How and where to object to a power station at St Phillips

If you wish to register your objection to the planning application by Conrad Energy to locate gas fuelled generators in an area of Bristol which already has some of the worst air quality

in the region, this guide will help

OBJECTIONS MUST BE IN BY MONDAY 28 TH JANUARY

Follow this LINK to the comments page for application #18/05628/F

You will see this page:

 

Please note that when you submit an objection to this planning application on the Council’s website you will need to complete all of the fields marked with a * truthfully as this is a formal objection to the planning application, and we do not want to give Conrad Energy’s lawyers any ammunition for an appeal.

 

Model Objection to Planning Application:

18/05628/F – Standby gas generator plant and associated infrastructure.  Philip Street Scrapyard, St Philips, Bristol, BS2 0TA.

Plan-EL as the relevant Neighbourhood Planning Group has worked closely with RADE [Residents Against Dirty Energy], St Philips Marsh Nursery School, and drawn upon the expertise of Air Quality Consultants Ltd in reaching this conclusion.

Use as a guide for your own set of objections, or Cut & Paste the following text into the box ‘Your Comment:’

……………………………………………..

 

Summary

 

There is no reason for this speculative, opportunistic proposal for an 8-Megawatt Standby Gas-Powered Electricity Generation Plant to be built here, or indeed within an urban area. It does not contribute to the local area in any way. Indeed, it produces pollutants [Nitrous Oxides, and Noise] that are detrimental to the Clean Air objectives the City is struggling to achieve; is contrary to its objective of Carbon Neutrality, and undermines the One City vision that seeks to be the backbone of the Bristol’s future.

 

Further, that such a proposal is suggested only 70 meters from a Pupil Referral Unit, and 80 Meters from a Nursery school is simply unacceptable in the context of the current evolving Planning Guidance for the area.

 

Dealing with the key points of the proposed development

 

Short Term Operating Reserve [STOR]

 

A STOR unit is intended to produce electricity when the National Grid requires it because of a shortfall at peak times. Electricity produced at such times fetches a premium price for the producer [Conrad Energy]. Urban STOR Plants are more problematic than beneficial when the alternatives [e.g. Battery Storage], and pollutant effects are recognised.

 

Even the developer [Conrad Energy] is exploring Battery Storage as an option elsewhere. This alone undermines their argument that STOR is the only option to meet National Grid short-term demand peaks. Indeed, having one of the earliest Battery Arrays at Lockleaze, the city is well aware of the alternatives. In Australia, the new Tesla Battery STOR plant [fed by a wind farm] can kick in within 0.14 seconds, far faster than any gas-fuelled plant can start. In California, two gas-fuelled STOR plants are being replaced by a battery array.

 

IF Conrad Energy is correct, and the plant will tend only to be active evenings, and other peak times – this will coincide with many of the new neighbours arriving home from work. This will blight and make redevelopment of the area significantly harder, as who would willingly move to live beside a Power Station? The Power Station would blight the area, rather than assist its redevelopment.

 

 

Site & Planning Statement

 

The Developers Planning Statement barely mentions either St Philips Marsh Nursery School [80 meters from the site] or the Meriton Pupil Referral Unit for adolescents [70 meters from the site].

Conrad Energy’s site selection criteria [on their website] are abandoned in this application, replacing “over 100 meters” with “suitable separation distances….” as the Nursery School, and Meriton is closer than 100 meters.

Throughout the Planning Statement, the Draft Bristol Local Plan is represented as years from implementation, and the emphasis is on the ‘current’ situation. This ignores the fact that currently there is an escalating number of planning applications based on the Draft Local Plan and not the current planning guidance for the area. The Developers Agent [Alder King] are well aware of this as they are agents for some of the very planning applications that seek to exploit opportunities created by the Draft Local Plan – not least a large amount of student and private sale housing. If the Council is unable to resist planning applications based on its Draft Local Plan, it follows that strict adherence to the existing guidance can no longer apply. Therefore, the area cannot be deemed suitable for an Industrial Scale Electricity Generation Plant.

