Agenda Item CAMBRIDGE CITY COUNCIL WARD: Queen Edith’sdemocracy.cambridge.gov.uk/documents/s19616/Application for... · • two biomass boilers* each of generating approximately

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Agenda Item

CAMBRIDGE CITY COUNCIL

REPORT OF: Head of Planning TO: Planning Committee WARD: Queen Edith’s Consultation response on Cambridgeshire County Council planning application ref: C/05009/12/CW for:

Proposal: Erection of Energy Innovation Centre (EIC) of 2,675sqm GEA as part of the wider expansion of Addenbrooke’s Hospital to form part of the Cambridge Biomedical Campus authorised under planning application ref:06/0796/OUT (Cambridge City Council), replacing the existing Addenbrooke’s boiler house. The EIC centre, as an energy from waste facility, incorporates clinical waste incineration generating electricity and heat; two gas-fired Combined Heat and Power units generating electricity and heat; and three dual fuel (oil and gas) conventional steam boilers, to be located to the south west of Addenbrooke’s Hospital between Robinson Way and Addenbrooke’s Road. Construction of an underground tunnel connecting the energy centre to the existing Addenbrooke’s Hospital for the transportation of clinical waste. Location : South West of Addenbrooke’s Road, between Robinson Way and Addenbrooke’s Road, Cambridge.

1. INTRODUCTION 1.1 This application for an Energy Innovation Centre (EIC) has been submitted to

Cambridgeshire County Council as it falls within their remit as the Strategic Waste Authority. The role of the City Council with this type of application is one of consultee as part of the overall public consultation process carried out by the County Council on the application. This is being brought before the Planning Committee at officers’ discretion, because it is a significant development that is of interest to Members. The purpose of this report is to agree the City Council’s response to the County Council consultation that will form part of the report by County Officers to their Planning Committee in June 2013.

1.2 The EIC is to serve the energy requirements of the Cambridge Biomedical

Campus, including Addenbrooke’s Hospital, as a whole. It will be located within the site covered by the Addenbrooke’s 20/20 outline approval for the extension of the Cambridge Biomedical Campus (CBC) for NHS and private clinical development, clinical research and biomedical and biotechnology research and related support activities. This would have included an energy centre to serve at least some of the new development. Since the approval of this outline application in October 2009, the Cambridge University NHS Trust have taken forward the proposal to develop an energy centre to serve the extended campus as a whole, replacing the existing incinerator. As this was not part of the original outline permission, it has had to be submitted as a full application rather than a Reserved Matters (RM). The proposed EIC will be subject to a separate permit regime, under the Environmental Permitting regulations, enforced by the Local Authority and the Environment Agency.


2. RECOMMENDATIONS 2.1 That the County Council be advised that the City Council raise no objection in

principle to the planning application but would recommend that the following issues are resolved prior to the determination of the application and that planning conditions are added to the planning permission to address the following matters:

2.2 Further detailed work:

• The applicant should consider the use of an extensive brown roof* on the building to help deal with water management issues and to help tie the building into the surrounding landscape.

• The tree planting should include larger species than the proposed Betula (Birch) to mitigate the visual impact of the mass of the buildings and of the chimneys. Either Tilia cordata ‘Green Spire’ (Lime) or Corylus colurna (Hazel) trees are suggested as relatively compact trees, which will attain some height.

• The application should take account of the approved Cambridge Biomedical Campus site wide Nature Conservation Management Plan (September 2010) to identify the protection and monitoring of Protected Species on site, and ecological enhancements are included in the proposals. * a brown roof is a living roof system with a growing medium which allows local plant species to populate the roof over time to encourage biodiversity.

2.3 A number of Planning Conditions and informatives are recommended as set out

in Appendix 1. 3. BACKGROUND 3.1 SITE DESCRIPTION/AREA CONTEXT 3.2 The site for the proposed Energy Innovation Centre (EIC) is south of the existing

Addenbrooke’s campus, on the southern end of the land covered by the Addenbrooke’s 20/20 outline application for the CBC (as shown in the Addenbrooke’s Composite plan in Appendix 3). Approval has been granted for the southern spine road, and the EIC will be immediately north of this, with the Multi Storey Car Park to the north east.

3.3 The site area is approximately 0.74 hectares. The application site includes an

additional area of 0.29 hectares because it covers the course of an extension to the existing underground tug way along a section of Robinson Way (as shown in the site plan attached to this report). This will be a means of moving waste from the hospital site to the EIC.


3.4 The site area and immediately surrounding land is in transition from previous agricultural use to become part of the enlarged CBC, which will extend to the railway line to the west. The majority of the area is currently grassed, with the Boulevard running through it, from a new roundabout with Robinson Way to the Addenbrooke’s Road roundabout. Work has recently commenced on the Multi Storey Car Park.

3.5 On the basis of the existing Addenbrooke’s 20/20 outline permission, reserved

matters already approved and those expected to come forward in the next few years, the context of the site will change very significantly, from open field to developed CBC. The landscape assessment has therefore considered how the EIC will sit in the landscape in the short, medium and long term.

3.6 The application site is relatively flat, as is the surrounding landscape. To the

southeast of the site, beyond the CBC site, the land starts to rise in the form of a chalkland ridge, the eastern end being the Gog Magog Hills/Down. South of the site is Nine Wells, the source of Hobson’s Brook, a historic man-made watercourse.

3.7 The site is allocated as for Clinical Services/Biomedical research in the

Cambridge Local Plan (2006). The site does not fall within a Conservation Area and there are no listed buildings adjacent or nearby.

3.8 RELEVANT PLANNING HISTORY

Reference Description Outcome

12/1304/REM Reserved Matters submission for Southern Spine Road pursuant to outline permission 06/0796/OUT.

A/C

11/0780/REM Reserved matters application (access, appearance, landscaping, layout and scale details) for a 1,228 space multi-storey car park (33,141sqm gross external floor area) and perimeter access road at the south west corner of Addenbrooke's campus, to serve Addenbrooke's as it expands and the new Papworth Hospital (pursuant to outline approval 06/0796/OUT).

