Chapter 4 Environmental Impact Assessment

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1 Chapter 4 Environmental Impact Assessment

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3 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment Environmental Impact Assessment 4.1 Introduction This chapter explains the main stages in the Environmental Impact Assessment (EIA) process, the approach followed to complete the EIA, including the legal requirements and other guidance underpinning the EIA process and the general approach taken in assessing the various environmental effects. Specific methodologies used on the specialist assessments of environmental effects are described in more detail within the individual topics chapters. Within this Environmental Statement (ES) there are two levels of environmental assessment reported. The first is the main EIA undertaken of the Legacy Communities Scheme (LCS), the development which is being applied for, and which is described in Chapter 2 - The Proposed Development. This assessment work included the assessment of cumulative impacts with other consented developments within and surrounding the future Queen Elizabeth Olympic Park, as is required under the EIA Regulations. This is the core of the EIA and follows standard guidelines and procedures. However a second level of assessment has been undertaken which covers developments that may come forward in the future, or alternative baseline conditions which may prevail in place of those that are currently predicted. These other aspects have been assessed using what is termed a sensitivity test for the purposes of this document. The methods used for both identifying what elements require a sensitivity test, and how this test has been undertaken, is reported at the end of this chapter in section Legislative Framework If a development is likely to have significant effects on the environment then an EIA is likely to be required under the terms of the European Community Directive 97/11/EC, amending Directive 85/337/EEC on the assessment of the effects of certain public and private projects on the environment. This Directive is transposed into UK law through The Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 2011 (henceforth referred to as the EIA Regulations). Under the EIA Regulations certain types of project always require an EIA (Schedule 1 projects) and other project only require EIA if they are likely to give rise to significant environmental effects (Schedule 2 projects). The proposed LCS falls within Schedule 2(10b) (urban development projects) of the EIA Regulations. Schedule 2(10b) projects which are in excess of 0.5ha and likely to give rise to significant environmental effects are deemed to be EIA Development and it is a requirement that a formal EIA is undertaken and an ES prepared for submission to the local planning authority, which in this case is the Olympic Delivery Authority Planning Decisions Team (ODA PDT). 4.3 Environmental Impact Assessment Process The basic principles of the EIA process were identified in Chapter 1. To recap, EIA is the process of identifying the likely significant environmental effects anticipated to result from the construction, and operation of a proposed development, both in terms of positive and negative effects as well as direct and indirect effects. The results of an EIA are drawn together and presented in an ES. Although the ultimate aim of the Environmental Statement is to ensure that the Local Planning Authority (LPA) has a full understanding of the environmental implications, and associated commitments, when determining the application the EIA process is also a tool to help ensure that environmental constraints and opportunities are to be taken into account during the design of the project. It is therefore also a tool for optimising a development s environmental performance. The Environmental Statement also provides information for the public and other stakeholders, to allow them to submit their views to the LPA during the determination period. The EIA Regulations allow applicants, under the provisions of Regulations 5(1), to request a Screening Opinion from the local planning authority. This is an opinion as to whether or not a formal EIA is required. In the case of the proposed LCS, it is clear that a formal EIA is required, largely because of the scale of the development and the potential for significant environmental effects (especially arising from increased traffic); and therefore a formal Screening Opinion has not been requested from the ODA PDT. 4.4 Scoping Having established that an EIA is required, the next stage is to identify the topics and issues that will be the focus of the assessment and to eliminate any topics and issues that require no further consideration. This process is referred to as scoping and is usually documented in the form of a Scoping Report. There is no statutory requirement to undertake scoping, but it is considered best practice and a critical early activity that sets the context for a detailed assessment. The scoping process aims to: Identify the topics and issues to the focus of the EIA; Eliminate any topics and issues not requiring further consideration (i.e. those that are not likely to lead to significant effects) and which would therefore not be considered further in the EIA; Define the technical, spatial and temporal scope of the study for each of the topics and issues to be considered; Define the approach and methodologies for conducting baseline studies; Define the approach and methodologies for predicting environmental effects and for evaluating the severity and significance of environmental effects; Identify the methods to be adopted for incorporating mitigation and other environmentally driven modifications into the design; and Define the consultation strategy to be applied to the EIA process. Consequently, and in accordance with Regulation 13 of the EIA Regulations, an EIA Scoping Report was submitted to ODA PDT, as the local planning authority, in October 2010, for the purpose of requesting a formal opinion on the scope of the EIA and ES. The Scoping Report set out the proposed scope of the LCS ES and provided initial details on the basis for and assumptions underlying the EIA including the assessment years, assessment scenarios, the developments that would

