC designated freshwater fisheries. Also includes all nature conservation sites of national importance designated by statute including Sites of Special Scientific Interest and National Nature Reserves. A groundwater aquifer constituting a valuable resource because of high quality and yield, extensive exploitation for public, private domestic, agricultural and/or industrial supply, or designated sites of nature conservation are dependent on groundwater. A floodplain or flood storage area necessary to protect highly vulnerable development and valued resources from flooding. A water resource of medium quality and medium sensitivity to change. More specifically, a surface water resource with a measurable degradation in its water quality as a result of anthropogenic factors, where the resulting water quality has only limited effect on the species diversity of flora and fauna in the water resource. Includes non-statutory sites of regional or local importance designated for water dependent ecosystems. A groundwater aquifer of limited value because its quality does not allow potable or other quality-sensitive uses (but which may be used for agricultural or industrial purposes) and where exploitation is not extensive, or where local areas of nature conservation are known to be sensitive to groundwater quality. A floodplain or flood storage area protecting development and resources which are classified to be of medium vulnerability. A water resource of low quality and low sensitivity to change. More specifically, a surface water resource with poor water quality resulting from anthropogenic factors, where the species diversity of flora and fauna is greatly affected by significant water quality degradation. A groundwater aquifer of low water quality and/or very low permeability that make exploitation of the aquifer unfeasible, or where changes to groundwater are not expected to have an impact on local ecology. A floodplain or flood storage area with limited or no flood protection value. Negligible A water resource of little or no interest. The nature and characteristics of impacts have been described to enable their magnitude to be determined. The nature of the impacts has first been expressed as: Adverse detrimental or negative impacts on an environmental resource or receptor; 186

191 Beneficial advantageous or positive impact on an environmental resource or receptor; or Negligible an impact on a resource/receptor of insufficient magnitude to affect the use/integrity. Where adverse or beneficial impacts have been identified, their magnitude has been assessed using the criteria set out in Table 9.2 below. Table 9.2: Indicative criteria used to determine the magnitude of adverse and beneficial impacts Magnitude Criteria Major Moderate Minor Loss (or gain) of a water resource or a major shift away from the baseline conditions. Effects that result in a fundamental change to water quality condition either by a relatively high amount over a long-term period or by a very high amount over an episode such that a water resource is greatly changed from the baseline situation. Any change that downgrades a site from good status (as this does not comply with the Water Framework Directive) or results in a loss of salmonid fisheries (or a similar gain would be beneficial). For groundwater, a major permanent or long-term change to groundwater quality or available yield. Existing resource use is irreparably affected. Changes to quality or water table level that have a major impact on local ecology. (If water availability is increased as a result of the development this is considered a benefit). For floodplains, a major loss (or gain through defence or compensation schemes) of flood storage capacity or change to risk of flooding. Loss (or gain) of a part of a water resource or a measurable shift from the baseline conditions. Effects that may be long-term or temporary. Effects that result in a change in the ecological status or productivity/commercial value of a water resource. Changes to the local groundwater regime predicted to have a slight effect on resource use but not rule out any existing supplies. Minor impacts on local ecology may result. For floodplains, a moderate loss (or gain) of flood storage capacity or change to risk of flooding. Localised effect on a water resource or a minor shift away from the baseline conditions. Changes in water quality that are likely to be relatively small, or be of a minor temporary nature such that water resource ecology or commercial value is slightly affected whether beneficial or adverse. Changes to groundwater quality, levels or yields that do not represent a risk to or benefit an existing resource use or ecology. For floodplains, a minor loss (or gain) of flood storage capacity or change to risk of flooding. 187

192 Magnitude Criteria Negligible Very slight change from the baseline conditions such that no discernible effect upon the water resource s ecology results. Very slight change from groundwater baseline conditions approximating to a no change situation. Potential impacts will be primarily assessed using the methodology outlined in Environmental Impact Assessment: A Guide to Procedures (ODPM, 2000) and in accordance with current best practice guidance. Once potential impacts have been considered appropriate mitigation measures that should be implemented as part of the proposed development process have been determined. Following the identification of impacts the magnitude of the impact is determined using the criteria in the table above, along with consideration of the value of the receptor. Once these are established the significance of the impact is determined using the criteria in Table 9.3. Table 9.3: Impact significance based on the value of receptors and the magnitude of impact Magnitude of Impact Value of receptor High Medium Low High Major Moderate/Major Moderate Medium Moderate/Major Moderate Minor/Moderate Low Minor/Moderate Minor Negligible/Minor Neutral/Negligi ble Negligible/Minor Negligible/Minor Negligible Consultation In addition to the consultation undertaken as part of the formal scoping opinion request (see Section 9.2.1), additional consultation has been undertaken with the EA and other statutory consultees to inform the FRA and Conceptual SUDS Strategy (Halcrow 2011b). Details of these consultations can be found in those documents. No additional consultation has been undertaken specifically for the production of this chapter. 9.3 Legislation, policy and guidance Water resources are managed and protected under UK legislation and regulations consistent with European Community Directives. Where relevant, the assessment takes into account the legislative protection afforded to water resources, through relevant plans and policies detailed below: EU Water Framework Directive (WFD) 2000/60/EC; EU WFD Groundwater Daughter Directive 2006/118/EC; 188

193 Groundwater Regulations 2010; Water Resources Act 1991; Water Act 2003, as amended; Water Industry Act 1991 (as amended by the Water Act 2003); Land Drainage Act 1991, as amended; Environment Act 1995, as amended; Environmental Permitting (England and Wales) Regs 2010; Planning Policy Statement 25 (PPS25) Development and Flood Risk (C&LG, 2010); and Flood and Water Management Act A summary of relevant legislation is included in Appendix 4.4. The EA provides guidance on good environmental practice for the prevention of pollution from certain activities in non-statutory Pollution Prevention Guidelines (PPG). Further guidance is also provided in the Control of Water Pollution from Construction Sites A Guide to Good Practice (CIRIA/C532). 9.4 Baseline conditions Hydrology There are no watercourses in open channel within the application site. The application site lies in the upper catchment of the Yeading Brook - West-Headstone Park Branch (as named by the EA on Figure 9.1)'). The West Arm Branch flows through Headstone Manor Recreation Ground where it receives flow from an outlet structure from the moat surrounding Headstone Manor. The channel is culverted in places. Upon exiting the recreation ground Yeading Brook (West Arm Branch) receives flow from an unnamed ditch, which for the purposes of this assessment has been called the Western Boundary Ditch and is shown on Figure 9.1. This Western Boundary Ditch is shown on Ordnance Survey maps to pass along the northern boundary of the Harrow View West site (possibly culverted) in an east to west direction. This ditch emerges into open channel from the gardens on Holmwood Close and runs southwards along the western boundary of Harrow View West site (Figure 9.1). At the southern end of the recreation ground this ditch flows into a culvert under the premises on Fairfield Drive, it turns in a south westerly direction and eventually flows directly into Yeading Brook (West Arm Branch). Yeading Brook, downstream of where this ditch enters, is of reasonable quality, with features such as riffles and small pools. Yeading Brook (West Arm Branch) continues in a south westerly direction through Ruislip. Approximately 7km south west of the application site, near Hillingdon, the 189

194 Yeading Brook (West Arm Branch) joins with the Yeading Brook (East Arm Branch) and continues flowing southwards, later forming the River Crane near Heathrow Airport. Yeading Brook (West Arm Branch) is joined by the Victor Road Branch and the Headstone Park Branch in Headstone Manor Recreation Ground, as shown on Figure 9.1.the Council has advised that the watercourse which extends along Victor Road and Harrow View, and is referred to in the SFRA as 'Yeading Brook-West-Victor Road Branch, is not a watercourse but is the route of a Thames Water sewer that outfalls to Yeading Brook. Existing drainage from the application site discharges at various locations along Harrow View and Headstone Drive. The points of discharge are detailed on the Thames Water Sewer Asset Records which are presented the FRA. The surface water sewer under Harrow View eventually discharges into Yeading Brook (West Arm Branch) as described above. The FRA also identifies that the sewer along Headstone Drive runs eastwards towards the Main West Coast Railway line (Figure 9.1) and the eventual discharge location is unknown. A network of silver recovery drains and a collection lagoon, associated with Kodak s manufacturing process, are also present within the application site. As noted in the FRA the lagoon discharges to the surface water drainage network, however it does not attenuate any surface water drainage flows Historical water quality The nearest point to the application site at which the Yeading Brook is currently monitored for quality by the Environment Agency (EA) is at North Hyde Road in Hawes, over 10km from the application site (NGR TQ ). The Yeading Brook tributaries within and near to the application site are not currently monitored for water quality by the EA. However previously, before a reduction in the monitoring network, the east and west arm branches were monitored. At this time water quality was monitored in accordance with the EA s General Quality Assessment (GQA) methodology with water quality being graded from A (very good) to F (bad). Under this previous system, the Yeading Brook (East and West Arm Branches) showed very poor water quality, although the east section was the worse of the two. This achieved only grade E until 2000 when it improved to a grade D. The west section was historically grade D meaning the quality was poor. The EA s factsheet for the Harrow Borough identifies that the Yeading Brook passes through a densely populated area and is likely to be affected by misconnections, due to incorrect domestic plumbing, which results in dirty or foul water being discharged into the watercourse. The Yeading Brook West Arm Branch may have slightly better water quality due to recent improvements of some unsatisfactory polluted surface water outfalls (EA s factsheet) Water Framework Directive 190

195 The Water Framework Directive (WFD) (2000/60/EC) introduced a new system for monitoring and classifying the quality of surface and ground waters. The process involves establishing the existing ecological and chemical status of all classified groundwater and surface waters, setting environmental objectives and devising programmes of measures to meet those objectives. The WFD sets a target of aiming to achieve at least good status in all waters. Whilst good ecological status is defined as a slight variation from undisturbed natural conditions in natural water bodies, artificial and heavily modified water bodies, such as the Yeading Brook, are considered unable to achieve natural conditions. Instead, artificial and heavily modified water bodies have a target to achieve good ecological potential. Ecological potential (as well as ecological status) is measured on the scale: high, good, moderate, poor and bad. Chemical status is recorded as good or fail. For a surface water body to be in overall good status or potential, both its ecological and chemical status must be at least good. The WFD also requires that ecological status or potential does not decline over time. The application site lies within the Thames River Basin District within which the Yeading Brook (West Arm Branch) is classified as a heavily modified water body (HMWB) due to urbanisation and flood protection. Table 9.4 provides WFD classification data for Yeading Brook. Table 9.4: Summary WFD classification data for Yeading Brook (west arm) from the Thames River Basin Management Plan. Category Water body ID Current Ecological Status Current Chemical Quality Yeading Brook (West Arm) GB Moderate Potential Does Not Require Assessment Status objective Good ecological potential by 2027 Protected Area Downstream water body Yes (Nitrates Directive) GB Crane (including part of the Yeading Brook) 191

196 Yeading Brook (West Arm Branch) is currently considered to be of poor status for invertebrates and moderate status for fisheries. It is considered to be technically unfeasible to achieve good potential by 2015 for this water body; therefore the water body has a target to meet good potential by and there are a range of mitigation measures proposed to be implemented to ensure this Discharges from sewage works Currently, surface water generated from the application site discharges to the Thames Water surface water sewers and the Western Boundary Ditch. Harrow is served by Mogden sewage treatment works (STW), near Twickenham, which discharges into the tidal River Thames at a rate of 690,000 cubic metres per day. Mogden currently serves a population equivalent of 1.85 million people and has been identified by Thames Water as having future growth/capacity issues. Thames Water is planning to improve Mogden by improving the unsatisfactory storm overflows and flow to full treatment Water resources and supply The River Thames is the primary source of the public s water supply in London. The split of licensed abstractions made within London indicates that approximately 63% of London s supply is taken from the freshwater River Thames upstream of Teddington Weir and stored in reservoirs. A further 22% of London s water supply comes from the River Lee. The remaining 15% of the water supply comes from groundwater, from the confined chalk aquifer beneath London. Above the chalk aquifer is a layer of London clay which, at the application site, is approximately 6-10m thick. The clay prevents the movement of water between surface waters and the aquifer, assuming it remains intact. Therefore there is no interaction between surface waters and ground waters. All of Harrow falls in Thames Water s London Water Resource Zone (WRZ), where average water consumption in was 170 litres per person per day. This compares to the five year average for the Borough of litres per person per day between 2005/06 and 2009/10. This WRZ is classified by the EA as being seriously water stressed. The Government has set a target for households to achieve 130 litres per person per day Abstractions and discharges 3 These are dates that the EU has chosen for the directive by which the status must be achieved to comply with the directive. 192

197 There is one abstraction licence held by Kodak Ltd (ref no. 28/39/36/0001) which uses groundwater. This licence will no longer be required following the proposed development of the application site, therefore releasing water for other uses. There are no discharge consents within 1km of the application site. Consequently there are considered to be no adverse impacts on abstractions or discharges from the proposed development of the application site and these receptors are not considered further Flood risk and drainage A FRA (Halcrow 2011b) has been produced for the proposed development of the application site which has considered the risk of flooding from a variety of sources. From a review of the EA s flood mapping website the development site lies within Flood Zone 1, which is described as having a low flood risk. This flood zone comprises land assessed as having a less than 0.1% annual probability (1 in 1000 chance of occurring in any given year) of river or sea flooding. The FRA confirms that in accordance with PPS25 all uses of land are appropriate in this zone. The EA has confirmed in writing that the south west corner of the Harrow View West site is 160m away from Flood Zone 2 however the Council s Strategic Flood Risk Assessment (SFRA) (MWH 2010) identifies that a small area of the application site (the south west corner of the Harrow View West site) is located within the functional flood plain. This is in contradiction to the data supplied by the EA but has been taken into account in the development of the parameter plans. The FRA identifies that pluvial flooding, due to large quantities of runoff being generated during heavy rainfall and allowing for climate change, is a primary source of flood risk due to the physical size of the development. This form of flooding can affect both the application site and adjacent lower lying areas. A SUDS drainage strategy has been developed that demonstrates that the parameter plans provide sufficient space for water and that properties can be protected from the risk of surface water flooding. The potential for flooding from groundwater sources has been discounted as the application site is underlain by 6-10m of clay which inhibits the movement of groundwater from the aquifer beneath Groundwater The application site lies on a layer of London Clay, classified as a non aquifer. From a review of the EA s website the application site is not located near to any source protection zones (SPZ). On the basis of the application site investigation undertaken for the North Car Park and Zoom Leisure as described in the Phase II Environmental Site Assessment (Conestoga et al 2008) and other sources, the application site overlies at least 0.5-1m of made ground. Underlying the made ground is London Clay (non-aquifer) to a depth of between 6 and 10m below ground level. As a result, interactions between surface and groundwater in the underlying Chalk are not expected and groundwater would be unlikely to affect surface water quality. 193

