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Demolition and Construction

Environmental Method Statement

1 - 3 Rawlings Street and Orford Studio,


Rosemoor Street,
London, SW3 2LP

A2 Environmental Consultants Ltd. 250 West George Street, Glasgow, G2 4qy


t: 0141 226 6945 f: 0800 066 4367 e: info@a2 environmental.co.uk w: www.environmental.co.uk

AD508A.R1.AD.TY Contents
Client Name: Orford Studios LLP
Reference: AD.508A.R1.AD.TY
Issue: Final
Date: November 2015

Approval Status;

Prepared by: John Marsh BSc (Hons) MSc CGeol


Position: Associate

Approved by: Alistair Dalziel BSc. MBA CDipAF MCIM


Position: Director

This report has been prepared by A2 Environmental Consultants Limited with all reasonable skill, care and diligence
within the terms of the Contract with the client, incorporation of our General Terms and Condition of Business and
taking account of the resources devoted to us by agreement with the client.
We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.
This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom
this report, or any part thereof, is made known. Any such party relies on the report at its own risk.

AD508A.R1.AD.TY Contents
CONTENTS
Executive Summary
1. Brief ....................................................................................................................................................... 3
1.1 Introduction ....................................................................................................................................... 3
2. Legislation Planning Policy and Guidance ....................................................................................... 5
2.1 Legislation ......................................................................................................................................... 5
2.2 Policy ................................................................................................................................................. 6
2.3 Guidance ........................................................................................................................................... 7
2.4 Standards to be adopted .................................................................................................................. 7
3. Description of Site Setting and Receptors ...................................................................................... 10
4. Description of the Works .................................................................................................................. 11
4.1 Overview of Development .............................................................................................................. 11
4.2 Demolition ....................................................................................................................................... 12
4.3 Excavation....................................................................................................................................... 13
4.4 Basement Formation and Underpinning ........................................................................................ 13
4.5 Piling ................................................................................................................................................ 13
4.6 Superstructure ................................................................................................................................ 14
5. Mitigation ............................................................................................................................................ 15
5.1 Neighbourhood Liaison................................................................................................................... 15
5.2 Baseline Monitoring ........................................................................................................................ 16
5.2.1 Noise ........................................................................................................................................ 16
5.2.2 Air Quality and Dust Risk Assessment ................................................................................... 16
5.3 Demolition and Construction Monitoring ........................................................................................ 17
5.4 Training ........................................................................................................................................... 17
5.5 General Measures to be adopted .................................................................................................. 18

AD508A.R1.AD.TY Contents
EXECUTIVE SUMMARY
Background and Objectives
A2 Environmental Consultants Ltd (A2) was commissioned by Orford Studios LLP to compile a
Construction and Demolition Method Statement that seeks to address the potential noise, vibration and
dust environmental impacts which could arise from the redevelopment of 1 - 3 Rawlings Street and Orford
Studio, Rosemoor Street, London, SW3 2LP.
The proposed project consists of:
• Demolition of Orford Studio building and construction of replacement building on Rosemoor
Street to provide 2 x 2 bedroom flats and 2 x 1 bedroom flat;
• Demolition of Rawlings Street building and construction of replacement building to deliver one
new residential house (1 x 4 bedroom); and
• Extension of single storey basement and associated alterations.

The site is in close proximity to a number of potentially sensitive noise dust and vibration receptors and
these include:
• Residential, retail and office uses along Rosemoor Street. Rawlings Street and Cadogan Street in
particular adjoining properties;
• The general public.
The minimisation of the potential environmental impacts including noise, vibration, dust and other
environmental nuisance in relation to the proposed demolition and construction works has been a cross
cutting theme in the development of key project documents including:

• Structural Engineer’s Construction Method Statement;


• Design and Access Statement;
• Construction Traffic Management Plan;
• Preliminary Site Waste Management Plan; and
• Building Research Establishment Environmental Assessment Methodology (BREEAM) report.

These have all been submitted as part of the supporting documentation to the planning application as
submitted to RBKC.

This Demolition and Construction Environmental Method Statement provides a collation of the
commitments and should be read in conjunction with all the submitted planning application documents and
drawings.
This Construction and Demolition Method Statement will be provided to contractors tendering for the works
and they will be required to adopt the recommendations of this document. In the event that changes to the
working method are proposed by the contractors; the contractor will be required, following authorisation of
the Client team, to agree the changes with RBKC Executive Director, Planning and Borough Development
in consultation with the Director of Environmental Health.
Orford Studios LLP has committed to ensuring that all works will be undertaken in accordance with all
relevant legislation, best practice guidance, British Standards and the requirements of the Royal Borough
of Kensington and Chelsea (RBKC). This will also be made a requirement for the contractors tendering
for the works.

Particular reference will be made to BS5228: Code of Practice for Noise and Vibration Control on
Construction and Open Sites; The Control of Dust and Emissions during Construction and Demolition
Supplementary Planning Guidance Mayor of London July 2014 and RBKC LDF Noise SPD May 2009.
The Contractor will be required to register the site with the UK’s “Considerate Contractors Scheme”.

AD508A.R1.AD.TY Page 1
Proposed methods of demolition include for concrete, the use of using non-percussive techniques and only
cutting machinery or hand methods, all other demolition shall only take place by hand. All excavations for
underpinning will be carried out by hand, using only non -percussive hand tools and for basement formation
by hand or utilising a micro excavator (maximum operating weight of 1.5 tonnes). The soil will be transferred
to normal 7m skips kept on site adjacent to Rosemoor Street. Any compaction of hardcore shall only be
carried out using non-vibrating methods.

The basement enclosure will be formed using piles. It is anticipated that a tracked Sectional Flight Augers
(SFA) piling rig will be used to bore from the existing ground level. The SFA process is considered to be
virtually vibration free and one of the quietest forms of piling. In addition it is likely that steel casing will
screwed down to approximately 3.0m below ground. This will act to guide the piles, more importantly it will
allow the rotation speed to be restricted without pulling in any earth. This precaution will further reduce any
risk of vibration.
A series of general best practice measures to be adopted during demolition and construction are provided
within this document including neighbourhood liaison, personnel training, vehicle use and maintenance and
general site procedures to minimise noise vibration and dust generation.
Prior to commencing the work and ongoing during the relevant phases of the project noise and vibration
and dust monitoring will be undertaken and the results provided to RBKC and communicated to the public
as part of the neighbourhood liaison.
An Air Quality and Dust Management Plan (AQDMP) will be submitted to RBKC prior to works commencing
on site.

