Bromley by Bow South Energy Strategy

Transcription

1 Bromley by Bow South Energy Strategy April

2 CONTENTS 1 INTRODUCTION POLICY REVIEW BASELINE CO2 EMISSIONS DEMAND REDUCTION (BE LEAN) COOLING AND OVERHEATING HEATING AND COOLING INFRASTRUCTURE (BE CLEAN) RENEWABLE ENERGY (BE GREEN) CONCLUSIONS APPENDIX A APPENDIX B This document has been prepared by AECOM Limited for the sole use of our client (the Client ) and in accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed between AECOM Limited and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM Limited, unless otherwise expressly stated in the document. No third party may rely upon this document without the prior and express written agreement of AECOM Limited. 1

3 INTRODUCTION 2 01

4 1 INTRODUCTION Purpose of the Report 1.1 The London Legacy Development Corporation (LLDC) is in the process of preparing a Bromley by Bow Supplementary Planning Document (SPD) to provide further guidance in relation to the Bromley by Bow Site Allocation and other relevant policies within its Local Plan 1. The area covered by the SPD is the Bromley by Bow Site Allocation AECOM was commissioned by the landowners group for Bromley by Bow South (henceforth referred to as the Site ), to develop a site-wide energy strategy. The landowners group represents the six major land owners of the Site: Danescroft Land Ltd, Lindhill Properties Ltd, British Land PLC, Vastint Holding B.V, Southern Housing Group, and London Legacy Development Corporation (LLDC). 1.3 It is the intention of the landowners to submit an illustrative masterplan to the Planning and Policy Decisions Team (PPDT) of the LLDC, to inform the SPD and demonstrate how the maximum parameters set-out in the SPD could be delivered on-site. This illustrative masterplan has been subject to environmental testing, and this report forms part of a series of reports which have been produced to form a separate evidence base identifying any potential significant environmental effects of the operation of the maximum extents/parameters implemented through the illustrative masterplan, and where further work might be required to support a planning application for redevelopment of the Site, or any part thereof. 1.4 The purpose of the energy strategy is to: inform the illustrative masterplan for the area being developed by Karakesevic Carson Architects (KCA); to inform the development of the Bromley by Bow SPD ( the SPD ) being prepared by LLDC s Planning Policy Decision Team (PPDT); and to inform the preparation of Energy Statements produced by developers as part of future planning applications for the Site, or any part of it. 1.5 The energy strategy aims to identify the design standards and associated energy infrastructure that will be necessary to enable future development to meet current energy and CO 2 policies established in local and regional planning policy as well as Part L of the Building Regulations. It also aims to ensure that a comprehensive approach is taken to energy provision that will enable opportunities that arise from larger scale developments to be captured, in particular the provision of low carbon, site-wide heating infrastructure. 1.6 This report addresses the strategy required to enable future planning applications on the Site (or any part thereof) to meet each level of the Mayor s Energy Hierarchy and LLDC s Local Plan policies. It covers the following broad themes: Energy efficiency (be lean) Supplying energy efficiently (be clean) Using renewable energy (be green) 1.7 Energy generation is a major contributor to global CO 2 emissions and global warming. Designing energy efficient buildings and incorporating low and zero carbon energy generation is therefore a vital part of ensuring that the illustrative masterplan is sustainable. The Site 1.8 The Site consists of 6.06 ha of land that is currently owned by six landowners: Danescroft Land Ltd, Lindhill Properties Ltd, British Land PLC, Vastint Holding B.V, Southern Housing Group, and London Legacy Development Corporation (LLDC). A strip of land owned by the Canals and Rivers Trust also lies within the Site, bordering the Lea Navigation canal. 1.9 The current land holdings are illustrated in Figure 1. 1 London Legacy Development Corporation Local Plan 2015 to Adopted 21 July

5 Figure 1: Bromley by Bow South existing land holdings Site Context 1.10 The Site is bounded by the A12 to the west, by the Lea Navigation to the east, by the North London Line (now part of London Overground) to the south and the Bow River Village development (currently under construction) to the north The surrounding rail, road and river infrastructure creates significant barriers in terms of connectivity and in terms of the potential to connect to existing district heating infrastructure or to extend new heating infrastructure beyond the Site boundary The A12 in particular means the Site is exposed to elevated oxides of nitrogen (NO x ) and particulate matter (PM 10 ) levels and to high levels of noise. This has implications for the design of homes in particular how effective ventilation and comfort is maintained for properties bordering the A12. It also has implications for any on-site energy centre combustion plant which must be carefully designed to avoid significant effects on air quality. 4

6 Figure 2: Site location and context 1.13 The Site falls within the LLDC Local Plan area and future planning applications will be determined by LLDC PPDT The LLDC Local Plan Site Allocation SA4.1 identifies the site for mixed use development comprising: New and re-provided retail floor space that is capable of functioning alongside a mix of uses, as a new District Centre; A primary school; A new 1.2 ha park; Riverside Walk; Community Facility (e.g. library); New homes with a significant element of housing; and New employment generating business space in a range of sizes and formats. Neighbouring Sites 1.15 There are a number of neighbouring sites that have consented planning applications, that are within the LLDC planning boundary, and whose landowners also have land holdings within the Site. In 5

7 particular, the Stand East and Bow River Village sites are of interest in terms of potential synergies with energy provision to the illustrative masterplan. Strand East (Sugar House Lane) 1.16 To the north east of the Site across the Lea Navigation is Strand East, a proposed development (currently under construction) by Vastint Holding BV and LandProp. This is a 10 hectare mixed-use development made up of: 1,200 new homes, 620,000 sq. ft. of business and commercial space, including local shops, cafes, restaurants and other community facilities, together with a 350-bedroom hotel. Outline planning permission was secured by LandProp in October Bow River Village (Bromley by Bow North) 1.17 Planning permission was granted in 2012 to Southern Housing Group for a masterplan delivering over 700 new homes and 100,000 sq. ft. of commercial space. A portion of this committed development sits within the Site itself. The elements outside of the Site involve demolition of the existing buildings and construction of 8 new blocks to provide 453 new homes, a car dealership, an additional 1,718 m 2 GIA of commercial floorspace, open space and parking. The first phase of the development is currently under construction and close to completion as illustrated in Figure 3. Figure 3 Bromley by Bow South (looking north along Lea Navigation April 2016) Emerging Masterplan and Phasing 1.18 Figure 4 sets out the illustrative ground floor plan for potential development on the Site, showing ground floor employment uses in blue, ground floor retail provision in red, homes in yellow and a proposed 2 form entry primary school in green Figure 5 sets out the illustrative massing for the scheme. Four taller buildings of between 16 and 25 storeys are located towards the south west corner of the Site. The taller building shown in pink in the south west corner of the Site is the currently proposed location for an on-site energy centre, which would be located in a double height space at ground floor level, and which would use the height of the building to allow energy centre flues to terminate at high level. 6

8 Figure 4 Illustrative ground floor plan 7

9 Figure 5: Illustrative building massing and heights (looking south) Phase 1 Phase 2 Phase 3 Figure 6: Illustrative phasing 1.20 Figure 6 sets out a summary of the illustrative phasing plan for the illustrative masterplan. The initial phases of development are expected to be at the southern end of the Site including the provision of the proposed energy centre in the yellow block in the south west corner. This is expected to be followed by re-provision of retail space and associated development at the northern end of the Site, allowing an existing Tesco store to be removed from the centre of the Site and the final phases of development to be delivered. 8

10 Illustrative Development Schedule 1.21 Energy calculations to determine site energy use and carbon emissions are based on an illustrative development schedule and non-domestic floor areas prepared by KCA 2. The information used is summarised in Table 1. Landowner Phase Retail Store Workspace Social Infrastructure GIA (sqm) 2FE School Homes No. of units Danescroft Land Ltd , , Lindhill Properties Ltd 1 1,024 37, British Land (northern parcels) , Vastint Holding B.V , LLDC , Southern Housing Group , British Land (excl. N parcels) ,844 46, TOTAL 3 2,324 1,341 4, , ,287 1,690 Table 1: Illustrative development schedule (based on KCA 25 February 2016) 1.22 At this stage, the illustrative development schedule does not include a breakdown of the size and type of units. The analysis in this report is based on the following working assumption of the site-wide unit split, agreed with KCA: 40% 1-bed flats, 40% 2-bed flats, and 20% 3-bed flats. 2 Provided by KCA on 25 February

