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DRAFT Sustainability Appraisal Report for the Emerging Local Plan ...

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not been approved yet and can be required to implement/contribute to suitable redesign,<br />

mitigation and offsetting measures.<br />

Development in Egham and Englefield Green – Policy LP04<br />

9.121 About 50% of <strong>the</strong> proposed residential developments in Egham will consist of applications <strong>for</strong><br />

less than 50 units. Two larger developments of over 100 units were already granted a<br />

planning permission– Wapshott Road a full planning permission and, very recently, Brunel<br />

University was granted an outline permission.<br />

9.122 An application <strong>for</strong> a development of 90 residential units at Wick Road, Englefield Green, has<br />

been recently submitted. It is recommended that <strong>the</strong> developer carry out traffic and air<br />

quality assessments to determine traffic and air quality impacts on <strong>the</strong> A30 and <strong>the</strong> Egham<br />

By‐Pass and Runnymede roundabouts.<br />

Redevelopment of <strong>the</strong> <strong>for</strong>mer DERA site – Policy LP08<br />

9.123 New development at <strong>the</strong> <strong>for</strong>mer DERA site will by far constitute <strong>the</strong> largest development in<br />

<strong>the</strong> Borough. An application <strong>for</strong> <strong>the</strong> development of <strong>the</strong> nor<strong>the</strong>rn site has been recently<br />

submitted to <strong>the</strong> Council. The application is supported by Transport and Air Quality<br />

Assessments. Several points should be raised regarding <strong>the</strong> provided assessments.<br />

9.124 The assessments demonstrated negligible transport and air quality impacts. This conclusion<br />

was reached after comparing <strong>the</strong> Proposed Development scenario (up to 76,970 sqm and up<br />

to 200 dwellings) with <strong>the</strong> already Consented Development scenario (approximately 90,000<br />

sqm of office space with ancillary uses). The developer’s argument is that compared to <strong>the</strong><br />

development that has already been consented, <strong>the</strong> Proposed Development will not produce<br />

additional traffic. There<strong>for</strong>e, when compared to <strong>the</strong> Consented Development, <strong>the</strong> Proposed<br />

Development will have a neutral effect on air quality in respect of both human health and<br />

ecological receptors.<br />

9.125 It is recommended that <strong>the</strong> developer resubmits <strong>the</strong> transport and air quality assessments,<br />

taking into account <strong>the</strong> fact that nei<strong>the</strong>r commercial nor residential development exists so far<br />

at <strong>the</strong> site. There<strong>for</strong>e, <strong>the</strong> traffic baseline should not include ei<strong>the</strong>r <strong>the</strong> permitted (but not yet<br />

built), or <strong>the</strong> proposed developments.<br />

9.126 Ano<strong>the</strong>r issue to be raised is that <strong>the</strong> developer has not considered <strong>the</strong> whole site (nor<strong>the</strong>rn<br />

and sou<strong>the</strong>rn part) in <strong>the</strong> assessment. Traffic and air quality impacts should be considered<br />

cumulatively and take account of <strong>the</strong> total number of residential units proposed <strong>for</strong> <strong>the</strong><br />

whole site, which amounts to 1,500.<br />

9.127 In addition, as nitrogen dioxide in Runnymede have not been reducing as predicted by<br />

national models, it is recommended that 2012 emission factors are used to determine air<br />

quality impacts of <strong>the</strong> development as a worse‐case scenario. Should <strong>the</strong> development be<br />

completed in 2020, nitrogen dioxide concentrations will be higher than when modelled <strong>for</strong><br />

2035. The developer has not considered <strong>the</strong> fact that (part or all of) <strong>the</strong> development might<br />

be completed earlier than 2035. Finally, given <strong>the</strong> sensitivity of <strong>the</strong> location, it is suggested<br />

that <strong>the</strong> significance criteria used to assess <strong>the</strong> magnitude of change in concentration <strong>for</strong><br />

annual mean NO 2 and PM 10 should be more stringent than <strong>the</strong> ones adopted by EPUK 58 and<br />

used by <strong>the</strong> Developer in <strong>the</strong>ir Air Quality Assessment.<br />

9.128 Regarding <strong>the</strong> Energy Statement prepared to support <strong>the</strong> application <strong>for</strong> <strong>the</strong> development of<br />

DERA’s nor<strong>the</strong>rn site, <strong>the</strong> developer proposed to achieve compliance with Code <strong>for</strong><br />

Sustainable Homes Level 3 and expressed commitment to exceed by at least 10% <strong>the</strong> carbon<br />

reductions mandated under Part L of <strong>the</strong> 2010 Building Regulations. It is also proposed to<br />

provide 10% of <strong>the</strong> of energy demand from renewable sources, with preference given to<br />

incineration and gas – fired Combined Heat and Power.<br />

9.129 In response to this Energy Statement, it is recommended that <strong>the</strong> developer meets CSH Level<br />

4 as CSH level 3 energy standard is already incorporated in <strong>the</strong> 2010 Building Regulations.<br />

Since level 4 of <strong>the</strong> Code will be required from 2013 under 2013 Building Regulations, it<br />

58 EPUK (2010) Development Control: <strong>Plan</strong>ning For Air Quality (2010 Update)<br />

Page | 139 Runnymede BC FINAL <strong>Sustainability</strong> <strong>Appraisal</strong> <strong>Report</strong> – Feb 2013

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