AD508A.R1.AD.TY Page 2
1. BRIEF
A2 Environmental Consultants Ltd (A2) was commissioned by Orford Studios LLP to compile a
Demolition and Construction Method Statement for the 1 - 3 Rawlings Street and Orford Studio,
Rosemoor Street redevelopment project.
This Demolition and Construction Method Statement has been prepared for the exclusive use of
Orford Studios LLP, and their advisors for the purpose of assisting them in defining suitable
environmental noise dust and vibration control measures to be adopted during demolition and
construction.

1.1 Introduction
The report has been compiled, in support of the planning application for the above development, to
advise on the measures, in accordance with the best practicable means, to be used to minimize
construction noise vibration and dust that could arise as a result of these works.
The purpose of the report is to provide information on the potential sources of noise, vibration and
dust that may arise from the demolition of the existing buildings and the construction of the new
development together with recommendations for mitigating or preventing potential nuisance.
Once planning permission is granted, the appointed contractor will be fully responsible for the
implementation of this plan and it will be necessary to resubmit this plan on the basis of changes that
may arise following the detailed engineering design of the works; the actual construction programme
and proposed methodology; or conditions prevailing at that time.
Whilst the contractors who will be undertaking the demolition and construction works have not been
appointed and the detailed engineering design has not been undertaken, this document provides
details of the likely works and best practice methods that will be adopted in order to minimise the
potential for the demolition and construction to result in dust or noise and vibration impacts.
This document should be read in conjunction with the Construction Management Plan 1 - 3 Rawlings
Street and Orford Studio, Rosemoor Street, London, SW3, (Form Structural Design Job No: 142191)
that provides full details of the proposed construction methods to be employed, and the following
documents:
• Haptic Architects Design and Access Statement;
• Eight Associates Preliminary Assessment BREEAM Domestic Refurbishment E756-
Preliminary Assessment-1409-18rm.docx;
• Eurosafe UK (Survey for Asbestos Containing Materials Project No: ES/55329);
• TTP Consulting Construction Traffic Management Plan;
• Preliminary Site Waste Management Plan;
• Planning Application Drawings.
The project consists of the demolition of Orford Studio building and construction of replacement
building on Rosemoor Street to provide 2 x 2 bedroom flats and 2 x 1 bedroom flat; demolition of
Rawlings Street building and construction of replacement building to deliver one new residential
house (1 x 4 bedroom); and extension of single storey basement and associated alterations.
The site is in close proximity to a number of potentially sensitive noise dust and vibration receptors
and these include:
• Residential properties along Rosemoor Street, Cadogan Street and Rawlings Street in
particular adjoining properties and their garden areas;
• Commercial Property adjoining the property on Rosemoor Street;
• The general public.

AD508A.R1.AD.TY Page 3
The most sensitive time periods are likely to be normal working hours for the retail and office uses,
night-time for residential uses.
Planning permission was granted on 22 April 2015 under application reference: PP/15/01396 for
largely the same development proposals. The amended planning application seeks to principally
alter the design of the Orford Studio building on Rosemoor Street and include the demolition of the
previously retained Rawlings Street facade.
With regards to the Rawlings Street facade, since demolition commenced on site (under application
reference: PP/15/01396), it has become unsafe to retain the front, flank and part of the rear elevations
of the property. The LPA have since confirmed that the building facade is defective. The design of
the replacement 1-3 Rawlings Street building will be as per the consented scheme, those elements
now to be removed will be replaced, like for like.
An indicative construction programme for the works is as follows:

Preliminary Programme

Demolition and structural works, including Start: May 2015


substructure, façade retention, End: February 2016
superstructure and roof
Construction and fit-out works through to Start: March 2016
Practical Completion End: September 2016

One main contractor will be responsible for the demolition superstructure and substructure, followed
by fit-out, where collaborative design solutions are encouraged to ensure the design team and
contractor establish the most efficient methodologies and buildability options.
The contractor will be responsible for determining the most appropriate method of demolition and
finalising the plant and equipment to be used. This document, however, draws on information from
the Orford Studios LLP Design Team who have provided information on the likely approach to
demolition and construction.
This report is divided into the following sections:
• Legislation, Planning Policy and Guidance;
• Description of site setting and receptors and current conditions;
• Description of works - Key Activities;
• Mitigation and best practice methods.

AD508A.R1.AD.TY Page 4
2. LEGISLATION PLANNING POLICY AND GUIDANCE

2.1 Legislation
Various strands of national, regional and local planning policy and guidance are relevant to the 1 - 3
Rawlings Street and Orford Studio, Rosemoor Street, London, SW3 Development. These include
(but are not limited to) the following:

Environmental Protection Act 1990 Noise and Dust nuisance is defined as a statutory nuisance in Part III of the act,
and Pollution Prevention and Control Sections 79-82 address Statutory Nuisance
(England and Wales) Regulations
2007

Control of Pollution Act 1974 The principal legislation relating to noise is derived from the Control of Pollution Act
1974, although law related to both Statutory and Common Law can be relevant in
the event that excessive noise nuisance is caused by an activity.

Powers are given to local authorities under the Control of Pollution Act 1974 (COPA)
for the control of noise from construction sites. Sections 59A, 60 and 61 of COPA
1974 allow councils to serve notices imposing requirements about the way in which
work is conducted.

Although it is a criminal offence to contravene such a notice without a reasonable


excuse, it is a defence that the work was carried out under a consent issued under
Section 61 of the Act. Such consents may be applied for in advance of construction
work being carried out. Regulations can be made to control noise from plant or
machinery under Section 68 of COPA 1974 but the policy preference has been to
use codes of practise, which have been issued under Section 71 to minimise noise.
Although breach of a code of practise is not a criminal offence, these may be taken
into account in legal proceedings.

Under COPA 1974 a local authority may designate all or part of its area as a noise
abatement zone. The consequence of this is that noise levels are recorded and
entered into a public register. Noise levels may only be exceeded with the authority's
consent, in effect setting an upper limit on noise levels.
The Noise Emission in the The intention of the legislation is to control and monitor noise of equipment for use
Environment by Equipment for outdoors so as to reduce noise nuisance. The scope of the Outdoor Noise Directive
Outdoor Use Regulations 2001 comprises a wide range of construction plant and equipment, equipment for
gardens, for lifting, pumps, drills, saws etc.