Air Quality Assessment

The Air Quality Assessment [AQA] is an attempt to model the real world to predict the effect of the proposed generator. A model is only that, a model, and this one does not take account of the known local changes that will affect wind & distribution patterns, for example, the tall buildings along the river bank, Feeder Canal, and new University Campus

The AQA recognises that the greatest risk from Nitrous Oxides [NOx] is to the ‘sensitive receptors’ at point ‘R1’. ‘R1’ is St Philips Marsh Nursery School, the ‘sensitive receptors’ are very young children, and the site lies within 15 meters of two ‘branches’ of the Air Quality Management Area [AQMA] within a local authority currently being required to reduce the levels of NOx by a Clean Air Zone or similar. The Clean Air Zone will quite likely cover the entire area. The Exhaust stacks proposed are only 7 meters high and probably inadequate even under this model.

In other words, by careful modelling that takes no account of the known local changes affecting the area, the NOx pollution that would affect the young children at the Nursery school is explained away. Simply increasing the height of the chimney from 7 to 12 meters in the recently revised design, will only disperse the pollutants over a wider area IF the higher chimney does not cool the gasses too much and cause them to ‘fall’ onto the surrounding area. A 5-meter higher sheet metal chimney in a river valley between two hills, where the already higher wind velocity will be speeded up by new taller buildings, will probably experience significant cooling. This cannot be modelled with any degree of accuracy without detailed knowledge of the new higher buildings that have yet to be built but will arrive within a few years. In short, higher chimneys may make the situation worse, because over cooled gasses from the chimneys may ‘dump’ pollutants even closer to the site. No-one can know – so is the risk to health acceptable, or should the precautionary principle of erring on the side of caution be applied for the sake of all the lungs in the city?

A more realistic assessment would recognise the extreme proximity of the Nursery School; a large number of new residential properties being built in the area, the changing airflow patterns from new developments; the lengths the City is going to reduce the levels of NOx; and draw the simple conclusion that this was the wrong development at the wrong time, in the wrong place.

CO2 Impact

The plant is projected to run for 2500 hours per annum. Gas Plants typically produce 549g of CO2 per hour. So three gas generators running for 2500 hours will add 4.12 tonnes of CO2 to the atmosphere each year.

Noise Assessment

The Noise Assessment takes no account of the known local changes that will affect the area within a short space of time, that is so extensive that it would be reasonable to take them into account.

The selection of sites to include in the Noise modelling conveniently ignores large developments proposed, e.g. at the corner of Feeder Road & Short Street [Application 18/04844/P], in terms favourable to the Developer.

Health Impact

The ward, Lawrence Hill, contains areas with the highest levels of breathing-related illness in the city. Barton Hill already suffers exceptionally high rates of COPD [Chronic Obstructive Pulmonary Disease]. The Council’s Public Health team should be asked to consider the medical impacts of this scheme.

It would not be unreasonable for the Council to obtain independent assessments of Air Quality and Noise taking into account all known developments and planning applications. Such an independent review would need to recognise that some of the closest ‘sensitive receptors’ are very young children of nursery school age.

For the reasons given the Planning Authority is urged to reject this planning application.

 

……………………………………………….

Finally, you should receive email confirmation that you have submitted a comment.

Summary:

 

There is no reason for this speculative, opportunistic proposal for an 8-Megawatt Standby Gas-Powered Electricity Generation Plant to be built here, or indeed within an urban area. It does not contribute to the local area in any way. Indeed, it produces pollutants [Nitrous Oxides, and Noise] that are detrimental to the Clean Air objectives the City is struggling to achieve; is contrary to its objective of Carbon Neutrality; and undermines the One City vision that seeks to be the backbone of the Bristol’s future.

 

Further, that such a proposal is suggested only 70 meters from a Pupil Referral Unit, and 80 Meters from a Nursery school is simply unacceptable in the context of the current evolving Planning Guidance for the area.

 

Dealing with the key points of the proposed development

 

Short Term Operating Reserve [STOR]

 

A STOR unit is intended to produce electricity when the National Grid requires it because of a shortfall at peak times. Electricity produced at such times fetches a premium price for the producer [Conrad Energy]. Urban STOR Plants are more problematic than beneficial when the alternatives [e.g. Battery Storage], and pollutant effects are recognised.

 

Even the developer [Conrad Energy] is exploring Battery Storage as an option elsewhere. This alone undermines their argument that STOR is the only option to meet National Grid short-term demand peaks. Indeed, having one of the earliest Battery Arrays at Lockleaze, the city is well aware of the alternatives. In Australia the new Tesla Battery STOR plant [fed by a wind farm] can kick in within 0.14 seconds, far faster than any gas-fuelled plant can start. In California two gas-fuelled STOR plants are being replaced by a battery array.