A/C

10/1209/EXP Replacement permission for extant outline permission 06/1279/OUT (The Forum development)

A/C

08/0521/FUL Boulevard road through proposed expanded Cambridge Biomedical Campus together with supporting drainage and landscape features

A/C

07/0651/FUL Erection of replacement Laboratory of Molecular Biology (Medical Research Council building)

A/C

06/1279/OUT The Forum Development: Redevelopment to provide: Learning centre, seminar/conference centre, development centre, hotel, retail, club, Enterprise Hub, together with shared accommodation/circulation areas, link to Elective Care Centre and extension to S. Ward block; car parking structure; access and service roads; landscaping and new areas of public realm; to accommodate 34,500 sqm of total development

A/C


area and 1,062 cars. 06/796/OUT Up to 215,000sqm floor space (excluding plant

areas) comprising 60,000sqm of clinical research and treatment (D1 and/or clinical in-patient treatment), 115,000sqm of biomedical and biotech research and development (B1(b)), 15,000sqm of biomedical and biotech research and development (B1(b)) or clinical research and treatment (D1 and/or clinical in-patient treatment), and 25,000sqm of either clinical research and treatment (D1 and/or clinical in-patient treatment) or higher education or sui generis medical research institute uses, and including related support activities within use classes A1, A3, B1, D1 (creches/nurseries) or sui generis uses, with no individual premises used for support activities to exceed 500sqm; new areas of public realm; landscaping; parking areas; highway works; drainage works and all other associated infrastructure.

A/C

3.9 POLICY

National National Planning Policy Framework 2012 Planning Policy Statement 10, Planning for Sustainable Waste Management Regional Cambridgeshire and Peterborough Minerals & Waste Development Plan - Core Strategy Development Plan Document (2011) CS19 The location of Hazardous Waste Facilities – Resource Recovery and Landfill. CS 29 The Need for Waste Management Development and the Movement of Waste

This Plan includes a strategic site-specific allocation for the replacement clinical waste facility (Policy CS19, Area of Search site W2). This was in response to Addenbrooke’s Hospital identifying the need for a new clinical waste facility to replace the existing facility. It also provided a Waste Consultation Area around this to protect the site allocation (Policies CS19 and CS30).

Local Cambridge Local Plan 2006 3/1 Sustainable development 3/2 Setting of the City 3/3 Safeguarding environmental character 3/4 Responding to context 3/6 Ensuring coordinated development 3/11 The design of external spaces 3/12 The design of new buildings 3/13 Tall Buildings and Skyline 4/13 Pollution and Amenity

4/14 Air Quality Management Areas 4/15 Lighting

5/15 Addenbrooke’s 8/2 Transport Impact 8/4 Walking and cycling accessibility


8/16 Renewable energy in major new developments 8/17 Renewable energy 8/18 Water, sewerage and drainage infrastructure 9/5 Southern Fringe

Supplementary Planning Documents Sustainable Design and Construction - Cambridge City Council (2007) The Location and Design of Waste Management Facilities Supplementary Planning Document – Cambridgeshire County Council (2011) Guidance for the application of Policy 3/13 (Tall Buildings and the Skyline) of the Cambridge Local Plan 2006. (2012)

4. THE PROPOSAL

4.1 The EIC is designed to fulfil the role currently undertaken by the existing Addenbrooke’s Hospital boiler and incinerator; and to serve the future expansion of the Cambridge Biomedical Campus. The development would reduce the Hospital Trusts’ carbon dioxide emissions by 47% and energy costs by 50%.

4.2 It is proposed that the EIC will have the flexibility to operate 24 hours per day

and 365 days per year, although in practice the plant will operate as required in order to meet heat and electricity needs. The plant will comprise:

• a combined heat and power unit generating between 6.8 and 7.5 megawatts of electricity; and a heat recovery steam generator generating approximately 2 megawatts of heat;

• two biomass boilers* each of generating approximately 3 megawatts of heat (initially fuelled by waste woodchip products, but with the capability to be flexible in the future with respect to fuel feedstock);

• a clinical waste incinerator generating 1.6 megawatts of heat from processing 350/kg/hour of clinical waste; and

• three dual fuel conventional steam boilers, one generating 4 megawatts of heat and two generating 10 megawatts of heat.

• Three 60 metre high chimney stacks. *biomass is a generic term for any organic material that can be used to produce heat, electricity or transport fuel.

A ‘tugway’ (underground passageway) will provide a link between the EIC and Addenbrooke’s Hospital, allowing clinical waste to be brought to the EIC without using the roads.

4.3 The EIC building will have a gross external footprint of approximately 2,500

square metres, with a service yard adjacent of some 2,200 square metres. The single building will be located on the eastern side of the site. It would have a saw-tooth roof, at an optimum 30 degrees to the south, to provide an opportunity for photo voltaic cells in the future. There would be three stacks (chimneys) extending above the roof level of the building, which would be 60 metres above


ground level. The existing hospital chimneys will be retained as they form part of the ventilation system for the Hospital. Landscaping will be provided around the site, more extensively on the east side where birch trees and timber bridges leading to viewing windows will be located, in an area softened by tall grasses. On the north and west the service yard will be screened by a line of fast growing trees.

4.4 The EIC will be accessed from the southern spine road (the reserved matters for

which were approved in January 2013 under delegated powers) off the Biomedical Campus, and the Addenbrooke’s Road. All deliveries will use this route, going to / from the M11. It is anticipated that there will be an average of 3-4 HGV trips per day (biomass and clinical waste), and an average of 24 trips generated by staff vehicles. The total traffic movements are expected to average 28 two-way trips per day.

4.5 The EIC has been sized to ensure that its outputs can grow with the CBC

requirements. Allowance has been made within the design for future expansion if required, including space for an additional gas fired combined heat and power unit; additional steam connections are design in case they are needed; and the roof has the capability to accommodate photovoltaic panels.

4.6 Since receipt of the original application, the County Council has re-consulted on

the application with additional information received from the applicant for the Environmental Statement in relation to air quality, including the human health risk assessment and noise and vibration and additional details for the Planning Statement of the carbon savings calculations and hierarchy of technologies. The responses set out in this report take account of that additional information.