Clean Air Act 1993 Emitting dark smoke from bonfires is an offence under this act

Building Act 1984 Applies to demolition of buildings and requires prior notification to the local authority
and production of a method statement before the work begins

Environment Act 1995 and Air Quality The Air Quality Strategy set standards and objectives for air pollutants under Part
Regulations 2010 IV of the Environment Act 1995.

Health and Safety at Work Act 1974 The purpose of this act is to secure the health, safety and welfare of person at work
and to protect against risk to other persons from these activities. Under this act the
Health and Safety Executive (HSE) issue sets of guidance notes,

Control of Asbestos Regulations 2012 Activities involving asbestos must be reduced to as far below the control limit
asbestos (0.1 asbestos fibres per cubic centimetre of air) as possible.

The Non-Road Mobile Machinery Sets out requirements to reduce emissions from diesel engines of non-road mobile
(Emissions of Gaseous and machinery
Particulate Pollutants) (Amendment)
Regulations 2011

AD508A.R1.AD.TY Page 5
2.2 Policy

National Planning Policy Framework States that planning policies should sustain compliance
with and contribute towards EU limit values or national
objectives for pollutants, taking into account the
presence of Air Quality Management Areas and the
cumulative impacts on air quality from individual sites in
local areas.
Core Strategy Basements Submission Planning Policy Emphasises the relevance of CE6 part B, makes
(April 2014) and Further Modifications reference to the potential construction impacts.
RBKC Adopted LDF Core Strategy Policy CE 5 Air Quality
The Council will carefully control the impact of
development on air quality, including the consideration of
pollution from vehicles, construction and the heating and
cooling of buildings. The Council will require
development to be carried out in a way that minimises
the impact on air quality and mitigate exceedences of air
pollutants.

Policy CL5 and CE 6 Noise and Vibration


The Council will carefully control the impact of noise and
vibration generating sources which affect amenity. The
Council will require new noise and vibration sensitive
developments to mitigate and protect occupiers against
existing sources of noise and vibration.

To deliver this the Council will:


• require that noise and vibration sensitive
development is located in the most appropriate
location and protected against existing sources
of noise and vibration, through careful design,
layout and use of materials, to ensure adequate
insulation from sound and vibration;
• resist developments which fail to meet local
noise and vibration standards;
• resist all applications for noise and vibration
generating development and plant that would
have an unacceptable noise and vibration
impact on surrounding amenity;
• require that development protects, respects
and enhances the attributes of the special
significance and tranquillity of tranquil quiet
areas.

Royal Borough of Kensington and Chelsea Noise Royal Borough of Kensington and Chelsea adopted its
Supplementary Planning Document – Adopted May Noise Supplementary Planning Document (SPD) on 21
2009 May 2009. The Noise SPD sets out the Council’s
supplementary planning advice for controlling noise from
new development and protecting noise sensitive new
development from existing noise. The SPD supplements
saved Unitary Development Plan (UDP) Policies CD40,
CD41, CD52, H2 and H4, providing detailed guidance on
their implementation.
Part M of Policy CL7 states the following: “Ensure that
RBKC Basement Planning Policy (adopted January 2015)
construction impacts such as noise, vibration and dust
are kept to acceptable levels for the duration of the
works”

AD508A.R1.AD.TY Page 6
POLICY 3.2 Improving Health and Addressing Health
The Further Alterations to the London Plan (adopted March
Inequalities New developments should be designed,
2015)
constructed and managed in ways that improve health
and promote healthy lifestyles to help to reduce health
inequalities.
Outlines measures to be undertaken and requires Dust
The Control of Dust and Emissions during Construction Risk Assessments to be carried out.
and Demolition Supplementary Planning Guidance
Mayor of London July 2014

2.3 Guidance
BS 6069 Part 2 ‘Characterization of air quality’ Dust is the generic term which the British Standard
document BS 6069 (Part Two) uses to describe particulate
matter in the size range 1 – 75μm (micrometers) in
diameter.
BS 7445: 2003 ‘Description and Measurement of Defines parameters, procedures and instrumentation
Environmental Noise, Part 2: Guide to the Acquisition of required for noise measurement and analysis.
Data Pertinent to Land Use’
BS5228-1: 2009 Noise and Vibration Control on Part 1 Annex C provides guidance on noise levels produced
Construction and Open Sites Part 1 Noise, Part 2 Vibration. by site equipment and activities and Part 1 Annex D
provides a method for estimating noise from construction
sites;
Part 2 provides a guide to vibration levels produced by site
equipment and activities
BS 8233:2014 ‘Guidance on sound Insulation and Noise Provides criteria for the assessment of internal noise levels
Reduction for Buildings-Code of Practice’. for various uses including dwellings and commercial
properties and recommended internal noise levels.

GLA and London Councils 2006’ ‘Best Practice Guidance: Provides best practice guidance on the control of dust from
The Control of dust and emissions from construction and sites
demolition
BS 6472-1:2008 ‘Guide to Evaluation of Human Exposure to Presents recommended frequency weighted vibration
Vibration in Buildings, Part 1: Vibration Sources Other Than spectra (for continuous vibration) and vibration dose values
Blasting’ (VDV) (for intermittent vibration) above which adverse
comment is likely to occur in residential properties.

BS 5228:2009 Part 1 Noise, Part 2 Vibration ‘Noise and Provides an industry accepted guide for noise and vibration
Vibration Control on Construction and Open Sites’ control and includes sound level data for individual plant as
well as a calculation method for noise from construction
activities. The standard also provides advice on potential
noise limits from construction sites.
BS 7385:1993: ‘Evaluation and Measurement for Vibration Presents guide values or limits for transient vibration, above
in Buildings - Part 2: Guide to Damage Levels from Ground which there is a likelihood of cosmetic damage.
Borne Vibration’

2.4 Standards to be adopted


Preliminary target criteria are proposed below for dust, noise and vibration, however, it is
acknowledged that best practice methods should be adopted at all time to minimise the potential
dust, noise and vibration.
Dust is the generic term which the British Standard document BS 6069 (Part Two) used to describe
particulate matter in the size range 1 – 75μm (micrometers) in diameter. Dust nuisance is the result
of the perception of the soiling of surfaces by excessive rates of dust deposition.