11 POLICY REVIEW 10 02

12 2 POLICY REVIEW Introduction 2.1 The energy strategy for the Site has been developed in response to national and local policies that aim to reduce carbon emissions from new development while protecting local air quality and indoor comfort for building occupiers. The main policies of relevance are summarised below. International Policy Drivers United Nations Framework Convention on Climate Change 2.2 Over the past 20 years the need to reduce the growth in global greenhouse gas emissions has been gaining momentum on the international political agenda. The main vehicle for international cooperation on climate change mitigation is the United Nations Framework Convention on Climate Change (UNFCCC). 2.3 Through the UNFCCC, most countries have been setting targets for national carbon emissions reductions and this is expected to continue following strengthening of international agreements at the 21 st Conference of the Parties (COP21) to the UNFCCC in Paris in Energy Performance of Buildings Directive 2.4 The European Energy Performance of Buildings Directive (EPBD) requires that: by 31 December 2020, all new buildings should be nearly zero-energy buildings ; and after 31 December 2018, new buildings occupied and owned by public authorities should be nearly zero-energy buildings. The Directive defines nearly zero-energy buildings such that the nearly zero or very low amount of energy required should be covered to a very significant extent by energy from renewable sources, including energy from renewable sources produced on-site or nearby. 2.5 EU Directives are met by member states transposing the requirements into national legislation. The UK Government has previously met EPBD requirements for new buildings by transposing the requirements into Part L of the Building Regulations. It can be inferred that the Government will bring forward policy that defines nearly zero-energy buildings in the UK and implements the EPBD requirements through Part L of the Building Regulations by December 2018 for at least some buildings. National Policy Drivers UK Climate Change Act 2.6 The Climate Change Act (2008) sets a legally binding target to reduce UK carbon emissions by 80% by 2050, against a 1990 baseline. The Committee on Climate Change advises the Government on the setting of binding 5-year carbon budgets on a pathway to achieving the 2050 target. The first four carbon budgets covering the period up to 2027 have been set in law. The current budget requires a 29% emissions reduction by 2017, while future budgets require reductions of 35% by 2020 and 50% by The Act is the driver behind a framework of national strategy and policy documents such as the UK Low Carbon Transition Plan (2009) and previously anticipated zero carbon homes policy. These in turn have informed the development of local planning policy and updates to the Building Regulations. UK zero carbon homes policy 2.8 In July 2015 it was announced that: the Government does not intend to proceed with the zero carbon Allowable Solutions carbon offsetting scheme, or the proposed 2016 increase in on-site 11

13 energy efficiency standards, but will keep energy efficiency standards under review, recognising that existing measures to increase energy efficiency of new buildings should be allowed time to become established. 2.9 This announcement effectively interrupted the previous schedule to update energy efficiency standards for homes every 3 years (with standards having been updated in 2013 and the next update due in 2016) and cancelled the policy for new homes to be zero carbon from This has created some uncertainty regarding national, London Plan and local planning policy, which included policies that anticipated the introduction of a UK zero carbon homes policy. National Planning Policy Framework 2.10 The National Planning Policy Framework was published in March 2012, replacing all previous Planning Policy Statements and guidance. Some of the key paragraphs relating to energy are set out below: 95. To support the move to a low carbon future, local planning authorities should: plan for new development in locations and ways which reduce greenhouse gas emissions; when setting any local requirement for a building s sustainability, do so in a way consistent with the Government s zero carbon buildings policy and adopt nationally described standards. 96. In determining planning applications, local planning authorities should expect new development to: comply with adopted Local Plan policies on local requirements for decentralised energy supply unless it can be demonstrated by the applicant, having regard to the type of development involved and its design, that this is not feasible or viable; and take account of landform, layout, building orientation, massing and landscaping to minimise energy consumption. 97. To help increase the use and supply of renewable and low carbon energy, local planning authorities should recognise the responsibility on all communities to contribute to energy generation from renewable or low carbon sources. They should: identify opportunities where development can draw its energy supply from decentralised, renewable or low carbon energy supply systems and for colocating potential heat customers and suppliers In paragraph 95, reference to the Government s zero carbon buildings policy now needs to be read in the context of the effective cancellation of 2016 zero carbon homes policy, but could apply to the UK implementation of EU policy on nearly zero-energy buildings described above. Local Planning Policies The London Plan The updated London Plan, published in March 2015, sets out a range of policies that influence the preferred energy strategy for the Site. Some policies address energy and carbon emission directly, while others aim to address air quality issues associated with combustion plant, to reduce cooling demands, and to reduce the risk of overheating in buildings. The main policy requirements are summarised in the sections below. 12

14 2.13 The Mayor s Supplementary Planning Guidance on Sustainable Design and Construction 3 and GLA s Guidance on the Preparation of Energy Statement s 4 provide further detail on how the policies should be interpreted and implemented. Energy use and CO 2 emissions 2.14 London Plan Policy 5.2 is the overarching policy relating to energy use in new development. It requires developments to make the fullest contribution to the mitigation of climate change and to minimise emissions of carbon dioxide. The policy includes the following energy hierarchy for assessing applications: using less energy, supplying energy efficiently, in particular by prioritising decentralised energy generation, and using renewable energy The policy includes a requirement for domestic and non-domestic developments being put forward between 2010 and 2016 to achieve a 40% carbon reduction against Part L The GLA Guidance on preparing energy assessments 4 states that this target should be treated as equivalent to a 35% reduction against Part L The policy also states that domestic development brought forward from 2016 should be zero carbon and non-domestic development from 2016 should meet Part L of the Building Regulations and from 2019 be zero carbon. This element of the policy was intended to align with national government s proposals for zero carbon homes by 2016 and zero carbon non-domestic buildings from However in July 2015 the Government announced within the Productivity Plan 5 that it does not intend to proceed with its zero carbon policy for homes. This announcement, combined with the Housing Standards Review carried out in created uncertainty on how the London Plan zero carbon targets would now be interpreted In the absence of a national policy on zero carbon or nearly zero-energy buildings, in March 2016 the GLA prepared an update to its guidance on the preparation of energy statements 7. This clarifies how the GLA expects the Policy 5.2 zero carbon targets to be implemented. GLA will require new homes forming part of major applications to be zero carbon from the 1st October I.e. Part L 2013 regulated emissions must be reduced to zero; of this reduction 35% must be achieved on-site. Any residual regulated emissions must be offset through payments to the Local Planning Authority for ring fenced investment in carbon reduction projects off-site. This will apply to Stage 1 applications received by the GLA after the 1st October The GLA guidance on preparation of energy statements sets a default price for carbon offsets of 60/tonne for 30 years. Where the local authority has established their own evidenced base price this would be applied. It is understood that LLDC will publish an SPD to the LLDC Local Plan covering offsetting arrangements. This is expected to set carbon offset payments at the default level of 60/tonne for 30 years, which is equal to 1,800 per tonne/year For non-domestic buildings there is no zero carbon requirement and from 1st October 2016 the target reduction for non-domestic buildings will remain at a 35% reduction in regulation emissions against the Part L 2013 baseline. A shortfall in meeting this target can be made up through an offset payment The GLA guidance requires that carbon reductions are reported separately for homes and nondomestic buildings so that offset payments can be easily identified The GLA Guidance on preparation of Energy Statements7 also requires that in order to show that energy demand reduction has been adequately addressed, building designs should meet the Target 3 Sustainable Design and Construction Supplementary Planning Guidance. London Plan Implementation Framework GLA. April ENERGY PLANNING Greater London Authority guidance on preparing energy assessments. GLA. March Which stated the Government s intention to amend the Energy Act (2008) to stop local authorities from setting local energy standards higher than those set within Part L of the Building Regulations. 7 ENERGY PLANNING Greater London Authority guidance on preparing energy assessments. GLA. March

15 Emission Rates (TER) in Part L of Building Regulations, through efficiency measures alone before account is taken of low carbon fuel supplies or renewable energy generation London Plan Policy 5.3 Sustainable Design and Construction requires development proposals to demonstrate that sustainable design standards are integral to the proposal, including its construction and operation, and ensure that they are considered at the beginning of the design process London Plan Policy 5.6 Decentralised Energy in Development Proposals requires that development proposals evaluate the feasibility of Combined Heat and Power (CHP) systems, and where a new CHP system is appropriate also examine opportunities to extend the system beyond the Site boundary to adjacent sites Major development proposals should select energy systems in accordance with the following hierarchy: Connection to existing heating or cooling networks Site wide CHP network Communal heating and cooling London Plan Policy 5.7 Renewable Energy requires major development proposals to provide a reduction in expected carbon dioxide emissions through the use of on-site renewable energy generation, where feasible. The supporting text to this policy sets an expectation that this should deliver carbon savings of 20%, although this is rarely feasible for dense urban schemes in London. Reducing cooling demands and overheating risk 2.26 London Plan Policy 5.9 Overheating and cooling requires the design to follow a cooling hierarchy to reduce the risk of overheating and the need for active cooling. This issue is now being given greater focus by the GLA. The GLA s Guidance on the Preparation of Energy Statements was recently updated to provide further guidance on the information the GLA expects applicants to provide as part of the preparation of Energy Statements, this now includes the preparation of the checklist attached as Appendix A to this report. Air quality 2.27 London Plan policy 7.14 states that developers are to design their schemes so that they are at least air quality neutral The London Plan states that new development proposals should meet the minimum air quality standards outlined in the Mayor s Supplementary Planning Guidance on Sustainable Design and Construction updated in April The SPG sets out emission standards for: individual gas boilers; communal gas boilers; solid biomass boilers; and Combined Heat and Power (CHP) plant Where individual and/or communal gas boilers are installed in commercial and domestic buildings they should achieve a NO x rating of <40 mg NO x /kwh Appendix 7 of the SPG sets out minimum emission standards for biomass boilers and CHP engines. The standards that are required to be met depend on whether baseline average annual mean nitrogen dioxide (NO 2 ) and PM 10 emissions are greater than 5% below the national objective or greater than 5% above or 5% below the national objective. Initial air quality assessment for the illustrative masterplan 8 suggests that due to the proximity to the A12 the majority of the site is likely to be exposed to NO 2 emissions above the air quality objective value of 40 µg/m 3 (see also section 6.29 and Appendix B) and hence the band B emission standards in Appendix 7 of the SPG are likely apply to any energy centre plant on the Site. If an on-site energy centre with gas CHP engines is provided these engines are expected to require either selective catalytic reduction (SCR) (lean burn engines) or non-selective catalytic reduction (NSCR) (rich burn engines). 8 Site 4.1 Bromley by Bow South - Air Quality Impact Topic Report. AECOM. April