4.7 Notwithstanding the planning process, due to the size and nature of the plant proposed the facility will be regulated under the Environmental Permitting (England and Wales) regulations 2010 as amended. The permitting regime is the means for giving detailed technical consideration to the emissions from the facility. The County Council as the Strategic Waste Planning Authority deals with determining planning application, whilst the Environmental Permitting regime is the responsibility of the Environment Agency and/or the Local Council’s Environmental Health Office, depending on what is proposed. In this instance, it has been confirmed that the Environment Agency will be responsible for the combustion plant (including the waste wood boilers) and the City Council for the clinical waste incineration activity in terms of the permit process.

5. ASSESSMENT 5.1 The County Council as the Strategic Waste Planning Authority for the

determination of the planning application is responsible for carrying out all statutory and non-statutory consultations and neighbourhood consultation in the same way as the City Council does for the planning applications for which it is responsible. County Council officers put forward their recommendations based on the outcome of these consultations and an assessment of planning policies and material considerations within the same legislative framework as the City Council operates. The County Council will therefore, determine the application through its own Planning Committee.


5.2 In this case the County Council officers have consulted:

County Council New Communities County Council Highway Development Control County Council Archaeology County Council Ecology County Council Growth & Development Environment Agency Natural England Highway Agency South Cambridgeshire District Council Hauxton Parish Council Great Shelford Parish Council The Wildlife Trust English Heritage Cambridgeshire Fire & Rescue Anglian Water Cambridge Water Cambridge Airport Health Protection Agency Civil Aviation Authority Fire and Rescue Service

The County Council have also consulted 2,260 neighbouring residents properties in the vicinity of the scheme and displayed statutory notices. A drop in session was held on Monday 17 December (5.00 - 8.30 pm) at Long Road Sixth Form College, Cambridge, which was manned by County Council officers and an officer from the Environment Agency. Around 30 people attended the event.

5.3 It is not the role of the City Council to duplicate this consultation process. Our

role is to make comments on the proposals as they have been submitted. In so doing and mindful of the consultations that have already been carried out the following officers in the City Council have been consulted:

Refuse & Environment Service (including Environmental Health, Air Quality, Contaminated Land and Waste Strategy Officers) Senior Sustainability Officer (Design and Construction) Head of Urban Design & Conservation Team Principal Landscape Architect Nature Conservation Officer

5.4 A summary of the outcome of these consultations is set out below (more detailed

comments are contained in Appendix 2).

The Results of Internal Consultation

Urban Design & Conservation 5.5 Support the proposal subject to consideration of the use of a brown roof rather

than the aluminium roofing material proposed to help with water management issues and to tie the building into the surrounding landscape. Full details of the proposed materials including samples panels on site should be required.


Landscape 5.6 Successful mitigation is dependent on the landscape treatment around the

building and the southern spine road to its south. Large trees, which will attain some height, are required to mitigate the visual impact of the mass of the buildings and of the chimneys. Further information should be provided on detailed soft landscape proposals, written specifications and implementation programme, hard landscaping proposals, a maintenance plan for the entire site and a management plan covering a period of 20 years.

Nature Conservation Officer

5.7 Evidence of a recent ecological survey should be provided. No ecological enhancements as included in the site wide plan, such as the provision of nest boxes in all buildings.

Senior Sustainability Officer (Design and Construction)

5.8 The general approach to developing an energy centre to serve the energy requirements of the site as a whole is fully supported. Such an approach will be the most efficient way in which to meet the energy needs of the site, and also represents the best approach in terms of reducing the carbon emissions of the Addenbrooke’s campus. The additional information provided on reporting the sustainability of the biomass fuel stock should help to ensure that it is sourced from sustainable resources. Additional information received from the applicant confirms that the materials to be used conform to the BRE A to A+ rating of materials, which is supported.

Refuse and Environment Service

5.9 Permitting Regime The EIC will be regulated under the Environmental Permitting (England and Wales) Regulations 2010, as amended 2010, as amended. As a result of recent amendments to the regulations the City Council will now be responsible for permitting the clinical waste incinerator. The Environment Agency will remain responsible for permitting the remainder of the plant. Developers are encouraged to parallel-track planning and permitting applications.

5.10 Air Quality

Modelling - The modelling indicates that there will be an unavoidable increase in emissions from the proposed EIC and, with a chimney height of 60m and all sources operating, there will also be an increase in air pollution in and around the facility. None of the increases in air pollution will lead to any breaches of National Air Quality Objectives or EU Limit Values, although the small increase in PM2.5 is contrary to its Exposure Reduction Target. Fuel Specification - A condition is recommended to give certainty to the fuel source, which should stipulate the actual grades of fuel to be used (A-C), the source of the fuel and require that any change to the fuel type or source should be agreed. The fuel source and type for the facility will be specified according to the requirements of the permitting regime. Chimney Height - A condition is recommended to give certainty to the chimney height, which should be 60 m above ground level and require that any change to the chimney height should be agreed. The final chimney height at the facility will be determined by the requirements of the permitting regime. Abatement - A condition is recommended to give certainty to the abatement technologies, which should stipulate that the abatement technologies selected should reflect Best Available Techniques and require that any change to the


abatement technology during the lifetime of the facility should require permission, as well as a permit revision. The abatement used at the facility will be determined by the requirements of the permitting regime. Summary - We recognise that there are financial benefits and carbon saving benefits arising from the proposed development; the planning merits of these benefits should be balanced against the human health impacts. The public health impacts can be minimised by ensuring that the chimney heights remain at least 60m height from ground level to allow good dispersion of pollutants and by maintaining strict controls over the source fuels used in combustion appliances.

5.11 Contaminated Land and Human Health Contaminated Land (On site Users) - A condition is recommended for a land contamination assessment and associated remedial strategy. Human Health Risk Assessment (Residents of Surrounding Areas) – This relates to the impacts to human health after the pollutants have been deposited to the ground. The outcomes of the human health risk assessment and the modelling are based on the assumption that the proposed incineration plant will comply with the Emission Limit Values. The human health risk assessment should take account of the impacts of any abatement failure on the incineration plant. These issues can be addressed at the permitting stage.