4 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment 4-2 be considered during cumulative assessment and the approach to the assessment of environmental effects including construction impacts. The Scoping Report identified the following environmental topics to be considered within the EIA. Table 4-1 Environmental Topics Considered within the EIA Scoped In Where covered within the ES Soils, Geology and Contaminated Land Chapter 6 Waste Chapter 7 Water Resources Chapter 8 Traffic, Transport and Access Chapter 9 Air Quality Chapter 10 Noise and Vibration Chapter 11 Townscape and Visual Amenity Chapter 12 Archaeology and Cultural Heritage Chapter 13 Ecology and Biodiversity Chapter 14 Socio-economic and Community Impacts Chapter 15 Microclimate - Wind Chapter 16 Daylight, Sunlight and Overshadowing Chapter Consultation LCS Consultation A full programme of stakeholder engagement and consultation has been undertaken between 2008 and 2011 in order to inform the development of the LCS proposal. The stakeholder involvement strategy developed for the LCS has extended beyond standard consultation processes to include direct engagement and participation during the development of the LCS and beyond. Stakeholders include community, public and specialists stakeholders. The stakeholder involvement strategy and the process undertaken to date is documented in detail within the Statement of Participation (REF) submitted in support of the LCS planning application and included the following activities: Time-bound events e.g. Legacy Now launch event (29 th February 2008), Legacy Company vision launch (October 2010); Specialist stakeholder and community workshops; Large scale public roadshows; Mobile exhibition; Youth Programme, outreach activities, local forums, online information provision and collection, etc.; Legacy lecture series; and Legacy volunteers programme EIA Specific Consultation A list of statutory and non-statutory organisations consulted during the scoping stage and the preparation of the ES is provided in Table 4-2 below. The scope of the EIA has been refined following the consultation on the Scoping Report as well as further stakeholder engagement undertaken during the preparation of the ES. These are mostly matters of detail, in terms of baseline, assumptions and assessment methods, which are detailed in the individual assessment chapters. A formal response to the Scoping Report and request for a scoping opinion was received on 26th November A copy of the Scoping Report is provided in Appendix 1A, whilst the formal Scoping Opinion provided by ODA PDT is provided in Appendix 1B of the ES. Since this time there have been ongoing discussions with the ODA PDT, and a number of outstanding issues identified in the Scoping Opinion have now been addressed. These have included: A summary of the consultation undertaken as part of the EIA process, comments received and how these comments have been addressed within this Environmental Statement is included in Appendix 4A. Table 4-2 List of EIA Consultees Interim Assessment Years Cumulative Effects Assessment Phasing Assessment linked to other Supporting Documents Agreement of Topic Specific Significance Criteria Individual comments on the approach to each topic There have been a number of minor changes to the scheme since the scoping report was issued to ODA PDT; some of which have arisen through ongoing discussions with ODA PDT. These changes have been discussed with ODA PDT and this has not led to any proposed changes to the scope of the EIA as outlined in the Scoping Report. Statutory Consultees London Borough of Waltham Forest London Borough of Tower Hamlets London Borough of Newham London Borough of Hackney Natural England Highways Agency Environment Agency Non-Statutory Cosultees London Fire and Emergency Planning Authority Port of London Authority London Thames Gateway Development Corporation British Waterways Department for Transport Health Protection Agency Lee Valley Regional Park Authority.

5 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment 4-3 Table 4-2 List of EIA Consultees Table 4-3 Information Required for Inclusion in an Environmental Statement Statutory Consultees Non-Statutory Cosultees A description of the aspects of the environment likely to be significantly Baseline section of topics, Chapters 6 to 17 affected by the development, including in particular, population, fauna, Olympic Delivery Authority Hackney Neighbourhoods and Regeneration flora, soil, water, air, climatic factors, material assets, including the English Heritage Transport for London London Borough of Greenwich Greater London Authority architectural and archaeological heritage, landscape and the interrelationship between the above factors. 4.6 Environmental Statement The aim of this ES is to report the findings of the EIA that has been undertaken for the LCS. There is no statutory provision as to the form of an ES; however, the ES must include as a minimum the information specified in Schedule 4 Part 2 of the EIA Regulations; and relevant additional information as is reasonably required to assess the environmental effects of the project, as specified in Schedule 4 Part 1 of the EIA Regulations (Ref 4.1). Table 4-3 below sets out these information requirements, together with the location of this information within this ES. Table 4-3 Information Required for Inclusion in an Environmental Statement A description of the likely significant effects of the development on the environment, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects of the development, resulting from: The existence of the development; The use of natural resources; The emission of pollutants, the creation of nuisances and the elimination of waste and the description of the forecasting methods used to assess the effects on the environment. Identification of Impacts section of topics, Chapters 6 to 17 Assessment Methodology section of topics, Chapters 6 to 17 Assessment Summary Table in Appendix O EIA Regulations: Schedule 4, Part 1 Location within ES Description of the development, including in particular : A description of the physical characteristics of the whole development and the land use requirements during the construction and operational phases; Chapter 2 The Proposed Development A description of the measures envisaged to prevent, reduce and where possible offset any significant adverse effects on the environment. A non-technical summary of the above information. Identification of Mitigation Measures section of topics, Chapters 6 to 17 Assessment Summary Table in Appendix O Separate stand-alone document A description of the main characteristics of the production processes, for instance, nature and quantity of the materials used; An estimate, by type and quantity, of expected residues and Impacts section of each of the topics, Chapters 6 to 17 An indication of any difficulties (technical deficiencies or lack of knowhow) encountered in compiling the required information. Details are provided in each individual topic chapter. emissions (water, air and soil pollution, noise, vibration, light, heat, radiation, etc) resulting from the operation of the proposed EIA Regulations: Schedule 4, Part 2 Location within ES development. Description of the development, comprising information on the site, Chapter 2 The Proposed Development. design and size of the development. An outline of the main alternatives studied by the applicant or appellant and an indication of the main reasons for the choice made, taking into account the environmental effects. Chapter 3 Alternatives A description of the measures envisaged in order to avoid, reduce and, if possible, remedy significant adverse effects. Mitigation section of topics, Chapters 6 to 17 The data required to identify and assess the main effects which the Baseline section of topics, Chapters 6 to development is likely to have on the environment. 17 An outline of the main alternatives studied by the applicant or appellant Chapter 3 Alternatives and an indication of the main reasons for the choice made, taking into account the environmental effects.