AD508A.R1.AD.TY Page 7
There are currently no standards or guidelines for dust nuisance in the UK and this reflects the
uncertainties in dust monitoring technology, and the highly subjective relationship between
deposition events, surface soiling and the perception of such events as a nuisance.
Under provisions in the Environmental Protection Act 1990, dust nuisance is defined as a statutory
nuisance. Complaints about excessive dust deposition would have to be investigated by the local
authority and any complaint upheld in law for a statutory nuisance to occur.
The regulation of dust deposition is, however, generally managed by suitable on-site practices and
mitigation rather than by the determination of statutory nuisance and/or prosecution or enforcement
notice(s).
An informal criterion for dust deposition of 200 mg/m2/day (as a 30 day mean) is however often
applied in the UK as an indicator of potential nuisance for sensitive receptors.
Noise, in the context of this study, can be defined as unwanted or undesirable sound derived from
sources such as road traffic, industries or construction works, for example, that interferes with normal
activities, including conversation, sleep or recreation. Vibration is related to noise resulting from the
transmission of low frequency energy through, typically, the medium of ground or buildings. It results
in small movements of the transmitting medium, which can cause discomfort if the movements are
large enough. In this document the potential for noise and vibration to be generated during demolition
and construction is considered.
BS 5228 provides practical information on noise and vibration reduction measures, and promotes a
‘best practice means’ approach to control noise and vibration. The calculation method provided in
BS 5228 is based on the number and types of equipment operating, their associated sound levels,
and the distance to receptors, together with the effects of any screening.
The types and numbers of construction plant will be finalised following the completion of the
engineering design and during the tender period. Ultimately there will be a trade off between
maximising the number of plant and equipment on site within the constraints of the site and project
programme.
BS 5228 provides further guidance on acceptable levels of construction noise within Annex E and
provides example criteria for the assessment of significance of construction noise impacts. One of
the potential suggested criteria within BS 5228 refers to the DoE Leaflet AL72: Noise Control on
Building Sites from 1976. Whilst this was published in 1974 and out of print, it is often still used to
define suitable target values.
Facade Target Noise Levels for Occupied Buildings during Core Working Hours:
Period Hours Time Period (T) LAeq,T (dB)

Monday-Friday 08.00-18.00 10 hours 75

Saturday 08.00-13.00 5 hours 75

NOTES:
(a)The LAeq,T noise level is the A-weighted equivalent continuous sound level, measured over the relevant time period
quoted above.
(b) The above noise limit relates to noise from the construction process at a point 1m in front of the facade of any occupied
building.

The above targets are recommended for this assessment as the basis for identifying potential
construction noise impacts, where the typical ‘worse case’ daily noise level prevails for a period
greater than one month, and where the baseline ambient noise level is predicted to increase by 3 dB
or more due to construction noise.
The correct timing of construction operations is expected to be critical in avoiding noise and vibration
nuisance to surrounding areas and premises. The contractor will be responsible for identifying
particularly sensitive periods in the works so that the potential problems can be minimised and that
early and good public relations with the adjacent tenants and occupants of buildings are essential.

AD508A.R1.AD.TY Page 8
Vibration from construction activities, in particular piling, may impact on adjacent buildings. The
target criteria used in this assessment relate to the potential for cosmetic damage, not structural
damage. The principal concern is generally transient vibration due to piling. Cosmetic damage is
most likely to occur within the first 20 metres (m) of piling activities and at greater distances, damage
is less likely to occur. Likely levels of vibration at given distances can be predicted from existing
piling vibration data - examples of which are included in Annex D of BS 5228 Part 2.
BS 7385 establishes the basic principles for carrying out vibration measurements and processing the
data, with regard to evaluating vibration effects on buildings.
The vibration dose value (VDV) is a measure of the amount of vibration that is experienced over a
specified period, and was defined so as to quantify the human response to vibration in terms of
comfort and annoyance.
On the basis of the guidance provided within BS 6472, target criteria for vibration levels during the
site preparation and construction of the development are set out in the table below.
The target vibration levels are considered representative of the threshold of annoyance and
applicable to the closest noise sensitive receptors to the site, which includes both residential
dwellings and offices and have been used as criteria for the assessment the predicted construction
noise levels.

Target Criteria for Construction Vibration

Period Vibration Dose Value ms-1.75

16 Hour Day (0700-2300) 0.4 Residential

8 Hour Night (2300-0700) 0.8 Office

These values represent a low probability of adverse comment level.


At values of 1.0mm/s it is likely that complaint will be caused in residential environments but may be
tolerated if prior warning is given to residents; at vibration levels of 10mm/s vibration is likely to be
intolerable for any more than a very brief exposure.
Augered piling is an inherently quieter method of piling than impact or percussive piling and produces
lower levels of vibration. Piling works are expected to take place in proximity to both existing sensitive
receptors and adjoining occupied buildings. As such, there is potential for vibration impact to
receptors due to piling works. Therefore it would be recommended that neighbourhood liaison takes
place at an early stage so that occupants of adjacent buildings should be informed in advance in
those cases where piling operations would come close to their building, such that any concerns can
be allayed and if necessary the programme of works amended to minimise disruption.
The most significant vibration sources are likely to be related to the insertion of bored pile casings
and possibly some of the breaking out activity. It is not possible to estimate the levels of vibration
with any certainty and it is therefore appropriate to undertake monitoring of the vibration levels during
works to ensure that appropriate vibration limits are met at adjoining buildings that will be the most
sensitive receptors. As part of this process, limits need to be placed on the vibration at sensitive
buildings.
Peak Particle Velocity Limits for Cosmetic Damage to Buildings (From BS7385 pt 2)

Peak component Particle Velocity in Frequency Range of Predominant


Pulse at base of building

Type of Building 4-15Hz 15Hz and above

Un-reinforced or light framed structures 15mm/s at 4HZ increasing to 20mm/s at 15 Hz increasing to


Residential or light commercial type 20mm/s a 15Hz 50mm/s at 40HZ and above
buildings

AD508A.R1.AD.TY Page 9
3. DESCRIPTION OF SITE SETTING AND RECEPTORS
The site, which is occupied by: 1-3 Rawlings Street; four storeys high including basement; and Orford
Studios, up to three storeys without a basement.

In the south western corner of the site a single storey extension connects 1-3 Rawlings Street and
Orford Studios at ground floor level.

The proposals involve the demolition of the Orford Studios and the re-modelling of 1-3 Rawlings
Street.