198 It is noted that some elevated concentrations of contaminants were identified in the application site assessment (Conestoga et al 2008) both in soils and in groundwater when compared with Drinking Water Standards. The impacts on groundwater resulting from the elevated concentrations of contaminants identified in the soils are assessed in the Ground Conditions chapter (Chapter 8). Therefore, this receptor is not considered further in this assessment Value of receptors From analysis of the above baseline information, the key water environment receptors for the application site, which could potentially be affected by the proposed development via a valid pathway, are identified in Table 9.5, together with their identified value. Table 9.5: Summary of identified water environment receptors and their assigned value and proximity to the application site. Receptor Indicators/features Value Yeading Brook (West Arm Branch) Western boundary ditch (tributary of Yeading Brook (West Arm Branch) Historical water quality data shows of poor quality. Partially culverted usually indicating poor water quality, but lower reaches show more natural features. Does not support any licensed abstractors. Has a small associated floodplain. Under WFD the watercourse is currently of moderate potential. Partially culverted usually indicating poor water quality. Does not support any licensed abstractors. Low value in terms of land drainage and preventing flooding. Not designated under WFD. Suffers from low and intermittent flows. Medium Low 9.5 Assessment of impacts prior to and during construction The construction stage of the proposed development poses risks to the water environment in terms of a potential risk to water quality. The nature and extent of the risks are explained below and an assessment is made of the significance of the potential impacts in accordance with the methodology and criteria described in Section Water quality of surface water bodies The activities during construction which may lead to water pollution include: exposure of permeable areas, earth movement, mobilising contaminants into surface water receptors; 194

199 wheel washing runoff, or muddy runoff from highways if appropriate wheel washes are not used; pollution due to vandalism of stores or plant; poor/inappropriate storage of materials and chemicals/fuels and wastes such as on permeable surfaces or without sufficient bunding capacity; creation of preferential pathways via piling operations, drainage schemes and services corridors; and pumping of contaminated surface water or groundwater accumulated on the application site or via de-watering directly into controlled waters. There is the potential that the Western Boundary Ditch and Yeading Brook (West Arm Branch) could be directly affected by pollution from the application site during construction which could result in impacts on water quality. Common issues could potentially include accidental spillages of fuels, lubricants and hydraulic fluids from construction plant, spillages of chemicals, hazardous materials, concrete slurry and sediment laden waters/runoff. Pathways may involve direct discharge to these watercourses, surface flow into a water body and discharge to a water body via means of a drainage system (i.e. if polluting materials are poured down the drains, such as those connecting to the surface water sewer under Harrow View). The Western Boundary Ditch and the surface water sewers provide a pathway for indirect impacts on the water quality of the main channel of Yeading Brook (West Arm Branch), located 150m downstream of the application site. As such, control of site runoff and drainage during construction will be of great importance. The magnitude of this impact can vary depending upon the location, quantities of sediment or pollutants released and the flows in the Western Boundary Ditch and Yeading Brook (West Arm Branch) at the time. During higher flows such as after rainfall events there will be greater dilution capacity of the watercourses and during fast flows the sediments or pollutants may be carried further downstream before being deposited. Without mitigation the magnitude of such an impact could be considered to be Medium on those receptors considered to be of Medium value (i.e. Yeading Brook (West Arm Branch)) and of low magnitude on the western boundary drain which is of low value. The significance of the impact is summarised in the table 9.6 below. 195

200 Table 9.6: Impact significance without mitigation of impacts upon water quality during construction. Receptor Value Magnitude of Impact Significance (without mitigation) Yeading Brook (west arm branch) Medium Medium Moderate adverse Western boundary ditch Low Low Negligible/Minor adverse Flood risk As stated in the FRA the runoff rates during the operation of the proposed development are to be attenuated to Greenfield rates to protect the downstream areas and drainage networks from increased risks of flooding. However during construction the proposed drainage system (including SUDS and attenuation facilities) will not necessarily have been installed and consequently there is a risk that not all flows will be attenuated during the operational phase. This poses a risk of flooding to the application site itself and potentially of increasing discharges into the local watercourses, particularly the Western Boundary Ditch during the works on the Harrow View West site. The Harrow View East site will drain to the surface water sewers (in Harrow View and Headstone Drive) and during a heavy rainfall event there is a possibility that, if flows are unattenuated, the sewers could reach maximum capacity cause flooding on the application site. The risk of this occurring during construction could be high at certain times when paved areas are still present within the application site which will provide overland flow routes. Once paved areas are removed the surface will be permeable and infiltration possible thereby reducing runoff rates and the risk will then be low. The magnitude of the impact from a flood event, when paved areas are still present on site, could be considered, as a worse case, to be of low to medium magnitude depending upon the location, intensity and duration. The significance of the impact upon the receptors without mitigation is summarised in the Table 9.7 below. Table 9.7. Significance of impacts upon flooding during construction, without mitigation Receptor Value Magnitude of Impact Significance (without mitigation) Yeading Brook (West Arm Branch) Western boundary ditch Medium Medium Moderate adverse Low Low Minor adverse 196

201 9.6 Assessment of impacts during operation Introduction Operational impacts are those which will occur following the completion of the proposed development and are generally considered to be more long term impacts. Often it is difficult to quantify the magnitude of long term impacts due to the timescales over which they may occur and the resilience of the environment to adapt to future changes, therefore professional judgement is used to undertake the assessment. The nature and extent of the impacts are explained below and an assessment is made of the significance of the potential impacts Water quality Preferential pathways for the movement of potential contaminants and pollutants may be created as a result of changes in the drainage regime of the application site. New sources, or the increased significance of existing sources of potential contaminants, may also occur and may include: sediment within surface water runoff; contaminants from vehicles (i.e. pollutants within the runoff from hardstanding areas such as roads and driveways); accidental spillages; and discharge of wastes, chemicals or foul water to surface water sewer drains or ground. These impacts have the potential to degrade surface water receptors over time. The magnitude of this adverse impact would be low on surface water receptors. The significance of the potential impact is shown in Table 9.8 below. Table 9.8: Impact significance of impacts upon flooding during operation, without mitigation Receptor Value Magnitude of Impact Significance (without mitigation) Yeading Brook (west arm branch) Medium Low Minor adverse Western boundary ditch Low Low Minor adverse Flood risk and drainage Without mitigation for attenuation of surface water runoff from the application site there would be potential impacts on the application site and areas downstream in relation to flood risk. These risks have been considered, with reference to PPS25, as part of the FRA and have informed the conceptual SUDS drainage strategy. As these 197

202 measures are considered to be part of the development proposals and not mitigation the impacts on flood risk from land are not considered further in this assessment. The FRA (Halcrow, December 2011) states that the aspiration of the proposed development is to retain runoff from the application site temporarily within the application site during storm events and release it at the original Greenfield rate. The FRA demonstrates that the developed site can accommodate the runoff generated by a 1 in 100 year storm, including an allowance for climate change and that the development proposals can be implemented without increasing any form of flood risk. It is recommended that the development site is served by a variety of SUDS techniques and attenuation features, suited to the design and site conditions, including swales, ponds, dry basins, permeable paving and attenuation tanks. The use of infiltration SUDS on the application site is not considered appropriate due to the impermeable nature of the underlying geology (i.e. London Clay) and the presence of contaminants in the Made Ground overlying the site. The SUDS networks will lead to a reduction in the current runoff rate from the existing site and therefore the proposed development will have a beneficial impact in terms of flood risk. 9.7 Mitigation measures During construction To mitigate short term impacts relating to the construction phase of the proposed development a Construction Environmental Management Plan (CEMP) will need to be prepared by the Principal Contractor and Environmental Manager in consultation with the EA and the Council s Environmental Health Officer. The CEMP will serve as an overarching planning and guidance document setting out the Contractor s best practice approach and methodology for management of the construction environmental risks, how environmental management measures will be implemented and how adverse impacts on the surrounding environment and local community will be minimised during construction Water quality Mitigation measures to be incorporated in the CEMP to address the identified adverse effects on water quality described above should build upon pollution prevention measures set out in the EA s Pollution Prevention Guidelines (PPGs): EA PPG01 General guide to the prevention of pollution; EA PPG02 Above ground oil storage tanks; EA PPG05 Works and maintenance in or near water; EA PPG06 Working at construction and demolition sites; EA PPG07 Refuelling facilities; 198

203 EA PPG08 Safe storage and disposal of used oil; EA PPG13 Vehicle washing and cleaning; EA PPG 18 Managing fire water and major spillages; EA PPG20 Dewatering underground ducts and chambers; EA PPG21 Pollution incident response planning; EA PPG22 Dealing with spillages on highways; and EA PPG26 Storage and handling of drums and intermediate bulk containers. In addition to the above PPGs the CEMP will also be prepared in accordance with CIRIA guidance documents, including Report 156: Control of water pollution from construction sites a guide to good practice (2001) and Report C648 Control of water pollution from linear construction projects (2006) which provides additional detail on actions required to reduce the impact of construction works on the water environment. The following website, compiled by UK environmental regulators, provides comprehensive environmental legislative guidance and basic requirements pertaining to demolition and construction works which should also be referred to when compiling the CEMP. The documents provide a range of measures to reduce and remove risks to the water environment, a selection of which includes the following: High risk activities will be undertaken away from sensitive receptors (i.e. watercourses and connections to surface water sewers), where practicable (e.g. re-fuelling area). Any drainage within a refuelling area will incorporate an isolation facility such that the outlet could be sealed in the event of a spill; An emergency spillage response plan will be produced, including location and types of spill kits and will also provide a full list of protocols and communications channels with the EA in the event of an accidental pollution incident; Appropriate equipment such as booms and absorption mats, in the event of an accidental spillage or pollution incident will be made available and easily accessible; Site signage will be erected showing who to contact in the event of a spillage or emergency; Monitoring of works areas to identify spills or possible leaks will be undertaken regularly; Location and type of bunded compounds for storage of fuel, refuelling and handling of chemicals (complying with current regulations for the safe storage of fuels, lubricants and other chemicals) will be sited to prevent leakage; 199

204 All plant used during the works will be of modern design, clean, inspected as suitable for use before delivery and use on site, inspected regularly for leaks and damage, and stored overnight in fuelling areas away from excavations or drainage; Drip trays will be used beneath all static plant or semi-static plant to prevent leakage and these will be checked regularly and emptied of rainwater as hazardous waste; All construction-phase routine maintenance of vehicles and machinery will be conducted off site and operational-phase maintenance work will be conducted in areas designed to prevent the pollution of surface waters; There will be appropriate designation of site parking and delivery waiting areas to minimise the potential for contamination of receiving surface waters by uncontrolled releases (i.e. leaks and drips); There will be protocols for vehicle washing activities and wash water management; The application site will be appropriately secured and monitored to prevent vandalism; Development of an erosion and sediment control plan or drain isolation which will consider the management of stock piles to limit runoff and potential pollution and minimise the movement of materials around the construction site (i.e. minimise double-handling); Any de-watering works will be appropriately managed to prevent entry of contaminants into surface waters and surface water sewers and any dewatered waters will be appropriately handled and disposed of. Sediment-laden waters will be pre-treated (settled) to remove suspended sediment prior to discharge; pumped water will be disposed of to grassed land or into an infiltration/settlement basin or soakaway. Offline settling tanks or settling basin may need to be installed for some of the works. Pumping needs to be at a slow rate to allow water to infiltrate and prevent scouring. Any temporary discharges to watercourse or sewer will be appropriately consented and approved by the EA/ sewerage undertaker. Water will be pump-returned to the watercourse at a slow rate or the energy of water dissipated to avoid disturbing and eroding the channel bed; and Site welfare facilities are to be self-contained units. The contractor will be required to demonstrate that all site managers, supervisors, foremen and operatives, together with security staff, will be provided with the relevant training and awareness of site procedures and the best construction practice. Should any pollution incidents occur the EA will be contacted without delay. Where possible, impacts will be avoided through the design, location and timing of works. With the application of the proposed mitigation measures, the impacts on water quality during construction are anticipated to be reduced to a negligible magnitude 200