16 LLDC Local Plan (July 2015) 2.31 Policy S.2 requires development to follow the energy hierarchy and the carbon reduction targets within the London Plan (March 2015). The policy also states that Where these targets cannot be met onsite, and until any nationally recognised Allowable Solutions system is in place, a financial contribution to the Legacy Corporation Carbon Offsetting Fund will be required. A supplementary planning document will be prepared, setting out the rate per tonne of carbon dioxide and the scheme for applying the funds raised Policy S.3 requires development to connect to existing energy networks in the Legacy Corporation area or to construct and connect to new energy networks where feasible and viable to do so. The policy also states that, if district heating is proposed, appropriate management mechanisms must be put in place to ensure that end customers are protected in respect of the price of energy provided and that heat losses from the network are minimised Policy S.4 requires development proposals to demonstrate that they achieve the highest standards of sustainable design and construction. Applications for major development will be required to include evidence that the following energy related measures have been taken into account within the development of a scheme: Carbon dioxide emissions reduction (including utilisation of renewable, low- and zero-carbon energy sources); Natural heating and ventilation; Utilisation of decentralised energy sources; and Accommodate utilities networks, including where appropriate, heating and cooling network pipes Policy S.7 states that proposals for new development should ensure that buildings and spaces are designed to avoid overheating and excessive heat generation internally and externally, while minimising the need for internal air conditioning systems. LLDC Corporate Standards 2.35 In addition to the national, London-wide and local planning policy targets, LLDC has made corporate commitments to a range of additional targets 9. Where these targets relate to this energy strategy and exceed those required by planning policy they are highlighted below: 15% reduction in embodied energy compared with conventional practice. 15% reduction in emissions over 5 years in actual in-use energy use through engagement with occupants and the promotion of energy efficient home appliances These targets are not planning requirements and as such would not be expected to be addressed through the Bromley by Bow SPD. However, they may apply to any development brought forward on the land owned by LLDC. Policy review summary 2.37 The key policy drivers and targets that have been identified as applicable to the development can be summarised as follows: Ensure that efficiency standards are sufficient to meet Part L 2013 Target Emission Rates prior to any allowance for low carbon or renewable energy supply options. Achieve a 35% reduction in regulated emissions on-site against Part L New homes to be zero carbon from 1 st October 2016, with a minimum 35% reduction in regulated emission on-site, and any residual emissions offset by payments to the LLDC offsetting fund at 60 per tonne for 30 years, equivalent to 1800 per tonne of residual annual CO 2.emissions. We assume this would apply to any planning application received by GLA after the 1 st October. 9 Environmental Sustainability Policy Your Sustainability Guide to QEOP LLDC April

17 Non-domestic buildings to be zero carbon from From now to 2019 non-domestic buildings to achieve a 35% reduction in regulated CO 2 emissions against a Part L 2013 Baseline. Prioritise connection to existing heat networks and where this is not feasible or viable develop new heat networks on-site where viable. Deliver a proportion of the Site s energy needs from renewable resources. Design homes and buildings to reduce cooling demands and minimise the risks of overheating. Ensure that any on-site energy centre plant is designed in line with London Plan air quality requirements including the emission standards set out in Appendix 7 of the Mayor s SPG on Sustainable Design and Construction. 16

18 BASELINE CO 2 EMISSIONS 17 03

19 3 BASELINE CO 2 EMISSIONS Introduction 3.1 GLA guidance on preparing energy assessments 10 states that the regulated CO 2 emissions baseline is the regulated CO 2 emissions assuming the development complied with Part L 2013 of the Building Regulations using Building Regulations approved compliance software. 3.2 The Target Emission Rate (TER) represents the maximum CO 2 emissions, under the regulations, allowed to arise from space and water heating, lighting, pumps, fans, and cooling. The GLA guidance goes on to establish that the regulated CO 2 emissions baseline is the aggregate of Target Emission Rates (TERs) of homes and non-domestic buildings multiplied by their respective Treated Floor Areas. 3.3 As detailed designs for homes and non-domestic buildings are not available at this early stage, baseline emissions for the Site were estimated according to the following methodology. Baseline emissions for homes Modelling and calculation of emissions for homes 3.4 Nine representative dwelling designs from previous AECOM projects were selected as reasonable examples of homes for the illustrative masterplan. All the homes proposed within the illustrative masterplan are flats, and the following representative unit types were selected: 1 bedroom flats (ground, mid and top-floor); 2 bedroom flats (ground, mid and top-floor); and 3 bedroom flats (ground, mid and top-floor). These representative dwellings were modelled in NHER Plan Assessor version 6.1, which is approved SAP 2012 compliant software for assessing compliance with Building Regulations Part L Regulated emissions for homes 3.5 The results of the NHER modelling include the Part L criterion 1 Target Emission Rate for each home. Unregulated emissions for homes 3.6 The unregulated baseline CO 2 emissions for cooking, appliances, small power and external uses were based on the SAP 2012 Appendix L calculation methodology 11. Unregulated, communal energy uses 3.7 It was assumed that internal corridors and cores in the residential blocks would cover a floor area equivalent to 10% of the treated floor area of homes. It was assumed that corridors would not be heated and would be lit by low energy lighting with presence detectors and timer switches to reduce energy consumption. The energy consumption of lifts and internal car and cycle parking were also estimated. Calculation of site-wide carbon emissions for homes 3.8 The approximate numbers of each representative dwelling type were derived from the total numbers of units in the illustrative development schedule (see Table 1) combined with the dwelling type mix (see paragraph 1.22). 10 ENERGY PLANNING Greater London Authority guidance on preparing energy assessments. GLA. March The Government s Standard Assessment Procedure for Energy Rating of Dwellings Edition version BRE. October

20 3.9 The total site-wide regulated carbon emissions for homes were calculated by multiplying the emissions for each dwelling type by the total number of homes of that type on the Site. A breakdown of carbon emissions per development phase was also calculated in a similar manner. Baseline emissions for non-domestic buildings 3.10 The baseline carbon emissions for non-domestic buildings were calculated using TER benchmarks, in kwh/m², for offices, retail space, and schools based on IES modelling carried out for previous AECOM projects. Emissions for each of these types of non-domestic building were calculated by multiplying the benchmark emissions by the corresponding floor area set out in the illustrative development schedule (see Table 1) The emissions rate for offices was also applied to calculate the emissions for the small area of communal uses in the schedule, and the retail benchmarks were applied to calculate the emissions for the retail store area The aggregate emissions for non-domestic buildings calculated from the benchmarks are taken as giving a reasonable estimate of baseline carbon emissions given the variability in design and resulting uncertainty in TER for these types of buildings at this stage of development The unregulated baseline CO 2 emissions arising from non-domestic small power was taken from IES modelling, which makes standard assumptions on typical fittings and running hours. The energy consumption of lifts was also estimated. Site-wide baseline CO 2 emissions 3.14 The regulated and unregulated baseline CO 2 emissions for the Site, calculated as outlined above, are set out in Table 2. (tonnes CO/year) Baseline emissions for Building Regulations Part L 2013 Compliant Development Regulated Unregulated Carbon emissions for homes 1,916 2,358 Phase ,091 Phase Phase Carbon emissions for non-domestic buildings Phase Phase Phase Site-wide annual carbon emissions 2,182 2,566 Table 2: Baseline site CO 2 emissions 3.15 The total baseline regulated emissions for the illustrative masterplan were calculated to be 2,182 tonnes of CO 2 per year. Of this 1916 tonnes of CO 2 per year relates to homes and 265 tonnes of CO 2 per year relates to no-residential uses. 19