6 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment 4-4 Table 4-3 Information Required for Inclusion in an Environmental Statement Baseline A non-technical summary of the above information. Separate stand-alone document In order to predict the potential environmental effects of the proposed LCS, the EIA process has compared the environmental conditions that will exist at the start of the development programme, i.e. without the LCS, with the conditions as they would be were the LCS to be constructed and occupied. The structure of the ES and that of individual chapters is outlined within Chapter 1 Introduction. 4.7 EIA Methodology This LCS ES has been prepared in accordance with the EIA Regulations, taking into account aspects of current best practice guidelines including: Environmental Impact Assessment. Department of the Environment, Transport and Regions (DETR) Circular 02/99 (Ref 4.2); Environmental Impact Assessment A Guide to Procedures. DETR 2000 (Ref 4.3); and Guidelines for Environmental Impact Assessment. Institute of Environmental Management and Assessment (IEMA) 2004 (Ref 4.4); Topic specific guidelines are referred to within the assessment methodology section of individual topic chapters. This section describes the overall EIA methodology followed for the assessment of the LCS. Methodologies used for assessing specific environmental topics are described in detail in the assessment methodology sections of individual topic chapters Spatial Scope The geographical, or spatial, scope of the assessment varies according to the environmental topic being assessed. For example, potential effects on archaeology are likely to be confined to those areas that will be physically disturbed by works, whilst the effects on air quality or visual impact could potentially be experienced at some distance from the site. Three geographical areas have been identified for the purpose of the assessment: LCS Red Line Boundary: Area defined by LCS planning application boundary (please refer to Figure 2.2 in Chapter 2). Inner Impact Area (IIA): Area defined on the basis of being within a 20 minutes walk from boundary of the LCS. (Figure 4.1) Outer Impact Area (OIA): The boundary of the outer impact area (OIA) has been derived from the boundary of the Opportunity Area Planning Framework (OAPF) and previous work on the Olympics Planning Application. The outer impact area has been kept consistent with this work to ensure a broad database of information and to keep data collection consistent. (Figure 4.1) The geographic area considered in the assessment of specific environmental topics is indicated in the individual topic chapters which in some cases go beyond the OIA. In this instance, most of the area where the LCS is proposed, the future Queen Elizabeth Olympic Park, is currently under construction in preparation for the London 2012 Olympic and Paralympic Games, with the development site only being released for development after the Games have concluded. The initial baseline position for the assessment of the LCS is therefore the completed Post Games Transformation (PGT) in December 2013/early 2014, which was granted planning permission in 2007, along with the permissions associated with the retained Olympic Venues, as set out within the 2007 Facilities and their Transformation Planning Application and associated EIA and Transport Assessment (TA); and subsequent consented amendments and new planning permissions, as described in Chapter 2 of this ES and the Planning Statement. A list of consented development identified within the inner impact area is provided in Appendix 4A. Given the relatively long period between the initial baseline conditions in 2013 and the predicted full built out date of 2031, consideration has been given as to how these conditions may change during the roll out of the development, and a prediction has also been made as to the likely baseline conditions during the intermediate assessment years (2021 and 2026) and final assessment year (2031), as described in the next section. Baseline conditions have been determined for each specialist environmental topic. The assumptions made in respect of such conditions are described in the baseline conditions section within individual topic chapters. Information contained within the Olympic Facilities and Legacy Transformation ES (Ref 4.5) has been used as the basis for the prediction of future baseline scenarios in the assumed start (2013) and intermediate assessment years (2021 and 2026). The baseline has been further enhanced by including data from monitoring reports from the Olympic Construction phase that have been made available during the assessment, e.g. BAP monitoring report 2010 (Ref 4.6); and where required, it has been supplemented with additional baseline surveys. It should be emphasised that all baseline scenarios are future predicted (or where appropriate, modelled) baselines for 2013 and may not necessarily be equivalent to the conditions prevailing at the time of assessment (spring/summer 2011). In the period of carrying out the assessment, the baseline was fixed to allow the technical assessments to be completed, and will not be subject to any further review. A key issue that should be considered when reading this Environmental Statement is the overall chronology of the Games and Legacy phases and the position of the chosen baseline scenario, against which environmental effects have been assessed, within this timeline. The Olympic Park site was originally an area of contaminated, low-grade and under-utilised industrial land. Through the various stages of the Olympic Games development process, what is to become known as the Queen Elizabeth Olympic Park will provide a vastly improved setting for the residential housing, employment space, community facilities and infrastructure which are proposed in the LCS planning application and will not only benefit the people who come to live there but the wider London community. The Olympic Park has been designed to be a high quality landscape, with exceptional visual character. Once the 2012 Games have concluded, some of the features within the Park such as the main venues will be retained for future use by the local community, whilst the Olympic Park will have served its purpose of hosting the games. At this point in time, the long-term regeneration proposals for the area, as outlined in the early stages of the bid to host the 2012 Games, will need to be pursued in order to ensure the Application Site does not

