Port of Hull Local Development Order

Transcription

1 Port of Hull Local Development Order Integrated Environmental Assessment Non Technical Summary March 2012 Final Prepared for: Hull City Council UNITED KINGDOM & IRELAND

2 REVISION SCHEDULE Rev Date Details Prepared by Reviewed by Approved by 0 February 2012 Integrated Environmental Assessment Non Technical Summary Laura Morrish Environmental Specialist Kirsty Cobb Associate Neil Stephenson Technical Director Consultation Draft 1 March 2012 Integrated Environmental Assessment Non Technical Summary Laura Morrish Environmental Specialist Kirsty Cobb Associate Neil Stephenson Technical Director Final URS WestOne Wellington Street Leeds LS1 1BA INTEGRATED ENVIRONMENTAL ASSESSMENT, NON TECHNICAL SUMMARY March 2012 i

3 CONTENTS Section 1 Introduction 1 Section 2 The Proposed Local Development Order 4 Section 3 Planning Policy 14 Section 4 Socio-Economics 16 Section 5 Land Use, Public Rights of Way and Recreation 18 Section 6 Transport Assessment 19 Section 7 Noise and Vibration 22 Section 8 Air Quality and Dust 24 Section 9 Water Quality and Hydrology 25 Section 10 Flood Risk Assessment 27 Section 11 Terrestrial Ecology and Nature Conservation 28 Section 12 Cultural Heritage 31 Section 13 Landscape and Visual Amenity 32 Section 14 Land Quality 35 Section 15 Waste Management 37 Section 16 Cumulative and Combined Effects 38 FIGURES (PROVIDED AT THE END OF SECTIONS): Figure A Site location plan showing LDO sites at the Port of Hull Figure B Site 1 Alexandra Dock indicative proposals Figure C Site 2a Queen Elizabeth Dock North indicative proposals Figure D Site 2b Queen Elizabeth Dock South indicative proposals Figure E Traffic and transportation study area and site access points Figure F Main surface water features Figure G Protected nature conservation sites close to the LDO sites Figure H Viewpoints for visual assessment Figure I Other developments close to the LDO sites INTEGRATED ENVIRONMENTAL ASSESSMENT, NON TECHNICAL SUMMARY March 2012 ii

4 1 Introduction 1.1 Background Hull City Council proposes to make a Local Development Order (LDO) for renewable energy related development on three sites within the Port of Hull. A LDO is a tool to simplify the planning requirements for development within a defined area and defined parameters. The Town and Country Planning Act 1990 grants local planning authorities the powers to make Local Development Orders, and the Town and Country Planning (Development Management Procedure) (England) Order 2010 sets out the procedures that must be followed to prepare and adopt an LDO including consultation requirements. Further information is provided in Section 2 (The Proposed Local Development Order) of this Non Technical Summary (NTS). 1.2 Single Integrated Environmental Assessment Report Given the nature, size and location of the development permitted by the LDO (as described in Section 2 (The Proposed Local Development Order) of this NTS), the following environmental assessments are required: Environmental Impact Assessment (EIA) for development that falls under Schedule 2 of the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 2011 ( the EIA Regulations ); Flood Risk Assessment (FRA) in accordance with Planning Policy Statement (PPS) 25: Development and Flood Risk (Department for Communities and Local Government (DCLG), 2010); and Transport Assessment (TA) in accordance with the Department for Transport guidance (Department for Transport (DfT) / DCLG, 2007) The Integrated Environmental Assessment (IEA) Report contains all three of the above assessments in a single report The following additional work elements are included within the IEA Report for completeness and ease of reference: Utilities Assessment (see Appendix 5A of IEA Report Volume 2); Flood Risk Assessment sequential test (see Appendix 10A of IEA Report Volume 2); and outline Site Waste Management Plan (see Appendix 16A of IEA Report Volume 2) A separate Design and Access Statement has not been prepared for the LDO as this will be considered at the reserved matters planning stage, but development design parameters are covered in Section 13 (Landscape and Visual Amenity) of this NTS and transport/ access issues are described in Section 6 (Transport Assessment) of this NTS. Integrated Environmental Assessment Report Non Technical Summary March