21 DEMAND REDUCTION (BE LEAN) 20 04

22 4 DEMAND REDUCTION (BE LEAN) Introduction 4.1 Future planning applications for the Site or any part thereof will need to demonstrate that buildings have been designed with efficiency standards that are capable of meeting Part L of Building Regulations through efficiency measures alone. At this illustrative masterplan stage no detailed designs have been prepared for homes and non-domestic buildings. 4.2 For homes, representative dwellings were modelled to determine the likely fabric specification required to meet Part L 2013 through efficiency measures and to establish indicative energy demands for homes complying with the Mayor s energy efficiency requirements. 4.3 For non-domestic buildings, experience from previous IES modelling exercises for detailed planning applications or subsequent detailed design were reviewed to determine the likely fabric specification and efficiency measures needed to meet Part L Energy efficient specification for homes 4.4 To meet Part L 2013 homes must achieve both a minimum Target Emission Rate as well as a minimum Target Fabric Energy Efficiency (TFEE) level. The TFEE is calculated based on the specific geometry of the home. 4.5 The modelling exercise carried out on representative dwelling types (and experience from previous schemes) suggests that it should be possible for homes on the Site to meet Part L 2013 through energy efficiency measures alone. Table 3 sets out an illustrative specification that enables the representative units modelled to meet the required TER and TFEE. In practice there is some flexibility for individual plot developers to trade off one element of the specification against another, for example improving air-permeability rates to allow a relaxation in the wall U-value. Element Units Average specifications Wall U-values W/m²K 0.18 Roof U-values W/m²K 0.13 Floor U-values W/m²K 0.13 Windows U-values W/m²K 1.25 Doors U-values W/m²K 1.2 Air permeability m³/m² 50 Pa 5 Ventilation Heating system type Heating system efficiency 93.5%* Thermal bridging Whole house mechanical extract Communal gas boilers Accredited Construction Details Notes: * This is the effective efficiency entered into NHER Plan Assessor to represent a communal boiler with weather and load compensation (taken from the SAP TER worksheet for a building with these controls and an 89.5% efficient communal gas boiler). Table 3: Illustrative average dwelling efficiency standards 4.6 It is expected that the detailed design teams will need to pay particular attention to designing out thermal bridges in order to avoid negatively affecting performance against Part L. Design teams may also need to consider an alternative strategy with regards to ventilation, depending on the external conditions (e.g. pollution and noise concerns) specific to their plot. 4.7 The specification has assumed centralised extract mechanical ventilation which provides the potential for higher boost mechanical ventilation rates than typical whole house mechanical ventilation and therefore calculated energy use better represents the systems that are likely to be needed to address noise and air quality issues from the A12. 21

23 Energy efficient specification for non-domestic buildings 4.8 The benchmarks used for non-domestic buildings were derived from previous modelling exercises. Table 4 sets out the corresponding illustrative specifications that should enable each building type to meet or improve on the Part L 2013 TER through efficiency measures alone. Element Wall U-values Units Average specifications Office Retail School Floor U-values 0.12 W/m²K * Roof U-values 0.12 Windows U-values Air permeability 50 Pa Cooling system type Fan coils Split units Split units & zonal extract Cooling efficiency (SEER) Heating type Communal gas boilers Heating efficiency >90% Notes: * U-values for floor and roof are often of minimal relevance where non-domestic buildings make up lower floors of apartment buildings Table 4: Illustrative energy efficiency specification for offices, retail space, and school 4.9 Note that the actual specifications for the buildings of any future detailed design associated with a planning application will have to be assessed and further defined following detailed energy modelling. This is because calculated results will vary according to the detailed built form, glazing areas and final uses. Unregulated energy uses 4.10 The estimated baseline unregulated energy demands for external and communal spaces include reasonable allowance for efficiency measures that are typically fitted as standard, for example low energy light fittings with effective controls It may be that additional demand reductions will be achievable through careful design and specification of specific energy-efficient products. It is not possible at this stage to quantify the extent of these additional savings, therefore no demand reduction from external energy uses has currently been assumed. Energy demand and CO 2 emissions after demand reduction Energy demand after demand reduction measures 4.12 The fabric specifications outlined above were used in the modelling to determine the energy demands following the application of efficiency measures to enable the savings against the Building Regulations baseline to be determined and allow sizing of district energy infrastructure. These are shown in Table 5 below. It is worth noting that the largest heat demands (around 46%) relate to the first indicative phase of development which supports the case for siting the proposed energy centre within Phase 1. 22

24 (kwh/year) Energy demands after demand reduction Space heating Hot water Regulated electricity Unregulated electricity Energy demands for homes 3,618,990 3,025, ,208 4,543,532 Phase 1 1,674,586 1,400, ,881 2,102,392 Phase 2 828, , ,871 1,040,442 Phase 3 1,115, , ,456 1,400,698 Energy demands for non-domestic buildings 155,456 61, , ,668 Phase 1 34,959 21, , ,162 Phase 2 37,540 10, , ,058 Phase 3 82,958 29,385 82,841 86,447 Site-wide energy demands 3,774,446 3,087,649 1,040,253 4,943,199 Table 5: Energy demands following demand reductions Carbon emissions and savings after energy demand reduction 4.13 The CO 2 emissions and savings calculated for the Site based on the fabric specifications above are set out in Table 6. (tonnes CO/year) Carbon emissions after energy demand reduction Regulated (tonnes CO/year) Unregulated* (tonnes CO/year) Regulated carbon savings after energy demand reduction Regulated (tonnes CO/year) Regulated (%) Carbon emissions / savings for homes 1,881 2, % Phase , % Phase % Phase % Carbon emissions / savings for nondomestic buildings % Phase % Phase % Phase %** Site-wide annual carbon emissions 2,127 2, % * Note 1: unregulated emissions are not affected. They remain as per the Baseline emissions in Table 2 above. ** Note 2: use of previous benchmark building designs for non-residential meant that in Phase 3 the standard package of efficiency measures fell slightly short of the TER, in practice this would be addressed through changes to the specification for the specific building once its use and geometry are known. Table 6: Site CO 2 emissions after demand reductions 4.14 Specifying high efficiency building fabric and services is expected to allow the development to meet Part L 2013 regulated target emissions through efficiency measures alone. Applying the energy efficient fabric specifications, set out in Table 3 for homes and Table 4 for non-domestic buildings, is estimated to reduce the total regulated site emissions by 54 tco 2 /year to 2,127 tco 2 /year. This is equivalent to a 2.5% reduction on the baseline regulated CO 2 emissions. Additional savings from fabric efficiency may be possible depending on the design of the individual buildings, but the extent of these savings can only be determined at detailed design stage In order to meet the carbon reduction targets for the Site every plot will need to meet Part L 2013 through efficiency measures alone. The design for some plots in particular those facing west onto the A12 is expected to need to be tailored to address noise and air quality issues. Some of the potential solutions are discussed in section 4.18 below. 23

25 Further Considerations for Detailed Design and Future Planning Applications 4.16 Detailed planning applications will require sample SAP models to be developed for a sample of the specific designs proposed. Similarly the specific non-residential building designs proposed will need to be modelled in SBEM, IES or other approved software packages The detailed fabric and ventilation strategy will need to be refined in a way that ensures both compliance with Part L, GLA and local plan efficiency requirements while at the same time reducing risk of overheating and maintaining comfort for users, sample overheating modelling will be required alongside sample energy modelling (see section 5.5) 4.18 Detailed designs will need to address the noise and air-quality issues specific to individual plots. Homes and businesses facing West onto the A12 will require particular attention to how adequate ventilation can be provided for maintaining comfort levels, while providing adequate noise attenuation and reducing exposure to air pollution. The potential measures available for addressing these issues will include: Using plan forms that locate circulation space and utility space on the west elevation to provide a buffer. Using winter gardens with mechanical ventilation to create a buffer from noise. Avoiding excessive glazing areas that would exacerbate overheating risk from afternoon and evening sun. Noise attenuating glazing and window design. Mechanical ventilation or whole house mechanical ventilation with heat recovery. Filtration of mechanical ventilation incoming air supply and careful positioning of air inlets away from major pollution sources. 24

