Construction and Environmental Management Plan

UL

April 2020

Draft Construction Environmental Management Plan

DRAFT CONSTRUCTION ENVIRONMENTAL MANAGEMENT PLAN

PROJECT NO. 02851

PROJECT NAME: RAYNERS LANE STATION

CLIENT: CATALYST HOUSING LTD & TRANSPORT FOR

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Issue Page(s) Revision Description Prepared Reviewed Authorised 00 All Whole document SB PT NE

Registered Copy* * If no “Registered Copy/Holder” is entered in box or registered number/name is in black then the document is uncontrolled and therefore not subject to automatic updating. Before using an uncontrolled document, refer to the United Living Intranet to establish its status and then obtain an updated issue as necessary.

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Contents

1 INTRODUCTION General Proposed Development Objectives Structure of the CEMP

2 BASELINE Introduction Site location Existing and proposed land use Existing site access Public transport Cycle access Ecology Trees Ground conditions

3 CONSTRUCTION PLAN General Construction Programme and Sequence Enabling works Construction works

4 IMPACT MITIGATION General Management structure Good Neighbour Policy Supply chain Systems and policies CEMP Monitoring

5 SITE SPECIFIC CONTROLS AND ARRANGEMENTS General Traffic management and control Construction site logistics Site arrangements Strategic plant Ecological impact mitigation

Appendices Appendix A. Existing, proposed and site constraints plans Appendix B. Noise, vibration and air quality control procedures. Appendix C. Strategic Road Network and traffic routing proposals Appendix D. Site Logistics Plan Appendix E. Response to Ecological Impact Assessment

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1 Introduction GENERAL

1.1 United Living (South) Ltd has compiled this Construction and Environmental Management Plan in support of the Catalyst Housing Ltd (CHL) planning application for the development of land adjacent to Rayners Lane Station for the construction of 128 residential apartments and a replacement commuter car park.

1.2 The Local Planning Authority and Highway Authority is the London Borough of Harrow (LBH).

1.3 The proposed Site is currently occupied by a 251-space car park bounded by Rayners Lane Station and embankment to the north, High Worple to the south, Rayners Lane Station and shops to the east and encompasses SINC woodland to the west.

PROPOSED DEVELOPMENT

1.4 The proposed comprises 'The proposed comprises four blocks, with one at five storeys and the others at part five part six storeys. The scheme will re-provide 75 commuter car parking spaces including 6no. Wheelchair Accessible bays. The proposed residential development is car free, with the exception of the accessible parking which is being provided in line with the London Plan.

1.5 A site location plan, proposed site development and constraints plans can be found at Appendix A.

OBJECTIVES

1.6 The focus of this CEMP is to address the construction principles that will be employed at the Site and set out mitigation measures that will be utilised to manage the impact of construction on local residents, the surrounding community and the local highway network.

1.7 The CEMP has taken into consideration:

• The Control of Pollution Act 1972 • The Health & Safety at Work Act 1974 • The Environmental Protection Act 1990 • The Clean Air Act 1993 • The Harrow Sustainability Appraisal, 2013 • BS 5228-1:2009+A1:2014 Code of practice for noise and vibration control on construction and open sites

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• Mayor of London SPG “The control of dust and emissions during construction and demolition”, 2014 • Construction (Design and Management) Regulations, 2015 • Non-Road Mobile Machinery (NRMM) Practical Guide, 2017 • Transport for London (TfL) Construction Logistics Plan Guidance, 2017 • The Mayors Transport Strategy, 2018 • The IP London Plan, 2019 • 2019 Construction Logistic Planning Guidance

STRUCTURE OF THE CEMP

1.8 This CEMP is structured as follows:

• Section 2: Baseline Conditions - Outlines the existing Site and the surrounding area’s transport and environmental characteristics; • Section 3: Development Proposals - Provides an overview of the Proposed Development, the construction scheme overview, the construction programme; and details of core working hours • Section 4: Construction Site Logistics Plan - describes equipment, layout and controls proposed for the development, including site arrangements and facilities, vehicular access routes, loading and unloading arrangements including strategic plant provision, and traffic management assessment and procedures. • Section 5: Impact Mitigation - Sets out the mitigation measures that will be employed, prior to, and during construction to minimise the impact of construction on local residents, businesses, the local highway network and existing biodiversity and ecology.

1.9 All appendices (A to E) are included at the end of this report.

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2 Baseline INTRODUCTION

2.1 This section provides information on the existing Site and the surrounding area, including local transport infrastructure, site conditions and surroundings. The baseline conditions establish the context of the CEMP.

SITE LOCATION 2.2 Figures 2.1 shows the location of the Site (and the red line boundary)which is in Rayners Lane Station car park in the London Borough of Harrow. The Site is ‘landlocked’ with a single access and egress point off High Worple at the south-east corner of the site. The northern boundary is formed by the railway embankment, tracks and station platforms serving the Piccadilly and Metropolitan lines. The station building and a parade of shops are on the eastern flank. A Site of Interest for Nature and Conservation (SINC) is located on the western boundary within the proposed red line, with the rear gardens of residential property on High Worple marking the southern edge of the plot.