The Orford Studio Building fronts Rosemoor Street. Orford Studios is a three storey building without
a basement that dates from the mid-twentieth century. The ground floor is used as garages with the
first floor and attic floors above both used as residential accommodation.

To the rear of the studio a later extension extends to the south western corner of the site and connects
to 1-3 Rawlings Street at ground floor level. This extension is predominately single storey creating
an accessible first floor terrace. At the eastern end adjacent to 1-3 the extension is constructed up
another floor to create additional habitable space. There is no connection to 1-3 at first floor level.

The facades and original party walls of the Rawlings Street are constructed from load-bearing
masonry and for Orford Studios, the facades, party walls, and the dividing walls between garages
are constructed from load-bearing masonry.

A single storey steel frame on the Rosemoor Street elevation supports the masonry above the garage
door openings.

The south eastern boundary is shared with number 33b Cadogan Street. To the rear the boundary
is shared with the rear gardens of numbers 27, 29, and 31 Cadogan Street.

The party wall (33b) is solid masonry construction and it is expected to extend down to a shallow
corbelled brick footing. The rear garden boundary is formed by a masonry wall approximately 1.20m
high.

A narrow alleyway separates Orford Studios from East House which runs along the south western
boundary. The party wall is solid masonry construction and it is expected to extend down to a shallow
corbelled brick footing.

The site is in close proximity to a number of potentially sensitive noise dust and vibration receptors
and these include:
• Residential properties along Rosemoor Street, Cadogan Street and Rawlings Street in
particular adjoining properties and their garden areas;
• Commercial Property adjoining the property on Rosemoor Street;
• The general public.
The overall setting of the site is considered to be quiet residential. The most sensitive time periods
are likely to be normal working hours for the commercial office uses, night-time for residential uses.
The closest properties to the development are the adjoining properties on Rosemoor Street and
Rawlings Street these would appear to be residential with the adjoining property on Rawlings Street
being an Estate Agents.

AD508A.R1.AD.TY Page 10
4. DESCRIPTION OF THE WORKS
Full details of the proposed development and construction methods are provided in the planning
application drawings and supporting information including the Construction Method Statement for the
development that provides details of the excavation, temporary works and construction techniques,
including details of the potential impact of the subterranean development on the existing and
neighbouring structures, based on the type of geology and hydrology found in the area.

4.1 Overview of Development


The project consists of the demolition of Orford Studio building and construction of replacement
building on Rosemoor Street to provide 2 x 2 bedroom flats and 2 x 1 bedroom flat; demolition of
Rawlings Street building and construction of replacement building to deliver one new residential
house (1 x 4 bedroom); and extension of single storey basement and associated alterations.
1-3 Rawlings Street has an existing basement this is to be replaced and extended to cover the
development footprint. The maximum depth of excavation beneath the existing ground level will be
around 3.5m below ground level.
Access Arrangements
A Construction Traffic Management Plan has been compiled for the site development works this
confirms the following:

The access to the property will be via Rosemoor Street. An area alongside the scaffold and 2.4m
high hoarding on Rosemoor Street will be used as the primary location for the delivery and removal
of materials, however, minor amendments could be made to this location over the course of the
project.

During demolition phase a licence for two skips will applied for and located beneath the Orford Studio
scaffold. At the beginning of each working day a mobile, fenced enclosure will be created outside
the property in the location where the licences have been validated. At the end of the day this fencing
will be removed and the area outside the hoarding line will be cleaned.
Soft Strip / Asbestos Removal Work
Asbestos containing materials have been identified at the property in a survey undertaken by
Eurosafe UK (Survey for Asbestos Containing Materials, dated 17 June 2014 Project No: ES/55329).

This identified Asbestos Containing Materials (ACMs) at a number of locations including, but not
limited to:
• Cement flue and cowl Ground Floor - Flat 4 kitchen: Amosite, Chrysotile;
• Bitumen coating Ground Floor - Kitchen – Sink: Chrysotile;
• Cement roof sheet Ground Floor - Lightwell - Underside of soffit: Chrysotile, Crocidolite;
• Insulating board Ground Floor - Bedroom - Underside of fire: Amosite, Chrysotile;

These were deemed by Eurosafe UK to be suitable for management (i.e. they did not require
immediate action).

A number of areas were identified that did, however, require immediate action for which access
should be restricted until remedial works have been undertaken. These included the basement
area where loose materials on the floor and waste bags were found to contain ACMs.

The proposed demolition and redevelopment works will require the removal of all ACMs. The findings
of the Eurosafe UK Report will need to be taken into consideration prior to carrying out any soft strip
or demolition. The exclusions of the report should be considered and further asbestos sampling may
be required.

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Some of the asbestos removal works (e.g. insulation board removal) may require licensing with the
Health and Safety Executive. Irrespective of this, all non-licensed work needs to be carried out with
the appropriate controls in place. However, for some types of work, the employer must meet
additional requirements. This is known as notifiable non-licensed work or NNLW, and requires
employers to:

• Notify work with asbestos to the relevant enforcing authority;


• Designate (identify) areas where the work is being done;
• Ensure medical examinations are carried out; and
• Maintain registers of work (health records).

For both licensable and non-licensable work the general requirements of the Control of Asbestos
Regulations 2012 will need to be complied with to prevent exposure to asbestos. It is an offence to
carry out licensable work with asbestos without a licence and those involved including the employer
could be prosecuted.

Form Structural Design have compiled a Structural Engineer’s Construction Method Statement for
the proposed redevelopment (Job No: 142191). This report primarily presents an outline structural
scheme for the construction of the new basement including the temporary works. All stages of the
envisaged construction sequence are described within Section 5.0 of the Construction Method
Statement report.

Of particular relevance to this assessment, this provides confirmation that:

• The proposal complies with the specific requirements set out in the ‘Subterranean Development
Supplementary Planning Document ‘SPD’ Guide May 2009 and emerging policy under the Core
Strategy Basements Submission Planning Policy (April 2014) and Further Modifications;

• The permanent and temporary works will be designed to relevant British Standards. The
temporary works and the method of works will be developed such that the effect on the
neighbours is minimised.