205 resulting in a negligible impact. It should be noted that the significance of the residual effects is based upon an assumed effectiveness of the proposed mitigation measures and assumes that all mitigation measures are implemented correctly Flood risk Where possible, impacts will be avoided or mitigated for through the design process, location and timing of works. During the construction phase, prior to completion of the permanent drainage system, there will be potential flood risks to the application site and surrounding areas due to uncontained and/or unattenuated surface water flows being released to watercourses and the surface water sewers. Such risks will need to be managed by the creation of temporary drainage, sumps, cut off trenches and on site storage as appropriate. Overland flow paths during the different phases of construction will need to be considered and included in the CEMP. With mitigation in place and appropriate timing of works the impacts from flood risk during construction is anticipated to be negligible. These risks have been considered, with reference to PPS25, as part of the FRA and have informed the conceptual SUDS drainage strategy During operation The mitigation of long term effects relating to flood risk will be managed as part of the detailed design. A conceptual SUDS drainage strategy has been developed to demonstrate that sufficient space has been made available for the management of water, including both the conveyance and attenuation systems and that properties are protected from the risk of surface water flooding. The local drainage authority will be responsible for maintaining the systems where adopted otherwise responsibility will fall to a management company. The ponds and swales, forming part of the conceptual SUDS drainage system, will assist with the removal of sediment from the surface water before final discharge to the watercourse and sewers. Other features likely to be considered at the detailed design stage to further promote sediment removal and improve water quality are expected to include silt traps, settlement basins, and reedbeds. By implementing such measures the impacts of the proposed development on water quality during operation will be negligible. Given that the Yeading Brook water body, as identified in the RBMP, is outside of the application site, the proposed development will not contribute or hinder the implementation of the mitigation measures or the target status of this water body as identified in the RBMP. 9.8 Conclusions and statement of residual significance Assuming that the mitigation measures identified in Section 9.7 are implemented appropriately, the residual effect on the water environment of the proposed development is anticipated to be reduced to negligible during construction. Residual impacts during operation are anticipated to be negligible with the introduction of a 201

206 SUDS based drainage system providing a beneficial impact. The assessment on the water environment is summarised in Table 9.9. Table 9.9: Significance of residual effects identified during the construction and operation of the proposed development following the implementation of mitigation measures Receptor Summary description of impact Significance of potential effect prior to mitigation Proposed mitigation Residual significance Construction Yeading Brook (west arm branch) Water quality Moderate adverse Implementation of CEMP Negligible Western boundary ditch Water quality Negligible/ Minor adverse Implementation of CEMP Negligible Yeading Brook (west arm branch) Flood risk and drainage Moderate Implementation of CEMP. Impacts avoided through the design, location and timing of works Negligible Western boundary ditch Flood risk and drainage Negligible/ Minor adverse Implementation of CEMP. Impacts avoided through the design, location and timing of works Negligible Operation Yeading Brook (west arm branch) Water quality Minor adverse Mitigation incorporated into design (via use of SUDS) Negligible Western boundary ditch Water quality Negligible/Min or adverse Mitigation incorporated into design (via use of SUDS) Negligible 202

207 Receptor Summary description of impact Significance of potential effect prior to mitigation Proposed mitigation Residual significance Yeading Brook (west arm branch) Flood risk and drainage N/a Reduction in current runoff rates through the incorporation of SUDS into the design of the proposed development Minor beneficial impact Western boundary ditch Flood risk and drainage N/a Reduction in current runoff rates through the incorporation of SUDS into the design of the proposed development Minor beneficial impact 203

208 10 Biodiversity 10.1 Introduction This section presents an Ecological Impact Assessment (EcIA) which considers ecology and nature conservation issues relating to the proposed development of Harrow View. This assessment has been undertaken to determine the potential impacts of the proposed development n the ecological features that occur within the application site and in its zone of influence (as defined by IEEM, 2006 i.e. 2km radius from the centre of the application site). It also describes the mitigation measures likely to be required and the opportunities available for potential ecological enhancements. The assessment is based on results from a systematic desk study, habitat surveys and protected species surveys carried out during 2010 and Methodology Scope of assessment Based on the desk study and surveys undertaken in 2010, the Scoping Report (Halcrow, 2011a) concluded that no additional ecological surveys were required for the EcIA and that sufficient information had been obtained to assess potential impacts on ecological features present within the application site and also within its zone of influence (i.e. 2km radius from the centre of the application site). The Scoping Report (Halcrow, 2011a) states that, based on the results of the comprehensive site surveys undertaken in 2010, specific consideration of issues relating to any legally protected species was not required in the EIA (i.e. these issues have been scoped out). However, assessment of unprotected species and habitats and potential opportunities linked to habitat creation proposals, as incorporated within the illustrative masterplan and described in Section 3, was required. As described in Section 4.2, the scoping opinion received from the Council in July 2011 highlighted the following key concerns relevant to the scope of the EcIA: No consideration of the ecological value of the watercourses within the application site was made within the EIA Scoping Report; and Due to the sub-optimal timing of the extended Phase 1 habitat survey in January 2010, the potential presence of species of notable flora and invertebrates may not been have fully assessed. There are no watercourses within the application site, although an open watercourse (a ditch) aligns the western boundary of the Harrow View West site within the Headstone Manor recreation ground (called the western boundary ditch in this report). A walkover survey of this watercourse, undertaken on 5th April 2011, identified very little flow and low nature conservation value. To address the concerns relating to the validity of the Phase 1 habitat survey (Appendix 10.1), an additional survey was undertaken on 29th July 2011 to re-assess 204

209 the entire application site and the conclusions of the previous extended Phase 1 survey, focusing on notable species and potential invertebrate interest. This incorporated an additional survey of the 'Yeading Brook (west-arm branch), (which aligns the western boundary of Harrow View West boundary within Headstone Manor recreation ground) focusing on notable plant species and legally protected species. These surveys did not identify any additional constraints and demonstrated that the original surveys were correct in their assessment of minimal ecological value (see Appendix 10.2). The results of these surveys are considered within the EcIA, but have not changed the scope of the assessment from that set out within the EIA Scoping Report i.e. that sufficient information has been obtained to assess potential impacts on ecological features that are present within the application site and within its zone of influence Assessment methodology Sources of information and survey methods Ecological baseline information has been collected through a number of studies, undertaken during the scoping stage Desk study Surveys The first step in identifying ecological survey requirements was to undertake a systematic desk study involving a review of records of habitats and species present in the zone of influence. This was commissioned from Greenspace Information for Greater London (GiGL) and from London, Essex and Hertfordshire Amphibian and Reptile Trust (LEHART). Table 10.1 lists the specialist ecological surveys that have been undertaken in the application site and, where relevant, the zone of influence, detailing the date the survey was undertaken, the methodology used and the area covered. It also indicates which appendix to refer to for further information. Table 10.1: Methodology and timings of specialist ecological surveys Survey Survey methodology Date undertaken Survey area Further details in Extended Phase 1 habitat Extended Phase 1 habitat survey in accordance with JNCC (2007) methodology - identified the main habitats on the application site and the presence of, or potential for, protected and/or notable species January 2010 The entire application site Appendix 10.1 Re-assessment of Phase 1 survey and confirmation of survey conclusions. July 2011 The entire application site Appendix

210 Survey Survey methodology Date undertaken Survey area Further details in Bats Bat Potential Assessment: Built Structures and Internal Building Inspections, in accordance with standardised methodologies as defined in the Bat Workers Manual (Mitchell- Jones 2004) and the Bat Survey Guidelines (Bat Conservation Trust, 2009) July 2010 All built structures within the Harrow View West site Appendix 10.3 Great crested newt Bottle trapping, egg searching and netting undertaken, in accordance with the guidelines set out in the Herpetofauna Workers Manual (Gent and Gibson, 2003) and Great Crested Newt Mitigation Guidelines (English Nature, 2001) July 2010 Headstone Manor moat (Harrow Museum) Appendix 10.4 Reptiles Reptile presence/likely absence survey, in accordance with the Herpetofauna Workers Manual (Gent and Gibson, 2003) and Froglife Advice Sheet (1999) May/June 2010 All suitable habitat within the application site (parts of Harrow View East site and Harrow View West site) Appendix 10.5 Visual tree assessment Visual tree assessment, including preparation of a tree constraints plan, in accordance with Mattheck and Breloer (1994) December 2010 The entire application site deleted Watercourses Ecological walk-over assessment April 2011 Western boundary ditch and Yeading Brook Appendix 10.7 Assessment of western boundary ditch during Phase 1 re-assessment July 2011 Western boundary ditch Included in Appendix Impact assessment The assessment has been undertaken according to the IEEM Guidelines for Ecological Impact Assessment in the UK (IEEM, 2006), which comprises the two stages (identification and valuation of features; and assessment of impact significance) described below. Identification and valuation of features Valuation of ecological features relies heavily on professional judgement and includes consideration of factors such as size, conservation status and quality of the 206

211 feature, as well as the policy and legal significance. The potential for a feature to increase in value (e.g. through habitat restoration) should also be taken into account. The value of habitats is measured against published selection criteria where available and reference is made to UK and local Habitat Action Plans (HAPs). The value of populations of different species also makes use of relevant published evaluation criteria where available, with reference to UK and local Species Action Plans (SAPs) and to lists of declining species. In accordance with the IEEM guidelines (2006) a geographic frame of reference has been applied to the valuation process. For the proposed development of the application site, the following geographic scales are relevant: Regional/county: e.g. habitats or species populations considered to be of value within Greater London. These are Sites of Metropolitan Importance, which include the best sites in London; District: e.g. habitats or species populations considered to be of value within the London Borough of Harrow. Sites designated as Sites of Borough Importance or Sites of Local Importance; Local: e.g. habitats or species populations of value in a local context (i.e. sites within the area of Wealdstone or Headstone); and Within the immediate zone of influence : i.e. within the application site and area in which ecological impacts may occur outside the application site boundary. The IEEM guidelines recommend that a threshold of value for the ecological features is defined i.e. the geographical scale at which the impact is significant. This threshold value relates to the consequences of impact, in terms of legislation, local planning policy and/or development control. Any ecological features identified above this threshold require more detailed assessment. For the purposes of this assessment, the threshold level of value has been set at local, i.e. ecological features of wildlife value in Wealdstone and Harrow (The Mayor s Biodiversity Strategy promotes no overall loss of wildlife habitats in London this is interpreted as referring to wildlife habitats of local value). Therefore, from Section 10.5 onwards ecological impacts are assessed in detail only for features of at least local value or for features that are subject to some form of legal protection (i.e. under the Wildlife and Countryside Act 1981, as amended). Assessment of impact significance When describing changes/activities and impacts on the identified ecological features, reference is made to the following parameters: whether the change/impact is positive or negative; magnitude the size or amount of impact (e.g. minor, medium, major); duration the time for which an impact is expected to last prior to recovery or replacement of a feature (e.g. short term, long term); 207

212 reversibility whether the change/impact is temporary or permanent; whether the change/impact is direct or indirect; and timing and frequency of the change/impact. All aspects of the construction and operation of the proposed development were subject to impact assessment in terms of biodiversity. The significance of the impacts of the proposed development has been assessed before and after mitigation (i.e. residual effects) and in the context of relevant legislation, local planning policy and development control. Impacts are considered significant when they are likely to have an effect (positive or negative) upon the integrity of ecological features within the zone of influence of the application site. Integrity encompasses the functioning and processes on which ecosystems depend and is defined as: The integrity of a site is the coherence of its ecological structure and function, across its whole area that enables it to sustain the habitat, complex of habitats and/or the levels of populations of the species for which it was classified. (DCLG, 2005a). Impacts are also considered significant if they are likely to have an effect upon the conservation status of habitats or species within a defined geographical area, with international conservation status being the most important and local conservation status the least important. The likelihood that a change will occur and also the degree of confidence in the impact assessment are indicated using the following scale: certain/near certain: probability estimated at 95% chance or higher; probable: probability estimated above 50% but below 95%; unlikely: probability estimated above 5% but less than 50%; and extremely unlikely probability estimated at less than 5% Consultation In addition to formal consultation on the Scoping Report (via the Council), the council Biodiversity Officer was also consulted regarding queries raised on the timing of the Phase 1 habitat survey and the value of potentially impacted watercourses. The comments received were addressed via a Phase 1 re-assessment (see Table 10.1), which included a comprehensive walk-over assessment of the relevant watercourses (i.e. the western boundary ditch). It was agreed with the Council s Biodiversity Officer that this was an acceptable approach Legislation and policy The key legislation, policy and guidance relevant to the proposed development at the application site and this assessment are: The Wildlife and Countryside Act 1981 (as amended); The Conservation of Habitats and Species Regulations 2010; Countryside and Rights of Way (CRoW) Act 2000; 208

213 Planning Policy Statement 9 (PPS9) Biological and Geological Conservation (2005); The London Plan: Spatial Development Strategy for Greater London (July 2011). This replaces The London Plan February 2008, consolidated with alterations since 2004; The saved policies within the adopted Harrow Unitary Development Plan (UDP) (July 2004). Of particular relevance are policy EP26 Habitat Creation and Enhancement and policy EP28 (Conserving and Enhancing Biodiversity); London Biodiversity Action Plan (London BAP): this identifies priority habitats that are of particular importance for biodiversity in London. The London Biodiversity Partnership has developed London Habitat Suitability Maps, which can be used by partners and developers to identify areas where creating and improving habitats would give the best benefit to biodiversity; Harrow Council Biodiversity Action Plan (Harrow BAP, 2008), and in particular the following individual plans: Generic Action Plan; Decaying Timber HAP; Grassland HAP; Park and Amenity Grassland HAP; and Standing and Running Water HAP; The Mayor s Biodiversity Strategy (2002): this document details the Mayor's vision for protecting and conserving London's natural open spaces. It seeks to ensure that there is no overall loss of wildlife habitats in London and that more open space is created and made accessible, so that all Londoners are within walking distance of a quality natural space; Harrow Council Nature Conservation Strategy (referenced in Harrow BAP not dated): aims to ensure the conservation, protection and enhancement of wildlife and its habitats in Harrow for current and future generations; Scrutiny Review of Public Green Spaces (Harrow Council, 2006): recommends the development of a BAP and a HAP for private gardens and open spaces; and The All London Green Grid (website: accessed August 2011): provides a strategic framework for creating, improving, managing and maintaining high quality Green Infrastructure and promotes cycling and walking throughout London. A full description of legislation, policy and guidance relevant to this assessment is given in Appendix Baseline conditions Introduction The following sections focus on ecological features that have been scoped in. The Scoping Report (Halcrow, 2011a) details all other baseline conditions. 209