Figure 2.1 Site location plan (c1:2500)

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EXISTING AND PROPOSED LAND USE 2.3 The Site is currently in use as a 251-space public car park, serving the station. There is an extensive TfL maintenance / infrastructure protection zone along the northern boundary. There is a UKPN substation on the southern boundary, accessed via High Worple. Further investigation is required to establish whether any cables from this asset traverse the site, although early investigations suggest not. An existing 875 mm diameter Thames Water surface water which runs below the footprint of Core D is likely to require diversion. There is also a surface water connection to the Smarts Brook culvert in the adjacent SINC which is noted as needing repair or upgrade. Further survey work is required to define both elements, and It is suggested these should be secured and executed as an enabling package ahead of the main construction works.

2.4 The proposed project is for the design and construction of 128 dwellings (Class C3) in 2 blocks. The larger of the blocks is sub-divided into three conjoined zones designated Cores A, B and C (running east to west). Core D is remote from Core A, B and C; separated by the TfL lifting zone. Core A houses a new substation and each block has dedicated cycle parking and refuse stores. The proposed development is planned as car-free with residential parking limited to blue badge holders only. Upon completion, the car parking spaces will be returned to public use. A new TfL cycle hub, offering 92 public cycle spaces, is below Core A, nearest to the station, in part compensating for the net loss of car parking space. Associated works include amenity space (communal garden / play area) and hard and soft landscaping.

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EXISTING SITE ACCESS Vehicle Access and Highway Network 2.5 There is a single access and egress point off High Worple shared with TfL. High Worple leads onto Alexandra Avenue / Imperial Drive, the A4090, which in turn connects into the strategic road network.

2.6 The local highway network, with key roads labelled, is provided in Figure 2.4. Proposed delivery routes to site beyond the local network are identified in Appendix C.

Figure 2.4: Local Highway Network

PUBLIC TRANSPORT 2.7 The site is very well served by public transport, achieving a PTAL score of 4.

Bus 2.8 Six stops serving four routes linking to Ruislip, Northwick Park, Harrow and Stanmore are located within approximately 400m of the site. Stop locations and frequency of service are presented in Figure 2.5 (extract from WSP Transport Assessment).

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Figure 2.5: Bus stop locations and service frequency - Rayners Lane

Rail 2.9 The site is within 200m of Rayners Lane Station, served by the Metropolitan and Piccadilly lines. Overground connections from Harrow on the Hill Station, serving Marylebone to Gerrards Cross, connect via bus or the both being within 10 minutes travel time.

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Figure 2.6: Rayners Lane – LUL train frequency (Ex WSP Transport Assessment)

CYCLING ACCESS 2.10. The site is less well served by the cycle network, although there are dedicated local cycle lanes connecting the majority of the routes between the over-ground stations at Harrow on the Hill, Northwick Park and Harrow and Wealdstone with Rayners Lane (Figure 2.7 below).

Figure 2.7: Designated cycle routes

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ECOLOGY 2.11 Midddlemarch Environmental Ltd Ecological Impact assessment that has been produced sets out the detailed ecological factors encountered on site along with further works: The works will be carried out in full accordance with the recommendations and where required a qualified ecologist will be appointed to attend site when works are taking place that have the potential to impact the existing site ecology. In particular the drainage works through the SINC area will be very carefully monitored and works will progress under the supervision of the qualified ecologist.

TREES 2.12 An Arboricultural Report provided by Middlemarch Environmental Ltd includes a Tree Survey Plan that identifies constraints to the development presented by the trees. This identifies root protection areas for retained trees as described in BS5837:2012 The works will be carried out in accordance with the requirements and specifications as set out within the above report.

GROUND CONDITIONS

2.13 A ground investigation report has been issued by GEA, which states that: • The site surfacing comprised a rough tarmac underlain locally by a granular sub-base, with thicknesses of between 100 mm and 300 mm encountered. • Made ground was encountered to depths of between 0.70 m and 1.40 m and generally comprised black, brown and dark grey silty clay and silty sandy gravel with variable inclusions of brick, concrete, clinker, ash, metal and coal. Below the made ground, the London Clay locally initially comprised a re-worked horizon of soft to firm bluish grey silty slightly sandy clay or silt with fine to medium gravel to depths of between 1.50 m and 2.00 m. • The London Clay extended to depths of between 2.70 m and 5.70 m, whereupon the basal beds of the formation, known as the Harwich Formation, were encountered to depths of 7.40 m and 8.20 m. • The Lambeth Group initially comprised the Lower Mottled Clay of the Reading Formation, to a depth of 17.30 m, whereupon the soils of the Upnor Formation were encountered, which extended to the maximum depth investigated, of 20.00 m. • Groundwater inflows were encountered in the Harwich Formation and underlying Lambeth Group at depths of between 6.00 m and 17.30 m, whilst shallow seepages were encountered in Borehole Nos 5 and 8 at depths of 1.00 m and 1.50 m in the made ground and London Clay respectively.

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• The results of contamination testing have indicated the samples of made ground tested to contain elevated concentrations of lead, PAH, TPH and sulphide. The findings suggest that piles are the most appropriate foundation solution. Piling design has yet to be carried out but pile diameters are expected to be 450mm and up to 24m deep.