26 COOLING AND OVERHEATING 25 05

27 5 COOLING AND OVERHEATING Addressing overheating risk Passive design measures to reduce overheating risk 5.1 In order to comply with London Plan policy 5.9, passive design measures will be required at the later design stages to minimise risk of overheating and reduce cooling demands. Appropriate measures may include: Optimising the percentage of glazed areas to meet good practice for daylighting levels without causing excessive solar gains. Developing dwelling and non-domestic building designs that optimise opportunities for natural and cross ventilation, e.g. dual aspect with openable windows, passive ventilation stacks. (In practice the scope for this may for some plots be constrained by noise and air quality considerations, particularly for buildings adjacent to the A12 which, as set out in section 4.18, will require building layouts, detailed glazing and ventilation design to address these constraints). Integrating external (ideally controllable) shading where possible. Designing windows to have a large free opening area with fine control to enable them to be opened to varying extents according to the ambient conditions. Designing windows at ground floor or other accessible levels with built-in security so they can be opened without fear of intruders entering the building. This could be limiters on the degree of opening or grilles or lockable ventilated shutters. Integrating thermal mass in daytime living spaces (but not in bedrooms where increased mass will delay the peak temperature and reduce the benefit of night ventilation, exacerbating overheating). Using LED and fluorescent lighting to reduce heat gains and energy use from lighting. Implementing external measures to mitigate the urban heat island effect e.g. green roofs / walls, and a high albedo (lighter coloured) materials palette and contributing to improved local microclimate e.g. through tree planting, winter gardens to encourage natural instead of mechanical purge ventilation. Overheating risk from district energy 5.2 Planning policy expects all buildings on the Site to be connected to a district heating network (see section 6). Recent experience with district heating has shown that poor secondary heating network design can lead to excessive heat distribution losses, additional energy costs for users, and unwanted internal gains potentially leading to overheating. 5.3 Procurement of the secondary network design should require that systems are designed in accordance with the Chartered Institute of Building Services Engineers / Association of Decentralised Energy Heat Networks Code of Practice 12 that addresses good practice in secondary network design. 5.4 In particular the future design should focus on the following measures to reduce overheating risk from the secondary networks in buildings: Utilising high insulation standards on all secondary network pipework with insulation levels above BS5422 and the Domestic Building Services Compliance guide. Including insulation of all valves, junctions, pipe hangers, etc. Designing the secondary system for low flow and return temperatures. Using ventilated risers and corridors to ensure that heat gains are dissipated. 12 Heat Networks: Code of Practice for the UK Raising Standards for Heat Supply. CIBSE. ADE

28 Reducing the extent of the secondary network by, for example, utilising more risers and less lateral pipework as illustrated in Figure 7. Figure 7: Reducing secondary pipework lengths (Source: Heat Networks Code of Practice 12 ) Dynamic thermal modelling to assess overheating risk 5.5 GLA guidance on preparing energy assessments states that in most circumstances, it is the GLA s expectation that dynamic thermal modelling is undertaken to demonstrate compliance with London Plan Policy Dynamic thermal modelling cannot be undertaken with the development information available at this outline stage. However, to demonstrate compliance with Policy 5.9, developers applying for planning permissions will be expected to submit evidence of an overheating assessment based on dynamic thermal modelling and information on both passive and active mitigation measures to avoid or reduce overheating. Modelling will have to be carried out under current and future climate scenarios in line with GLA guidance 13 and LLDC Local Plan Policy S.7 to demonstrate that the buildings have been designed to minimise overheating risk. Further Considerations for Detailed Design and Future Planning Applications 5.7 As set out in sections 5.1 to 5.6 above detailed designs will need to be developed to reduce the risk of overheating. Thermal modelling will need to be undertaken for sample units proposed to show that acceptable comfort conditions can be achieved for current and future climate conditions in London. 5.8 Detailed designs will need to consider noise and air-quality constraints in particular those relating to the A12. Potential measures for addressing these constraints are set out in section ENERGY PLANNING Greater London Authority guidance on preparing energy assessments. GLA. March

29 HEATING AND COOLING INFRASTRUCTURE (BE CLEAN) 28 06

30 6 HEATING AND COOLING INFRASTRUCTURE (BE CLEAN) Introduction 6.1 London Plan policy 5.6 includes the following hierarchy for considering the potential for supplying energy efficiently via heating and cooling infrastructure: connection to existing heating or cooling networks site-wide CHP network communal heating and cooling Connection to Existing Heat Networks 6.2 A review of the London Heat map identified that the only existing heat network in the vicinity of the Site is the Queen Elizabeth Olympic Park (QEOP) heat network shown in yellow in Figure 8. Figure 8 Local Heat Network (Image from search of London Heat Map) 6.3 The QEOP heat network was developed to serve the 2012 Olympic Games, Stratford City including Westfield Shopping Centre, and legacy development on the Olympic Park. The network consists of two interconnected sub-networks primarily served by separate energy centres, King s Yard energy centre, which is located on the western boundary of the Olympic Park and Stratford City energy centre. The heat network is operated by ENGIE East London Energy Limited under a 40 year concession agreement with LLDC and Stratford City Developments Limited. 29

31 6.4 Part of LLDC s planning remit is to promote the future extension of the QEOP heat network beyond the Olympic Park. 6.5 AECOM held initial discussions with ENGIE and with the LLDC Planning Policy Decision Team to understand the potential for extending the QEOP heat network to serve development at Bromley by Bow South. ENGIE is keen to promote a connection but there are a number of constraints that mean this is likely to be challenging. 6.6 A connection would only be possible with the full commitment of the landowners of neighbouring developments at Strand East and Bromley by Bow North. ENGIE and LLDC are in discussions with the landowners of Strand East (which include Vastint Holding B.V one of the landowners of Bromley by Bow South) regarding a potential connection agreement. A route has been developed for extending the Olympic Park heat network to serve the Strand East development. The intention is that this would create a connection to the north-eastern corner of Strand East indicated by the black star in Figure 9. This connection is subject to ongoing commercial discussions between ENGIE, Vastint and LLDC. Figure 9 Conceptual Extension of ENGIE Heat Network 6.7 If the landowners of Strand East and ENGIE were to agree a connection to Strand East, there is the potential for further extension of the heat network to serve the Site. To realise this potential, a number of further challenges would need to be overcome. 6.8 First, Vastint Holding B.V would need to enable ENGIE to extend their primary heat network across the Strand East site. The green line in Figure 9 shows a conceptual network route from the northeastern corner of Strand East (the black star in Figure 9) to a connection point at the north-eastern corner of the Site. No work has been undertaken or discussions held with the landowners of Strand East to test the feasibility of this route and it is anticipated that securing such a route at this stage would involve complex and lengthy negotiation with no guarantee of success. 6.9 A means of crossing the Lea Navigation, that separates Strand East from the Site, would then need to be secured. The canal could be crossed either by integrating district heating pipework into an existing bridge crossing, or by ENGIE seeking permission for a separate pipe bridge crossing An initial review of possible crossing points with KCA identified a planned new bridge between the Strand East development and Southern Housing Group s Bow River Village /Bromley by Bow North development, which is marked by a red star in Figure 9. However, this bridge has already received planning consent and the landing on the near side of the canal is outside the Site boundary. For this to be used as a crossing point it would potentially require a revised design for the bridge, a revised planning application for the bridge crossing, and the cooperation of all relevant landowners to enable the crossing and allow the primary network to cross their land. A suitable route would need to be 30

32 identified and designed into both the Strand East and Bow River Village developments. Note that both Strand East and Bow River Village/Bromley by Bow North have planning consent and are under construction, Phase 1 of the latter is close to completion Based on discussions with ENGIE and the issues identified above, it is considered unlikely that a connection could be delivered to the QEOP heat network and such a connection could not be guaranteed by the Site Landowners Group, hence an alternative on-site solution is required. It is suggested, however, that flexibility is maintained for linking to and from neighbouring networks in future and that emerging heat network proposals for neighbouring sites are kept under review. Connection to planned heat networks 6.12 The heat network proposals set out in energy strategies for developments neighbouring the Site are summarised below. Bow River Village/Bromley by Bow North 6.13 The Energy Strategy that accompanied the Bromley by Bow North planning application 14 reviewed the potential to connect to the Olympic Park Heat network. It concluded that the heat loads for Bow River Village/Bromley by Bow North were unlikely to create a sufficiently attractive case to warrant the anticipated high costs of creating the necessary extension from ENGIE s network to the site. The timing of such a connection was also uncertain. On that basis an on-site energy centre was proposed to serve dwellings in Phase 1 of the development which would be served by gas CHP engines estimated at the time to have a capacity of 50kWe/100kWth. It was proposed that flexibility was maintained for a future connection to the Olympic Park network or to any wider network that may develop. The heat plant was proposed to be located in an energy centre located in block R4. This is located along the A12 and approximately in the centre of the Bow River Village/Bromley by Bow North site. It was also proposed to provide m 2 of PV for Phase As noted in section 6.6 above, development of Bow River Village/Bromley by Bow North immediately adjacent to the Site, is underway and close to completion. From a conversation with Southern Housing Group, it is understood that the energy centre has been provided as outlined in the Energy Strategy with a single energy centre with a small CHP engine serving Phase 1 only, this will be maintained and operated under Southern Housing Group s existing services maintenance contracts. Billing will be undertaken under a contract with Vital Energy. The heat network for Phase 1 has been designed to enable subsequent connection to a wider district heating network, but the energy centre does not have the capacity to provide low carbon heat to customers off-site or to subsequent phases of Bow River Village/Bromley by Bow North. The next proposed phase of development, Phase North A, will have its own dedicated energy centre and will not be connected into Phase 1. Strand East 6.15 In July 2015 Vastint Holdings BV submitted an updated Energy Study for Strand East as part of addressing their Section 106 obligations 15. This sets out a range of options that Vastint Holding BV have explored for energy provision to the Strand East site. The Energy Study states that the preferred option from an economic perspective is to make a connection to the QEOP heat network and as noted above the landowners are involved in ongoing discussions to achieve acceptable commercial arrangements. Should it not be possible to obtain a commercially acceptable and viable connection their second preferred choice will be to deliver an on-site heat network. Should that not prove viable in terms of cost and protecting heat prices for consumers, their third choice would be a block based community air-source heat pump solution. They had also explored the potential for a water sourced heat pump solution linked to a site-wide heat network, however, following further investigation and engagement with the water authority, water source heat pumps were not considered to be appropriate for a site-wide solution at Strand East for a number of reasons, including: Complications and costs associated in securing an appropriate abstraction license; Water abstraction limits (due to flow rates, depth of rivers, etc.) resulting in insufficient supply to meet site heat demands; 14 The Bromley By Bow North Energy Strategy East Thames Group and Southern Housing Group. WSP. March Strand East Energy Study. Peter Brett Associates On behalf of Vastint UK B.V July