4.2 Demolition
Existing buildings cover most of the site. During demolition, full height scaffold will be installed to the
front elevations in Rawlings Street and Rosemoor Street for the full length of the buildings to be
demolished / retained.
Masonry walls form the boundary to all sides of the site these will initially retained and additional
timber hoarding of at least 5 kg/m2 surface density will be installed & attached to the protection
scaffold.
The scaffold will be fully fitted with vertical sheets of Monarflex Scaffold Sheeting, to visually shield
the works & contain small particles of debris & nuisance dust from escaping the site.
Particular care will be taken when working in close proximity to the existing party walls, foot path etc.
so as not to cause damage to the existing retained structures or undermine the existing retained
structures.

Dust suppression will be employed, by the most appropriate method available, to minimise the
release of dust during the demolition process. Care will be taken to ensure that this does not result
in run-off of sediment laden waters into drains or neighbouring properties.

The Construction Method Statement provides a commitment that:


• All demolition of existing concrete shall be undertaken using non-percussive techniques and only
cutting machinery or hand methods shall be used; and
• All demolition (excluding demolition of concrete works) shall only take place by hand.

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4.3 Excavation
The Construction Method Statement confirms that:

• All excavations for underpinning will be carried out in a traditional hit and miss sequence by hand,
using only non -percussive hand tools to ensure that at any time during the works the integrity of
the superstructure is not compromised.

• All excavation (other than for underpinning) shall be carried out by hand or utilising a micro
excavator (maximum operating weight of 1.5 tonnes). The soil will be transferred to normal 7m
skips kept on site adjacent to Rosemoor Street.

• Any compaction of hardcore shall only be carried out using non-vibrating methods.

4.4 Basement Formation and Underpinning


Where the boundary is shared with 33b, 31, 29 Cadogan Street and East House on Rosemoor Street,
the existing footings will be underpinned using simple mass concrete underpins that ensure the
existing walls above remain structurally independent to the new basement box. A separate RC liner
wall will be constructed inboard to resist all lateral earth loading. This wall will be separated by a
vertical slip membrane from the underpinning to ensure that the new RC box structure is structurally
independent.

The existing wall front/facade was to be retained on 1-3 Rawlings Street, the existing footings will be
underpinned using simple mass concrete underpins to ensure the existing walls above remain
structurally independent to the new basement box. With regards to the Rawlings Street facade, since
demolition commenced on site (under application reference: PP/15/01396), it has become unsafe to
retain the front, flank and part of the rear elevations of the property. The LPA have since confirmed
that the building facade is defective. A separate RC liner wall will be constructed inboard to resist all
lateral earth loading. This wall will be separated by a vertical slip membrane from the underpinning
to ensure that the new RC box structure is structurally independent.

4.5 Piling
At the front of the Orford Studio Building, where access is possible, it is proposed to install a
contiguous piled wall to form all the external walls of the excavation. Again a separate RC liner wall
will be constructed inboard of the piles to resist all lateral earth loading. In this instance these walls
will be tied to the piles to ensure that the new RC box structure takes support from the piles preventing
excessive settlement.
A wide range of pile types have been considered to form the new basement enclosure. Augered
piles generally result in a lower magnitude of vibration than driven piles and it is anticipated that these
will be used in this instance.
• An experienced piling contractor shall be appointed to undertake the works and pile design. All
method statements, drawings and calculations will be submitted to the engineer for review. The
contractor will be required at tender stage to identify all precautions to be taken to ensure that the
works are to be carried out in a manner which minimises any noise and vibration.

• It is anticipated that a tracked piling rig will be used. These can be operated in the confined areas
and use Sectional Flight Augers (SFA) up to 600mm diameter to bore from the existing ground
level. The SFA process is considered to be virtually vibration free and one of the quietest forms
of piling.

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Using this method it would be anticipated that steel casing would be screwed down to approximately
3.0m below ground. This will act to guide the piles, more importantly it will allow the rotation speed
to be restricted without pulling in any earth. This precaution will further reduce any risk of vibration.
Vibration from construction activities, in particular piling, may impact on adjacent buildings. The
criteria used in this assessment relate to the potential for cosmetic damage, not structural damage.
The principal concern is generally transient vibration due to piling. Cosmetic damage is most likely
to occur within the first 20 metres (m) of piling activities and at greater distances damage is less likely
to occur. Likely levels of vibration at given distances can be predicted from existing piling vibration
data - examples of which are included in Annex D of BS 5228 Part 2.

4.6 Superstructure
Above the RC ground floor basement capping slab it is proposed that the upper floors will consist of
concrete poured over structural metal decking spanning between steel beams. These beams will
take support from the load bearing facades both new and retained together with several new internal
load bearing blockwork walls that extend up through the full height of the building.

The contractor may put forward alternative solutions to suit his programme and method of working.
These will be reviewed by the design team but no proposals will be considered unless they can
satisfactorily demonstrate that they satisfactorily minimise any noise and vibrations that may affect
the neighbouring properties.

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5. MITIGATION
At this pre-planning stage the contractors who will be undertaking the project have not been selected.
It is anticipated that a list of suitable contractors will be drawn up from those who Orford Studios LLP
and their design team have a previous working experience or knowledge.
The evaluation of the suitability of the contractors to undertake the project will include an assessment
of the ability of the contractors to manage their works in an environmentally responsible manner that
preserves the reputation of the Client and is protective of the public and the surrounding
neighbourhood.
It is anticipated that the project will be broadly divided in to two main contracts. Firstly a demolition
contractor will demolish the existing buildings before passing the site over to a main contractor who
will manage the construction phase. It is anticipated that this contractor will in turn employ a series
of subcontractors to undertake particular specialist activities.
This Demolition and Construction Environmental Method Statement will be provided to contractors
tendering for the works and they will be required to adopt the recommendations of this document. In
the event that changes to the working method are proposed by the contractors; the contractor will,
following authorisation of the Client team, submit and agree the changes with RBKC Executive
Director, Planning and Borough Development in consultation with the Director of Environmental
Health.
As part of the tender requirements the contractor will be required to conform to all relevant legislation
and guidance including British Standards. Particular reference will be made to BS5228 and the
Mayor of London’s SPG: The Control of Dust and Emissions during Construction and Demolition
(July 2014). All relevant measures identified in this document should be followed including but not
limited to the below.