5.12 Noise and Vibration - Full details of the construction of the building and how this

can contain the unloading noise should be required by a noise insulation condition. A condition for a Construction Environment Management Plan (CEMP) to cover noise and vibration including construction hours, construction delivery hours, dust and site lighting etc is appropriate and should be applied. Conditions to cover noise arising from the operational phase, including plant and equipment, the emergency generator and delivery hours should be applied.

5.13 Odour - In order to ensure that adequate odour controls measures are put in

place and maintained during operation however, a condition requiring full details of the odour mitigation is required.

5.14 Lighting - A condition is recommended to require the full details of any floodlighting and/or external lighting to be submitted for approval. There may be an issue for wildlife, biodiversity, night-sky and aircraft safety. The Highways Authority, City Council’s biodiversity officer, and the City Airport and/or the Civil Aviation Authority should be are consulted on this matter.

5.15 Waste Strategy No comments. 5.16 Assessment of Consultation Responses 5.17 The principle of developing the EIC to serve the whole Addenbrooke’s and CBC

site is fully supported. This approach will be the most efficient way in which to meet the energy needs of the site and the best approach in terms of reducing the carbon emissions of the Addenbrooke’s campus. The new energy centre should reduce emissions by 47%, while reducing energy costs for the Trust by 50%. This approach meets the requirements of Cambridge Local Plan Policy 3/1 for sustainable development and Policy 5/15 for development at Addenbrooke’s, in meeting the requirements for the management of waste/energy demands as a


result of the proposed expanded campus as permitted by the Addenbrooke’s 20/20 outline planning permission.

5.18 The proposals for the EIC have been subject to a series of pre-application

meetings with the involvement of City and County Council officers since March 2012. As a result of the internal consultations a number of detailed points have been raised which would be appropriate to be addressed by the applicant before the application is determined or for the County Council to control via planning conditions.

Visual impact 5.19 It is accepted that the proposed EIC building will have a significant visual impact

in the short to medium term until the land to the south is developed which will help integrate the building into the Biomedical campus as a whole. The Environmental Statement recognises that the proposed chimneys will continue to have a significant impact in the long term. The three new chimneys will be of a similar height to the existing. Although they will have a significant visual impact on this part of Cambridge they will become part of the character of the Biomedical Campus as the site is built out. The scale and massing of the proposed building fits within the constraints of the overall parameter plans for the site. The design of the roof of the building through the use of a ‘saw tooth pattern’, created by the strong angled pitches, elevates the design from a simple industrial ‘shed’. The quality and finish of the materials to be used will be important to create a distinctive building. The Urban Design Officer has highlighted concerns for the proposed aluminium roofing material, which would have potential to be quite reflective. The use of a brown roof would help integrate the building better into its surroundings as well as help deal with water management issues. It is recommended therefore that the applicants consider the use of a brown roof (as set out in section 2 of this report). Should permission be granted a condition is recommended to require proposed materials and sample panels on site to ensure that the quality and finish is appropriate (Appendix 1, Condition 1).

5.20 The visual impact of the building needs to be mitigated, particularly on the

southern boundary, as it is located near the edge of the Green Belt with valued views to and from the Gog Magog Hills. The proposed landscaping should be of sufficient size to mitigate the building mass where possible. The Landscape Officer has recommended a larger species of tree than proposed to help with this mitigation. In the medium term the EIC will have large buildings to the east and west, and with the proposed chimneys and neighbouring buildings, large trees will be needed to mitigate the visual impact of their mass. Native species to fit with the agricultural landscape would be more appropriate than the use of garden species as proposed. It is recommended therefore that the applicants consider a larger tree species (as set out in section 2 of this report). Should permission be granted conditions are recommended for hard and soft landscaping details to be agreed and a long-term maintenance plan (Appendix 1, Conditions 2, 3 and 4). Further work is required on the ecological survey to take account of the approved CBC site wide Nature Conservation Management Plan to identify the protection and monitoring of Protect Species on site and to ensure that ecological enhancements are included in the proposals (set out in Section 2 of this report).


Air quality and emissions 5.21 Environmental Health Officers have had detailed discussions with the applicants

and County Council officers on a number of issues in relation to air quality and the use of biomass, the impact on human health and noise impacts. Environmental Health Officers have advised that there will be an unavoidable increase in air pollution as a result of the waste management facility and the waste wood/biomass boiler. They have reservations about the appropriateness of siting an additional combustion process within a sensitive location with schools, hospital facilities and housing nearby, due to the potential negative impact on human health. The Air Quality Assessment shows however, that the proposed development will not lead to any specific breaches of air quality standards. The Environmental Health Team generally considers a development acceptable if it can demonstrate an improvement in air quality or at least no deterioration in air quality.

5.22 Cambridge Local Plan policy 4/13 specifies that development should only be

permitted which does not lead to significant adverse effects on health, the environment and amenity from pollution; or which can minimise any significant adverse effects through the use of appropriate reduction or mitigation measures. The National Planning Policy Framework (NPPF) states that ‘Local planning authorities should focus on whether the development itself is an acceptable use of the land, and the impact of the use, rather than the control of processes or emissions themselves where these are subject to approval under pollution control regimes.’ The operation of the facility will be subject to a separate permit process, which will determine if an operation can be managed on an ongoing basis to prevent or minimise pollution. The type of fuel source proposed for the biomass is of some concern as different fuels can lead to different pollutant emissions. The proposed fuel is waste wood feedstock, which is provided in different grades of recycled wood and would come from a local source from Waterbeach. In order to be certain of the fuel source to ensure that emissions are within the acceptable limits a condition is recommended to secure the fuel source details (Appendix 1, Condition 6).

5.23 The proposed chimney height will also have an impact on the air quality. The

proposed height is 60 metres from finished ground level, which is acceptable; any lowering of height could have a negative impact on health, due to the lower dispersion of emissions. Any change in height would need to be assessed given the air quality issues and the visual impacts of the chimneys. A condition is therefore recommended to ensure the chimney height is 60 metres (Appendix 1, Condition 7). The proposed clinical waste incinerator and waste wood/biomass boilers will have abatement measures to control emissions. In order to ensure that the measures installed are the best available technology and installed as proposed a condition is recommended to require full details of the abatement measures (Appendix 1, Condition 8).