33 Technical challenges relating to discharging water; and The inappropriately large size of a system required to meet site-wide heat demands 6.16 As noted above, Vastint Holdings BV is currently discussing connection of Strand East to the QEOP heat network. Should this not materialise the landowners preferred option is to install their own energy centre, their Energy Study 15 notes they have discussed this with a range of potential providers. This could provide a potential opportunity for a third party ESCO provider for Strand East to link energy centre provision with future development of the Bromley by Bow South Site. The fact that the network would have to cross the Lea Navigation Canal and the advanced delivery programme for Strand East again makes this an unlikely and challenging scenario. Provision of a site-wide heat network at Bromley by Bow South Energy Demands and Plant Sizing 6.17 In the absence of a viable connection to an existing heat network, LLDC s local plan would support the creation of a site-wide heat network served by gas CHP engines where this would be viable to operate Analysis of the anticipated site wide uses and heat demands suggests that at full build out of the illustrative masterplan would be sufficient heat load to support a potentially viable, low carbon district heating solution. It is anticipated that this would serve space heating and hot water demands in homes and non-domestic buildings on the Site Careful consideration would be required at the detailed design phases to consider the detailed sizing and provision of plant in relation to the anticipated build-up of heat demands over time. As identified in para 1.20, development on the Site is likely to be delivered in phases to enable the re-provision of retail space to replace the existing Tesco store Table 7 sets out the anticipated heat demands for the illustrative masterplan, following the application of the efficiency measures outlined in section 4 but allowing for realistic heat losses in the distribution network. These demands have been used to develop an estimate of the likely energy centre plant sizes which in turn have been used to enable assessment of air quality implications and the required sizing of the energy centre to be accommodated within the illustrative masterplan The energy demands assume that secondary network losses within housing blocks are designed to be no greater than 15% by following the guidance in the CIBSE and ADE code of practice on heat network design 16 and other recognised industry good practice. The losses in the primary network are assumed to be 7%, based on published heat loss figures for the QEOP heat network in 2014/15. (kwh/year) Heat demands after demand reduction (with realistic network heat losses of ~22%) Space heating Hot water Total heat demand Heat demands for homes 4,411,723 3,688,539 8,100,262 Phase 1 2,041,401 1,706,768 3,748,168 Phase 2 1,010, ,654 1,854,912 Phase 3 1,360,064 1,137,118 2,497,181 Heat demands for non-domestic buildings 189,509 75, ,958 Phase 1 42,617 26,472 69,089 Phase 2 45,763 13,155 58,918 Phase 3 101,129 35, ,951 Site-wide heat demands 4,601,232 3,763,988 8,365,220 Table 7: Heat demands for a site wide heat network Preliminary CHP sizing calculations were undertaken based on site-wide heat demands at full buildout. These suggest that, as an indication, a 1.16 MWe (1.2 MWth) CHP engine with a 120 m 3 heat 16 Heat Networks: Code of Practice for the UK Raising Standards for Heat Supply. CIBSE. ADE

34 store would achieve a balance between supplying a high proportion of site heat demands and significant carbon savings from CHP, and achieving CHP running hours of around 5000 hours/year which is a level generally considered consistent with cost-effective CHP operation. More detailed assessment of energy demands and optimisation of CHP engine and thermal storage size could affect the sizing of this engine An additional consideration would be whether to use a single large CHP engine or two smaller engines. This decision would have implications for the phasing of the plant, as in the single engine scenario the CHP wouldn t be operational until sufficient load was operational, which could be some time into the development. Two smaller engines would offer some further advantages in terms of matching loads better but would have lower efficiencies and higher maintenance costs than one large engine. With 45% of the expected heat demand associated with Phase 1 of the illustrative phasing plan, there is potential for significant loads to be available early in the build out process It has been assumed that the on-site CHP would meet approximately 70% of the heating and hot water demand for the Site. The other 30% would be met by gas boilers. Detailed analysis of heat profiles and load diversification has not been carried out at this outline stage. A more detailed analysis will be needed once phasing and building uses are better defined. This should consider phasing and in particular the overall timescale from the first development phase to full build out. These factors will determine the extent to which an energy centre solution based on a single large CHP engine is costeffective Based on the anticipated heat loads and CHP engine capacity, we would anticipate that the scheme would require an energy centre with a footprint around sqm. Further work will be required to refine this figure as the detailed design progresses At present it has been assumed that the plant room would be located on the bottom floor of the block footing the 22 storey tower in the south west corner of the Site, on land owned by Danescroft Land Ltd. This energy centre location is marked in Figure 10 by a red star. It is expected that this block would be delivered as part of the first phase of the illustrative masterplan, enabling early connection of development to a low carbon heat source and reducing the need for temporary plant. Location of the plant room in one of the tallest buildings on the Site would help to reduce any visual impacts of the flue An alternative energy centre location, in the south west corner of the Site, on land owned by Lindhill, Properties Ltd has also been considered as an option and is marked in Figure 10 by a black triangle. In this location, the energy centre is closer to the canal, which, while noting the findings of the Strand East Energy Study (see section 6.15), could have the potential for use as a heat source in future (see section 6.44). While the energy centre flue in this location would be at a much reduced height compared to location in the 22 storey tower at the south west corner of the site, initial air quality assessment has concluded an energy centre located in the south east of the Site can deliver similar air-quality effects to one located in the south west of the Site. (see paragraph 6.29). 33

35 Figure 10: Potential on site energy centre identified by red star (black triangle = alternative option) 6.28 Figure 11 presents the indicative phasing for the illustrative masterplan. It is expected that the first phase of development will be at the southern end of the Site followed by development at the northern end of the Site and finally completion of development at the centre of the Site. This will require early implementation of the heat network connecting the energy centre in the south with proposed development at the north. The detailed network layout design will need to be developed to enable the phased development. A notional network route is illustrated in Figure

36 Phase 1 Phase 2 Phase 3 Figure 11: Indicative primary network phasing 6.29 A preliminary assessment of the impact on air quality of the proposed on-site energy centre (Scenario 1) and an optional location in the south east of the site (Scenario 2) have been included in the Air Quality Impact Topic Report that forms part of the EIA evidence base and in a technical note addressing the air quality impacts of alternative energy centre locations (see Appendix B) that concludes that The near ground level impacts for Scenario 1 and Scenario 2 are very similar at a height of 1.5 m above local ground level (see Figure 2). Roadside annual mean concentrations of nitrogen dioxide peak at circa 80 µg/m 3 close to the A12 and decrease across the site towards the air quality objective value of 40 µg/m 3 at the Eastern boundary. In the absence of any onsite baseline measurement data, it would be reasonable to assume that the objective value is not achieved within the application site boundary with the proposed development in place. The energy centre emission contribution to near ground level annual mean concentrations of nitrogen dioxide are negligible for each alternative location. At a height of 21 m or 30 m above local ground level (see Figure 3 Appendix B) the contribution from road traffic exhaust emissions on the A12, is less marked. With the energy centre located in the South Western corner of the site (Scenario 1) the emissions from the energy centre are likely to elevate annual mean concentrations of nitrogen dioxide on the facades of taller buildings on the site, by less than 1 µg/m 3 over part of the application site. A similar effect is not likely to occur with the energy centre located in the south eastern corner of the site. With the use of air quality mitigation on all floors and all residential or public buildings, it should be possible to provide future users of the buildings with air of good quality, if the energy centre is located in the south western corner of the site. This mitigation is likely to take the form of filtration, with the option of openable windows for purge ventilation. The alternative energy centre location in the south eastern corner of the site can deliver similar impacts on air quality but from a much lower release height The air quality analysis assumes that the CHP engine(s) would be fitted with selective catalytic or noncatalytic reduction equipment to treat flue gases, so as to achieve the emission rate requirements for development in Band B 17 set out in Appendix 7 of the Mayor s Sustainable Design and Construction SPG, i.e. NO x emissions at reference O 2 of 95 mg/nm 3 or below The CHP engine specification, flue design and flue gas treatment will need careful consideration at detailed design stage to ensure that the necessary carbon savings targets and NO x emissions standards are met It is anticipated that the scale and density of development is sufficient to enable the potential for a sitewide district heating scheme served primarily by gas-fired CHP to be cost-effective, in which case procurement via a third party energy services company (ESCo) becomes a potential option. No engagement has been undertaken with potential ESCo providers at this early stage. The chosen 17 Baseline Annual Mean NO 2 and PM 10: between 5% below or above national objective. 35