214 There are no statutory sites designated for nature conservation within 2km of the application site. There are 8 locally designated sites within 2km of the application site boundary. All of these are set some distance (minimum 750m) from the application site and are not hydrologically or otherwise connected, with the exception of Headstone Manor Copse Site which is of Borough Grade II Importance for Nature Conservation (HwBII07). However, this site has been scoped out of the impact assessment due to its distance from the application site (120m at nearest point) and the nature of the habitat present (dry woodland) Harrow View West site habitat The Harrow View West site is dominated by amenity grassland (sports pitches and bowling greens) and tarmaced tennis courts. To the north and east are large hardstanding areas (car parks) which contain various outbuildings. The application site is bordered by well maintained single-species hedges. The eastern boundary supports amenity shrub planting with trees. The southern boundary is marked by a very tall Leylandii hedge, the western boundary by Leylandii to the south and poplars to the north, and the northern boundary by various trees and scrub bushes. These tree and shrub features have the potential to provide habitat for breeding birds. However, they are considered of low ecological value in their own right (ref. Arboricultural Impact Assessment, Kodak, by Landmark Trees, 2011) and are therefore not included in the impact assessment (Section onwards) Harrow View East site habitat Parts of the Harrow View East site are bordered by mature trees (some of which are non-native). These tree and shrub features have the potential to provide habitat for breeding birds. However, they are considered of low ecological value in their own right (Landmark Trees, 2011) and are therefore not included in the impact assessment (Section onwards). Other than amenity planting around the main office block, an area of mown grass at the northern end and a small area of coarse grassland on the eastern boundary, there is little vegetation present in this part of the application site Visual tree survey The visual tree survey, carried out by Landmark Trees in December 2010, showed that trees or groups of trees on or around the application site were of low to moderate quality and generally concentrated around the periphery. Tree species were dominated by Lombardy poplar (Populus nigra), lime (Tilia sp.) and cypress (Cupressocyparis leylandii). These tree and shrub features have the potential to provide habitat for breeding birds. However, they are considered of low ecological value in their own right (Landmark Trees, 2011) and are therefore not included in the impact assessment (Section onwards) Species of conservation concern Based on the desk study and site surveys undertaken during the scoping stage, Table 10.2 Error! Reference source not found. summarises the legally protected species or 210

215 species of recognised conservation concern that are present or potentially present within the application site and therefore scoped in. Species scoped out of the assessment include badgers, great crested newts, reptiles, water vole, stag beetle, black redstart and invasive species, as described in the EIA Scoping Report (Halcrow 2011a). Table 10.2: Present or potentially present legally protected species or species of recognised concern Species Bats Breeding birds Presence or possible presence within areas impacted by the proposed development Medium potential for bats to be roosting in some of the buildings and trees at Harrow View West site given the presence of suitable habitat features. Negligible potential at the Harrow View East site. However, no evidence of roosting bats was found during a survey, including an internal and external inspection of all buildings and trees, undertaken in July 2010 High potential to be present in all areas of scrub, amenity planting and trees Valuation and potential for impact of ecological features For features that are scoped in, this section describes potential impacts that may occur as a result of the proposed development of the application site, without mitigation. The geographic value of these features is also identified. Breeding birds potential disturbance to nesting birds from works or removal of trees, shrubs and hedges in which they are nesting. This feature is valued as within the zone of influence, but as breeding birds receive legal protection, these are scoped in for further assessment; and Bats potential death or injury of bats. If found to be present in the future, this feature would be considered of local value. Bats also receive legal protection and so are scoped in for further assessment. Note however, that no evidence of roosting bats was found during surveys carried out in Assessment of impacts during construction Potential impacts Potential ecological impacts could occur as a result of demolishing buildings, clearing land/vegetation and as a result of the construction process (see Section 2). Positive impacts can occur as a result of habitat creation, including the planting of trees and shrubs on the entire site and the creation of the proposed SUDS wetland area on the Harrow View West site. Following comprehensive surveys undertaken throughout 2010 and in accordance with the assessment methodology described in Section , only two groups of species (bats and breeding birds) were identified as requiring further detailed 211

216 Bats assessment within the EIA. Positive impacts on habitats are also subject to assessment, for example from the habitat creation. Surveys have confirmed that bats are not using the potential roost habitats identified in trees and buildings within the application site. Sufficient information has been obtained to conclude that the impact of construction on bats is not significant, predicted with a near certain degree of confidence. However, as a precautionary measure, further surveys will be undertaken prior to any demolition/construction works. This will ensure that the assessment remains as up to date as possible. The works are planned in five phases, with the final phase of development (part of the Harrow View East site) due for completion in 2020 (see Section for details on phasing). As bats may begin to roost in buildings or mature trees, this precautionary approach is therefore justified. If bat roosts are found to occur on the application site in future, mitigation can be carried out to re-locate them. A licence would be required from Natural England for this procedure to take place Breeding Birds The proposed development is likely to result in the loss or reduction of a number of mature individual bushes, hedgerows and mature trees which, although of low ecological value in their own right, could be used by nesting birds. However, the application site is considered to be of value to birds at only the level of the immediate zone of influence, and therefore below the threshold at which impacts could be considered to be significant. However, there is a risk that the construction works will affect breeding birds by causing disturbance to birds nesting in hedgerows, trees and bushes, if tree/hedgerow works are undertaken during the bird breeding season (early February to September inclusive). This would result in a minor negative (direct) and temporary impact. Although this disturbance could result in a short-term reduction in breeding success, the impact of construction works on the conservation status of any species of bird, is considered to be not significant, predicted with a near certain degree of confidence. However, there is potential for contravention of the Wildlife and Countryside Act 1981, as amended, if works are carried out during the breeding season Potential mitigation Bats Mitigation measures are proposed to address the identified adverse impacts on breeding birds, and to ensure that potential future impacts on bats are avoided (if found to be present during pre-demolition/construction survey). As surveys have confirmed that bats are not using the potential roost habitats identified in trees and buildings within the application site, no impacts have been identified and no specific mitigation is required. 212

217 However, as a precautionary measure, further surveys will be undertaken prior to any demolition/construction works to ensure that the assessment remains as up to date as possible given the phased nature of the works and therefore the likely prolonged timescale Breeding birds It is recommended that negative impacts on breeding birds are avoided by undertaking demolition of buildings or removing any trees and shrubs outside of the bird breeding season (early February to September), in advance of the construction works. This is particularly important given the proposed phasing of the works and therefore the likely prolonged timescale over a number of breeding bird seasons. If demolition/tree felling is not possible during this period then an experienced ecologist would need to check for active nests before works are carried out in the vicinity of the nest. If breeding birds were found works would then cease until the chicks fledged Assessment of impacts during operation Potential impacts Bats The proposed development will result in mixed land use, including housing areas, employment units, offices, retail, leisure and open space. Operation of the application site is likely to involve day-to-day activities typical of residential, employment and amenity areas, for example increased car use, foot traffic, noise and lighting levels and both formal and informal management of green space and associated new habitats. Surveys have confirmed that bats are not using the potential roost habitats identified in trees and buildings within the application site. Sufficient information has been obtained to conclude that the impact of the operation of the proposed development on bats is not significant, predicted with a near certain degree of confidence. However, due to the phased nature of the works, this assessment may change, subject to a precautionary approach of undertaking further surveys prior to demolition/construction. Possible enhancement works that will improve the potential value of the proposed development site for bats above its current baseline include bat boxes, bat bricks, planting of native trees and use of directional low pressure sodium lamps. These are not confirmed enhancements and will be considered further during detailed design Breeding birds The operation of the application site is not likely to have any real foreseeable impact on the conservation status of any species of bird, and is therefore considered to be not significant, predicted with a near certain degree of confidence. There is potential for contravention of the Wildlife and Countryside Act 1981, as amended, if tree/shrub works (which may be undertaken at times during the normal day-to-day operation of 213

218 the application site, e.g. by property owners) are carried out during the breeding season, although this is beyond the control of the applicant. The phasing of the works will not affect this assessment. Possible enhancement works that will improve the potential value of the proposed development site for breeding birds above its current baseline include nesting boxes, new native trees and shrubs, green and brown roofs. Again these are not confirmed elements of the project Habitat creation The development proposals will include a fully coordinated landscape, open spaces and Sustainable Urban Drainage System (SUDS) network as described in Section 3. Provision in the design will enable future links to be made to a possible settlement pond and reedbed filtration system for Headstone Manor Recreation Ground (although this is not part of this planning application). The following habitats will be created, which are the subject of targets in the Harrow Local Biodiversity Action Plan (LBAP): Standing and running water (ponds and wet vegetated ditches); and Grassland. Assuming that plans for habitat creation are implemented it is predicted that the operation of the application site will have a minor positive (direct) and permanent effect on LBAP habitats, predicted with a near certain degree of confidence. This is because of the current low ecological value of the application site. Any habitats created are likely to continue to improve (in terms of their ecological value) beyond the end of the construction phase (providing the habitats are managed appropriately) Potential mitigation Bats The assessment has shown there will be no impact on bats during operation. Therefore no mitigation is required Breeding birds Negative impacts on breeding birds during operation have been assessed as not significant. There is potential for contravention of the Wildlife and Countryside Act 1981, as amended, if tree/shrub works (which may be undertaken at times during the normal day-to-day operation of the application site, e.g. by property owners) are carried out during the breeding season, although this is beyond the control of the applicant. No mitigation measures are therefore required Enhancements In addition to the habitat creation proposals that have formed part of the landscaping and SUDS drainage strategy to the development (see Section (c)), a number of other specific enhancements are possible which would create new, or improve 214

219 existing, habitats to benefit protected and other species (see Table 10.3). These will be considered further during the detailed design stage. Most are likely to be more suitable to the Harrow View West site than to the Harrow View East site, but will be considered for the entire application site. Table 10.3: Possible enhancements to the existing ecological features Species Bats Reptiles/ Amphibians Birds Invertebrates Habitats Enhancement Provision of bat boxes on suitable buildings and trees. Incorporation of bat bricks within the new buildings to provide roosting sites and access to the buildings themselves. Planting of new native trees and shrubs to provide new potential foraging and commuting habitat. The use of directional low pressure sodium lamps, directed away from commuting or foraging areas, where lighting is required. Provision of areas of long, tussocky grassland in undisturbed areas of the application site. Provision of refugia such as log piles adjacent to these areas of long grass. Provision of suitable ponds and scrapes. Installation of bird boxes of various designs on suitable buildings and trees. Provision of nest boxes in eaves for species such as swifts Apus apus. Planting of new native trees and shrubs to provide perching, foraging and nesting habitats for local birds. Provision of green and brown roof habitats on new buildings (such as commercial buildings) to provide foraging habitat for black redstart. Provision of deadwood habitats such as log piles in undisturbed areas, especially in conjunction with other habitats such as tussocky grassland to benefit species such as stag beetle. Provision of a diversity of habitats such as tussocky grassland or wildflower meadows. Provision of brown or sedum roofs on new buildings to benefit invertebrates. Habitat creation focused on the following LBAP habitats: standing and running water (ponds, wet vegetated ditches, reedbeds); decaying wood; grassland Conclusions and statement of residual significance The desk study revealed that there were no nationally designated sites and 8 locally designated sites within 2km of the application site. Due to the distance from the 215

220 application site and the nature of the habitats, there were no impacts identified on any of these sites. It was determined in the Scoping Report (Halcrow 2011a) that no additional ecological surveys were required for the EcIA and that sufficient information has been obtained to assess potential impacts on ecological features that are present within the application site and also within the zone of influence of the application site. The agreed scope of this assessment is therefore limited to potential impacts on bats, breeding birds and new or improved habitats resulting from habitat creation and enhancement. The application site does not currently support populations of bats. Sufficient information has been obtained to conclude that the impact of both construction and operation on bats is not significant. However, as a precautionary measure, further surveys will be undertaken prior to any demolition/construction works to ensure that the assessment remains as up to date as possible given the phased nature of the works and therefore the likely prolonged timescale. The application site may support populations of breeding birds and disturbance will be avoided by carrying out vegetation removal outside the breeding season (or having an experienced ecologist check for nests). The residual impacts on the conservation status of bird populations are predicted to be not significant; The proposed development includes possible LBAP habitat creation and enhancement which will improve the biodiversity value of the proposed development site above its current baseline, including creation or improving standing and running open water, wetland habitat, woodland, decaying wood and enhancements for bats, birds and other species. Details of habitat creation and enhancement are still under development, linked with Headstone Manor Recreation Park proposals and the illustrative masterplan (see section (c)). The residual impact on LBAP habitats is predicted to be positive (direct); and Overall, the residual impact for all potential impacts identified is therefore considered as not significant, but with habitat enhancements resulting in positive improvements on the application site. Table 10.4 summarises impacts, mitigation and residual effects. 216

221 Table 10.4: Significance of residual effects identified during the construction and operation of the proposed development following the implementation of mitigation measures Receptor Characterisation of unmitigated impact on the feature Significance without mitigation and confidence level Proposed mitigation and enhancement Residual significance and confidence level Construction Bats Bats confirmed not present. Due to prolonged timescale resulting from phased nature of works, further surveys are required to ensure assessment remains accurate. No impact near certain Provision of bat boxes, bat bricks, new native trees and low sodium lamps. Near certain not to have a negative effect on conservation status therefore not significant Breeding birds Risk that works will affect the legal protection to breeding birds by causing disturbance to birds nesting in hedgerows, trees and bushes. Negative (indirect) near certain Avoid disturbance by carrying out vegetation removal outside the breeding season (or have an experienced ecologist check for nests). Provision of bird boxes and new native trees. Consideration of green/brown roofs. Near certain not to have a negative effect on conservation status therefore not significant Operation Bats Bats confirmed not present. No impact near certain None required Near certain not to have a negative effect on conservation status therefore not significant Breeding birds Risk that maintenance works to vegetation will affect breeding birds. Negative impact Not appropriate for applicant. Near certain not to have a negative effect on conservation status therefore not significant LBAP Habitats Creation of LBAP habitats. Positive (direct) near certain None required Near certain to have a positive (direct) effect on conservation status 217