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3 CONSTRUCTION PLAN GENERAL

3.1 The proposed programme for the construction of the development is outlined and examined in this section.

CONSTRUCTION PROGRAMME AND SEQUENCE

3.2 Commencement of the main works on site, subject to all consents and procurement approvals being in place, is currently anticipated to be in mid-February 2021 with a forecast completion by February 2023. The overall duration is 104 calendar weeks. The main works are preceded by a set of enabling activities.

There is currently no plan for phased occupation. The sequence of the works is planned to commence from Core D, working out from the back of the site progressing west to east.

Key dates are as follows:

Activity Wk Nr Start Wk Nr Finish Site set up and hoarding 1 4 Substructure and drainage 4 48 Superstructure 14 70 Envelope 24 86 Fitting out 33 95 Testing and commissioning 56 98 Externals and landscaping 53 104 Block completion Block A 73 Block B 104

3.3 There are no existing buildings to demolish on the site; it is assumed existing car park equipment and infrastructure will be removed towards the end of the enabling period.

ENABLING WORKS

3.4 There is an opportunity in the time frame between planning award and procurement of the construction works to reduce the risk profile of the project in terms of time, cost and environmental impact. This can be achieved by undertaking a series of facilitating activities including site preparation, services diversions, further site investigations and further stakeholder engagement.

Site Preparation 3.5 Any tree removal activity should be undertaken during this period, ensuring that works are completed ahead of the nesting season. Notice will need to be given to LBH six weeks in advance of the planned activity.

Services 3.6 Further survey and investigation has been recommended in relation to repair of the outfall running towards the Smarts Brook culvert and the need for diversion of the existing 875mm diameter surface water sewer. Expediting both items ahead of the main works will reduce the risk of run off from the site entering the culvert; and will avoid possible programme prolongation resulting from incorporation of these activities into the construction works.

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3.7 An application/order for a temporary builders supply should be made in the enabling phase so that site work is able to commence with a source of clean power thereby eliminating a source of risk from noise, fuel storage and diesel emissions associated with temporary generation. The existing substation to the rear of No 17 High Worple would seem to offer a likely power source, subject to consultation with UKPN.

Soil and ground investigations 3.8 The ground investigation report has identified elevated levels of PAH, TPH and sulphide in addition to asbestos fibres within the sample tests that have been undertaken. This would potentially result in soils removed from the site being classified as hazardous, with the need for segregation and extensive temporary stock piling required prior to safe disposal. Although manageable this is not the lowest risk solution given the proximity of the Smarts Brook culvert. A preferable approach would be to leave potentially contaminated soils undisturbed and capped/contained below hard landscaping areas as far as is reasonably practicable, minimising the risk disturbance, exposure and cross contamination. In order to minimise or better define the scope of any remediation measures required, further ground investigations should be undertaken to establish the full extent and nature of contamination within the existing soils.

Permits, approvals and licences 3.9 Detailed discussions will be undertaken with the respective responsible licencing authorities in order to advance the application process for permits required to carry out the site works. Unusually it is unlikely that hoarding and crossover licences will be required. Relevant consultees and authorities include:

• London Borough of Harrow Environment and Parks o Tree removal • London Borough of Harrow Planning and Development o Planning submissions and procedural approvals • London Borough of Harrow Traffic, Highways & Asset Management Service o Traffic management and control • TfL/LUL o Approval of construction methodology (in accordance with TfL London Underground Guidance Document G0023 - Infrastructure Protection - Special Conditions for Outside Parties Working On or Near the Railway) • Fire services • Police

Stakeholder consultation 3.10 This period will also be used to continue consultations with stakeholders; to begin familiarisation with, provide information to and take soundings from local residents, neighbours and organisations about the construction process and to introduce construction team. Aims and objections 3.11 The objective by the end of the enabling period is to have established conditions whereby potential construction impacts are minimised by addressing neighbour concerns, ensuring correct approval protocols are in place and where possible the risk profile of construction operations is reduced.

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CONSTRUCTION WORKS

Ground works 3.11 Ground works consist of removal of the existing car park surface; piling, reduced levels excavation and removal of unsuitable spoil, pile caps and ground floor slabs; internal and external drainage and external services trenching. As noted the foundations have been designed as piles. The final design and installation method will need to minimise noise and vibration generation respecting the needs of local residents and the sensitivity of adjacent railway operations. Continuous flight augured (CFA) piles are expected to be selected. Connection details to utilities have yet to be developed.

Superstructure and envelope 3.12 The apartment blocks are designed as reinforced concrete frames,. Cladding is traditional brick (anticipated as hand set) over a steel framing system. The sheathing layer over the SFS will a fire rated board. Balcony balustrades are in metalwork. Windows are composite aluminium, currently specified as triple glazed. Roofing systems are bio-diverse.

Fitting out 3.13 Internal finishes will typically be lightweight dry lined partitions. A variety of floor finishes are anticipated including vinyl, carpet, laminated timer or ceramics depending on usage. The heating is underfloor using central air source heat pumps via an ambient loop or HIU system.

Landscaping 3.14 The external and landscaping works includes a communal garden / play area a the west end of the site, cycle storage, car parking, hard and soft landscaping and some reconfiguration of the entrance road. These will be completed during the final construction stages.

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4 Impact Mitigation GENERAL

4.1 This section of the CEMP sets out mitigation measures and general procedures that will be employed during construction to minimise the impact of construction on the local residents, neighbouring occupiers, the local highway network and local ecology.

