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94Wembley Area Action Plan - Proposed Submission Version10 Response to climate changeStrategic Policy10.1 As the scientific understanding of climatechange and its likely impacts become clearer sincethe Kyoto protocol was drawn up in 1997 toimplement the United Nations FrameworkConvention for Climate Change,there have beenvarious international, EU, national, London andlocal climate mitigation targets set to tackle climatechange collectively. The NPPF acknowledges thatplanning plays a key role in helping shape placesto secure radical reductions in greenhouse gasemissions, minimising vulnerability and providingresilience to the impacts of climate change, andsupporting the delivery of renewable and lowcarbon energy and associated infrastructure.10.2 UK Climate Projections predict that summeraverage temperatures in London will, given a lowemissions scenario, rise by 1.6˚C over 30 yearsbetween 2010 and 2039, that summer rainfall willdecrease by 7% in 2020 and that winter rainfall willincrease by 6% in the same time period. The mainclimate change impacts on London will beoverheating (urban heat island effect), waterscarcity, increases in the frequency of flooding,severe weather events and more frequent heatwaves. Increasingly it is acknowledged that acertain level of climate change is inevitable anddevelopment will need to be built to cope with achanging climate.10.3 The London Plan sets out a comprehensiverange of policies to underpin London’s response toclimate change. It concludes that the effects ofclimate change could seriously harm Londoners’quality of life, particularly the health and social andeconomic welfare of vulnerable people. TheMayor’s Climate Change Mitigation and EnergyStrategy contains further proposals to reducecarbon dioxide emissions and to tackle climatechange through decarbonising London’s energysupply, reducing the energy consumption ofLondon’s existing building stock and movingtowards zero emission transport in London.10.4 Nearly all residential development will bewithin the Wembley Growth Area where majorresidential proposals are required to achieve aminimum rating of Code for Sustainable HomesLevel 4 in line with policy CP19 of Brent CoreStrategy. A rating of BREEAM “Excellent” isexpected for major non-residential developments.Policy Context10.5 Wembley AAP covers a diverse mix ofresidential, industrial, shopping, leisure,entertainment, community and office land uses infragmented land ownership, such that the areapresents challenges when trying to achieve social,economic and environmental sustainability. Thereare mechanisms to reduce carbon emissions fromnew developments in Wembley through the LondonPlan, UDP and LDF planning polices, buildingregulations and other initiatives. The first step inreducing carbon emissions from development inWembley is to ensure new development uses lessenergy in line with the Mayor’s energy hierarchy to“be lean, be clean and be green."10.6 Climate change will have a significant impacton the economic, social and environmental wellbeing of Wembley. Hotter summers will have abigger impact in Wembley because of thepredominance of concrete and buildings. Heatwaves will mean more people are likely to sufferfrom illnesses and could also lead to damage toroads, railways and buildings. Heavy thunderstormsand intense winter downpours will become morecommon, and will lead to flash flooding where thedrainage system cannot cope with the increasedrainfall. It is therefore crucial that futuredevelopment in Wembley addresses these impactsand limits its contribution to climate change byminimising carbon emissions.10.7 Specific issues for Wembley include thelegacy of industrial use in the area which led to alack of green and ‘cool’ spaces. Much of Wembleyis deficient in open space and there are few maturetrees. Land adjacent to the Wealdstone Brook ismost at risk of flooding, although much of Wembleyis also prone to surface water flooding. In addition,the majority of the sewer network in the Wembleyarea is undersized.The whole of the AAP area isan Air Quality Management Area (AQMA). Anyproposals for new development will have to complywith London Plan policy 7.14: Improving Air Qualitywhich seeks to minimise increased exposure toexisting poor air quality and make provision toaddress local problems of air quality, particularlywithin AQMAs.
Wembley Area Action Plan - Proposed Submission Version95Response to climate change 10Climate Change MitigationDecentralised Energy10.8 Under policy 5.5 of the London Plan, theMayor expects 25 per cent of the heat and powerused in London to be generated through the useof localised decentralised energy systems by 2025.Currently schemes coming forward are proposingsite-wide combined heat and power (CHP)solutions, however greater efficiencies could beachieved if a wider Wembley network wasestablished. This would need to overcome barriersof connecting different sites to one another andfinding a site for a single energy centre. There isa significant financial risk in pursuing a singleenergy centre solution for Wembley and this wouldrequire substantial viability testing. It is consideredmore appropriate to ensure developments withinWembley are network ready by installing theappropriate infrastructure to connect to any futuredistrict energy network should it be forthcoming inthe future.WEM 32Decentralised EnergyMajor developments will be expected toconnect to or contribute towards adecentralised energy system unless it can bedemonstrated that such provision is notfeasible or the proposed heating system is100% renewable. Developments completedprior to the implementation of the energycentre should be designed so that they canswitch to the energy centre once it isavailable. Decentralised energy systemsincorporating energy from waste will besupported.Energy from Waste10.9 The London Plan supports possibledecentralised energy opportunities to utilise energyfrom waste. The EU Waste Framework Directiveclearly ranks the ‘waste hierarchy’. Prevention,which offers the best outcomes for the environment,is at the top of the priority order, followed bypreparing for re-use, recycling, other recovery anddisposal, in descending order of environmentalpreference. Brent will continue to support initiativesto reduce waste generated. CP19 of Brent CoreStrategy requires major proposals to submit aSustainability Statement that include the indicationof reusing recycled aggregates and constructionmaterials. Good progress is being made to recyclemore in Brent; however, there is still some left overwaste, known as ‘residual waste’, which cannot berecycled and is currently disposed of to landfill.Waste to energy (in the form of electricity and/orheat) or energy from waste conversion is anincreasingly recognised approach to resolving twoissues in one - waste management and sustainableenergy. Facilities to recover energy from wasteparticularly if combined with heat recovery for adecentralised energy network to provide heat toresidential, commercial and community units inWembley will make Wembley self-sufficient. Thereare a number of new and emerging technologiesthat are able to produce energy from waste withoutdirect combustion. Any proposed technologies mustnot pose a threat to human health or theenvironment. A high standard design of the buildingand chimney stack must be achieved.WEM 33Energy from WasteMajor energy from waste facilities will beallowed only in the area east of Fourth Way.Environmental impact assessments and healthimpact assessments will be required toaccompany the planning applications for suchfacilities which also have to deliver high qualitydesign. Small scale proposals to recoverenergy from waste generated locally will besupported providing there will be nodetrimental impact on human health and noincrease in pollution emissions andgreenhouse gases and the environmentalimpacts from vehicular movements areacceptable.
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