222 11 Landscape and Visual Amenity 11.1 Introduction It is the aim of this landscape and visual impact assessment to identify the significant effects that the proposals will have on the surrounding landscape character and visual amenity and, where these effects have an adverse impact, to recommend suitable mitigation. This chapter describes the assessment process. It begins with the methodology used and the scope of the assessment, followed by an analysis of the existing landscape character and visual amenity, to create a baseline. How this baseline is affected by the proposals is then assessed, using the methodology described below and in Appendix This chapter is supported by a Landscape Appraisal Plan (Figure 11.1) and relevant photographs (Appendix 11.2) Methodology Scope of assessment The assessment documented within this chapter is based on the scope of work identified within the EIA Scoping Report (Halcrow, 2011a). The main impacts of the proposed development were stated as: Loss of open green space in the Harrow View West; Visual impact of new buildings on adjacent residential properties; and Disruption due to construction, including on earlier completed phases of the proposed development. A key priority was identified, to reduce impact on the sensitive residential receptors. The following mitigation was suggested to achieve this: Avoidance retain existing trees and hedgerows to maintain screening; Reduction Avoid creating tall buildings in close proximity to existing residential receptors and include plant screens as part of the proposed development; Remediation New planting and the removal of factory buildings could enhance the local townscape and removal of the tall brick wall creates an opportunity to better integrate the application site with its surroundings; and Enhancement The design should enhance views in and out of the application site. The scoping opinion received from the Council in July 2011 highlighted the following specific issues relevant to the scope of the landscape and visual assessment: PPS1, The saved policies of the Harrow Unitary Development Plan (2004), the emerging Core Strategy and The London Plan: Spatial Development Strategy for Greater London (Feb 2008, consolidated with alterations since 2004) (since replaced with 2011 version) should be referred to as relevant legislation and 218

223 plans. It should also be noted that the Green Grid is relevant to this section of the ES given the consideration of visual amenity; In addition to the identified viewpoints and impacts the ES will need to consider views in to the application site from the railway line, as the application site forms a very prominent gateway for those entering Wealdstone from the north; The implications of the phasing programme of the EIA is not just limited to new residents but will clearly impact on existing residents and businesses and this will need to be considered as part of the ES; and The scoping report states that the removal of the factory buildings may be a potential significant enhancement to the Townscape of this area of Harrow. This is noted but the cultural and historic legacy of these buildings requires careful consideration. The assessment presented within this chapter addresses the above comments by: making appropriate references to the stated legislation, strategies and plans; identifying views from trains as a local viewpoint during the undertaking of the LVIA, identifying existing residents and businesses as receptors within the LVIA and assessing changes likely over time given the proposed phasing programme; and addressing past and proposed changes to the cultural heritage of this site within the Cultural Heritage and Archaeology chapter of the ES and the supporting Heritage Statement (BDP, 2011x), the findings of which will inform the preparation of the LVIA Assessment methodology The assessment methodology used within this chapter broadly complies with The Guidelines for Landscape and Visual Impact Assessment, Second Edition (2002), published by the Landscape Institute (UK) and the Institute of Environmental Management and Assessment. Appendix 11.1 provides a detailed description of the methodology used in this assessment and the key steps are summarised below. A desk study and site visit (visit, by a Chartered Landscape Architect, occurred on 24th June 2011) were performed to enable the following: The study area was divided into its component landscape character areas. The landscape character of each of these is the overall product of the area s characteristics, and these characteristics in turn, are made up of individual landscape elements. These are identified to generate a baseline against which, the proposals could be assessed. The sensitivity of each landscape character area (i.e. its capacity for change) was assessed as part of this baseline; Identification of landscape character effects, which are a result of proposals altering, enhancing or removing existing elements, or adding new elements; Visual effects relate to changes in views from particular view points. View points that experience any visual effect due to the proposals are termed a 219

224 visual receptor. The sensitivity of a visual receptor was determined through its use/type; e.g., Residential, commercial, recreation, etc; Effects were assessed for both the construction and operation of the proposals. Each landscape character and visual effect was assessed to determine its magnitude of impact. This allowed each effect to be considered qualitatively; and The significance of an effect was determined through assessing the relationship between the effect s magnitude of impact and the sensitivity of the existing landscape character or visual receptor Legislation and policy Legislation Scheduled Monuments are protected under: Ancient Monuments and Archaeological Areas Act The setting of Scheduled Ancient Monuments is a material consideration in the planning approval process Planning policy The following planning policy documents were consulted during the assessment. A description of the relevant text within these policies can be found in Appendix 4.4. Planning Policy Statement 1: Delivering Sustainable Development (Department for Communities and Local Government, May 2006); Planning Policy Statement 5 (PPS5): Planning for the Historic Environment (Department for Communities and Local Government, March 2010); The London Plan: Spatial Development Strategy for Greater London (Greater London Authority, July 2011); The Harrow Unitary Development Plan (Saved Policies) (the Council, 2004); Core Strategy (Submission Draft 4th April to 16th May 2011) (the Council); Harrow and Wealdstone Area Action Plan: Issues and Options Consultation Document (Harrow Council, May 2011); Sustainable Building Design (adopted May 2009) (the Council); and Accessible Homes (adopted 18 March 2010) (the Council) Baseline conditions Landscape designations The application site lies within the All London Green Grid, which is a framework for creating, improving, managing and maintaining high quality green infrastructure, 220

225 published by the London Development Agency in partnership with Design for London. The grid incorporates projects suggested by local authorities. The Harrow Green Grid Project Schedule outlines works to restore Headstone Manor (including the Harrow View West) through improving the water quality of the moat, new planting and native habitats and enhancing views in and out of the manor. The Harrow View East site portion of the application site is designated as a connecting route and should achieve this through negotiation with the developer of the application site. Four groups of trees along Harrow View have Tree Protection Orders (TPO 874). TPOs are placed on trees that require protection from unauthorised works due to the contribution they make towards the local environment, including being a significant element of the local landscape character. Adjacent to the application site, on its western side, is Headstone Manor. The manor and its associated structures and landform (including a moat) are Grade 1 listed and are also designated as a Scheduled Monument. In addition, one of the outbuildings to the south of the manor and a barn to the southwest are individually listed as Grade 2 and 2* respectively. The land adjacent to the application site, on its western side (Headstone Manor), is also designated Metropolitan Open Land (MOL). MOL is outlined in The London Plan and is intended to protect open areas that are distinct from built-up areas, and/or provide features and landscapes of recreational, historic, nature conservation, or habitat interest. There are several Grade 2 listed buildings, approximately 400m to the east of the application site; a war memorial, Wealdstone Police Station, the Victory Public House and Harrow and Wealdstone Station. Further details on sites of historic or archaeological interest are included in Chapter Regional landscape character The application site lies within the London Borough of Harrow, which itself lies within the M25 ring, to the north-west of inner city London, with Wembley approximately 3km to its south-east and Junction 1 of the M1 approximately 6km to the east. The application site lies within the sub character area of National Character Area 111 Northern Thames Basin (as defined by Natural England), entitled Hertfordshire Plateaux and River Valleys. This area is characterised by its diverse mix of settlements, woodland and agriculture. It is a zone of commuter homes, new towns and the Garden Cities of Ebenezer Howard. Much of the countryside is transitional, being an indication of where rural Hertfordshire merges with the North London suburbs. It often has an unkempt and muddled appearance due to the lack of management in the green belt north of London. Motorways and major trunk roads (including the M25 and M1) are significant features of the landscape, having a strong influence on the character as they cut through the natural form of the land, creating dense corridors of activity. 221

226 Local landscape character (See Figure 11.1: Landscape Appraisal Plan) The Council s Character Assessment of Harrow s Residential Areas describes the local area as one of transition between the heavily urbanised inner London and the increasingly rural counties beyond. This characteristic is emphasised by the views of tree-covered uplands of Pinner Hill and Harrow Weald Ridge to the north of the proposed development site. Views of the ridge are further accentuated by the large, white building of Bentley Priory. To the south, Harrow-on-the-Hill is clearly visible with its elevated rows of terraced houses and the prominent St. Mary s Church spire at its peak. The following landscape character areas (CA) were identified during the desk study and site visit: Character Area 1 (CA1): The industrial area of Headstone (within which the application site lies) is characterised by its dominating, large industrial buildings and large expanses of concrete or loose gravel surfacing (Photo 6 in Appendix 11.2). Within the Harrow View East site this is joined by large scale industrial elements, such as pipes and girders. Colours in the industrial area are de-saturated and uniform, being restricted, for the most part, to the flesh/red brick of the buildings and the grey of the concrete and steel. The prominent security features around the industrial properties, such as high walls, surveillance cameras, mesh fencing, controlled gates and presence of security personnel, create an inhospitable atmosphere (Photo 4 in Appendix 11.2), which is accentuated by the wide, busy roads (Headstone Drive and Harrow View (Photo 12 in Appendix 11.2)) and an elevated high speed train line. The roads and train line both act as barriers around the application site, often eliminating pedestrian access and permeability. Tree and shrub planting is present in the industrial area, but is mostly planted in single species rows, creating further uniformity in colour and pattern. Planting is more extensive in the Barratt Way Industrial Estate, to the east of the train line and application site, but business units and on-street parking dominate the area (Photo 8 in Appendix 11.2). The units are uniform in colour and texture, and have few windows or frontage to contribute to the street scene. The proximity to the rail means that passing trains are a dominant characteristic of Barratt Way, as are views over the railway lines to the Harrow View East site (Photo 9 in Appendix 11.2). For most of the industrial area, views are restricted to the foreground due to the tall buildings and walls, though these tall buildings and a tall chimney are local landmarks due to their size. It is rare that a view of the green spaces to the north and west can be taken in. In summary the industrial area has a low landscape quality, due to its lack of variation in colour, dominance of industrial elements and hard-standing, inhospitable nature, and lack of views out to the green suburbs that characterise Harrow as a whole. Low Sensitivity Character Area 2 (CA2): The Harrow View West site is made of two distinct areas. The eastern side is made up of a car park and buildings (Photo 11 in Appendix 11.2). 222

227 This area is dominated by the large expanse of concrete hard-standing and the large volume of parked cars. The buildings are relatively industrial in their character, with monotone concrete, steel and brick facades. Along the northern edge of the Harrow View West site is a poorly maintained area of shed buildings surrounded by concrete hard-standing. In high contrast to the concrete areas, the sports fields of the Harrow View West site are dominated by the open grassed fields and surrounding tree lines/dense hedges. It is the surrounding planting that forms a distinct barrier between the concrete car park and the green fields. Unfortunately, this planting also prevents the open green space of the fields having any positive impact on the adjacent residential and parkland areas. The steel mesh/heras fencing and the dense, tall evergreen hedges along the edges of the Harrow View West site dominate views in and out (Photos 1 and 3 in Appendix 11.2). Low Sensitivity Character Area 3 (CA3): The parkland area adjacent to the western parcel of the application site (the Harrow View West site) is made up of Headstone Manor Recreation Ground and Headstone Manor. The parkland area is characterised by its well maintained open grass fields, intimate tree-lined paths and play facilities. The area is semi-natural in character, the dominant characteristics clearly illustrating the combined overarching processes of natural growth and human intervention. The planting also successfully screens views of the surrounding roads and the industrial area to the east, enabling the parkland area to be completely separated from it in character. This is especially so at Headstone Manor. The manor site is dominated by the well-maintained historical buildings and interpretation facilities. The Manor is surrounded by a moat, which is an attraction for wildlife, and is densely planted. This dense planting prevents views to the east (Photo 15 in Appendix 11.2) and allows the manor to be an isolated area of high tranquillity despite its proximity to the Harrow View East site. High Sensitivity Character Area 4 (CA4): Character Areas 1-3 sit within a large residential landscape. The residential area is characterised by its predominantly long, straight streets with semi-detached housing. There is a strong green characteristic due to mature street tree planting, the presence of planted front gardens and the close proximity to open green space. These characteristics are more predominant progressively west, creating a high quality and typically suburban landscape, and reflecting the regional landscape character of a transition between urban and rural. The residential area to the immediate east of the application site contains a larger proportion of terraced town houses, with smaller front gardens. Proximity to Wealdstone town centre and the denser composition gives this area a more urban character. The proximity to the industrial area is a significant detractor to the quality of the landscape in the residential area. However, the tall chimney within the application site provides a significant landmark with historical/cultural connotations to the residential surroundings. Medium Sensitivity Character Area 5 (CA5): Wealdstone town centre, to the south-east of the application site, is characterised by its large main roads (particularly the A409 trunk road), corporate elements, civic elements such as Harrow Crown Court, the High Street, and Harrow and Wealdstone Station. The landscape is highly urban, with few green 223

228 elements and a high level of vehicle and pedestrian traffic and business activity. Medium Sensitivity Visual amenity (see Figure 11.1 Landscape Appraisal Plan) The built-up and heavily planted nature of the surrounding landscape means that views of the application site are often partial and specific to a particular location. Despite this, the elevated ground to the north and south, and the large scale of the existing structures within the Harrow View East site mean that the visual envelope is relatively widespread as shown on Figure The visual receptors (VR) shown in Table 11.1 were identified during the desk study and site visit. Table 11.1: Visual Receptors Visual Resource (VR) no. Name Sensitivity to change VR1 Headstone Manor High Sensitivity VR2 Headstone Manor Recreation Ground High Sensitivity VR3 Homes on Pinner Park Avenue High Sensitivity VR4 Homes on Holmwood Close High Sensitivity VR5 Homes along southern edge of Harrow View West site High Sensitivity VR6 Victor Road Low Sensitivity VR7 Homes on Victor Road High Sensitivity VR8 Headstone Drive Low Sensitivity VR9 Homes on Headstone Drive High Sensitivity VR10 Harrow View Low Sensitivity VR11 Homes on Harrow View High Sensitivity VR12 Train line Low Sensitivity VR13 Harrow Crown Court Medium Sensitivity VR14 Business units on Hailsham Drive Medium Sensitivity VR15 Harrow and Wealdstone Station Medium Sensitivity VR16 Homes on Cecil Road High Sensitivity VR17 Barratt Way Industrial Estate Medium Sensitivity 224