MANAGEMENT STRUCTURE

4.2 The site construction team will include specialist personnel who will appointed to take control of and manage key responsibilities described within this CEMP. The Project Manager retains overall accountability but will appoint dedicated personnel for this project in the roles of Logistics Manager and Community Liaison Officer. Specialist consultants for design and environmental monitoring amongst other disciplines will also be appointed to act for the contractor. The Project Manager will also be supported by the Company’s Health, Safety and Environmental Management department.

4.3 United Living South is registered with the Considerate Contractors Scheme and this project will be tasked with maintaining and surpassing company’s scoring record within the scheme

4.4 Site contact details and out of hours emergency contact details will be prominently displayed on site hoardings. Daily inspections will be undertaken in the vicinity of the site and on footways to check for potential hazards (including blocked footways and the build-up of rubbish).

4.5 Contact details are as follows:

Principal Contractor: TBA

Senior Project Manager: TBC

Health and Safety Advisor TBA

Other team members will be added to the contacts list as they are appointed

4.6 The Logistics Manager for the project will undertake the transport co-ordination and operate the delivery management system (DMS) for the project.

4.7 The Project Manager will be accountable for stakeholder relations but will be assisted by and his construction management team and the Community Liaison Officer in keeping neighbours and local organisations informed of the construction progress.

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GOOD NEIGHBOUR POLICY

4.8 Effective communication will be essential to maintaining good neighbourly relations throughout the works, and the PM and CLO will ensure that the adjacent community remains informed of progress, future activities and have opportunities to discuss their concerns directly with team.

4.9 Methods of communication will be varied and will include:

• Attendance at local meetings (when required) to explain progress, future activities any potential effects, and opportunity for any questions to be answered • Newsletters • Information boards • Viewing apertures to perimeter hoarding, providing local residents with a safe means of seeing the construction works progress • Copies of CCS audit reports

4.10 There may be a need for separate consultation or meetings arranged for particular neighbours or local organisations who may have specific concerns.

SUPPLY CHAIN

4.12 It will be mandatory for subcontractors, suppliers and consultants engaged on the Project to implement relevant elements of the CEMP into their activities and processes.

4.13 The supplier selection process will consider an organisation’s resources, ability and track record in compliance with requirements of the CEMP

SYSTEMS AND POLICIES

Noise and vibration control 4.14 United Living South Ltd procedures for control of noise, dust and vibration are attached at Appendix B.

4.15 Best Practicable Means, as defined in Section 72 of the Control of Pollution Act 1974, will be employed at all times to reduce and control noise and vibration.

4.16 The quietest / lowest impact processes that are reasonably practicable will be employed on site to carry out the construction works. Other measures to be implemented to minimise noise are:

• No construction works, without prior approval from the LBH, will take place outside the hours of 08:00-18:00 Monday to Friday and 08:00-13:00 Saturday; • The quietest vehicles and plant shall be used as far as is reasonably practicable; • Voices and conversation around the site perimeter to a minimum and low in volume; • No banging of doors, gates, scaffolding, or other objects; • No machinery starting up on site before the designated start times; • Locating plant, equipment, storage areas and worksites away from neighbouring properties, where reasonable practicable; • Machines and equipment in intermittent use will be shut down or throttled down to a minimum when not in use; • The use of site hoardings or portable acoustic enclosures/screens, where practicable; • Fixed items of construction machinery will be electrically powered rather than powered by diesel or petrol (where feasible and subject provision of a temporary builders supply);

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• The use of noise reducing shrouds during piling operations; and • Maintaining and operating all vehicles, plant and equipment in an appropriate manner, to ensure that extraneous noise from mechanical vibration, creaking and squeaking is kept to a minimum. • No engines left running on vehicles unloading/loading on site; • Construction personnel carefully placing waste into the skip / vehicles when loading; • Using low impact and low volume machinery and tools where possible; and • Local residents will be advised of the start and finishing dates/times of particularly noisy works (e.g. piling). These activities will be timed where possible to minimise the disruption to local residents.

4.17 Noise and vibration monitoring will be carried out at the site during construction activity. In the event that a complaint or concern is raised by a local resident, an immediate review will be carried out to establish the degree of noise created and to establish how to best develop a solution.

Air pollution, dust and dirt control. 4.18 The control of dust is a prime concern for all construction projects, particularly during periods of dry and windy weather. Best practice guidance contained within the Greater London Authority’s ‘The Control of Dust and Emissions from Construction and Demolition’ and ‘Dust and Air Mitigation Measures’ guidance provided by the Institute for Air Quality Management will be utilised to control dust.

4.19 A potential source of nuisance at Rayners Lane will be dust generated by traffic operating on unmade surfaces. The site will require a lengthy temporary road for delivery access and vehicle turning. Subject to service run locations and programme constraints the existing tarmac surface will be retained for as long as possible and maintained in a clean condition. If it is not possible to retain the existing surface, the permanent road construction will be brought forward formation level and temporarily capped. Temporary road surfaces will be treated with dust suppressants.

4.20 Dust emissions will be monitored visually throughout working hours. If dust is observed either in the air or deposited on vehicles or other sensitive receptors, works will be suspended and working practice reviewed to determine a method to prevent the issue reoccurring.