7 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment 4-5 remain vacant and not contribute to the regeneration of the wider area, as has been the case with some previous Olympic Games sites. This will require the transformation and Legacy development of the Olympic Park, which was designed to enable the 2012 Games to take place. This will result in changes to some of the features which are a result of the Games and Post Games Transformation development whether these were intended features or not, for example, long distance vistas through the Park. This EIA has considered the transformed Olympic Park after the 2012 Games as the baseline scenario against which to assess the potential environmental effects of the LCS proposals; This baseline scenario is however, only one stage in the overall time line from the preparation of the Olympic Park to the ongoing regeneration of the area. The design work and EIA technical analysis has ensured that the Legacy development is as compatible as possible with the original design concept for the Olympic Park, especially its retained venues, whilst at the same time ensuring that adverse environmental effects are addressed and opportunities for enhancement incorporated whenever possible. Examples include alterations to development Parcels in PDZ6 to continue views from the Velodrome to the Stadium and also changes to PDZ1 to continue views of Aquatics Centre from PDZ Assessment Scenarios & Years An indicative phasing programme for the delivery of the LCS has been developed for the purpose of this EIA based on a number of considerations including market attractiveness of plots, assumed market take-up rates, place making principles, timely delivery of social and key infrastructure ( infrastructure triggers ). Three main LCS delivery phases have been proposed as follows: Phase One covers a period from 2013 to 2014 and includes minor amendments to the consented Post Games Transformation proposals approved by the ODA Planning Decision Team in July These minor amendments will be submitted as a separate but related Planning Application, expected to be submitted at the end of Phase Two of the LCS development is anticipated to be occupied from 2015 to 2021 and is expected to deliver up to: o 257,278sqm Residential (C3); o 10,821sqm Retail (A1, A2, A3, A4, A5); o 2,610sqm Employment (B1a); o 14,500sqm Hotel (C1); o 10,541sqm Cultural Facilities (D1); o 2,300sqm Leisure Facilities (D2); and o 10,000sqm Student Accommodation (C2).Phase 3: is anticipated to be occupied from 2022 to 2031 and is expected to deliver up to 460,585 sqm of floorspace. Phase Three, the final phase of the LCS development, is anticipated to be occupied from 2022 to 2031 and is expected to deliver up to: o 380,916sqm Residential (C3); o 15,167sqm Retail (A1, A2, A3, A4, A5); o 27,759sqm Employment (B1a); o 15,770sqm Employment (B1b, B1C); o 19,668sqm Cultural Facilities (D1); and o 1,306sqm Leisure Facilities (D2). It is also assumed that the construction works will involve a consistent level of, predominantly, housing development across each LCS phase, with no significant peaks in development activity across the whole construction period. It should be noted however that in order to retain the necessary flexibility to adjust the implementation of the scheme in response to prevailing market conditions, no commitment can be made at this stage to specific calendar dates for completion of the whole scheme or individual Planning Delivery Zones (PDZ). In order to undertake a robust EIA which considers the likely significant effects of the proposed development across the entire construction period, a number of assessment scenarios and intermediate assessment years have been agreed with ODA PDT at appropriate points in the development programme. The principal assessment year and interim assessment years for the purpose of the EIA are as follows: 2021: Interim Assessment of assumed development at 2021 upon completion of the LCS Phase and Phase 2 (approximately one third of total development). The baseline for this assessment includes background development i.e. that which was assumed for the 2013 baseline. 2026: Interim Assessment of assumed development at 2026 (approximately two thirds of total development). The baseline for this assessment includes background development i.e. that which was assumed for the 2013 baseline. Assessment in this year is limited as there is no indicative spatial phasing available. Assessment for this year is largely qualitative in nature. 2031: Principal Assessment of assumed development at 2031, upon completion of LCS Phase 3 (development completed in its entirety). The baseline for this assessment includes background development i.e. that which was assumed for the 2013 baseline. In addition, in 2021 and 2026 there will be a need to consider the potential interactions with the Interim uses (see section ), the possibility of a 60,000, rather than a 25,000, seat stadium, a delay to the opening of Crossrail and the developments that may be promoted under the Olympic Legacy Supplementary Planning Guidance (OLSPG). These will be dealt with in the form of sensitivity tests, the format of which is described later in this chapter (see section 4.9). Table 4.4 below illustrates the total development scenario that will be assessed, in various ways, for each of the assessment years. Phase 3 has been split into two sub phases to account for the interim assessment year in 2026 Table 4.4 Development scenarios assessed for each assessment year. Assessment Year LCS Phase 1&2 ( ) LCS Phase 3a ( ) (qualitative only) LCS Phase 3b ( ) Consented Developments (DAD/SHLAA) Table 4.4 Sensitivity Testing scenarios assessed for each assessment year. Assessment Year

8 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment 4-6 Table 4.4 Sensitivity Testing scenarios assessed for each assessment year. Table 4.5 Assessment Scenarios and Years Considered for Each Environmental Topic Assessment Year Interim Uses Without Crossrail Olympic Legacy SPG 60,000 seat stadium The level of assessment necessary at different phases of the development will vary from topic to topic. For a number of topics an assessment linked to the time when the environmental effects are occurring will provide a more accurate approach than using fixed assessment dates. This is the case for topics such as archaeology and cultural heritage. For other topics where baseline conditions are likely to change over time as new receptors are introduced into the area (e.g. housing is constructed and occupied having an effect on traffic levels within the site) assessment of intermediate years has been undertaken. This will vary between chapters and each chapter outlines the approach that has been taken. The most objective way to assess the likely significance of environmental effects is to undertake a quantitative assessment. Quantitative assessment is possible when the effects of the development can be modelled, and typically this is possible for traffic and transport, air quality, noise and vibration, flood risk, daylight, sunlight and overshadowing and microclimate assessments. The benefit of this approach is that the results of the modelling work can be directly compared to guideline or mandatory environmental quality standards. For other topics or scenarios the baseline data does not lend itself to quantitative analysis and the assessment is therefore qualitative and more subjective as a