229 Visual Resource (VR) no. Name Sensitivity to change VR18 Harrow Teachers Centre Medium Sensitivity VR19 Homes on Lynn Close and Carmelite Road High Sensitivity VR20 Homes on Pinner Park Gardens and Mulberry Place High Sensitivity VR21 Homes on Harrow View (north) High Sensitivity VR22 Harrow Weald Ridge High Sensitivity VR23 The Grove Harrow on the Hill High Sensitivity VR24 Homes on north slope of Harrow Hill High Sensitivity 11.5 Assessment of effects on landscape character prior to and during construction In this section the effects of the construction of the proposed development on each landscape character area are assessed. The impact of these effects is assigned a magnitude as described in the methodology. This magnitude does not take into account any mitigation measures recommended later in this chapter of elsewhere in the Environmental Statement. This section includes several character areas that are not included in the baseline. This is a reflection of the proposed development s phased construction; meaning earlier completed phases, and their landscape character, will become receptors to effects during construction. Character Area 1 (CA1) Industrial: Generally, there will be an increased presence of large scale machinery on the application site during demolition and construction operations, as well as a large increase in activity and noise. The application site will become more flat and expansive as buildings and structures are removed. Low Sensitivity; Minor Adverse Impact; Minor Significance Character Area 2 (CA2) Harrow View West site: Generally, there will be an increased presence of large scale machinery on the application site during demolition and construction operations, as well as an increase in activity and noise. The clearance of portions of the Harrow View West site playing field and surrounding trees will also remove green elements from the landscape. Low Sensitivity; Minor Adverse Impact; Minor Significance Character Area 3 (CA3) Parkland: Demolition and construction works in the western end of the application site during Phase 1b may affect the isolated and tranquil character of Headstone Manor and the Headstone Manor Recreation Ground, through additional noise and activity (Photo 1 in Appendix 11.2). This effect will be mitigated to a degree by the existing planting around the moat and the north/west edge of the existing Harrow View West site (if retained). High Sensitivity; Moderate Adverse Impact; Moderate Significance 225

230 Character Area 4 (CA4) Residential: Properties along the edges of the application site will be exposed to increased noise and views of the works. This is impact is relatively slight as the influence of the works on the residential character simply replaces that of the existing industrial site. As perimeter walls are removed (Photo 5 in Appendix 11.2) and the tree planting around the Harrow View West site is cleared (Photo 1 and 3 in Appendix 11.2), the adjacent roads and properties will be increasingly exposed to the long, expansive views into the application site during the works. Existing industrial traffic along Harrow View and Headstone Drive will be replaced with the works traffic. Medium Sensitivity; Minor Adverse Impact; Moderate Significance Character Area 5 (CA5) Wealdstone Town Centre: During Phase 1a the town centre may experience some distant noise from, and partial long views of, the works. Existing industrial traffic will be replaced with the works traffic. Medium Sensitivity; Minor Adverse Impact; Minor Significance Character Area 6 (CA6) Proposed development Phase 1a: Properties along the edges of the area will be exposed to noise and views of the works in Phase 1c and 3. Medium Sensitivity; Moderate Adverse Impact; Moderate Significance Character Area 7 (CA7) Proposed development Phase 1b: Properties along Harrow View will be exposed to noise and views of the works in Phase 2. Medium Sensitivity; Minor Adverse Impact; Minor Significance Character Area 8 (CA8) Proposed development Phase 1c: Properties along the edges of the area will be exposed to noise and views of the works in Phase 3. Medium Sensitivity; Moderate Adverse Impact; Moderate Significance Character Area 9 (CA9) Proposed development Phase 2: Properties along the southern edges of the area will be exposed to noise and views of the works in Phase 3. Medium Sensitivity; Moderate Adverse Impact; Moderate Significance Table 11.2: : Significance of effects identified on landscape character during the construction of the proposed development prior to the implementation of proposed mitigation measures Receptor Sensitivity/ Value Summary description of impact Magnitude of impact Significance of potential effect without mitigation CA1 Low Activity and machinery on application site CA2 Low Activity and machinery on application site CA3 High Views of works and noise Minor Adverse Impact Minor Adverse Impact Moderate Adverse Impact Minor Adverse Minor Adverse Moderate Adverse CA4 Medium Views of works Minor Adverse Impact Moderate Adverse 226

231 Receptor Sensitivity/ Value Summary description of impact Magnitude of impact Significance of potential effect without mitigation CA5 Medium Distant partial views of works CA6 Medium Views of works, noise CA7 Medium Views of works and noise CA8 Medium Views of works, noise CA9 Medium Views of works, noise Minor Adverse Impact Minor Adverse Impact Minor Adverse Impact Minor Adverse Impact Minor Adverse Impact Minor Adverse Minor Adverse Minor Adverse Minor Adverse Minor Adverse 11.6 Assessment of effects on landscape character during operation In this section the effects of the operation of the proposed development on each landscape character area are assessed. The impact of these effects is assigned a magnitude as described in the methodology. This magnitude does not take into account any mitigation measures recommended later in this chapter of elsewhere in the Environmental Statement. Character Area 1 (CA1) Industrial: Generally, the industrial landscape of the application site will be replaced with a residential/employment landscape. The dominant industrial structures and large buildings will be replaced with houses and offices that are appropriate to the scale of their surroundings and contribute to the street scene. The linear and uniform coloured planting, including trees covered with TPOs along Harrow View, will be replaced with planting with variation in form and colour. The large expanses of concrete and gravel will be replaced with a designed public realm and there will be a large increase in the green elements within the application site. The removal of the 2m high Harrow View East site perimeter wall and the associated security elements will allow the application site to integrate with the surrounding landscape. The uniformity of the existing landscape will be replaced with one of variable colour and pattern, greatly improving the aesthetic quality and enhancing the transitional urban/rural landscape, for which the local area is known. Low Sensitivity; Major Beneficial Impact; Moderate Significance Character Area 2 (CA2) Harrow View West site: The character of the western portion of the Harrow View West site will become more natural through the removal of existing fencing and linear evergreen planting (Photo 1 in Appendix 11.2), and the addition of natural elements such as native planting and ponds. The extending and opening of views, due to the removal of some of the screening around the application site, will make this area more open; and with its recreational facilities, closer in character to the open green space that surrounds Headstone Manor to its north and 227

232 west. The areas of concrete hard-standing and monotone buildings will be replaced with a designed street scene with more green elements and higher landscape quality. The Harrow View West as a whole will be more integrated with the surrounding landscape through the removal of the evergreen hedges and steel fencing. Low Sensitivity; Major Beneficial Impact; Moderate Significance Character Area 3 (CA3) Parkland: The character of the western portion of the Harrow View West site will become more natural through the removal of existing fencing and some of the linear evergreen planting (Photo 1 in Appendix 11.2), and the addition of natural elements such as native planting and ponds. The extending and opening of views, due to the removal of some of the screening around the sports field, will make this area more open; and with its recreational facilities, closer in character to the open green space that surrounds Headstone Manor to its north and west. These effects will improve the landscape quality of the setting of Headstone Manor, and tie into the aims of the Green Grid Headstone Manor Restoration - to improve views from the Manor. High Sensitivity; Major Beneficial Impact; Major Significance Character Area 4 (CA4) Residential: The removal of the high walls and security elements around the application site, the opening up of inward views and the creation of access routes will change the perimeter of the application site from its current inhospitable character (Photo 4 in Appendix 11.2), to an active edge. The active edge will contribute positively to the character of the surrounding streets and will be more welcoming to pedestrians and drivers. The retention of the existing chimney will enhance this element s beneficial influence on the residential area as a landmark with historical/cultural significance. Medium Sensitivity; Major Beneficial Impact; Major Significance Character Area 5 (CA5) Wealdstone Town Centre: Some partial views of new tree planting and the new buildings could enhance views from the town centre. Medium Sensitivity; Minor Beneficial Impact; Minor Significance Table 11.3: Significance of effects identified on landscape character during the operation of the proposed development prior to the implementation of proposed mitigation measures Receptor Sensitivit y/value Summary description of impact Magnitude of impact Significance of potential effect without mitigation CA1 Low Industrial character replaced CA2 Low Removal of hardstanding and buildings CA3 High Improved setting for Headstone Manor Major Beneficial Impact Major Beneficial Impact Major Beneficial Impact Moderate Beneficial Moderate Beneficial Major Beneficial 228

233 Receptor Sensitivit y/value Summary description of impact Magnitude of impact Significance of potential effect without mitigation CA4 Medium Active edges improve street scene CA5 Medium Views of improved street scene Major Beneficial Impact Minor Beneficial Impact Major Beneficial Minor Beneficial 11.7 Assessment of effects on visual amenity In Table 11.x the effects of the proposed development on each visual receptor are assessed. The impact of these effects is assigned a magnitude as described in the methodology. This magnitude does not take into account any mitigation measures recommended later in this chapter of elsewhere in the Environmental Statement. 229

234 Table 11.4: Effect of proposed development on Visual Receptors during construction and operation Receptor Sensitivity Distance Arc ( ) Existing view Effects of demolition/construction Effects of operation VR1: Headstone Manor (Photo 15 in Appendix 11.2) High 100m H <45 V <45 Partial mid-views of evergreen trees along edge of Harrow View West site, and partial distant views of large industrial buildings during winter. Partial mid and distant views of demolition and construction of Phase 1b may be possible during winter months. Minor Adverse Impact; Moderate Significance Partial views of new greenspace will be possible. Minor Beneficial Impact; Moderate Significance VR2: Headstone Manor Recreation Ground (Photo 1 in Appendix 11.2) High 0m H V <45 Clear view of the evergreen planting and fencing around the existing Harrow View West site, and partial views of industrial buildings above the trees. Clear foreground view of the Phase 1b works on the new greenspace. Moderate Adverse Impact; Major Significance Clear foreground view of new natural greenspace and recreation facilities, in place of existing fencing and evergreen planting. Major Beneficial Impact; Major Significance VR3: Homes on Pinner Park Avenue High 0m H V <45 Partial views of Harrow View West site car park (Photo 11 in Appendix 11.2) and playing field through hedge planting. Clear views of Phase 1b demolition and construction works once hedge planting is removed. Moderate Adverse Impact; Moderate Significance Partial views of Phase 1b residential properties through proposed planting. Moderate Beneficial Impact; Moderate Significance VR4: Homes on Holmwood Close High 0m H V <45 Partial views into Harrow View West site through planting. Elevated partial views of Phase 1b demolition and construction. Minor Adverse Impact; Minor Significance Partial views of Phase 1b residential properties through proposed planting and elevated views of new greenspace. Moderate Beneficial Impact; Moderate Significance 230

235 Receptor Sensitivity Distance Arc ( ) Existing view Effects of demolition/construction Effects of operation VR5: Homes along southern edge of Harrow View West site (Photo 3 in Appendix 11.2) High 0m H V Views limited to mesh fencing, earth banks and evergreen tree planting in the foreground. Clear views of Phase 1b demolition and construction works once planting and bank is removed. Major Adverse Impact; Major Significance Clear views of Phase 1b residential properties, streetscape and greenspace. Major Beneficial Impact; Major Significance VR6: Victor Road (Photo 2 in Appendix 11.2) Low 50m H V Narrow partial view of brick wall along Harrow View and the large scale buildings and industrial structures. Clear view of Phase 3 demolition and construction works at ground level. Minor Adverse Impact; Minor Significance Narrow but extended view into the Phase 3 proposed development, taking in new public realm and planting. Major Beneficial Impact; Moderate Significance VR7: Homes on Victor Road (Photo 2 in Appendix 11.2) High 50m H V Narrow partial view of brick wall along Harrow View and the large scale buildings and industrial structures. Clear view of Phase 3 demolition and construction works at ground level. Minor Adverse Impact; Moderate Significance Narrow but extended view into the Phase 3 proposed development, taking in new public realm and planting. Major Beneficial Impact; Major Significance VR8: Headstone Drive (Photo 5 in Appendix 11.2) Low 0m H V Clear view of brick wall in foreground with a regular arrangement of tree planting and partial views of extensive areas of gravel behind. Clear view of Phase 1a/1b demolition and construction works at ground level. Moderate Adverse Impact; Minor Significance Clear view of employment buildings and civic public realm of Phase 1a and 1b. Views extended into the application site. Major Beneficial Impact; Moderate Significance 231

236 Receptor Sensitivity Distance Arc ( ) Existing view Effects of demolition/construction Effects of operation VR9: Homes on Headstone Drive (Photo 5 in Appendix 11.2) High 20m H V Clear view of brick wall in foreground with a regular arrangement of tree planting and partial views of extensive areas of rubble behind. Clear view of Phase 1a/1b demolition and construction works at ground level. Moderate Adverse Impact; Major Significance Clear view of employment buildings and civic public realm of Phase 1a and 1c. Views extended into the application site. Major Beneficial Impact; Major Significance VR10: Harrow View (Photos 4 and 12 in Appendix 11.2) Low 0m H V Clear foreground view of brick wall and security gates set against the large industrial buildings and structures. Clear and extensive view of Phase 2/3 demolition and construction works at ground level. Moderate Adverse Impact; Minor Significance Clear view of residential landscape along the road side, with increased planting and views into the application site. Major Beneficial Impact; Moderate Significance VR11: Homes on Harrow View (Photos 4 and 12 in Appendix 11.2) High 20m H V Clear foreground view of brick wall and security gates set against the large industrial buildings and structures. Clear and extensive view of Phase 2/3 demolition and construction works at ground level. Moderate Adverse Impact; Major Significance Clear view of residential landscape along the road side, with increased planting and views into the application site. Major Beneficial Impact; Major Significance 232