5.1 Neighbourhood Liaison


It is recognised that early liaison and effective communication with people who may be affected by
the works is essential to maintain good neighbourhood relations.
The maintenance of good relations with neighbours and implementation of a programme of ongoing
liaison and respect with regards to the local environment and residences will form an important
aspect of the successful management of the project.
The contractor will appoint a dedicated Community Liaison Manager who will be focused on engaging
with the community to provide the appropriate information and to be the first line of response to
resolve issues of concern. The names and contact telephone numbers and email addresses of all
Site personnel with responsibilities for both supervision and management of the Works shall be
notified to the Director of Environmental Health (DEH) or the Officer and will be displayed on the site
hoarding.
The following actions will be taken:
• Once planning consent has been obtained, formal contact will be established with residential
neighbours and those who could potentially be affected by demolition of the existing
buildings on site and the construction / build out of the Proposed Development This will
include consultation on this Demolition and Construction Environmental Method Statement
and include identifying any particularly sensitive times of day.
• Outside normal working hours, site security will act as the main point of contact via a
dedicated phone number / hot line. Security will alert the Community Liaison Manager if
necessary (available 24 hours).
• Any complaints will be logged, fully investigated, and responded to quickly, advising what
action has been taken. If necessary, complaints will be reported to the relevant department
of the RBKC;
• Regular Monthly News letters will be distributed around the neighbourhood; and

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• Public notice boards will be established at site entrances providing contact details of the
person(s) accountable for neighbourhood liaison including environmental matters.

5.2 Baseline Monitoring


At present there is no baseline, vibration or dust information for the site. As it is anticipated that the
project will be commenced in 2015, it is recommended that a full baseline survey is undertaken prior
to commencement.

5.2.1 Noise
An Environmental Noise Survey and NPPF Assessment Report was undertaken by Hann Tucker
Associates in September 2014. This was undertaken to establish, by means of fully automated
environmental noise monitoring, the existing A-weighted (dBA) L90, Leq and Lmax environmental
noise levels at selected accessible positions over approximately 96 hours and to establish, by means
of fully automated environmental noise monitoring, the number of Lmax noise events which exceed
82dBA between 23:00 and 07:00 hours.

This found that the arithmetic average of the daytime LAeq(16-hr) and night time LAeq (8-hr) noise levels
ranged between 50-51dB and 43-44dB respectively. The dominant noise sources were noted to be
road traffic and nearby building work. The recorded values fall within Noise Exposure Category A
for both daytime and nightime.

In advance of the project commencing further noise measurement surveys will be undertaken to
establish ambient and background noise levels at that time. These will be undertaken in accordance
with the recommendations of BS 7445-1:2003 and will include measurements at identified noise
sensitive receptors.

5.2.2 Air Quality and Dust Risk Assessment


In accordance with The Control of Dust and Emissions during Construction and Demolition
Supplementary Planning Guidance (SPG) Mayor of London July 2014 an Air Quality and Dust Risk
Assessment has been undertaken for the project at this planning stage to provide a summary of the
risk to soiling, health and the natural environment from the proposed demolition, earthworks,
construction and trackout activities.
In accordance with this it is confirmed that an Air Quality and Dust Management Plan (AQDMP) will
be submitted to RBKC prior to works commencing on site following the guidance in the SPG this will
take into account any planning conditions or s106 agreements following the development application
and the actual programme of works.
A separate management plan will be compiled for the asbestos removal works to be undertaken as
part of the soft strip prior to the demolition phase.
In accordance with Chapter 4 of the Mayor’s SPG the risk category of these works has been
evaluated following the general principles of the Institute of Air Quality Management’s (IAQM) 2014
Guidance on the Assessment of Dust from Demolition and Construction.
The proposed works are of a small scale and the dust emission magnitude is considered to be Small.
However due to the proximity of the neighbours and without mitigation measures they could result in
nuisance at a local level and present a cumulative impact.
Demolition – The scale of the demolition is Small (<20,000m3, <10m above ground) however it is
acknowledged that the construction material has some potential for dust to be generated;
Earthworks- The scale of the earthworks is Small (the site area is <2,500m2, the soil type is sand
and gravel, small numbers of earth moving equipment will be used, the total material to be moved
will be <10,000 tonnes);
Construction - The scale of the construction is Small (<25,000m3);

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Trackout – The potential impact is Small as the materials are to be directly transferred into skips
and no tracking on road is to be carried out by any excavation plant.
The Sensitivity of the receptors are considered to be High due to the immediate proximity
neighbouring garden areas and residential uses (with >10 receptors <20m from the property).
The Human Health Impact sensitivity is considered to be Low based on an assumed Annual Mean
PM10 concentration of <28µg/m3 (RBKC Modelled Annual Mean Concentrations of Particulate
Matter).
The Ecological Sensitivity of the area is considered to be Low.
Based on Tables 4.6-4.9 of the Mayor’s SPG the risk categories are as follows:

Potential Risk
Impact

Demolition Earthworks Construction Trackout

Dust Soiling Medium Risk Low Risk Low Risk Low Risk

Human Health Low Risk Low Risk Low Risk Low Risk

Ecological Low Risk Low Risk Low Risk Low Risk

5.3 Demolition and Construction Monitoring


Throughout demolition and construction, a programme of monitoring shall be implemented to ensure
that condition limits are not exceeded and that all the relevant thresholds.
A dust, noise and vibration monitoring programme will be developed in consultation with RBKC to
ensure that dust, noise and vibration at sensitive receptors are adequately monitored and managed.
The site management shall carry out regular site inspections to monitor compliance with air quality
and dust control procedures, record inspection results, and make an inspection log available to the
local authority when asked. Increase the frequency of such monitoring if circumstances that may
result in higher emissions (e.g. prolonged dry weather) occur.

5.4 Training
The contractors operating on site will be expected to demonstrate that they have undertaken
appropriate training of their staff to ensure that they are aware of the measures that are to be taken
on site to minimise noise, vibration and dust generation.
All employees should be advised regularly of the following, as part of their training:
• The proper use and maintenance of tools and equipment and in particular, sound-reduction
equipment;
• The positioning of machinery on site to reduce the emission of noise to the neighbourhood
and to site personnel;
• The avoidance of unnecessary noise when carrying out manual operations and when
operating plant and equipment;
• The protection of persons against noise;
• The operation of sound measuring equipment (selected personnel).