5.24 Former investigations undertaken in the wider site as part of the CBC

development for land contamination have noted the absence of significant contamination. Further gas monitoring will need to be undertaken and a full land contamination assessment and remedial strategy condition is recommended to ensure that appropriate measures are taken (Appendix 1, Condition 9).


Noise and odours 5.25 The delivery and unloading of fuel and waste to the EIC will take place internally

within the proposed building, however details of the insulation of the building will be required to ensure that any noise disturbance is kept to a minimum. Potential noise as a result of the proposed plant also needs to be considered and therefore a condition to ensure full details are provided is recommended (Appendix 1, Condition 10). Potential noise from the proposed emergency generators should be considered and details required (Appendix 1, Condition 11). There will be potential disturbance during the construction phase of the development. A condition to secure details through a site wide construction environmental management is therefore recommended (Appendix 1, condition 5). The collection and deliveries made to the site in the operation of the EIC could lead to potential noise disturbance and a condition is therefore recommended to control the hours allowed for these; only between 7am and 7pm Monday to Saturday and none on Sundays or Bank Holidays (Appendix 1, Condition 12). The applicants have carried out an assessment of the potential odour from the clinical waste. In order to ensure that adequate odour control measures are put in place and maintained during the operational phase a condition requiring full details of the odour mitigation measures is considered necessary (Appendix 1, Condition 13). The applicant has not provided a detailed lighting strategy at this stage and therefore a condition is recommended for details to be approved to ensure that light pollution is minimised (Appendix 1, Condition 14).

6. CONCLUSIONS 6.0 The Addenbrooke’s 20/20 outline permission provided for a strategic expansion

of the Addenbrooke’s campus to provide clinical research and treatment, biomedical and biotech research and development facilities, which will have significant long-term economic benefits for the whole Cambridge sub-region. There is also a clear need for Addenbrooke’s to be able to maintain its position as a location for clinical, biomedical and hospital related functions of national importance. The air quality impacts would not breach air quality standards. Any impact has to be balanced against the benefits and sustainable location of the facility within the Addenbrooke’s campus and the strategic context of the proposals.

6.1 The results of the internal consultations have raised a number of detailed points,

as highlighted in section 2 of this report, which would be appropriate for the applicant to address before the application is determined. Subject to the controls as recommended through the planning conditions as set out in section 2, Appendix 1, the proposal for the EIC is considered to meet Local Plan policies and the NPPF and should be supported. These recommendations have been passed onto applicant via the County Council so that they can be taken account prior to the application being determined by the County.

6.2 The Committee is therefore recommended to approve the recommendation at

paragraph 2 of this report. 7. IMPLICATIONS (a) Financial Implications – None


(b) Staffing Implications – None (c) Equal Opportunities Implications – None (d) Environmental Implications – As set out in the Consultation responses section (e) Procurement – None (f) Consultation and Communication - None (g) Community Safety - None BACKGROUND PAPERS: The following are the background papers that were used in the preparation of this report: Planning application C/05009/12/CW To inspect these documents contact Ann Barnes, Cambridge County Council on extension 01223 715526 The author and contact officer for queries on the report is Janine Richardson on extension 7295. Report file: Date originated: 28 May 2013 Date of last revision: 28 May 2013


Appendix 1 – Recommended Planning Conditions Materials 1. Prior to the commencement of development, full details of the proposed materials including sample panels to be constructed on site should be submitted and approved. Soft landscaping 2. Prior to the commencement of development, detailed soft landscape proposals, including planting plans, written specifications and implementation programme should be submitted and approved.

Hard landscaping 3. Prior to the commencement of development, fully detailed hard landscape proposals to include levels, specifications of materials, furniture, boundary treatments and lighting should be submitted and approved.

Landscape maintenance 4. Prior to the occupation of development a landscape maintenance plan for the entire site (to include 5-year replacement planting regime) and a management plan covering a period of 20 years should be submitted and approved.

Site Wide Construction Environmental Management Plan 5. Prior to the commencement of development a Site Wide Construction Environmental Management Plan should be submitted and approved. This should cover construction and phasing programme, contractors arrangements, construction hours, delivery times, waste management, noise method and monitoring and noise levels for construction equipment, vibration methods and levels, dust management and wheel washing, site lighting, drainage control measures, screening and hoarding, access arrangements, signage, consideration of sensitive receptors, complaints and membership of Considerate Contractor Scheme. Fuel source 6. Prior to the commencement of development the grades and source of biomass fuels to be used shall be submitted and approved. Chimney height 7. The chimney height shall be 60m above finished ground level.

Abatement details 8. Prior to the commencement of development full details of the abatement technologies to be used for the CWI and waste wood/biomass boilers should be submitted and approved.

Contaminated land 9. Prior to the commencement of development a contaminated land assessment and associated remedial strategy including desk study, site investigation and report and proposed remediation strategy should be submitted for approval. Works should be carried out in accordance with the findings and a closure report submitted for approval.

Insulation of buildings/plant 10. Before the development is occupied, a scheme for the insulation of the building(s) and/or plant in order to minimise the level of noise emanating from the said building(s)


and/or plant should be submitted for approval. The scheme as approved should be fully implemented before the use permitted is commenced.

Emergency generator 11. Before the development is occupied, a scheme for the insulation of the emergency generators in order to minimise the level of noise emanating from the said emergency generators should be submitted and approved and the scheme as approved be fully implemented before the use permitted is commenced. The scheme should include the following: (i) Generator - Emergency Use Only

The generator should only be used in the event of mains power failure or in accordance with (ii) below. It should not be used as an alternative supply in the event of disconnection from the mains supply.

(ii) Generator - Hours of Running for Maintenance Running of the generator as part of routine maintenance and repair shall only take place for up to 60 minutes at a time, once per month and be between the hours of 8am – 6pm Monday to Friday, 9am –1pm Saturday and no time Sunday or Public Holidays.