result. Topics for which qualitative assessment is typically undertaken include townscape and visual amenity, soils and geology, and biodiversity. A summary of the level of assessment that has been undertaken across the development period for each environmental topic is provided in Table 4.5 below. Table 4.5 Assessment Scenarios and Years Considered for Each Environmental Topic Environmental Assessment Coverage Topic Environmental Topic Waste Water Resources Traffic Transport and Access Air Quality Noise and Vibration Townscape and Visual Amenity Assessment Coverage The assessment is based on a strategy for managing waste over the entire construction period, as well as the full build out in No additional or differing effects are likely outside of the general operation of the scheme, and it is not therefore considered necessary to assess the effects of interim assessment years. An assessment has been undertaken for 2031 which includes the modelled flood risk assessment and qualitative assessment of the effects on water quality. The assessment of construction effects is considered for the entire construction phase. No additional or differing effects are likely outside of the general operation of the scheme, and it is not therefore considered necessary to assess the effects of interim assessment years. A full assessment based on full traffic model outputs has been undertaken for both 2021 and Where the 2031 results indicated potential effects, limited qualitative assessment was undertaken for other interim years. The air quality assessment is linked to the traffic model outputs: A fully modelled assessment has been undertaken for both 2031 and A limited quantitative assessment has been undertaken for 2026 based on the results of the 2021 and 2031 model runs and the likely build out for these assessment years. The noise and vibration assessment is linked to traffic model outputs.: A fully modelled assessment has been undertaken for both 2031 and A limited quantitative assessment has been undertaken for 2026 based on the results of the 2021 and 2031 model runs and the likely build out for these assessment years. A full assessment has been undertaken for 2031, including Zones of Theoretical Visibility (ZTV) and photomontages. An assessment in 2021 to capture the changes up to this date in visual amenity and on adjacent townscape character. This has included additional Zones of Theoretical Visibility (ZTV); however, no photomontages are provided for this period. As there is no information available regarding the likely development plots that will be built out by 2026, and the TVIA is so reliant upon this information, an interim assessment for 2026 has not been possible. Soils, Geology and Contaminated Land A full assessment of operational effects has been undertaken for The assessment of construction effects is considered for the entire construction phase. Effects relate mainly to the operational effects of the use of residential gardens, and therefore assessments in the interim assessment years are not considered necessary. Archaeology and Cultural Heritage The archaeological assessment is linked to the period when impacts are likely to occur, as they will result from construction, as opposed to a fixed assessment date. Assessment of effects on the setting of cultural heritage features is linked to the Townscape and Visual Amenity assessment and is therefore considered for 2021 and 2031 assessment years.

9 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment 4-7 Table 4.5 Assessment Scenarios and Years Considered for Each Environmental Topic Environmental Assessment Coverage Topic The EIA Regulations require the ES to provide a description of the proposal in terms of location, size and design that would allow for the assessment of the likely significant environmental effects of the project (adverse and beneficial). In using the term likely the EIA Regulations are seeking to ensure that the main effects have been identified that could well happen, and not necessarily all theoretical effects, unlimited by the application of reasonable assumptions. A fully modelled assessment has been undertaken for Microclimate - A qualitative assessment (based on professional judgement) has been undertaken for 2021 Wind and 2026 based on the results of the 2031 model outputs and the likely build out for these assessment years A fully modelled assessment has been undertaken for 2031 Daylight, A qualitative assessment (based on professional judgement) has been carried out for 2021 Sunlight and and 2026 based on the results of the 2031 model outputs and the likely build out for these Overshadowing assessment years. A full assessment has been undertaken for the full build out in Ecology and A qualitative assessment (based on professional judgement) has been carried out for 2021 Biodiversity and 2026 based on the likely build out and the proposed long-term biodiversity strategy for the area. A full quantitative assessment has been undertaken for 2031and Socio- A qualitative assessment based on professional judgement has been undertaken for 2026 Economic based on the results of the 2021 and 2031 outputs and the likely build out for these assessment years. A comprehensive assessment has been undertaken for Cumulative A qualitative assessment based on professional judgement has been undertaken for 2026 Impacts based on available information on the development schedule and extrapolated from the results of the 2021 and 2031 assessments All technical teams have assessed construction effects based on the commencement of some elements of construction in The teams have also been asked to consider whether bringing forward the construction of buildings in 2013 would in any way affect the findings outlined in this document. The conclusion of this element of assessment is provided in Chapter 18, section In addition, all technical teams have considered the potential effects of the proposal which is the subject of the separate planning application for the District Heat Network Extension (DHNE). For each topic there has been an assessment as to whether any separate likely significant environmental effects arise specifically from the DHNE proposal. The result of this assessment was that no separate environmental effects were identified for any of the topics. For this reason there is no separate reference to the effects of the DHNE in any of the topic specific chapters.basis for Assessment The LCS is a long term regeneration project which is expected to be developed over a period of 18 years from In order to provide a degree of flexibility to allow some evolution of the proposals over this period, in particular in response to changing market conditions, the planning application seeks outline planning permission for the LCS. As individual development parcels are brought forward, the detailed design will be considered at the Reserved Matters stage. A number of legal cases have helped to clarify the requirements of the EIA