237 Receptor Sensitivity Distance Arc ( ) Existing view Effects of demolition/construction Effects of operation VR12:Train line Low 30m H V Elevated extensive views over the industrial landscape of Waverley Industrial Estate and the application site, taken in at speed Extensive views of Phase 2/3/1a demolition and construction works throughout the application site. Minor Adverse Impact; Minor Significance Partial views of the employment buildings and civic public realm along the north-eastern edge of the application site, through proposed planting. Moderate Beneficial Impact; Moderate Significance VR13: Harrow Crown Court Medium 0m H V Elevated views of the expansive areas of gravel and the backdrop of large industrial structures in the mid-distance. Extensive views of Phase 1a demolition and construction works throughout the application site. Moderate Adverse Impact; Moderate Significance Elevated views of the employment buildings and civic public realm of Phase 1a. Major Beneficial Impact; Moderate Significance VR14: Business units on Hailsham Drive Medium 0m H V Views of the expansive areas of gravel and the backdrop of large industrial structures in the mid-distance. Extensive views of demolition and construction works throughout the application site. Moderate Adverse Impact; Moderate Significance Partial views of the employment buildings and civic public realm of Phase 1a. Major Beneficial Impact; Moderate Significance VR15: Harrow and Wealdstone Station Medium 450m H <45 V <45 Narrow distant view of the tops of the industrial buildings and structures over the buildings and houses between. Temporary view of demolition works to the tall industrial buildings and structures. Minor Adverse Impact; Minor Significance Narrow partial views of the proposed employment buildings may be possible, but likely to be minimal. Minor Beneficial Impact; Minor Significance 233

238 Receptor Sensitivity Distance Arc ( ) Existing view Effects of demolition/construction Effects of operation VR16: Homes on Cecil Road (Photo 7 in Appendix 11.2) High 175m H V <45 Foreground view of industrial compounds and elevated train line, with tall boarding screening longer views further west. Some views of the large industrial buildings may be possible from first floor windows. Temporary view of demolition works to the tall industrial buildings and structures. Minor Adverse Impact; Minor Significance Partial elevated views of the proposed employment buildings may be possible, but likely to be minimal. Moderate Beneficial Impact; Moderate Significance VR17: Barratt Way Industrial Estate (Photo 9 in Appendix 11.2) Medium 80m H V Despite the train line and planting in the foreground, views are dominated by the large buildings of the application site. Direct view of demolition and construction works, though the train line will screen views of ground level working. Minor Adverse Impact; Minor Significance Elevated views of the proposed employment buildings. Moderate Beneficial Impact; Moderate Significance VR18: Harrow Teachers Centre Medium 200m H <45 V <45 Very narrow, partial view of the top of one of the large industrial buildings. Partial view of elevated demolition and construction works. Minor Adverse Impact; Minor Significance Partial view of the proposed employment buildings. Minor Beneficial Impact; Minor Significance VR19: Homes on Lynn Close and Carmelite Road High 70m H V Elevated and extensive views of the application site over the train line and Harrow View road. Extensive and direct views of the demolition and construction works. Moderate Adverse Impact; Moderate Significance Direct elevated views of the employment buildings and civic public realm. Major Beneficial Impact; Major Significance 234

239 Receptor Sensitivity Distance Arc ( ) Existing view Effects of demolition/construction Effects of operation VR 20: Homes on Pinner Park Gardens and Mulberry Place (Photo 10 in Appendix 11.2) High 0m H V Elevated view dominated by the large brick building in the northern end of the application site. The building rises higher than the homes despite their elevation and screens all views beyond. Elevated view of demolition works to the large building. Views will become more extensive over Phase 2 and 3 works when the building is levelled. Major Adverse Impact; Major Significance Partial elevated views of the residential proposals in Phase 2, through proposed planting. Major Beneficial Impact; Major Significance VR21: Homes on Harrow View (north) High 30m H V <45 Elevated partial views, over Harrow View road, of the Harrow View West site carpark, through existing planting. Direct views of the demolition and construction works of Phase 1b. Moderate Adverse Impact; Major Significance Elevated partial views of new apartment buildings and terraces, through proposed street tree planting. Major Beneficial Impact; Major Significance 235

240 Receptor Sensitivity Distance Arc ( ) Existing view Effects of demolition/construction Effects of operation VR22: Harrow Weald Ridge (Photo 13 in Appendix 11.2) High 2.5km H <45 V <45 Very distant elevated view taking in most of North Harrow and Wealdstone, with Harrow on the Hill as a backdrop. The large industrial buildings are clearly visible amongst, and clearly contrast with, the residential suburban landscapes. Distant view of elevated demolition and construction works. Minor Adverse Impact; Moderate Significance The application site will integrate more with its surroundings and not disproportionately dominate the view. The application site will have increased tree cover and smaller structures, allowing a clearer view of Harrow on the Hill, while retaining the chimney landmark which highlights the application site amongst the wider landscape. Moderate Beneficial Impact; Major Significance VR23: The Grove Harrow on the Hill (Photo 14 in Appendix 11.2) High 2km H <45 V <45 Elevated mid-distance view of the application site with the large industrial buildings and structures visible above the civic and residential buildings between. Distant view of elevated demolition and construction works. Minor Adverse Impact; Minor Significance The application will mostly disappear from view, except for some of the taller employment buildings allowing a clearer view of Harrow Weald Ridge. Minor Beneficial Impact; Minor Significance 236

241 Receptor Sensitivity Distance Arc ( ) Existing view Effects of demolition/construction Effects of operation VR24: Homes on north slope of Harrow Hill (Photo 14 in Appendix 11.2) High 2km H <45 V <45 Elevated mid-distance view of the application site with the large industrial buildings and structures visible above the civic and residential buildings between. Distant view of elevated demolition and construction works. Minor Adverse Impact; Minor Significance The application will mostly disappear from view, except for some of the taller employment buildings allowing a clearer view of Harrow Weald Ridge. Minor Beneficial Impact; Minor Significance 237

242 11.8 Mitigation measures In this section recommendations are made with the aim of mitigating the adverse effects of the proposed development. The purpose of mitigation is to eliminate an adverse effect and, where this is not possible, to reduce the effect s magnitude of impact or significance During construction Refer to the Noise chapter of this ES for the assessment of noise impact and recommended mitigation. A method statement to restrict on site working hours to daytime only would help mitigate the impact of additional activity on residential areas, due to the increased likelihood that people are away from home during those hours. Though this does not reduce the magnitude of impact for this effect, it does isolate it to times when the residential receptors are at their least sensitive. A method statement should include a plan of access routes for heavy plant, with the aim of avoiding narrow residential streets, such as Pinner Park Avenue, and close proximity to green space, such as Victor Road, wherever practicable; therefore isolating the effect of the vehicles to routes that are already busy and accommodate existing industrial traffic. Hoarding installed and maintained around the application site would screen inward views from surrounding residential areas, particularly along Harrow View and Headstone Drive, where the proximity of homes increases the impact of construction upon them. Incorporating art/public participation or interpretations of the works and the history of the application site onto the boards would help this landscape element to contribute to the street scene. Progressing demolition works outward, from the centre of the phases, may limit the period that clear views of the works can be taken in, as perimeter buildings, structures, walls and planting will remain as a screen to inward views. This would be particularly effective in Phase 1b temporarily retaining the evergreen tree lines during works to screen views in from Headstone Manor, the recreation ground and the surrounding homes During operation All effects during operation have been assessed to be beneficial. However, this beneficial impact relies on the assumption that the low quality industrial landscape will be replaced with a higher quality landscape of employment buildings, homes, public realm and open green-space. Therefore, the finish of these elements is vital to the delivery of a beneficial impact. The proposed development should integrate with and enhance the positive aspects of the local and regional landscape character and visual amenity, especially the suburban transition of rural and urban, with a large amount of varied native green elements and easy access to green open space. The streetscape should be stimulating and pedestrian friendly and generate a strong sense of place. Views towards the surrounding hills should be exploited where practicable. 238

243 If followed through to a high quality finish with a suitable long term maintenance plan that includes soft and hard landscape elements, the green space proposals in Harrow View West will greatly improve the setting of Headstone Manor and tie into the restoration plans for the area as part of the All London Green Grid Conclusions and statement of residual significance The increased activity and introduction of additional heavy plant, vehicles and machinery to the application site, during demolition and construction works, will have an adverse impact on the application site s character. Yet, due to the low landscape quality of the application site and its immediate surroundings, this impact is not of major significance or particularly damaging. The impact on the surrounding landscape character areas is where damage, though temporary, could occur. The residential areas, Headstone Manor, Headstone Manor Recreation Ground and the earlier completed phases of the proposed development (e.g. Phases 1a to 1c) all have a higher landscape quality and are more sensitive to change. Effects, likely to have an impact on the surrounding landscape character areas, are limited to noise (refer to Noise chapter) and visual amenity. As described in the assessment, the existing visual amenity is often limited to partial views in particular locations, due to the residential blocks and large amounts of tree and shrub planting. Due to this (and the phasing plan), most receptors will not experience visual effects for the full period of the construction works. Receptors with a wider arc of view (due to proximity or elevation) will experience a longer term and higher magnitude adverse impact, which could be mitigated to a degree by measures such as hoarding, and retaining existing screening elements until it is necessary to remove them. Properties on Pinner Park Gardens and Mulberry Place are of particular note as their elevated views of Phase 2 works ( ) may be difficult to screen, and during , extensive views over the demolished Phase 2 to Phase 3 works may be possible. Once completed, the proposed development proposals will have a beneficial impact on the local character areas and visual amenity. This will be achieved through the removal of a low quality industrial landscape, and its replacement with a higher quality landscape, consisting of characteristics that enhance the urban/rural transitional character of the local area and provide a more stimulating visual amenity, through variation in colour and form and an increase in green elements. The beneficial impact of removing industrial elements alone has been illustrated by the demolition of buildings W105, W155 and W93, prior to Through the removal of perimeter walls, and the retention and enhancement of the chimney landmark, the application site will contribute to its surroundings through the enhancement of views into the application site and offer a more hospitable environment to pedestrians. The setting of Headstone Manor will be improved through the proposed green space in Harrow View West and tie into future Green Grid plans. Trees covered by TPO874 along Harrow View may be lost. Although retention of these trees would benefit the application site due to their maturity and ability to screen, their loss would not reduce the beneficial impact of the proposed development. 239

244 Table 11.5: Significance of residual effects identified during the construction and operation of the proposed development following the implementation of mitigation measures Receptor Summary description of impact Significance of potential effect Proposed mitigation Residual significance Construction CA4 Surrounding existing residential character areas Views of works Moderate Significance Working hrs, access routes, boarding, maintain existing screening Minor Adverse CA6/8/9 New residential character areas Views of works Minor Significance Working hrs, access routes, boarding, maintain existing screening Minor Adverse VR2/5/9/11/ 21 Various local visual receptors including Headstone Manor and adjacent residents Extensive views of works Major significance Working hrs, boarding, maintain existing screening Moderate Adverse VR20 Residents on Pinner Park Gardens and Mulberry Place Extensive views of works from elevated position Moderate Significance Working hours Moderate Adverse Operation All receptors Beneficial Impact Major Significance Ensure quality of proposed development Major Beneficial 240

245 12 Socio-economic 12.1 Introduction This chapter of the ES presents an assessment of the potential impacts and likely significant socio-economic effects of the development arising from the demolition and construction works and on completion of the development. This chapter describes the socio-economic policy context; the methods used to assess the potential impacts; the baseline conditions at and surrounding the site; the potential direct, indirect and wider socio-economic impacts; mitigation measures integral to the development proposals; and the significance of residual effects. In particular, this chapter presents the results of the assessment of the potential impacts related to employment levels created by the development and the potential impacts associated with the new residential population on-site, including any impact on local social and community infrastructure Methodology Scope of assessment Social and economic impacts will arise from changes to the present uses on the site, from the construction process and from new uses in the completed development. The application site is currently designated as a Strategic Industrial Location/Preferred Industrial Location as defined by the London Plan (2011). As this designation is principally for economic reasons, the socio-economic assessment has required a full assessment of the likely economic and employment impacts of the development, using recognised best-practice methodology. This has been assessed separately in a standalone economic/employment report to support the planning application. Housing elements of the development will need to meet a range of basic planning requirements notably in relation to children s play space and contributions to, or provision of, community facilities Assessment methodology The following section outlines the methodologies applied to identify and assess the range of potential socio-economic impacts that could result from the development. This assessment has been set against the existing socio-economic conditions at the application site and in the local area within the District and/or Regional context where relevant. Baseline data was analysed at the following spatial levels: Application site; Local the surrounding wards: Headstone North, Headstone South, Marlborough and Wealdstone. This area is defined as the Local Impact Area (LIA); 241

246 District the London Borough of Harrow (the Council); and Regional London. Baseline socio-economic conditions have been established through the interpretation of nationally recognised research and survey information including: 2001 Census Data 4 ; January -December 2010 Annual Population Survey data 5 ; 2011 Greater London Authority (GLA) Ward Level Population Projections 6 June 2011 Claimant Count data 7 ; 2009 Business Register and Employment Survey 8 ; 2010 School Census data 9 ; 2010 Indices of Multiple Deprivation data 10 ; and 2011 National Health Service (NHS) data 11. The assessment seeks to establish the potential social and economic impacts of the development and to assess the likely significant effects against the current baseline conditions. The assessment has been based on the following approach and associated methodologies: Review of the development proposals, including any mitigation measures; and 4 Office of National Statistics, (2001), Census. 5 Office of National Statistics, (Jan Dec 2010), Annual Population Survey. 6 Greater London Authority, (2011), SHLAA Ward Population Projections. 7 Office of National Statistics, (June 2011), Claimant Count. 8 Office of National Statistics, (2009), Annual Business Inquiry. 9 Department for Education, (2010), School Census. 10 Department for Communities and Local Government, (2010), Indices of Multiple Deprivation. 11 National Health Services, (2010), Business Services Data. 242