4.21 Dust generating activities will be minimised and carried out a safe distance from adjoining properties and site boundaries. Where possible, dust generating activities will be undertaken off- site. Power tools used in dust-generating activities will be fitted with vacuum bags to minimise dust.

4.22 Machinery exhaust emissions will be kept as low as is practicable by using well maintained vehicles and machinery at all times. All on-road vehicles accessing the site will comply with the requirements of the London Low Emission Zone.

4.23 Mud and debris on the road is regarded as one of the main environmental nuisances and safety problems arising from construction sites. All vehicles removing spoil from the site will be fully sheeted to minimise the risk of any mud over spilling onto the highway.

4.24 The Logistics Manager will undertake daily inspections of the site and the roads surrounding the site to ensure that dust control measures are complied with. The LM will also record and respond to all dust and air quality pollutant emissions complaints and will maintain a log of any complaints and any action taken to resolve the issues.

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Storage of materials 4.25 Policies and procedures for the storage and handling of materials on-site will include: • Providing dedicated material storage areas and suitable containers and covers that prevent / minimize the risk of contamination from spilled materials, e.g. placement of covered containers on hardstanding as well as prevent damage or loss through exposure to the elements; • All liquids and solids of a potentially hazardous nature (for example, diesels, oils and solvents) will be stored in appropriate bunds over hard standing areas to prevent leakage to the ground and water regime, in compliance with legislation, Environment Agency standards and best practice; • A ‘Just in time’ delivery regime and effective co-ordination between contractors and suppliers to prevent materials being spoiled, lost and / or wasted • Fuel storage for site plant and equipment will be held in double bunded containers with spill kits allocated to each location.

Waste management 4.26 The project team will issue a project waste management plan prior to commencement. This sets out procedures including: • Responsibilities • Method/Implementation • Site Waste Management Plan • Identification and Storage • Hazardous Waste • Inspection • Waste Minimisation • Waste Transfer • Waste Carriers and Waste Disposal Sites • On Site Processing of Waste • Waste Monitoring • Sub-Contractors Waste • Restrictions • Records • Documentation • References • Definitions • Controlled Waste • Hazardous Waste

4.27 All contractors working on the site will be required to minimise waste at source and maximise recycling and re-use of demolition and construction materials wherever possible and practicable; such arisings will be dealt with in a manner that reduces environmental effects and maximises potential re-use of materials.

4.28 All wastes that cannot be reused or recycled, including contaminated soils and materials, will be disposed of in accordance with legislation and best practice. All waste materials will be collected and stored in suitable receptacles before they are taken off site. Waste materials will not be allowed to accumulate because of the fire/vermin risk.

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4.29 Where space permits waste will be segregated on site, in accordance with LBH Sustainability Appraisal (2013). As a minimum soils, masonry waste and plasterboard will be segregated on site. General waste is most likely to be sorted and segregated off site. The supply chain will include specialist waste carriers that provide services off site to separate waste into materials that can be recycled and who then deal with the segregated waste appropriately.

4.30 The control and handling of any contaminated materials will also be carried out in accordance with the relevant legislation. ACMs which have been found in soils samples will be screened, segregated and removed by an appropriately licensed contractor in accordance with the Control of Asbestos Regulations 2006.

4.31 Whenever deliveries are undertaken, traffic marshals will be used to ensure that no dirt or rubbish is left on the highway.

Prevention of water pollution - run off and de-watering 4.32 The Site Manager will ensure that consultation with the local sewerage undertakers and the relevant environmental agencies has been undertaken to ensure that all necessary permissions / discharge consents are obtained prior to discharge of water from site.

4.33 To ensure contamination does not arise all fuel bowsers will be bunded to 110% of their capacity; all re-fuelling will be undertaken at a designated location on site and services of mobile plant will only be permitted on site in exceptional circumstances. Refer to procedure UL-EMS-PRO-5009, ‘Water Management’ for further guidance regarding the prevention of water pollution

Safety and environmental management plans 4.34 Management plans will be set out to formalise procedures for the safe execution of the works and environmental protection of the site.

Emergency response plans 4.35 Emergency Response Plans shall be completed by the Project Manager, as required. These plans shall be reviewed on a 6 monthly basis, and may include:

• Emergency Response Plan • Environmental • Collapse of Tower crane • Collapse of Structure • Overturning of Excavator, Piling Rig & other Plant • Recovery of Injured Person from • Tower Crane, Mast Climber and Cantilever Platform • Collapse of Scaffold Platform • Collapse of Mobile Crane • Collapse of Excavation • Recovery from Confined Space Incident • Emergency Evacuation (Gas Leak, UXB) • Suspected Release of Asbestos Fibres

CEMP MONITORING

4.36 The CEMP together with other strategic documents will be regularly monitored reviewed and updated as the project develops

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4.37 The environmental management plan will framed against objectives and targets and will detail: • Responsibilities • Method/Implementation • Establishing Objectives and Targets • Documenting Objectives and Targets • Monitoring Objectives and Targets • Reviewing Objectives and Targets • Specific recording and monitoring regimes will be established for: o Energy consumption, CO2 emissions, and water consumption as a result of the use of construction plant, equipment (mobile and fixed) and site accommodation.