Regulations in relation to outline planning applications and the need to provide sufficient detail within the proposal to enable identification and assessment of likely significant environmental effects; whilst retaining the flexibility required for the successful delivery of the scheme. In this respect the Rochdale cases are relevant to the LCS planning application in that they provide clarification on the information required to describe the proposed development. The key points arising from these cases which are considered applicable to the LCS EIA are summarised below: the outline planning application should acknowledge the need for details of a project to evolve over a number of years, within clearly defined parameters; the EIA should take account of the need for evolution within those parameters, and reflect the likely significance of such a flexible project in the ES; within those defined parameters of the project, the level of detail of the proposals must be such as to enable a proper assessment of the likely significant environmental effects and the identification of mitigation measures, if necessary considering a range of possibilities: the assessment may conclude that a particular effect may fall within a fairly wide range. In assessing the likely effects, it is entirely consistent with the objectives of the Directive to adopt a worst case approach. Such an approach will then feed through into the mitigation measures envisaged...it is important that these should be adequate to deal with the worst case, in order to optimise the effects of the development on the environment ; it is for the local planning authority, in granting outline planning permission, to impose conditions to ensure that the process of evolution keeps within the parameters applied for and assessed. In order to provide an adequate definition of the scheme for the purpose of the EIA, a Development Specification & Framework (DSF) has been prepared which sets out the description of the LCS development for which planning permission is sought. The key purpose of the DSF is to provide the crucial linkage between the environmental information provided in the ES and the description of the project in those areas where flexibility is provided to enable the scheme to evolve over the development period. It does so together with the parameter plans by specifying the parameters, constraints and restrictions within which the flexible elements of the project must be contained, in the subsequent approval processes so that the scheme remains at all times within the scope of the EIA process related to the permission granted. For the LCS, the site has been divided into Planning Delivery Zones (PDZs) which reflect distinctive areas of character within the planning application site. PDZs have been further divided into a series of aggregated building plots or Development Parcels (DP). In addition to the DSF and associated Parameter Plans, a Design and Access Statement (DAS) has been prepared which sets out the design rationale for the proposals, leading to Design Codes for the site and specific to each PDZ with which the detailed design proposals will need to comply. The Design Codes are submitted as part of the application and it is anticipated that these will be subject to a condition whereby all future development on the site will need to comply with them.

10 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment 4-8 The EIA process reported in this ES has assessed the LCS scheme within these defined parameters, and identified the likely significant effects of the LCS development on the environment. If granted, the planning permission will include planning conditions to ensure that all reserved matters applications brought forward under the outline planning permission (or any application for other approvals required under the outline planning permission) comply with these defined parameters. Reflecting the long development period, the proposed Parameter Plans necessarily allow for a degree of flexibility in the form of development. This flexibility on the parameters could theoretically lead to some forms of development which may not necessarily be realistic in terms of buildability. For example, when maximum building height parameters are applied to the fullest possible extent this could theoretically result in large imprecise building blocks occupying whole Development Parcels. In reality the parameters will be tempered by both the maximum floor spaces shown in the development schedule and the Design Codes which, when applied to the parameters, will limit the scale of the built form and add further levels of detail. Given the need to assess the likely significant environmental effects (not every possible environmental effect, however minor or unlikely), the flexibility incorporated within the parameters presents the EIA process with a challenge when deciding which, of all the possible permutations of development that could be delivered within the parameters, to use for the assessment of likely significant environmental effects. If maximum parameters are assessed, the effects identified may not necessarily be likely ; rather they would be the unrealistic worst case scenario. On the other hand, if particular, more realistic, development assumptions are used to allow for the assessment of a reasonable worst case scenario, this could result in the inaccurate assessment of effects, as a scheme could in theory come forward which differs from the development assumptions assessed. In addition, the large number of design permutations that are possible within the parameters would require individual assessment teams to consider a large number of variations, without this necessarily providing the desired accuracy in assessing likely significant effects. This EIA has sought to address the above issues by following a combination of different approaches, developed to produce an appropriate assessment for each respective individual topic: For certain topics e.g. soil, geology and contaminated land, water resources, and waste, spatial parameters such as building heights are not relevant in terms of their assessment of likely significant effects. For example, however tall a residential building is, there are no implications in terms of contaminated land; the main factor that is important is whether the residence has a garden For certain topics e.g. air quality and noise, the initial assessments have been undertaken based on maximum parameters, and in many cases it has been found that the parameters are not in fact a critical factor in the significance of effects. The main driver of significance for air quality and noise has been shown to be traffic figures. The traffic information has been derived from the traffic model, which in turn has been derived from the maximum floorspace. This is therefore considered to be a reasonable worst case. For certain topics e.g. microclimate-wind, daylight, sunlight and overshadowing; a staged approach