247 Assessment of the socio-economic effects using a number of methodologies, data sources and assumptions. These are set out below: - construction effects have been assessed using standard ratios of construction employment to output, assuming an average annual output per employee, applied to estimated total demolition and construction costs for the development; - calculation and analysis of the population and child yield 12 arising from the development has been carried out by applying the Council s child yield methodology; - employment expected to be generated by the commercial floorspace during the operational stage of the development has been calculated by applying standard job density ratios based on the Employment Density Guide by the Homes & Communities Agency 13 ; - an assessment of current capacity in schools surrounding the application site has been based on information from the Annual Schools Census data (2010), as well as the Council s school admissions booklets; - the capacity of existing primary healthcare facilities in the local area has been assessed using NHS data. This information was then compared to the likely population forecasts for the proposed development to assess the likely effects on primary healthcare provision; - spending estimates by residents has been calculated using average national household expenditure on goods and local services of per week; - spending on food and drink by those working on-site during the operational stage of the development has been calculated at 6 per day per worker 15 ;and 12 Child yield is usually taken to relate to the impact of new dwellings upon the local education authority s services by adding children to the local school rolls. 13 Homes and Community Agency, (2010), Employment Density Guide. 14 Office of National Statistics, (2010), Family Spending. 15 YouGov, (2006). 243

248 - demand for open space and playspace has been assessed based on the number of children likely to be living in the development against the level of provision that will be made on-site and the location of existing open spaces and playspace facilities within 800m of the site. This assessment has been made in accordance with the Greater London Authority (GLA) s Supplementary Planning Guidance (SPG) on Providing for Children and Young People s Play and Recreation and the National Playing Field Association Standards. There are no technical significance criteria relating to the assessment of socioeconomic effects. The assessment of effects is carried out against a benchmark of current socio-economic baseline conditions prevailing at, and around, the application site. As with any dataset, baseline data will change over time. The most recent published data sources have been used in this assessment, however it should be noted that in some instances these data are not be up-to-date. For example, the latest available census data is from In addition, a number of assumptions have been made in relation to likely uses in each use class within the Area Schedule as well as the likely tenure mix to be adopted. This assessment has been carried out on the maximum quantum of commercial floorspace that is being applied for and therefore the assessment of the effect on employment generation is a maximum scenario. The residential housing mix used to model the population is an indicative mix and therefore the precise unit mix and % of affordable housing may be subject to change. The assessment has been based on information received from a number of parties including the applicant, and it is assumed that the information is accurate. The assessment of effects assumes that the development would be realised as per the parameter plans and proposals that accompany the Outline Planning Application. The assessment of the significance of the development s likely residual environmental effects has been carried out using the following criteria: Character and duration of the potential impact: temporary/permanent, direct/indirect/secondary; Geographical context of the potential impact: regional (Greater London), district (the Council) and local (LIA); Magnitude of effect: - Beneficial - advantageous or beneficial outcomes to a socio-economic resource or receptor; - Negligible - imperceptible outcomes to a socio-economic resource or receptor; and - Adverse - disadvantageous or adverse outcomes to a socio-economic resource or receptor. Significance of effects which is described as: 244

249 Major (substantial change to employment prospects and local economy, change in population and demand for social infrastructure); Moderate (noticeable change to employment prospects and local economy, increased population and demand for social infrastructure); Minor (hardly perceptible change to employment prospects and local economic conditions, increased population and demand for social infrastructure); and Negligible (no effect) Consultation As part of the masterplan process the applicant has undertaken a thorough consultation exercise details of which are outlined in section 2.6. This consultation process highlighted a number of socio-economic issues raised by the community which have helped shape the illustrative masterplan and the type of social infrastructure which has been included in the development. In additional consultation in relation to socio-economic issues has been undertaken with numerous interest groups and stakeholders, including: the Council and Education Authority; the Council/s Major Developments Panel; Harrow Primary Care Trust; The New Schools Network; Harrow in Business; West London Business; and A number of other local interest groups Legislation and policy A full description of policy and plans that has been considered as part of the socioeconomic study is included in Appendix 4.4. The main documents considered are listed here National Policy Draft National Planning Policy Framework Draft, 2011; Ministerial Statement, Planning for Growth (March 2011); Planning Policy Statement 1: Delivering Sustainable Development, 2005; Planning Policy Statement 3: Housing, 2011; Planning Policy Statement 4: Planning for Sustainable Economic Growth, 2009; 245

250 Planning Policy Guidance 17: Planning for Open Space, Sport and Recreation, 2002; Providing for Children and Young People s Play and Informal Recreation Supplementary Planning Guidance, 2008; and Policy Statement Planning for Schools Development, Regional policy London Plan, Spatial Development Strategy for Greater London, 2011; and London Housing Strategy, Local policy Harrow Unitary Development Plan 2004 (Saved Policies); Local Development Framework, Pre-Submission Core Strategy, 2011; and Harrow and Wealdstone Area Action Plan, Issues and Options Consultation, Baseline conditions Current Baseline This section summarises the characteristics of the existing socio-economic conditions of the application site and the surrounding area. These conditions are considered in the context of wider local, district, regional and national socio-economic climates. The information provides the baseline against which the potential impacts of the development have been assessed. The application site is located in Harrow, Greater London and is divided into two areas by a local road (Harrow View). The western area, the Harrow View West site, is currently occupied by car parking and a former privately operated leisure facility (Zoom Leisure Centre, which closed in 2011) and associated outdoor recreational facilities and playing fields which are not for public use or access. Kodak Football Club continues to use the playing fields through private arrangement. The Harrow View East site consists of Kodak s existing operations and large areas of cleared brownfield land where industrial buildings have recently been demolished. Following a recent re-organisation, this site now employs around 570 people. Kodak s operations have been consolidated into the northern part of this site, leaving a cleared area of 5.4 ha. Harrow View East site is designated as part of a Strategic Industrial Location (SIL). A railway line runs adjacent and to the east of the application site and the surrounding area is generally residential with Wealdstone Town Centre to the east of the railway line. 246

251 Figure 12.1 Context Map The application site falls into the proposed Harrow and Wealdstone Intensification Area, which is an area designated for increased housing and commercial developments and benefits from high public transport accessibility Demographic Profile Age Data from the 2001 Census shows there to be a total resident population in the Local Impact Area (LIA) of approximately 37,032. The total for the council was 206,828. In 2010, the mid-year population estimate for the Council was 230,000. The Greater London Authority population projection for the LIA was 40,133 for According to the 2001 Census data, in general, the age profile of the LIA population is similar to borough wide, regional and national figures. A third of the LIA s population is aged between 20 and 40, compared to the slightly lower proportion in the council and England as a whole (30% and 28% respectively) and higher proportion in London as a whole (36%). With only 13% of its population aged over 64, the LIA s population is marginally younger than the council and English averages (14% and 16% aged over 64 respectively) but older than the London average (12%). Ethnicity Half of the population of the council and the LIA are of White British origin, compared to 60% in London as a whole. Both the LIA and the council also have a high proportion of people of Indian origin (20% and 22% respectively) compared to London as whole (6%). 247

252 The next largest minority groups in the LIA are of Irish (6%), Asian or British Asian (5%), Black Caribbean (4%) and other White (4%) origins. These groups are similarly represented in the Council as a whole. Qualifications According the 2001 Census, the population of the LIA has a similar level of qualifications as the Council; approximately one fifth of both populations have no qualifications compared to a quarter in London as a whole. Approximately 30% of London, the Council and the LIA have Level 4/5 qualifications. Within the LIA itself, the population of Wealdstone has a lower skill level than the three other wards which make up the Local Impact Area: 27% of its population has no qualifications, compared to Headstone North, Headstone South and Marlborough (16%, 17%, 22% respectively). Only 24% of Wealdstone s population has level 4 qualifications and above compared to higher proportions in Headstone North (33%), Headstone South (36%), Marlborough (31%), the Council (29%) and London (31%) Economic profile Employment and Economic Activity The existing employment uses on-site are based in Kodak s factory on the Harrow View East site. There are currently 570 jobs on-site. The 2001 Census showed that the economic activity in the LIA (70%) was marginally higher than the Council (68%) and London (68%). In August 2011, 3.7% of residents in the LIA were claiming job seekers allowance (JSA), compared to 2.7% in the Council and 4.4% in London. The average for the LIA does not show differences between the wards. In August 2011, 5% of Wealdstone was claiming JSA compared to only 2.1% in Headstone North. Occupation of Residents According to 2001 Census data, the top three occupations of the resident population in the LIA are: Administrative Professional and Technical Occupations (18%); Managers and Senior officials (17%); and Professional occupations (17%). Collectively, these three occupations account for 51% of all occupations held by residents in the ward. This compares to 52% and 48% for the Council and London respectively. Business Structure Data from the Annual Business Inquiry (2009) shows that education, manufacturing and health are the biggest employment sectors in the LIA, accounting for 15%, 14% and 11% of all jobs. With just under a tenth of all jobs each, the construction and 248

253 business administration and support services represent the next largest sectors. These figures compare to the Council where retail, education and health are the largest sectors (12%, 11.6% and 11.1% respectively). The most important employment sectors for London are professional, scientific & technical (11.3%), business administration & support services (10.8%) and public administration & other (10.6%). Table 12 1: Business Structure (ABI 2009) Local Impact Area Harrow London Manufacturing 14% 4.9% 2.9% Construction 9% 8.3% 3.4% Retail 7% 12.0% 9.0% Professional, scientific & technical 6% 7.9% 11.3% Business administration & support services 9% 8.9% 10.8% Education 15% 11.6% 7.5% Health 11% 11.1% 9.3% Public admin & other 5% 10.0% 10.6% Housing Housing Type Data from the Census shows that the housing stock in the LIA is predominantly comprised of houses and bungalows (72%). This is comparable to the Council (73% houses and 27% flats/maisonettes/apartments) but differs from the London average (48% flats/maisonettes/apartments and 52% houses). The application site does not currently contain any housing. The surrounding area is largely residential, with housing located to the south, west, and north and to the east on the other side of the railway line. Housing Tenure In terms of tenure, the LIA has a lower proportion of social rented housing (9%) compared to the Council (11%) and regional figures (26%) Census Data shows that the LIA also has a higher proportion of owner occupied housing (76%) than the borough wide area (75%). It is also higher than the average for London as a whole (57%). Deprivation Figure 12.2 illustrates Indices of Multiple Deprivation (IMD) in the Council. The indices combine information relating to income, employment, education, health, 249

254 skills and training, barriers to housing and services and crime into an overall measure of deprivation. Figure 12.2 shows that the application site is not located within an area classified amongst the top 20% most deprived in England. There are only three small areas classified within the top 20% most deprived areas in England in the Council. Figure 12.2 Indices of Multiple Deprivation Community infrastructure Education Figure 12.3 shows education facilities within a 1 km radius of the application site. It shows that there are 6 primary schools within 1 km of the application site. 250

255 Figure 12. 3: Education and Health Facilities situated within 1km of the site Table 12.2 below shows the capacity of these schools, the number of pupils on roll and their surplus capacity. This information is taken from the Annual School Census 2010, published by the Department for Children, Schools and Families (DCSF) and annual admissions booklets published by the Council. The table shows that St Teresa s Catholic Primary School and Whitefriars Community School are currently operating with surplus capacity. The other four schools are operating at capacity. Pinner Park Infant and Nursery School is open to pupils aged between 4 and 7 and Pinner Park Junior School to those between 7 and 11. The remaining four schools are open to pupils aged between 4 and 11. Table 12.2: Primary School Capacity within 1KM of the application site Primary School Capacity Number on Roll Surplus Capacity Whitefriars Community School Marlborough Primary School Pinner Park Junior School Pinner Park Infant and Nursery School St Teresa's Catholic Primary School and Nursery

256 Primary School Capacity Number on Roll Surplus Capacity Cedars Manor School Total Table 12.3 below shows the level of surplus secondary school capacity currently available within the Council. It shows that there is a large surplus capacity at secondary school level within the Council (20%), with only The Sacred Heart Language College operating near capacity. Each of these secondary schools also has a 6th form. The Sacred Heart Language College and the Salvatorian Roman Catholic College are both located within 1km of the application site. Table 12.3: Secondary school capacity in the London Borough of Harrow Name Capacity Number on Roll Surplus Capacity Hatch End High School 1,500 1, Park High School 1,500 1, Canons High School Nower Hill High School 1,500 1, Whitmore High School 1,350 1, Rooks Heath High School 1, Bentley Wood High School Harrow High School and Sports College The Sacred Heart Language College Salvatorian Roman Catholic College Total 11,100 8,838 2,262 Health Figure 12.3 maps General Practitioner (GP) surgeries, dentists, opticians and pharmacies within 1km of the application site. It shows that there are 10 dentists, 4 opticians, 8 pharmacies and 6 GP surgeries within 1 km of the application site. NHS Individual List Size Data (2011) provides information on the number of patients registered to each GP practice nationally, this is published annually. The average list 252

257 size for the 6 GP surgeries is 1,895.The average list size for the Council as a whole is approximately 1,700. Open Space and Leisure Facilities Figure 12.4 below maps open space and leisure facilities within 1 km of the application site. It shows that there is one leisure centre within this area; Harrow Leisure Centre is located to the east of the application site. Facilities include two indoor pools, a fitness centre, 8 squash courts, combat rooms, a rock climbing wall, snooker and table tennis rooms, a cafe and activity rooms. Headstone Manor, which includes a large expanse of open space, an historic moated manor house dating back to the 14th century, a tithe barn and two smaller agricultural buildings, is located to the west of the Harrow View West site. The manor house is home to Harrow Museum which displays permanent and temporary exhibitions exploring various aspects of local history. This area is open to the public and free to visit. There are several other open space areas within 1 km of the application site. The closest is Pinner Park which is located to the north west of the application site. There are several other areas of open space including Harrow Weald Recreation Ground which is located to the north and includes several tennis courts. To the west is Byron Recreation Ground which lies adjacent to Harrow Leisure Centre. Figure 12.4: Open space and leisure facilities within 1 km of the application site 253