37 ESCo is likely to have its own preferences for the detailed plant selection and phasing necessary to make the network cost-effective. The procurement process for securing the design and future operation of the network should ensure a scheme is delivered that satisfies both London Plan and Local Plan targets in relation to both carbon emissions reduction and air quality The detailed procurement of a site-wide heat network would need to ensure appropriate price protection controls are in place to ensure that the overall costs incurred by heat consumers for both heat supply, standing charges and maintenance are competitive with conventional systems. This could include registration of the scheme under the Heat Trust s consumer protection scheme. 18 This has been set up to address a range of consumer protection issues, in the absence of a fully regulated heat market. CO 2 emissions with a site-wide heat network served by gas CHP 6.34 The CO 2 savings associated with serving the Site from an on-site CHP system have been calculated, as shown in Table For the purposes of the assessment the following has been assumed: Realistic network heat distribution losses of 7% from the primary network (equivalent to published losses for the Engie QEOP heat network) and 15% from the secondary network (considered possible if best practice design measures are followed) The efficiencies used for the on-site CHP case are based on the technical specifications of an ENER-G E1165 gas CHP engine: o Electrical output: 1169 kwe o Electrical efficiency: 37.2% o Heat output: 1228 kwth o Heat efficiency: 41.7% o Fuel input (HHV/GCV): 3020 kw This is for illustrative purposes only at this outline stage. The actual sizing of the CHP would be refined through the design process, should this become the preferred option. The efficiency of the engine and proportion of heat load met by CHP will determine the extent of carbon savings from this option. Calculations are based on the assumption that at full build out the Gas CHP would provide ~70% of the total heat demand and gas back up/peak load boilers would serve ~30% of the demand. The saving in regulated CO 2 emissions associated with both implementation of efficiency measures and connection of buildings to the proposed on-site energy centre are set out in Table 8. This shows that for homes there is expected to be a cumulative reduction in CO 2 emissions of 36.1% sufficient to meet the 35% reduction in Part L 2013 regulated emissions required by London Plan 5.6. For non-residential buildings the savings are smaller at 15.4%. The reduced saving for non-residential buildings reflects the proportionately lower heat demands in nonresidential buildings but also the way that district heating is dealt with for the notional building in the national calculation method that underpins Part L 2013 calculations. Table 9 sets out the CO 2 emissions separately for efficiency measures and connection to the heat network. This shows that for homes connection to the heat network results in a 34.3% reduction in baseline regulated emissions in addition to the savings from efficiency and for nonresidential buildings the saving relating the heat network only are 8.1%

38 (tonnes CO/year) Carbon emissions after heat network with gas-fired CHP Regulated (tonnes CO/year) Unregulated (tonnes CO/year) Carbon savings after heat network with gas-fired CHP Regulated (tonnes CO/year) Regulated (%) Carbon emissions for homes 1,225 2, % Phase , % Phase % Phase % Carbon emissions for non-domestic buildings % Phase % Phase % Phase % Site-wide annual carbon emissions 1,449 2, % Table 8: Site emissions after implementation of efficiency and a site-wide heat network served by gas CHP Baseline: Part L 2013 of the Building Regulations Compliant Development (tonnes CO/year) Carbon emissions for domestic Carbon emissions for nondomestic buildings Regulated Unregulated Regulated Unregulated 1,916 2, After energy demand reduction 1,881 2, After heat network / CHP 1,225 2, Regulated domestic carbon dioxide savings (tonnes CO/year) (%) Regulated non-domestic carbon savings (tonnes CO/year) (%) Savings from energy demand reduction % % Savings from heat network / CHP % % Cumulative on site savings after energy demand reduction and CHP % % Table 9. Incremental and cumulative changes in regulated carbon dioxide emissions after implementation of a site-wide heat network served by gas CHP Future Flexibility for Heat Supply Electricity grid decarbonisation and fuel emission factors 6.36 The emission factor for grid supplied electricity is expected to fall progressively over time in response to a changing mix of generation capacity on the electricity network (including less coal, greater take up of renewable energy and a renewal of baseload nuclear power stations). The emission factor for mains gas is on a small upward trend due to an increase in the importation of liquid natural gas and a reduction in North Sea gas supplies The impact of these changes is that over time the emissions associated with technologies that use electricity to produce heat or power will go down. This will make ground source heat pumps and air source heat pumps that use mains power to extract heat from local ambient heat sources, usually displacing gas heating fuel more attractive in terms of net carbon emissions. Conversely the carbon 37

39 savings benefits of combined heat and power (CHP), photovoltaics (PV) and fuel cells that generate power locally, displacing grid electricity will go down The carbon savings achieved by gas-fired CHP in the current calculations that underpin Part L of building regulations depend strongly on the difference between the emission factor of the gas fuel used in the engines and the electricity generated, displacing mains power. As such, the merits of CHP relative to other carbon saving solution for new development are particularly affected by the expected changes in carbon emission factors. Figure 12 compares the net CO 2 emissions associated with providing a unit of heat from market-ready low carbon heating technology options (vertical axis) at a range of emission factors for grid electricity (horizontal axis). (The heat pump efficiencies assumed in Figure 12 reflect data from Energy Saving Trust field trials reports (March 2012), which are the default efficiencies used in SAP calculations. Gas fired CHP engines of the scale likely for a heat network required for the illustrative masterplan would have an electrical efficiency of around 35%.) Figure 12: CO 2 emissions for heat from various sources against electricity emissions factor. (Note: gas emission factor 212 gco2/kwh; total thermal plus electrical CHP efficiency is 77%.) 6.39 CO 2 emission factors used in the calculations for Building Regulations Part L compliance, and which in turn are typically used to demonstrate that planning policy targets are being addressed, are based on published figures set out in the Standard Assessment Procedure (SAP) The current grid emission factor used for Part L for both homes and non-domestic buildings is 519 gco 2 /kwh. DECC s Updated Energy and Emissions Projections 2015 expect grid carbon intensity to fall to ~100 gco 2 /kwh by around Figure 12 illustrates that, assuming a constant emission factor for gas, air source heat pumps have just passed the point (emission factor for electricity below ~530 gco 2 /kwh) where they offer a small carbon saving compared to an 85% efficient gas boiler. The grid emission factor would need to drop to below ~420 gco 2 /kwh before air source heat pumps can provide heat at lower carbon emission rates than gas fired CHP. 38

40 Figure 13 CO 2 emissions for heat from various sources against predicted future electricity emissions factors (as published in SAP 2012 consultation (Note: gas emissions factor increases over time. CHP efficiency relates to electrical efficiency; total CHP efficiency (i.e. thermal plus electrical) is 77%.) 6.41 Figure 13 plots the predicted future gas and electricity emission factors as reported in the Technical Papers supporting SAP 2012 and the impact on the CO 2 emissions per kwh of heat if the SAP calculation method were to remain unchanged. Based on these emission factor projections and including distribution losses at 22% of the heat delivered, gas CHP would offer a carbon saving over a gas condensing boiler until around 2022, over an ASHP with an average efficiency of 213% until around 2019 and over a GSHP with an average efficiency of 272% until around By 2025 a current SAP calculation using the emission factors projected in the SAP 2012 technical paper would show there is little difference between the carbon emissions associated with heat from CHP and heat from direct electricity In practice there is considerable debate around whether the electricity grid will decarbonise at the rate that Government projects, and whether a single set of emission factors applied to all technologies will in future be adequate to reflect the complexity of the energy system. Grid decarbonisation is expected to be accompanied by greater use of intermittent renewables in the form of wind and solar. Grid decarbonisation is expected to be accompanied by a growing demand for electricity for heating and transport uses. To manage this increased demand and increased intermittency there is expected to be a need for more dynamic management of supply and demand. This will be needed to help avoid excessive grid reinforcement costs. This is likely to favour the availability of a range of heat supply technologies that are incentivised to operate based on the particular conditions on the network. For example when there is excessive wind availability, electricity may be cheap incentivising the use of heat pumps to utilise the surplus low carbon power. When there is a lack of wind and high demands for power, CHP may still offer a lower carbon alternative to other marginal fossil fuel generation (where heat is typically wasted) and would continue to be incentivised. Recent work by DECC has made the case that gas CHP will continue to offer an effective carbon saving solution until What this analysis identifies, is that it may be desirable to enable flexibility for a range of heat sources to be connected to the network as fiscal incentives and emission factors change. While initially gas CHP engines are likely to be the preferred low carbon source for the energy centre operator, by the time they reach the end of their life that may no longer be the case. 19 Bespoke Gas CHP Policy- Summary of Analysis Results & Conclusions. DECC. December