is considered more appropriate. This provides an initial assessment based on the maximum parameters model. Where significant effects are identified, further design assumptions are applied in order to define the likely significant effects. The assessment of residual effects is then considered to be based on a reasonable worst case scenario. Tables are provided in each chapter that define the basis of assessment for each of the specific technical assessments. In order for a robust assessment of the social and economic impacts of the LCS, it was necessary for that assessment, to make various assumptions as to unit mix, unit size and affordable housing provision (including quantum and tenure). Details of these assumptions are set out in the Housing and Social Infrastructure Statement [ref: LCS-GLB-ACC-HSIS- 001], Assessment of Significance Introduction The purpose of an EIA is to assess the likely significant effects of a project on the environment. The determination of the significance of the potential effects arising from the proposed LCS development is therefore a key stage in the EIA process. There is no statutory definition of what constitutes a significant effect within the EIA Regulations. However, significance is generally taken as a function of the importance or sensitivity of a feature (e.g. rarity, fragility, replaceability, and value of the feature or resource as well as the resilience of the feature potentially affected) and the magnitude of the potential effect (which may encompass matters such as: duration, spatial extent, and frequency of the effect). Significance is generally determined on the basis of expert judgement applied to qualitative information. however, for certain environmental effects e.g. human receptors affected by adverse air quality or noise, the significance of the effect is determined with reference to the predicted level of effects set against accepted levels of exposure e.g. environmental quality standards, providing a quantified assessment of significance Generic Approach to Assessment of Significance In order to help describe the general process through which significance is determined, the following paragraphs and tables provide a generic approach. The detailed approach taken for each of the separate topics varies from this approach to a greater or lesser extent. However, the basic principles apply throughout all of the technical assessments. For some of the technical assessments there are topic specific published guidelines, and where this is the case these have been used and references made to the relevant publication. The following generic criteria have been used (where appropriate to the issue being addressed) in this ES to inform the assessment of the significance of an effect: Extent and magnitude; Duration of effect i.e. short, medium or long term; Reversibility of effect; Sensitivity and value of receptor; Comparison with legal requirements, policies and standards; Comparison with applicable environmental thresholds; and Effectiveness of mitigation (residual effects). Taking into account the above criteria, the significance of the effects arising from a development can be categorised using a seven point scale, as illustrated in table 4-7 below. Table 4-6 Significance Categories Value of Resource Magnitude of Effect V. High High Medium Low Negligible V. Large Major Major Moderate Moderate Minor

11 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment 4-9 Large Major Moderate Moderate Minor Minor Medium Moderate Moderate Minor Minor Neutral Small Moderate Minor Minor Neutral Neutral Negligible Minor Minor Neutral Neutral Neutral Table 4-7 Significance Categories and Descriptions Significance of Effect Major adverse Moderate adverse Minor adverse Typical Description A large and detrimental change, likely or apparent exceeding of accepted (often legal) threshold A medium scale change which, although not beyond an accepted threshold, is still considered to be significant (due to scale, duration etc) A small change that, whilst adverse, is not significant and does not exceed legal or guideline standards. Neutral No appreciable or material change No Minor beneficial Moderate beneficial Major beneficial A small positive change, but not one that is likely to be a key factor in the overall balance of issues A medium scale change that is significant in that it the he baseline conditions are improved to the extent that guideline targets (e.g. UK BAP targets) are contributed to. A large and beneficial change, whereby the improvements to the baseline are significant and previously poor conditions are replaced by new legal compliance or a major contribution is made to national targets. Considered to be a significant effect As discussed, each discipline has further refined the above typical criteria for assessing significance based on relevant standards / guidelines for its particular topic. Alternative categories have been applied where topic specific methodologies favour their use (e.g. slight, substantial and negligible ). A detailed explanation of the specific criteria used for the assessment of each individual topic is set out in the Assessment Methodology section of individual ES chapters Assessment of Construction Effects The identification of construction effects has been made on the basis of existing knowledge, techniques and equipment. A notional reasonable worst case scenario has been used for each specialist assessment with respect to the envisaged construction methods, location (proximity to sensitive receptors), phasing and timing of construction activities. As identified previously it is anticipated that there will be a steady build out of Development Parcels and as such there will be no peak construction year. As part of the supporting planning application documentation, a Code of Construction Practice (CoCP) (Ref 4.8) has been prepared. The Code of Construction Practice (CoCP) supports the planning applications for site preparation works, infrastructure construction and works for the development of the LCS. It sets out management measures which No No the Legacy Company will require its developers and contractors to adopt and implement for any construction within the LCS Site and related off-site activities. The CoCP sets out a series of objectives and measures to be applied throughout the LCS construction activity, to maintain satisfactory levels of environmental protection and limit disturbance from construction activities as far as reasonably practicable. The developer s or the contractor s team will be required to appoint a suitably qualified Environmental Manager (EM) who will be responsible for monitoring and auditing compliance of the projects with all environmental commitments set out in the CoCP and elsewhere in other relevant environmental legislation. The EM will report to the Legacy Company. In addition to the CoCP, a number of other documents are also being submitted in support of the planning application which set out