Environmental Incident & Complaint Notification 4.38 All environmental complaints and incidents will be documented and recorded on ULS’s Active SHEQ online system, in accordance with United Living Environmental Accident, Incident Emergency Procedure by the Site Manager. The Site Manager will communicate the complaint or incident to the Operations Manager and the Environmental Advisor. Refer to procedure UL-EMS-PRO-5004, ‘Environmental Complaints’ for guidance regarding the receipt and review of environmental complaints.

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5 SITE SPECIFIC CONTROLS AND ARRANGEMENTS GENERAL

5.1 The most significant potential environmental impacts from the development are:

• Traffic noise and disturbance to local residents • Additional traffic volumes creating congestion leading to: o Increased road hazards o Harmful emissions • Conflict with other road users, pedestrians and cyclists, with particular note of the intersection between the A4090, High Worple and the site entrance • Alteration to / impacts on the local habitat / ecology. • Increased potential for environmental hazards including air quality impacts from emissions and dust.

Adherence to the management plans and procedures outlined in section 4 above will mitigate potential nuisance from construction generated noise, emissions and waste. The physical measures and management controls outlined below reinforce general procedures and will provide specific risk mitigation for the most prominent impacts.

TRAFFIC MANAGEMENT AND CONTROL

5.2 The traffic management and logistics plan is a key component of the management control documents and vitally important to the Rayners Lane development.

5.3 The traffic management plan sets out to regulate the increased traffic volumes which are the inevitable consequence of a major construction project and mitigate their impact on the local environment. Key components are: • Directives to ensure construction traffic is routed wherever possible, to avoid residential and other sensitive urban zones • Planning and regulation of supply to avoid congestion through the use of a delivery management system • Formulation of a construction site travel plan to reduce traffic volumes from commuting construction personnel • Use of appropriate systems and equipment to speed up dwell times • Gate and security control • Compliance monitoring and management The proposals for Rayners Lane are explained below.

Construction Logistics and Cyclist Safety (CLOCS) 5.4 United Living will ensure that all contractors and fleet operators at the site sign up to the CLOCS standards for managing WRRR. All vehicles over 3.5 tonnes accessing the site will be required to have the vulnerable road user safety kit, and membership of the FORs scheme to Silver standard will be a requirement

5.5 The Logistics manager and his team of traffic marshals will undertake checks of vehicles accessing the site. In the event that a vehicle arrives at the site and is not fitted with the above safety kit then the vehicle may be refused entry and a non-conformance report completed.

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Construction traffic routing 5.6 Construction traffic routing on the strategic road network (SRN) is shown in Figure 5.1 below.

Figure 5.1 Construction traffic routing

5.8 All suppliers will be issued with routing instructions to the site confirming the requirement to use the SRN

5.9 Use of the agreed vehicle routes will be included as a contractual requirement to all haulage or delivery firms employed on the site. This communicated at pre start meetings with the company and traffic rules will be issued at the gates to reinforce the requirement to drivers. The delivery management system will also issue routing instructions

5.10 Non-compliance is monitored through the system e.g. unscheduled deliveries arriving without notice, disregard for site rules etc will result in vehicle being turned away and other penalties applied through the contract.

Delivery management system (DMS) 5.11 All deliveries will be controlled by a strict delivery booking system which will distribute deliveries across the week and across working hours. Deliveries will not be accepted outside of their designated time-slot, and such deliveries will be asked to re-book. Unless there is capacity to accommodate within the specified loading area, unplanned deliveries will be turned away and advised to return to the site at a pre-arranged delivery time. Unplanned deliveries will not be permitted to wait at any location on the local highway network in the vicinity of the Site.

5.12 If, due to unforeseen circumstances such as plant break down or adverse weather, a vehicle cannot be unloaded, it will be directed to a designated holding location to await call forward. Holding location options for Rayners Lane include Heston Services (15 miles), Services (15 miles) or London Gateway Services (14 miles). Each offers similar round trip journey times to site

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5.13 On a weekly basis the Logistics Manager will evaluate details of the daily profile of deliveries proposed for the upcoming week, including the proposed unloading method and specific location Hauliers will be required to contact the site on a daily basis and indicate their delivery schedule for the following day. The proposed deliveries will be checked against the weekly delivery schedule. When planning deliveries the following will be considered:

• All deliveries to the Site will be restricted to the timings set out within this document; • Deliveries will be permitted only in the specified loading areas; • A policy to stagger deliveries will be employed to avoid vehicles queuing or waiting on the local highway network in the vicinity of the Site; and • Material storage areas will be prepared on-site in advance of deliveries to minimise loading and unloading times.

5.14 All deliveries to the site will be organised to take place between the hours of 08:00-18:00, Monday to Friday and 08:00-13:00 Saturday. Where feasible ULS will minimise deliveries during the peak hours (08:00-09:00 and 16:00-1800).

5.15 Sufficient time will be given between deliveries to allow for any delays as a result of the delivery vehicle getting stuck in traffic or the loading / unloading taking longer than expected and to avoid any vehicles waiting on the surrounding highway network.

Construction travel plan 5.16 The peak workforce engaged on site is estimated to be up to 250 personnel. In order to reduce the impact of the numbers of construction personnel commuting, parking on site, except for essential maintenance / servicing vehicles will be prohibited.