Collection and delivery hours 12. There should be no collection or deliveries to the site during the operational phase outside the hours of 0700 hrs and 1900 hrs on Monday – Saturday and there should be no collections or deliveries on Sundays or Bank and public holidays.

Odour mitigation 13. Details of odour mitigation to be submitted and approved in writing. Measures to be fully operational before the use permitted is commenced. In carrying out the assessment it is also recommended that the applicant should have regard to the Environmental Agency Technical Guidance Note H4 – Odour management, Consultation DRAFT 2009 and the document Additional guidance for H4 Odour Management, How to comply with your environmental permit- March 2011, and the DEFRA document “Odour Guidance for Local Authorities, DEFRA, March 2010”.

Lighting scheme 14. Prior to occupation of the development details of proposed floodlighting or external lighting should be submitted and approved. Informatives are recommended in relation to: The permitting regime Considerate Contractors scheme Developers Guide to Contaminated Land in Cambridge Noise levels information Advice on measures to control airborne dust


Appendix 2 – Consultee responses (The responses are a summary of the comments that have been received. Full details of the consultation responses can be inspected on the application file). Urban Design & Conservation General - Recognise that the proposals will have a significant visual impact on the surrounding landscape due to the 3 proposed flues that will be 60m in height. Whilst the building can be ‘anchored’ into the landscape using appropriate landscaping, the flues will continue to have a significant impact on the setting of this part of Cambridge. As with the southern Multi-storey Car Park (MSCP), proposed as part of the CBC masterplan (Application reference: 11/0780/REM), the proposed EIC will sit in a somewhat isolated position until other sites within the campus are developed. As with the MSCP, the context of the proposals will change dramatically in the coming years. In the short term the building, setting the flues to one side, will be more visually apparent ahead of further development on the CBC site. However, over time the building will form part of the overall built form on the campus. Scale and massing - Whilst an energy centre was not envisaged as part of the original CBC masterplan, the scale and massing of the proposals fit within the constraints of the overall parameter plans for site. The approach to the massing creates a well-articulated roofscape through the use of a ‘saw tooth pattern’, created by the strong angled pitches. Overall the effect is to create a sculptural form to the building that elevates the design from a simple industrial ‘shed’.

Elevations and materials - Overall the approach taken to the design of the elevations is supported, which use simple materials in a more refined way. Crucial to the overall quality of the finished building will be the detailing of junctions between materials and the quality of construction on site. There are concerns with the proposed roofing material that have the potential to be quite reflective. The strong preference, expressed at the pre-application discussions, was for an extensive ‘brown roof’ on the building. Such an approach would help deal with water management issues but also help tie the building into the surrounding landscape. The applicant is encouraged to use an extensive brown roof and that the application should be amended accordingly. If the proposed standing seam aluminium roofing material were progressed a large-scale panel on site to assess its suitability would be needed. Public realm - Given the use and function of the building, considerable effort has been placed on trying to integrate it with the proposed surrounding street network and activating the edges for example through the incorporation of the ‘viewing windows’ on the east elevation that integrate with the landscape and public realm. This approach is supported, although as with the materials used on the building, care will be needed to ensure that elements do not fall away at the implementation stage and that the scheme is well executed. Should the scheme be approved, further information should be supplied on the proposed materials including sample panels to be constructed on site.

Landscape The methodology for the impact assessment is in accordance with the industry standard and is fully supported. The report, and particularly the Zone of Visual Influence as seen in Appendix D.1 of the ES, highlights the fact that the Energy Innovation Centre (EIC) will have an adverse visual impact. The impact will be greater in the short term until land to the south of the EIC is developed which will help integrate the mass of the building into the hospital complex as a whole. However, it is recognised in the report that the chimneys will continue to have an adverse visual impact in the long term. The three new chimneys are of a similar height to the existing. The focus must be to mitigate the visual impact, particularly as the EIC is located on the southern boundary of the city and on the edge the Green Belt with valued views to and from the Gog Magog Hills. Successful mitigation is dependent on the landscape treatment around the


building and the southern spine road to its south. The tree planting must include larger species than the proposed Betula (Birch). Birch is also an inappropriate species for the edge of Cambridge. In the short term the EIC will stand isolated on the edge of the hospital complex and for the most part surrounded by flat fields. In the medium term it will have large buildings to the east and west of it. The EIC, with accompanying chimneys and neighbouring buildings, will need large trees around it to mitigate the visual impact of the mass of the buildings and of the chimneys. Either Tilia cordata ‘Green Spire’ or Corylus colurna are suggested as relatively compact trees, which will attain some height. In addition, the use of garden species within the planting palette is not supported. The development and accompanying planting is on the edge of the Green Belt and a working agricultural landscape and must be strictly low key and native; garden species would be a discordant element and inappropriate. Should the scheme be approved further information should be provided on detailed soft landscape proposals, including planting plans, written specifications and implementation programme, hard landscaping proposals, a maintenance plan for the entire site and a management plan covering a period of 20 years. Nature Conservation Officer Evidence of a recent ecological survey should be provided. The approved Cambridge Biomedical Campus site wide Nature Conservation Management Plan (September 2010) does not appear to be referenced in the application. This document identifies Protected Species that require protection and monitoring across the development site and the application should address this. No ecological enhancements as included in the site wide plan, such as the provision of nest boxes in all buildings, are referenced in the application.