the environmental standards and commitments that will apply across the LCS development. These include the following: Global Remediation Strategy (GRS): The GRS establishes the principles and approach to the assessment of potential effects from the LCS on the standard of remediation undertaken under the consented 2007 Olympic scheme. Furthermore the GRS provides a framework for further ground contamination assessment works in the event that new pollutant linkages are assessed to be introduced through the LCS. Construction Transport Management Plan (CTMP): The Applicant is keen to promote the sustainable transportation of construction material. The Applicant will, following the grant of permission, submit a Construction Transport Management Plan (CTMP) for approval by the LPA under a condition anticipated on the planning permission sought. This will be enforced by the Applicant on all principal contractors, sub-contractors, developers and others who deliver the development, as well as by the LPA under the condition anticipated on the planning permission. It will be updated and reviewed as required in conjunction with the LPA in accordance with the planning condition. Construction Environmental Management Plans (CEMPs): Individual contractors and developers will be required to prepare and implement individual Construction Environmental Management Plans (CEMPs). The CEMPs will set out how the contractor intends to operate the construction and work sites and will set out the specific control measures necessary to deliver the requirements of the CoCP. It will also set out a regime for auditing/monitoring the implementation of the CEMP. These plans will be subject to the approval of the Applicant, as well as being enforceable by the LPA under a condition anticipated on the planning permission sought. Demolition and Site Waste Management Plan (DSWMP): The Applicant will, following the grant of permission, submit a Demolition and Site Waste Management Strategy (DSWMS) for approval by the LPA under a condition anticipated on the planning permission sought. Individual principal contractors and developers will be required to prepare and implement Site Waste Management Plans (SWMP), in accordance with the Code of Construction Practice and the requirements of the Environment Agency (EA). The assessment of construction effects assumes the implementation of generic mitigation measures as set out in the above documents e.g. use of temporary noise barriers to reduce noise levels where appropriate and practicable, control of dust on haul roads etc. The purpose of this is to focus on the scheme specific effects, rather than generic construction effects that can be easily addressed using generic site practices and methods. The ES identifies and assesses construction effects that are likely to remain after these mitigation measures are in place. Reference to the CoCP and other relevant documents is made throughout the ES, as applicable, where it provides mitigation for predicted effects.

12 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment Additional Assessments In addition to the main assessment of environmental effects, the following assessments have been undertaken as part of the LCS EIA process: Assessment of Cumulative Effects; and Sensitivity Testing. The assessment of cumulative effects takes into account those consented developments in the vicinity of the LCS. Consented schemes where development will be completed during or before 2013 have been identified and form part of the 2013 baseline. This includes the Westfield development. Schemes that have received planning permission but for which construction will not begin until after 2013, have been considered as part of the cumulative effects assessment. A schedule of the consented developments that have been considered as part of the cumulative effects assessment is provided in an Appendix 4A of the ES. A cumulative effect assessment for these schemes has been undertaken for the 2021 intermediate assessment year and final year of The consented schemes that form part of the cumulative assessment but not the baseline are shown on the following Figure 4.1. In addition, a sensitivity testing approach has been followed for the consideration of certain elements of development relating to the wider Queen Elizabeth Olympic Park for which planning consent has not been granted but which could impact on LCS. As these developments are not consented at the time of the assessment, they are not included within the formal cumulative effects assessment Approach to Cumulative Effects Assessment The EIA Regulations require the ES to consider the cumulative effects of the proposed development. In the context of EIA, cumulative effects are generally described as the combined effects of different development activities within the vicinity of the development site, or those of different aspects of a single development on a particular receptor. The assessment of cumulative effects has been undertaken in accordance with the following best practice guidelines: Guidelines for the Assessment of Indirect and Cumulative Effects as well as Effect Interactions (European Commission, May 1999) Addressing Cumulative Effects (Canadian Environmental Agency, 1999) Two types of cumulative effects have been assessed: Cumulative effects arising from simultaneous construction activities within the LCS site: Following the completion of the assessment of each PDZ, individual environmental topics have considered any potential cumulative effects as a result of simultaneous construction activities on adjacent PDZs. The final assessment for each PDZ has been based on the findings of all technical chapters and professional judgement. The spatial scope of this assessment has been restricted to within the red-line boundary. Cumulative effects arising from the LCS and other nearby consented schemes being under construction at the same time or having overlapping operational phase effects, which are not accounted for in the baseline used within the assessment. The cumulative effects assessment for the LCS has been based upon the best available public information (at the time of commencement of the assessment in April 2011) on consented or existing developments in the wider area, including the Strategic Housing Land Availability Assessment and Housing Capacity Study (SHLAA/HCS) as well as other types of consented development, for which information has been sought from each of the relevant local planning authorities and which has been developed into the applicant s Development Application Database (DAD).

13 Legacy Communities Scheme: Environmental Statement Chapter 4: Environmental Impact Assessment 4-11 Fig 4.1 Sites Selected for Cumulative Effects Assessment. 1. Stratford Village Clays Lane 2. Stratford City Development Fairfield Road 4. Site at North East Junction of Morris Road Bow Common Lane 6. Land at West side of Homer Road at intersection with Wick Road 7. Bridge House Shepherds Lane