41 6.44 One of the potential alternative heat supply technologies for the future will be heat pumps, utilising heat sources in the natural environment. The most likely sources of heat that could be exploited in this location would be heat from the air through the use of air-source heat pumps, or heat from the river. Extracting heat from the river would require detailed engagement with the Environment Agency and the Canals and Rivers Trust on the required abstraction licenses and physical infrastructure needed to utilise heat from the river, which has not been undertaken at this outline stage Based on previous studies by AECOM key constraints for river water extraction are likely to be the size of the physical structures required to filter abstracted water and accommodating these without restricting river traffic. Abstraction and discharge licenses would also be required from the Environment Agency as well as a flood defence consent for any works within the canal or to the canal wall. These in particular are aimed at limiting flow rates and temperatures to avoid any impact on the river/canal ecosystem as well as introducing additional flood risks. The limited flow rates within a canal system are likely to limit water abstraction rates, hence the capacity of heat that can be extracted, however, there may be potential for the canal to serve part of the load and this could be reviewed further at detailed design. While the previous study for Strand East ruled out the use of water source heat pump for a site-wide heat provision, see paragraph 6.15 above, this technology may be able to serve a portion of the load and the economic and carbon cases will evolve as grid emissions fall. Summary 6.46 The ability to connect to ENGIE s Olympic Park Heat network would appear unlikely in particular with regard to the likely timeframes for development commencing. Connection would be reliant on a range of factors which are outside the landowner s control. While a connection appears unlikely it is suggested that the future development safeguards routes that would enable subsequent linking of networks should this prove viable or beneficial and that discussions are held with landowners of adjacent sites and any appointed ESCo(s) to consider any commercial advantages of linking energy provision across sites In line with London Plan and LLDC Local Plan policy requirements it is proposed that a site wide heat network is delivered to serve all plots within the illustrative masterplan. The current masterplan is based on delivering a single energy centre for the site-wide network on land owned by Danescroft. Land Ltd (the south-western corner of the site). This will form the first phase of the illustrative masterplan thus enabling connection to the heat network from the outset Future detailed design will need to ensure that plant is selected that meets the NO 2 and PM 10 combustion emissions limits set out in Appendix 7 of the Mayor s Supplementary Planning Guidance on Sustainable Design and Construction An alternative energy centre location has been identified in the south east corner of the site which could potentially offer some additional future flexibility to utilise canal water via heat pumps, as grid electricity CO 2 emission factors fall. The detailed feasibility of utilising the canal water has not been explored at this stage as gas CHP would currently offer lower carbon emissions. An energy centre in this location is expected to deliver similar air-quality effects as the currently proposed location on the south west corner of the site Preliminary calculations suggest that the efficiency measures set out in Section 5 and connection to the proposed on-site energy centre served by gas CHP engines would reduce CO 2 emissions for homes by 36.1% against the Part L 2013 baseline. This is sufficient to meet the 35% reduction in Part L 2013 regulated emissions required by London Plan policy 5.6. For non-residential buildings the savings are smaller at 15.4% and will required additional renewable energy measures to meet the 35% reduction target (see Section 7). Implications for the SPD 6.51 The analysis has shown that a site-wide district energy solution is a potentially viable solution for the Site and would deliver significant CO 2 savings in line with London Plan and Local Plan Policies. 20 Sustainable Design and Construction Supplementary Planning Guidance. London Plan Implementation Framework GLA. April

42 6.52 There are likely to be benefits in maintaining the flexibility for the future heat network provider to exploit alternative heat sources as the grid decarbonises The anticipated presence of heat networks on neighbouring sites presents the potential for collaboration between landowners and their energy services providers to explore the benefits of a wider area solution, but the timing of current developments and the significant infrastructure barriers presented by the Lea Navigation would make this particularly challenging. Further Considerations for Detailed Design and Future Planning Applications 6.54 The Landowner s group in conjunction with their appointed M&E consultant will need to further develop the strategy for delivering the energy centre and heat network. This will include: reviewing the options for procuring the construction and operation of the energy centre and heat network. This may include discussions with potential ESCo providers if a third party design and operate model is followed; the detailed sizing and selection of plant in relation to proposed phasing and air quality standards; ensuring energy centre designs address noise and vibration between the energy centre and neighbouring properties; identification of detailed routes and phasing for the heat network pipework including assessment of existing utility constraints; the contractual arrangements between landowners to ensure heat connections are guaranteed and will provide confidence to any third party energy services provider; and establishing appropriate arrangements to protect consumers in terms of the price paid for heat, maintenance and operation. 41

43 RENEWABLE ENERGY (BE GREEN) 42 07

44 7 RENEWABLE ENERGY (BE GREEN) Introduction 7.1 London Plan policy 5.7 states that within the framework of the energy hierarchy (Policy 5.2), major development proposals should provide a reduction in expected carbon dioxide emissions through the use of on-site renewable energy generation, where feasible. The following technologies are listed in the London Plan for developers to consider: biomass heating, cooling and electricity; renewable energy from waste; photovoltaics; solar water heating; wind and heat pumps. Biomass 7.2 A site-wide heat network served by on-site gas-fired CHP is likely to be the preferred option for the Site, in which case the majority of heat demand would be met by the gas-fired CHP engines and there would be no remaining base load for the integration of individual biomass boilers. 7.3 Biomass boilers could be considered as an alternative to gas CHP to serve the heat network, but biomass heating is lower down the energy hierarchy than gas CHP and has a number of significant disadvantages: combustion in small (sub power station) scale biomass boilers and associated fuel transport are likely to have significant adverse impacts on air quality in an area which is already exposed to elevated NO x and particulate emissions from the A12; the need for a solid fuel store would increase energy centre space requirements, potentially affecting the area available for other planned land uses; national strategies for meeting the UK s Climate Change Act target of an 80% reduction in UK CO 2 emissions have highlighted that biomass is best used to meet high temperature industrial heat needs which cannot easily be met from other low carbon energy supply options. 7.4 The scope for biomass to contribute to the energy strategy for the Site was judged to be minimal and based on the considerations above it was screened out of further consideration. Energy from waste 7.5 Energy from waste facilities generally become technically feasible and cost-effective at a district scale when waste can be collected from a large area and the heat can be distributed via a district heating system. There are currently no waste to energy facilities in the vicinity of the Site. The provision of a site-wide heat network on the Site would not prevent future connection to a wider area heat network served by energy from waste, should such a facility and interconnecting heat networks become available. 7.6 The scope for energy from waste to contribute to the energy strategy for the Site was judged to be negligible in the short term and it was screened out of further consideration. Photovoltaics 7.7 Solar photovoltaic panels generate electricity and can therefore be integrated into developments in combination with heat generating technologies such as CHP without conflict in the form of competition for available heat load. 7.8 To maximise output, panels should be installed in locations where they are not shaded by the building itself (including e.g. lift cores, railings, antennae, services plant, building maintenance units, etc.) or by neighbouring buildings. The panels should ideally be installed facing south, at a degree pitch. 7.9 On this basis suitable areas for PV installation on the Site, on roof areas expected to be free from overshading by neighbouring buildings, were identified on the illustrative roof plan for the illustrative masterplan, as shown by the blue areas in Figure 14. The numbers on the roof plan indicate the 43

45 number of storeys in the block. The storey height is circled in red when the block includes nondomestic uses. Phase 2 1,465 m 2 PV panel area installable Phase 3 1,200 m 2 PV panel area installable Phase 1 1,860 m 2 PV panel area installable Numbers are building heights in storeys; red circles mark shared blocks with homes and non-domestic space Figure 14: Roof plan showing gross roof area (blue) likely to be suitable for PV The gross area of the roofs identified and shaded blue, was estimated to be around 14,130 m 2. The gross area was reduced by 20% to allow for avoidance of self-shading, and the size of the PV array was then limited to 40% of the remaining area to allow for other uses of the roof space, including 30% amenity uses and rooftop plant. This results in a maximum area available for PV across the site of 4,520 m 2, equivalent to an array with a peak output of approximately 600 kwp. Figure 14 shows broadly how the maximum PV area would break down across each of the illustrative phases. It is expected that as part of detailed planning applications PV areas would be refined based on further assessment of shading based on detailed geometries and more detailed assessment of energy demands, but the calculations carried out to date suggest there is sufficient roof space to enable, sufficient PV capacity for all phases of the illustrative masterplan to meet the required on-site 35% reduction in Part L 2013 regulated emissions While a degree pitch is the optimum pitch for individual panel output, it is assumed that installation on flat roofs would be frame-mounted at 15 degree pitch to avoid self-shading between PV panels and optimise the capacity of output for a given roof area. 44