5 1.3 Non Technical Summary This document provides a NTS of the EIA, FRA and TA that have been carried out. Technical details are provided in the IEA Report (Volumes 1-3). A NTS is specifically required for EIA in accordance with the EIA Regulations. EIA is a formal process for identifying the potential environmental impacts of a proposed development and assessing the significance of any likely environmental effects that may result, then identify ways to reduce adverse effects (mitigation measures) Key environmental topics to be considered by the IEA for the LDO developments were identified through an informal scoping process. Following a briefing for statutory consultees on the general scope and purpose of the LDO by Hull City Council, an informal IEA Scoping Document was circulated to the statutory consultees and a scoping meeting was then held to provide an opportunity for feedback and discussion The scoping process concluded that the following technical topics are relevant to the IEA: socio-economics; land use, Public Rights of Way, recreation and amenity; traffic and transportation; noise and vibration; air quality and dust; water quality and hydrology; flood risk and drainage; terrestrial ecology and nature conservation; landscape and visual amenity; cultural heritage; land quality; and waste management Wherever possible each of the specialist sections of this NTS describing the potential impacts of the LDO developments has been set out in the same broad format for ease of comparison. Firstly the current environmental conditions relevant to the assessment are identified and then the changes ( impacts ) that are predicted to occur due to the construction and operation of the LDO developments are identified. The results of the predicted changes are called effects, and these are described as significant or not significant following consideration of the scale of change and the nature of the receptor. Significant effects are those which are considered to be important and may require mitigation (i.e. measures to reduce adverse effects) In order to consider the impacts of the LDO developments it is also necessary to consider any other changes that may occur in future without the LDO developments, so that these two scenarios can be compared. Integrated Environmental Assessment Report Non Technical Summary March

6 1.3.6 A great deal of relevant information for the IEA is available from the EIAs, TAs and FRAs undertaken for three other proposed developments within the LDO area (see Section 2 (The Proposed Local Development Order) of this NTS) for which applications have been submitted. For ease of reference these are referred to as the three proposed developments. Information contained within these assessments has been relied upon to inform this IEA The IEA has been undertaken by URS with input from JMP Consultants Ltd. The authors of each section of the report are listed in Table 1. Table 1: Authors Chapter Number Chapter Title Authors Chapter 1 Introduction URS Chapter 2 The Proposed Local Development Order URS Chapter 3 Planning Policy URS Chapter 4 Socio-Economics URS Chapter 5 Land Use, Public Rights of Way and Recreation URS Chapter 6 Transport Assessment JMP Consultants Limited Chapter 7 Noise and Vibration URS Chapter 8 Air Quality and Dust URS Chapter 9 Water Quality and Hydrology URS Chapter 10 Flood Risk Assessment URS Chapter 11 Terrestrial Ecology and Nature Conservation URS Chapter 12 Cultural Heritage URS Chapter 13 Landscape and Visual Amenity URS Chapter 14 Land Quality URS Chapter 15 Waste Management URS Chapter 16 Cumulative and Combined Effects URS and JMP Consultants Limited Chapter 17 Summary of Significant Environmental Effects URS and JMP Consultants Limited Integrated Environmental Assessment Report Non Technical Summary March

7 2 The Proposed Local Development Order 2.1 The Humber Enterprise Zones Enterprise Zones offer tax breaks to businesses locating within them in the form of discounted business rates and enhanced capital allowances on plant and machinery. A simplified planning process (such as that provided by the proposed Port of Hull LDO) and superfast broadband are also proposed There are two Enterprise Zones relevant to the proposed Port of Hull LDO. The Humber Renewable Energy Super Cluster Enterprise Zone was approved by Government in August 2011, and the Humber Green Port Corridor Enterprise Zone was approved in November These Zones cover sites on the north and south banks of the Humber Estuary. The aim of the Humber Enterprise Zones is to attract large top tier manufacturing companies (Original Equipment Manufacturers (OEMs)) and associated supply chains to sites around the Humber, to create a renewable energy super cluster. The Humber Local Enterprise Partnership will receive an income from business rates, which will be invested in skills and infrastructure to promote economic growth in the wider Humber area This Integrated Environmental Assessment (IEA) Report considers the potential environmental, flood risk and transport impacts of the Port of Hull LDO developments, which includes development within the Humber Enterprise Zone sites at Alexandra Dock and Queen Elizabeth Dock. Section 2.3 provides a description of the areas included in the LDO. 2.2 Proposed Hull Local Development Order and Description of LDO Development The proposed Port of Hull LDO will apply to three sites at the Port of Hull. The sites are numbered 1 (Alexandra Dock), 2a (Queen Elizabeth Dock north) and 2b (Queen Elizabeth Dock south) (see Figure A and Section 2.3) The proposed LDO will grant outline planning permission for development within the LDO area that is associated with renewable and low carbon industries as follows: development for the manufacture/ assembly/ testing/ research and development/ transportation of components and ancillary facilities/ infrastructure for a renewable energy installation or for transmission of energy from a renewable energy installation; and the erection of buildings for general industrial use (Class B2, as defined by the Town and Country Planning (Use Classes) Order 1987 and its subsequent amendments), As the LDO grants outline planning permission, planning consents for reserved matters such as layout, scale, appearance and landscaping will be required The LDO will not prohibit other types of development within the LDO area, but separate planning consents would be required for development that falls outside of the parameters defined in the LDO. Integrated Environmental Assessment Report Non Technical Summary March

