1)
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Should the CEMP identify the need for PM10 monitoring (following a risk assessment), the CEMP should state that the following procedures will be followed and a plan showing the location of each monitor should be included:
The real time PM10 monitor/s will be installed prior to work commencing on site at locations to be agreed with the Environmental Health in advance.
The monitoring system must be used to provide alerts at 200æg/m3 as well as an action level of 250æg/m3 (as 15 minute means) to inform the site's Environmental Manager (or other appropriate person) in the form of SMS text when the level has been exceeded.
The alert level of 200æg/m3 (15 minute mean) should be used to check on site activities and used to ensure that activities will not lead to a breach of the action level.
If the action level of 250æg/m3 (15 minute mean) is reached, works will cease and action taken to rectify immediately.
The designated site manager will be responsible for dealing with elevated levels of PM10, investigating and logging action taken.
The monitoring system will allow access to the real time data. Summary reports of exceedences, investigations and the remedial actions taken should be provided to Environmental Health if requested to [email protected]. The council will be provided with a password to enable real-time access to PM10 monitoring data.
2)
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The applicant is advised that the following issues must be addressed in any resubmission for approval of Condition 15 (Construction Environmental Management Plan) and Condition 21 (Risk Assessment):
The construction environmental management plan must cover both the demolition and construction stage.
Section 7 of the submitted construction environmental management plan (Operational Control) makes reference to an integrated risk assessment and method statement process and appropriate control measures, but does not provide any detail on this as required by the Mayor's Supplementary Planning Guidance 'Control of dust and emissions during construction and demolition' April 2014.
Appropriate control measures for dust and emissions should be specified from the risk level determined. This should include for example compliance with London NRMM Standards, avoiding use of petrol and diesel generators and installation of solid screens around dust generating activities.
A risk assessment is needed to determine what PM10 monitoring is required (if any) and details of monitoring, including a plan showing the location of monitors must be provided.
A time table of dust generating activities is required.
3)
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The applicant is advised that the following issues must be addressed in any resubmission for approval of condition 22 (Low Emission Strategy):
The floor areas given in the strategy differ to those of the consented scheme.
The transport emissions are above benchmark and no detail on mitigation is proposed.
The strategy is in contravention with Condition 23, which states that CHP should not be used to meet the carbon reduction targets.