 

IF Conrad Energy is correct, and the plant will tend to only be active evenings, other peak times – this will coincide with many of the new neighbours arriving home from work. This will make redevelopment of the area significantly harder, as who would willingly move to live beside a Power Station? The Power Station would blight the area, rather than assist its redevelopment.

 

 

Site & Planning Statement

 

The Developers Planning Statement barely mentions either St Philips Marsh Nursery School [80 meters from the site] or the Meriton Pupil Referral Unit for adolescents [70 meters from the site].

Conrad Energy’s own site selection criteria [on their website] are abandoned in this application, replacing “over 100 meters” with “suitable separation distances….” as the Nursery School, and Meriton is closer than 100 meters.

Throughout the Planning Statement, the Draft Bristol Local Plan is represented as years from implementation, and the emphasis is on the ‘current’ situation. This ignores the fact that currently there is an escalating number of planning applications based on the Draft Local Plan and not the current planning guidance for the area. The Developers Agent [Alder King] are well aware of this as they are agents for some of the very planning applications that seek to exploit opportunities created by the Draft Local Plan – not least a large amount of student and private sale housing. If the Council is unable to resist planning applications based on its Draft Local Plan, it follows that strict adherence to the existing guidance can no longer apply. Therefore, the area cannot be deemed suitable for an Industrial Scale Electricity Generation Plant.

Air Quality Assessment

The Air Quality Assessment [AQA] is an attempt to model the real world to predict the effect of the proposed generator. A model is only that, a model, and this one does not take account of the known local changes that will affect wind & distribution patterns, for example, the tall buildings along the river bank, Feeder Canal, and new University Campus

The AQA recognises that the greatest risk from Nitrous Oxides [NOx] is to the ‘sensitive receptors’ at point ‘R1’. ‘R1’ is St Philips Marsh Nursery School, the ‘sensitive receptors’ are very young children, and the site lies within 15 meters of two ‘branches’ of the Air Quality Management Area [AQMA] within a local authority currently being required to reduce the levels of NOx by a Clean Air Zone or similar. The Clean Air Zone will quite likely cover the entire area. The Exhaust stacks proposed are only 7 meters high and probably inadequate even under this model.

In other words, by careful modelling that takes no account of the known local changes affecting the area, the NOx pollution that would affect the young children at the Nursery school is explained away. Simply increasing the height of the chimney from 7 to 12 meters in the recently revised design, will only disperse the pollutants over a wider area IF the higher chimney does not cool the gasses to much and cause them to ‘fall’ onto the surrounding area. A 5-meter higher sheet metal chimney in a river valley between two hills, where the already higher wind velocity will be speeded up by new taller buildings, will probably experience significant cooling. This cannot be modelled with any degree of accuracy without detailed knowledge of the new higher buildings that have yet to be built, but will arrive within a few years. In short, higher chimneys may make the situation worse, because over cooled gasses from the chimneys may ‘dump’ pollutants even closer to the site. No-one can really know – so is the risk to health acceptable, or should the precautionary principal of erring on the side of caution be applied for the sake of all the lungs in the city?

A more realistic assessment would recognise the extreme proximity of the Nursery School; the large number of new residential properties being built in the area, the changing airflow patterns from new developments; the lengths the City is going to reduce the levels of NOx; and draw the simple conclusion that this was the wrong development at the wrong time, in the wrong place.

Noise Assessment

The Noise Assessment takes no account of the known local changes that will affect the area within a short space of time, that is so extensive that it would be reasonable to take them into account.

The selection of sites to include in the Noise modelling conveniently ignores large developments proposed, e.g. at the corner of Feeder Road & Short Street [Application 18/04844/P], in terms favourable to the Developer.

It would not be unreasonable for the Council to obtain independent assessments of Air Quality and Noise taking into account all known developments and planning applications. Such an independent review would need to recognise that some of the closest ‘sensitive receptors’ are very young children of nursery school age.

For the reasons given the Planning Authority is urged to reject this planning application.

 

 

https://planningonline.bristol.gov.uk/online-applications/applicationDetails.do?activeTab=makeComment&keyVal=PH3Z7LDNN5000