5.17 The site is well served by public transport. Rayners Lane underground station is within easy walking distance and buses stop in close proximity to the site (see figures 2.5 and 2.6 in Section 2 above).

The use of public transport and or cycling will be encouraged. The site will publish a construction travel plan which will include the following measures:

• Local public transport timetables and route maps, displayed within the on-site facilities; • Provision of the right facilities for changing, showering and drying within the site welfare set up, for those who elect to walk or cycle; • Provision of a safe and secure storage area for bicycles within the construction site compound; • Promotion of local recruitment and employment of local companies

5.18 Monitoring of work force travel arrangements is carried out via the access control system, which records home locations for each site attendee. This is used to monitor CO2 emissions resulting from travel.

Gate control and compliance 5.19 Traffic marshals will be employed both at the entrance to the site on High Worple and at the construction gate. The gate will be manned whenever the site is in operation. The traffic marshal’s role will include control and monitoring of: • Compliance with CLOCS standards • Adherence to the DMS • Comprehensive use of wheel wash facilities

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• Use of the pit lane • Gate security

5.20 Weekly logistics meetings will held to plan and co-ordinate delivery movements and delivery slot allocated. These will be processed through the DMS and issued to suppliers.

5.21 Suppliers who fail to comply with the Traffic Management Plan will be sanctioned, initially through refusal to accept deliveries and, ultimately via remedies available within supply contracts.

CONSTRUCTION SITE LOGISTICS

5.22 The construction logistics arrangements are illustrated below in Figure 5.3 below.

5.23 The principal features are: • Hard standing /haul road for deliveries and vehicle turning with wheel wash facility prior to exit • Reconfiguration of site entrance to prevent backing up onto High Worple • Just in time deliveries, distributed to the work face from the vehicle bed • Crane and fork lift distribution on site • Use of three zone-controlled tower cranes o No over-sail to the LUL boundary line o Adequate capacity and reach to all cores • Construction hoists for the fit out phase Traffic management at the junction of the site and High Worple will need to be agreed with TfL and the LBH Highways team. Remodelling of the approach to site to allow vehicles pass and either traffic light control or a no entry box are considered necessary. Figure 5.3 refers

Figure 5.3 Site arrangements - delivery access and turning

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SITE ARRANGEMENTS

Hoardings and perimeter 5.24 A 2.4m high solid hoarding will be erected on the east and west boundaries. Further discussion will be required with TflL to determine how the works are segregated from rail operations on the northern boundary. The existing garden fences on the southern side of the site will be enhanced using a line of heras panels with the dual function of segregating construction operations and defining the extent of the RPAs required along the boundary line

Protection fans and scaffold wrap 5.25 Full external scaffolding will be required to construct the external envelope. This will be wrapped in fire retardant monarflex to provide:

• Privacy to residents opposite the site • A measure of acoustic damping • Shielding from light spillage • Containment of potential dust and debris drift from site operations.

Fans will be erected along the northern face of ach core as an additional protection measure to rail maintenance operations below.

Lighting 5.26 General site illumination will be directed into towards the building, away from wild life habitats and so as not to cause glare to the railway line or residential properties. The scaffold wrap will also provide shielding against light spillage.

Site Security 5.27 Site security will include the following measures:

• Remotely monitored CCTV cameras (trained along and looking into the site side of the boundary) will be installed around the perimeter once it is established. • Permanently manned gate security / traffic marshal coverage to the entrance gate • SIA certified security guarding. As the project progresses the security presence will be stepped up, ultimately to a 24 hour attendance as the risk profile from theft, fire and vandalism increases. • Security lighting of general access routes around site subject to spillage constraints

Site offices and welfare facilities 5.28 The site offices and welfare facilities will be located along the southern boundary at the east end of the site. The facilities are sized to accommodate the anticipated peak labour force and management team in addition to space for the client team.

STRATEGIC PLANT

Tower Cranes 5.29 Three tower cranes will be used to support construction operations (figure 5.3). One 30m radius luffing jib will service core D with two 40m radius cranes required for Cores A, B and C.

5.30 These will be zone controlled in operational hours and are specified for an out of service radius of around 10m so as not to interfere with railway operations, nor over-sail residential property.

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Discussion will need to be held with UKPN. It would appear that TC2 will over-sail the substation on the south boundary.

Hoists 5.31 Construction hoists will be provided for the fit out phase. A single goods / passenger hoist has been selected for Core D. Three hoists are used on the remaining cores. One will be goods passenger, two will be goods only models.

ECOLOGICAL IMPACT MITIGATION

5.32 Mitigation measures responding to the Rayners Lane Construction Phase Ecological Impact Assessment (produced by Middlemarch Environmental Ltd) are included in Appendix E. Where drainage works are required within the SINC area additional ecological review and monitoring works will be required and support from a qualified ecologist will be sought in connection with any such works.