8 2.2.5 The Humber Estuary is designated for its importance for birds as a Site of Special Scientific Interest (SSSI), Special Protection Area (SPA), Special Area for Conservation (SAC) and Ramsar site collectively referred to as the Humber Estuary European Marine Site. The LDO will not permit development that would have a significant effect on the Humber Estuary European Marine Site Alexandra Dock contains four listed buildings/ structures the Dock itself, a hydraulic engine house and tower, and a pumping engine house are Grade II listed, and a 100 ton steam crane is Grade II* listed. The LDO will not permit development that would affect a listed building or structure The LDO will also not permit Schedule 1 EIA development as defined by the EIA Regulations The developments will be required to maximise the development opportunity offered by the Port of Hull LDO area to support the renewable energy sector and not prevent any further development of the Port of Hull LDO area. The developments will also be required to promote strong links with existing operators and businesses and enable the Port of Hull to continue its operations. LDO Development Parameters Development parameters set out in the proposed Port of Hull LDO to limit the scale of development are shown in Table 2. Table 2: Port of Hull LDO development parameters Site 1 Alexandra Dock Layout shall reflect the indicative layout plan (see Figure B) Total building footprint shall not exceed 20% of the total development area. Total building footprint = up to 93,600 m 2. Each building shall, unless otherwise agreed by Hull City Council be constructed with a minimum BRE Environmental Assessment Method (BREEAM) standard of very good. Buildings shall not exceed 22 m in height. Assembly activities may take place in open areas, but will not exceed 100 m in height. Site 2a Queen Elizabeth north Layout shall reflect the indicative layout plan (see Figure C) Total building footprint shall not exceed 30% of the total development area. Total building footprint = up to 94,200 m 2. Each building shall, unless otherwise agreed by Hull City Council, be constructed with a minimum BREEAM standard of very good. Buildings shall not exceed 30 m in height. Assembly activities may not take place in open areas to the east of the building(s), and will not exceed 30 m in height. Site 2B Queen Elizabeth South Layout shall reflect the indicative layout plan (see Figure D) Total building footprint shall not exceed 30% of the total development area. Total building footprint = up to 58,500 m 2. Each building shall, unless otherwise agreed by Hull City Council, be constructed with a minimum BREEAM standard of very good. Buildings shall not exceed 30 m in height. Assembly activities may not take place in open areas to the north and east of the building(s), and will not exceed 30 m in height. Access from access points off Access from access points off Access from access points off Integrated Environmental Assessment Report Non Technical Summary March

9 Site 1 Alexandra Dock the A63/ A1033 (Hedon Road). Site 2a Queen Elizabeth north the A63/ A1033 (Hedon Road). Site 2B Queen Elizabeth South the A63/ A1033 (Hedon Road) Each LDO development will need to reduce carbon emissions by securing at least 10% of its energy from decentralised and renewable or low-carbon sources. There are a range of different options available to potential developers by which these targets can be met, and consequently the details of the renewable source for each LDO development will be agreed at the reserved matters stage It is assumed for the purposes of the IEA that no trees will be lost as result of the LDO developments, so no tree survey has been undertaken. The LDO includes a condition to protect the existing trees on site. 2.3 The LDO Area The Port of Hull The LDO area comprises three sites, making a total are of 97.7 ha. These are located at the Port of Hull (see Figure A): Site 1 is referred to as Alexandra Dock, approximately 46.8 ha; Site 2a is referred to as Queen Elizabeth Dock North, approximately 31.4 ha; and Site 2b is referred to as Queen Elizabeth Dock South, approximately 19.5 ha The Port of Hull is located in the Yorkshire and Humber region, predominately within the administrative boundary of Hull City Council (the most eastern part falls within the jurisdiction of East Riding of Yorkshire), to the east of Hull city centre. The three LDO sites fall entirely within the administrative area of Hull City Council The Port has had a long history of development, having adapted over the years to the changing economic demands of local, regional, national and international markets. Today, it handles a wide variety of cargo including containers, liquid bulks including oils, dry bulks, timber, steel and other metals, Roll-on Roll-off (Ro/Ro) traffic and passenger traffic. Site 1 Alexandra Dock The Alexandra Dock site was opened in 1885 and is used for port operations, which currently includes mainly timber and liquid bulks importation. The majority of Site 1 comprises hardstanding and operational warehouse buildings Planning consent applications for a facility at Alexandra Dock for the manufacture, assembly, testing and shipment of wind turbines for the offshore wind power industry, known as Green Port Hull (GPH), was submitted to Hull City Council by Associated British Ports (ABP) in December EIA, FRA and TA were undertaken to support the consent application in 2011 (URS Scott Wilson and JMP Consultants Ltd, 2011). Integrated Environmental Assessment Report Non Technical Summary March