Senior Sustainability Officer (Design and Construction) The general approach to developing an energy centre to serve the energy requirements of the site as a whole is fully supported. Such an approach will be the most efficient way in which to meet the energy needs of the site, and also represents the best approach in terms of reducing the carbon emissions of the Addenbrooke’s campus. The Planning Statement that accompanies the planning application notes that the new energy centre should reduce emissions by 47%, while reducing energy costs for the Trust by 50%. Additional information was requested on carbon calculations and hierarchy of technology to ensure that levels of carbon reduction are maximised for the scheme and to ensure that the use of higher carbon emitting technologies will be minimised. The information provided by the applicant and approach being taken is supported. The current design and specification of the equipment within the energy centre relates to the current energy demands of the site, with some flexibility and expansion capacity to accommodate the future expansion of the campus, which is welcomed. Connection to a site-wide energy network is likely to represent the most cost effective way for future developments to meet some of their carbon reduction requirements, be this linked to Building Regulations or future planning policies. What is not apparent however, is how much of the demand that will be generated by the expansion of the campus could be met by the energy centre. Some further clarification as to the extent to which the design of the energy centre has been future proofed in terms of capacity would be welcomed. Additional information has been provided by the applicant in the document "Biomass Fuel and Fuel Testing Specification" dated January 2013. With regards to my initial concerns surrounding how the applicant will secure the long-term sustainability of the biomass fuel stock, this document sets out an approach to the preparation of quarterly reports on the sustainability of the biomass fuel stock, which will be submitted to Ofgem. These reports will apply to both feedstock sourced in the UK and that imported from abroad and will include: Country of origin, source material and any applicable environmental quality assurance schemes. This thorough approach to reporting on the sustainability of the biomass fuel stock should help to ensure that it is sourced from sustainable resources. This combined with the approach of utilising waste wood as far as is practicable helps to overcome my initial concerns, and I can confirm that I support the approach being taken.


The reference to future proofing the design of the energy centre roof to allow provision of photovoltaic panels is welcomed. It may also be necessary to future proof electrical infrastructure to ensure that the future installation of photovoltaic panels is straightforward. The application also lacks detail on the wider sustainability of the design of the building itself, for example in terms of sourcing of materials with low environmental impacts and minimising construction waste. It is noted that only a partial sustainability checklist has been completed, which misses out the sections on materials and construction waste, pollution and biodiversity. Additional information received from the applicant confirms that the materials to be used conform to the BRE A to A+ rating of materials, which is supported.

Refuse and Environment Service Permitting Regime The Environmental Permitting (England and Wales) (Amendment) Regulations 2013 have now been published. However currently, with the exception of the clinical waste incinerator, this authority has not received any information regarding the thermal inputs and fuel consumption capacities of the various plant proposed. This information is necessary to determine which part of the Regulations will apply to the plant and consequently which authority will be the regulating authority. Developers are encouraged to parallel-track planning and permitting applications.

Air Quality Modelling - In summary, the modelling indicates that there will be an unavoidable increase in emissions from the proposed EIC and, with a chimney height of 60m and all sources operating, there will also be an increase in air pollution in and around the facility. None of the increases in air pollution will lead to any breaches of National Air Quality Objectives or EU Limit Values, although the small increase in PM2.5 is contrary to its Exposure Reduction Target. Fuel Specification - The comprehensive draft Biomass Fuel and Fuel Testing Specification states that the waste wood feedstock for the biomass boiler will be Grade A – C recycled wood, mostly Grade C. This is described as suitable for WID compliant installation (PAS 111:2012, British Standards Institution). The Environmental Statement comments that the boilers can also be operated on virgin wood to provide future flexibility and resilience. A change to combustion of virgin wood instead of waste wood would not have the same carbon benefits because local supplies of wood are limited and supplies would have to be brought in from a greater distance. In addition, there would the loss of the carbon saving benefit compared with land filling of waste wood. Emissions of Nitrous Oxides and Particulate Matter would be about the same as with waste wood, although the impacts from other pollutants would be lower from burning a cleaner fuel. A change in fuel source from/to waste wood/clean wood would change the relevant permitting regime, but the same emission limits would apply. Although not mentioned in the written documents, it is understood that there is a possibility of a change to locally sourced Refuse-Derived-Fuel (RDF) or Solid-Recovered-Fuel (SRF), which would also lead to new pollutant emissions in this sensitive area. If the planning application is approved, than a planning condition is recommended to give certainty to the fuel source, which should stipulate the actual grades of fuel to be used (A-C), the source of the fuel and require that any change to the fuel type or source should require a new planning application. The fuel source and type for the facility will be specified according to the requirements of the permitting regime. Chimney Height - Chimney height is crucial. If the chimney height were to be lower, the negative health impact would be greater. Conversely, if the chimney height were to be higher then the negative health impact would be lower. Increasing chimney height would help towards mitigating the negative health impact of this proposal, but any improvement would have to be backed up with additional modelling to show how much improvement could be achieved. We would strongly support an increase in chimney height. If the planning application is approved, then a planning condition is recommended to give certainty to the chimney height, which should stipulate that the chimney height will be 60 m above ground level and require that any change to the chimney height should require permission. The final chimney height at the facility will be determined by the requirements of the permitting regime. Abatement - The replacement CWI is designed with a sodium bicarbonate and activated carbon dosing system to control sulphur oxides, heavy metals, dioxins and furans, and total organic


carbon (TOC) emissions. A urea based Selective Non-Catalytic Reduction system is planned to reduce emissions of nitrous oxides and a reverse jet ceramic filter system is planned to control particulate and acid gas emissions. There should be some improvement in the short term as the replacement will be new equipment and less vulnerable to exceedences as a result of breakdowns. The waste wood/biomass boilers are designed with flue-gas recirculation in both the primary and secondary combustion chambers to reduce nitrous oxides formation. Urea injection will be used to abate NOx emissions, dry lime injection to control sulphur oxides and activated carbon to control heavy metals, dioxins and furans, and Total Organic Carbon emissions, as well as reverse jet bag filter system is installed to abate particulate emissions. Both the CWI and the waste wood/biomass boilers will have Continuous Emissions Monitoring. In the case of abatement failure, the operation would shut down. This process would take approximately 2 – 3 hours, depending upon the load. During this time combustion would be incomplete and emissions to air would continue. Under the permitting regime, no more than 4 hours uninterrupted ELV exceedences are allowed – and no more than 60 hours in total of exceedences are allowed each year. If the planning application is approved, a planning condition is recommended to give certainty to the abatement technologies, which should stipulate that the abatement technologies selected should reflect Best Available Techniques and require that any change to the abatement technology during the lifetime of the facility should require permission, as well as a permit revision. The abatement used at the facility will be determined by the requirements of the permitting regime.