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APPENDICES

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APPENDIX A

EXISTING, PROPOSED SITE CONSTRAINTS PLANS

• APPENDIX A1 Existing site plan • APPENDIX A2 Proposed site plan • APPENDIX A3 Site constraints Plan

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APPENDIX B - NOISE, VIBRATION AND AIR QUALITY CONTROL PROCEDURES

• APPENDIX B.1

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• APPENDIX B.2

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APPENDIX C - STRATEGIC ROAD NETWORK AND TRAFFIC ROUTING PROPOSALS

• APPENDIX C1 - Local Highway Network • APPENDIX C2 - Construction traffic routing

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APPENDIX D - SITE LOGISTICS PLAN

• APPENDIX D - Site logistics plan

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APPENDIX E - RESPONSE TO CONSTRUCTION PHASE ECOLOGICAL IMPACT ASSESSMENT

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Ecological Scale of Description of Impact/s and Effect in Mitigation by Additional Mitigation Proposed and Residual Effect Compensation / Overall Effect / Conclusion Feature Importance Absence of Mitigation Design Mechanism to Secure Enhancement to Address Residual Effect

Nature Conservation Sites Rayners Lane Local Loss of small amount of early successional Retention of None proposed. Residual adverse Planting of green No significant long- term effect on Railsides – Site of (Borough) woodland habitat from SINC. majority of effect, significant roofs/screens, trees, overall quality or quantity of the SINC / Importance for habitats at Local (Site) wildflower planting and broadleaved woodland habitat Nature within SINC. level. gardens Conservation (Borough Grade Further enhancement to be outlined within 1) BEMP. Root compaction and damage. Indirect Retention of A virtually continuous RPA on the southern Not significant N/A Not significant temporary impacts from air pollution. majority of boundary using heras fence panels to create a Increase in siltation and pollution to Yeadling the nature non-traffic zone will be established as part of hoarding / site set up works and maintained Brook. Further loss / degradation of habitat. conservation throughout construction. Specification to meet site. the requirements of BS5837:2012. Section 211 notice to be issued 6 weeks prior.

A solid hoarding between the SINC to the west and the site will prevent any construction access onto the SINC.

Repairs to the feeder into Yeading Brook proposed as a low impact enabling activity.

Pollution controls noted in CEMP • Air quality and dust monitoring (Section 4.18)

• Storage on site (Section 4.25)

• Waste management (Section 4.26)

• Prevention of water pollution (Section 4.32) • Emergency response planning (Section 4.36) • CEMP monitoring (section 4.37)

Adverse effect, significant at up to Local (Borough) level. Habitats Onsite – Poor Local Habitat loss. N/A None proposed. Residual adverse Planting of green Not significant. In the medium to long- semi- improved (Site) effect, significant roofs/screens, trees, term, the establishment of newly grassland, young Adverse effect, significant at Local (Site) at Local (Site) wildflower planting and created habitats has the potential to scattered trees, level. level. gardens constitute a beneficial effect at a Local scattered scrub (Site) Level. and tall ruderal Further enhancement vegetation to be outlined within BEMP. Offsite early Please refer to Rayners Lane Railsides – Site of Importance for Nature Conservation (Borough Grade 1) above successional woodland

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Ecological Scale of Description of Impact/s Mitigation by Additional Mitigation Proposed and Mechanism Residual Effect Compensation / Overall Effect / Conclusion Feature importance and Effect in Absence of Mitigation Design to Secure Enhancement to Address Residual Effect

Species Bats Local Disturbance of foraging / commuting N/A Pollution control measures as noted above. Not significant N/A Not significant (Site) habitat. Confirmatory preconstruction survey to be conducted. Adverse effect, significant at Local (Site) Noise generating works restricted to complete level. prior to 18:00. Site lighting to be controlled. General safety and security illumination to be directed onto site away from railway embankment or SINC and screened using monarflex Badgers Local Temporary reduction in foraging success due N/A Confirmatory pre-construction habitat survey to Not significant N/A Not significant (Site) to injuries from open excavations / pipework be commissioned. – Not significant. In addition to general measures e.g. pollution control, good practice in securing excavations and daily inspections required as a matter of course for ground work activities will minimize risk of entrapment. Birds Local Loss of suitable nesting habitat. Killing, injury N/A Pre-construction habitat / nesting survey to be No breach of Tree planting and Not significant (Site) or disturbance to nesting birds during site conducted prior to site clearance. wildlife green roofs clearance. Tree removal prohibited between March and legislation August. Pollution controls as set out within CEMP. Adverse effect, significant at Local (Site) level.

Breach of wildlife legislation. Reptiles Local (Site) Increased disturbance during construction N/A Environmental controls outlined within CEMP Not significant N/A Not significant works. and above. The site is considered sub-optimal to support reptiles. Particular / special measures not Adverse effect, significant at Local (Site) considered practicable level. Hedgehog Local (Site) Loss of suitable habitat. Not significant. N/A N/A Not significant Not significant

If present, potential for a temporary increase In addition to general measures e.g. pollution in mortality and reduced breeding success control, good practice in securing excavations (open excavations / pipework leading to and daily inspections required as a matter of course for ground work activities will minimize trapping / injury). risk of entrapment.

Adverse effect, significant at Local (Site) level. Invasive n/a Spread of invasive species. N/A Invasive Buddleia recorded on site to be Not significant N/A Not significant plants cleared on completion of hoarding employing cut-stump treatment of herbicide. Concentrated glyphosate or triclopyr to be applied to freshly cut surfaces. Monitoring of spread to be carried out throughout duration of works. Ecological consultant to confirm acceptability of treatment in relation to impacts on SINC.

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