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5.5 General Measures to be adopted
Hours of Work
The following standard permitted hours would be followed for Site work:
08:00 to 18:30 hours (Monday to Friday);
08:00 to 13:00 hours (Saturday); and
No working is permitted on Sundays or Bank Holidays.
Lorry Movements
• There shall be no Lorry movements to and from and at the Site outside the following hours:
o Between 9:30 hours and 15:00 hours Mondays to Fridays;
o and from 08.00 to 13.00 on Saturdays;
• There shall be no lorry movements on Sundays and Public Holidays;

Piling / Percussive Work


Works that involve the use of percussive or boring equipment (including piling) and which is likely to
propagate noise and vibration within adjacent residential dwellings, shall only be carried out between:
• 09:00 - 12:00 (Monday to Friday);
• 14:00 - 17:00 (Monday to Friday) or at other times as agreed; and
• At no time Saturday or Sunday.
Basement Excavation
The use of mechanical plant for excavation of the subterranean space shall only be carried out
between:
• 08.00 and 17.00 Monday to Friday or at other times as agreed, and
• At no time Saturday or Sunday.
Pre-site preparation
Prior to the commencement of the works the specialist ground works contractor will provide detailed
method statements for all aspects of the construction for approval by the engineer. These statements
will address all the site specific procedures described in the previous sections to necessary to
minimise any noise and vibration that may affect the neighbouring properties. The contractor shall
also:
• Identify responsible person in charge of environmental matters;
• Erect solid barriers at the site boundary;
• Erect effective barriers around dusty / noisy activities; and
• Ensure machinery, fuel and chemical storage and dust generating activities are not located
close to boundaries and sensitive receptors if at all possible.
Vehicles
• The frequency of vehicle movement will be confirmed by the chosen contractor and
approved by the council before works commence;

• All mobile vehicles associated with the demolition / construction should comply with the
standards of the London Low Emission Zone;
• Avoid unnecessary revving of engines, all vehicles should switch off engines when not
required - no idling;
• Manufacturers’ enclosure panels need to be kept closed;

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• Start up plant and vehicles sequentially rather than all together;
• Care should be taken to site equipment away from noise-sensitive areas;
• Where possible, loading and unloading should also be carried out away from such areas;
• The movement of plant onto and around the site should have regard to the normal operating
hours of the site and the location of any noise sensitive receptors as far as is reasonably
practicable;
• Where possible minimise noise from audible reversing alarms by planning vehicle movement
routes around site;
• All loads entering and leaving site to be covered;
• The exposure of wheels to soil will be limited. On this basis wheels will be hand cleaned
when required. A wheel wash will be will be provided to minimise dirt on the public highway;
and
• The footpaths and streets adjacent to the site will be cleaned each evening.
Equipment
• Non-road mobile machinery (NRMM) of net power between 37kW and 560kW shall conform
to the requirements set out in Chapter 7 Mayor of London’s SPG The Control of Dust and
Emissions during Construction and Demolition (July 2014);
• Compressors and generators – the compressor or generator Manufacturers’ enclosure
panels need to be kept closed, where possible the metal casing should be acoustically
dampened and an acoustic screen shall be placed between the equipment and noise
sensitive areas;
• Concrete Breakers hydraulic breakers and ‘munchers’ shall be used where appropriate
• Concrete mixing and batching – where possible this should be done behind a barrier and
when filling with aggregate this should not be allowed to fall an excessive height. Concrete
mixer drums should not be hammered.
• Noise Reduction Enclosures – where noise reduction enclosures are employed they shall
follow the guidance provided in section B2 of BS5228-1 to the satisfaction of the Director of
Environmental Health or Officers nominated by him.
Demolition
• Sheet and screen buildings with suitable material and where possible strip inside buildings
before demolition begins;
• Ensure that a specialist contractor removes any asbestos before demolition; and
• Materials should be removed from site as soon as possible.
• All brickwork and concrete demolition work is to be constantly watered to reduce any airborne
dust.
• Demolished materials are to be removed to a skip placed in front of the site which will be
emptied daily.
• The pavement to the sides of the property is to be washed and cleaned down each day.
• Any debris or dust / dirt falling on to the street and public highway will be cleared as it occurs
by designated cleaners and washed down fully every night.
Chute and Skips
• Securely cover all skips;
• Minimise drop heights to control the fall of materials by using variable height electrical
conveyors or chutes;

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• Regularly damp down surfaces with water;
• Completely enclose skips and chutes whenever possible;
Waste Disposal / Burning
• No bonfires;
• Segregate waste at source and recycle/dispose of in accordance with legislation.
Excavation and earthworks
• All dusty activities should be damped down, especially during dry weather;
• Temporarily cover earthworks if possible;
• Minimise drop heights to control the fall of materials; and
• Only remove secure covers in small areas during work and not all at once.
Stockpiles
• Make sure that stockpiles exist for the shortest possible time;
• Do not build steep sided stockpiles or mounds or those that have sharp changes in shape;
• Whenever possible keep stockpiles or mounds away from the site boundary, sensitive
receptors and surface drains; and
• Wherever possible, enclose stockpiles or keep them securely sheeted.
Cutting and grinding
• Ideally, cutting, grinding and sawing should not be conducted on-site and prefabricated
material and modules should be used;
• All equipment should use water suppressant or suitable local exhaust ventilation systems;
• Use dust extraction techniques where available;
• All other equipment should be fitted with water suppressant systems;
• Use local exhaust ventilation; and
• Service all fans and filters regularly to ensure they are properly maintained
Concrete Pours
• In order to avoid overruns past the site operating hours the pour size and concrete workability
shall be considered.
• The Site shall enter into a written protocol with the concrete supplier regarding timing of
deliveries to ensure works can be completed within the permitted hours.
• The protocol shall be deposited with the Director of Environmental Health or Officers
nominated by him.
• For basement works concrete shall be placed by gravity feed wherever practicable. Failing
this the position and location and acoustic shielding of any concrete pumps shall be as
agreed with Director of Environmental Health or Officers nominated by him.
BREEAM Commitments
A BREEAM assessment has been undertaken in support of the proposed redevelopment (Eight
Associates Preliminary Assessment BREEAM Domestic Refurbishment E756-Preliminary
Assessment-1409-18rm.docx) and of particular relevance this confirms that the chosen contractor
will:

• Operate an Environmental Management System such as ISO14001 ;


• Registered with the Considerate Constructors Scheme and will achieve a score of >35;

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• The design team has confirmed that a pre-refurbishment waste audit will be carried out in line with
ICE guidelines in order to establish materials that can be recovered, re-used and recycled. In
addition; and
• The contractor will be required to operate a site waste management plan in line with BREEAM
criteria, and meet their ‘best practice’ waste generation and diversion benchmarks.

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