Summary - There will be an unavoidable increase in air pollution as a result of the inclusion of the proposed additional waste management facility, the waste wood/biomass boiler, at the

Energy Innovation Centre. Whilst the Air Quality Assessment shows that the proposed development w ill not lead to any specific breaches of air quality standards, the Environmental

Health Team generally consider a development acceptable if it can demonstrate an

improvement in air quality or at least no deterioration in air quality (although this is not currently formal City Council policy). A preferred approach would be to show what abatement

technologies could be used to bring the levels of emissions not only below the limits required

by WID, but even lower, such that the impact would be barely perceptible.

The need for the Clinical Waste Incinerator (CWI) at the Addenbrooke’s site is recognised. Replacement of the existing CWI system will, at least in the short-medium term, reduce the number of reported exceedences of Emission Limit Values. However, there is no operational requirement for the inclusion of a biomass boiler at Addenbrooke’s, as the waste wood will be imported onto the site. The increase in air pollution will result irrespective of the fuel source, virgin wood, waste wood or RDF/SRF. The nature of the emissions and consequent air pollution will depend upon the nature of the fuel source.

Emissions and levels of air pollution will increase in future years as development at the Addenbrooke’s continues. The location of this proposed development is not in accordance with Renewable Energy Strategy which indicates that biomass be taken up in areas off the gas grid and not in urban areas. Therefore, the environmental health team questions the

appropriateness of the siting of an additional combustion process in a sensitive location with

schools, hospital facilities and housing nearby, because of the potential negative impact on human health in both the short term and the long term.

We recognise that there are financial benefits and carbon saving benefits arising from the proposed development; the planning merits of these benefits should be balanced against the human health impacts. The public health impacts can be minimised by ensuring that the chimney heights remain at least 60m height above ground level to allow good dispersion of pollutants and by maintaining strict controls over the source fuels used in combustion appliances.

Contaminated Land and Human Health – Contaminated Land (On site Users) - Former investigations undertaken in the wider area as part of the CBC development have noted the absence of significant contamination. Elevated


concentrations of carbon dioxide were identified during the investigation of the MRC site, known as Lab of Molecular Biology (chalk geology was identified as the possible source). The Environmental Statement submitted for EIC confirms that further ground gas monitoring will be undertaken in order to assess the gassing regime on the site; gas mitigation measures will be implemented if deemed necessary. This is accepted. Any ground gas monitoring programme undertaken is required to be in line with CIRIA 665. All these issues can be covered by a full contaminated land condition. Human Health Risk Assessment (Residents of Surrounding Areas) The Air Quality section presented above discusses the impacts of the air pollution emitted from the proposed development to human health. The section presented below discusses the impacts to human health after the pollutants have been deposited to the ground. Limited additional information has been submitted on the points made regarding compliance of the risk assessment model used and PCB emissions. Instead heavy reliance was placed on the feedback provided by the Environment Agency. It is noted however that the Environment Agency has issued the following caveat ‘We have not validated the numerical predictions. If this were to be regulated by the Environment Agency, we would expect to do this as part of a detailed audit to inform permitting decision making.’ We would therefore require that the points raised previously be addressed in a satisfactory manner if the Local Authority regulated the proposed installations. We are also aware that the air quality monitoring data from Weybourne Station were not directly used in the human health risk assessment. Instead they were applied in the ADMS modelling (Table 7.24) in order to calculate annual average concentrations (those were subsequently used in the HHRA, as per Appendix B.3). The outcomes of the human health risk assessment and the modelling are based on the assumption that the proposed incineration plant will comply with the Emission Limit Values. We are aware of instances where the existing incinerator breaches the permitted emissions regarding dioxins (for example, exceedances occurred during December 2012). A revised human health risk assessment for the likely impacts of such abatement failures should be undertaken. We understand that this approach is also supported by the Environment Agency. Additionally PBA should use the real time emissions observed during those incidents in order to demonstrate the effects of any abatement failure. In summary the following issues should be addressed at the permitting stage:. - Limited additional information has been submitted for the issues regarding the compliance of the USEPA model and the PCB emissions; heavy reliance was placed on the EA correspondence. We would require that these issues be addressed if the Local Authority regulated the facility. - A revised human health risk assessment should be undertaken and consider the impacts of any abatement failure on the incineration plant (emission data from the existing plant should be used in the model).

Noise and Vibration The additional information provided by the applicant has addressed initial concerns regarding potential noise from the operation of the EIC. Although it is confirmed that delivery unloading activities are only to take place internally, the proposed construction of the building (block work, cladding and grillage to the lower level) appears to be insufficient to contain all noise generated by such deliveries. Full details of the construction and how this can contain the unloading noise can be required by a noise insulation condition.

The evaluation report dated 15 April 2013 produced by 10db Acoustics, is agreed with and the recommended conditions supported. A condition for a Construction Environment Management Plan (CEMP) to cover noise and vibration including construction hours, construction delivery hours, dust and site lighting etc is appropriate and should be applied.

It is not clear at this stage whether or not noise from all or some of the plant will be covered by the permitting regime. The control of noise through the planning regime by way of condition(s) will cover all the plant irrespective of whether or not they require a permit and continue, even if some or all of the plant were to become not subject to the control of a PPC Permit in the future.


It is essential that conditions are applied to cover noise arising from the operational phase, including plant and equipment and the emergency generator. Odour The applicant has provided further information and assessment on odour, which is satisfactory. In order to ensure that adequate odour controls measures are put in place and maintained during operation however, a condition requiring full details of the odour mitigation is required.

Lighting It is noted that a detailed lighting strategy will be prepared as part of the detailed design for the Energy Innovation Centre. A condition is therefore recommended to require the full details of any floodlighting and/or external lighting to be submitted for approval. There may be an issue for wildlife, biodiversity, night-sky and aircraft safety. It is therefore recommended that the Highways Authority, City Council’s biodiversity officer, and the City Airport and/or the Civil Aviation Authority are consulted on this matter including when it comes to the discharge of condition.

Waste Strategy No comments.


Appendix 3 - Plans Addenbrooke’s Composite Plan


EIC Site Plan


EIC Ground Floor Plan


EIC East and south elevations