10 2.3.7 The GPH application is yet to be determined. Site 2a Queen Elizabeth Dock North Site 2a is split into northern and southern sections by the dock railway line running between the Port and Salt End. A railway spur also passes through the site from west to south (see Figure C). The northern area includes bare ground and hardstanding. Land in the southern area was reclaimed in the 1960s. There are pools of shallow water in wet seasons, and a variety of vegetation has established in areas not in current use Site 2a is used for port operations as required, which currently include parking and storage, including container storage. Some parts of Site 2a have no formal use, but are employed on a short term or ad hoc basis when additional space is required. Other notable land uses currently within Site 2a include a tank-farm to the south-west of the dock railway lines, and a metal recycling operation to the north-east of the dock railway lines Site 2a does not have direct access to the Estuary, but is located close to King George and Queen Elizabeth Docks (to the west and south-west) Planning consent for an Energy from Waste and Recyclate Bulking Facility (EfW facility) (proposed by the Waste Recycling Group) on part of Site 2a was granted by Hull City Council and East Riding of Yorkshire Council in January 2007, but the development has not yet been built. EIA, FRA and TA were undertaken to support the consent application in 2006 (RPS Consultants, 2006) An Harbour Revision Order (HRO) application for Hull Riverside Bulk Terminal (HRBT), a new bulk terminal and associated jetty and rail loop on part of Site 2a (and Site 2b) was submitted by ABP in 2010, but the application has not yet been determined by the Marine Management Organisation. EIA, FRA and TA were undertaken to support the consent application in 2010 (Scott Wilson, 2010) The northern - and easternmost parts of Site 2a fall within the port area, but has not been the subject of any recent consent applications, and has therefore not been studied in detail as part of recent EIA, FRA and TAs. However, baseline environmental information has been gathered to inform the IEA. Site 2b Queen Elizabeth Dock South Site 2b comprises land reclaimed from the Humber Estuary from 1999 onwards. A small part of Site 2b is hard surfaced and is currently used for general port operations, including container storage. The rest of the site is unused The southernmost area adjacent to the Estuary has been reclaimed since 1999, and has no formal use at present. The HRO for HRBT would include this small area of land within the operational port boundary and permit general port operations on this area. A bulks conveyor and access road would also cross Site 2b as part of the proposed HRBT development, and a jetty would be constructed joining this land. As described above for Site 2a, EIA, FRA and TA were undertaken to support the consent application for HRBT in 2010 (Scott Wilson, 2010). Integrated Environmental Assessment Report Non Technical Summary March

11 2.4 Construction of the LDO Developments Due to the outline nature of the LDO it is not possible to accurately anticipate the length or timing of the construction period. The LDO will expire after five years of adoption, and only development commenced before this time will be permitted Whilst there is a possibility that the LDO developments may be phased, in order to provide a worst case assessment of construction impacts, the IEA considers the likely effects if all LDO developments were constructed simultaneously Details of construction methods and materials will not be available until the detailed design stage. For the purposes of this assessment the following construction activities are anticipated (where necessary): site clearance; construction of access roads and connection to existing highway; excavations and installation for drainage and services; construction of buildings (this may include some including piling activities); and landscaping and fencing The location of construction compounds will also be determined at the reserved matters stage but it is anticipated that they will be located within the LDO area Construction activities are anticipated to take place during normal working hours (08:00-18:00) Monday to Friday. Lighting may be required and is likely to comprise low level task lighting The number of temporary staff required during the construction of the LDO developments cannot be accurately predicted at this stage, but based on similar development proposals it is estimated at approximately 391 staff. 2.5 Operation of the LDO Developments Due to the outline nature of the LDO it is not possible to accurately anticipate details of the operational activities that will take place across the three sites. The buildings will house manufacturing operations, such as the production of components for renewable energy technologies Activities such as storage, parking and loading/ unloading will take place at all sites and assembly may take place in open areas of the three LDO sites. As Site 1 assembly activities will not exceed 100 m in height, whilst at Sites 2a and 2b they will not exceed the height of the proposed buildings (30 m) and will only take place where sensitive receptors are shielded by the buildings (see Table 2) The operational assessment will consider the impacts and effects from all LDO developments operating at the same time as a worst case assumption For the purposes of this IEA Report it has been assumed that operation on the three sites will be 24 hours. This is in line with current operations at the Port of Hull. Integrated Environmental Assessment Report Non Technical Summary March

12 2.5.5 It is anticipated that the proposed LDO developments will employ approximately 1,173 permanent staff based on similar development proposals. 2.6 Need and Alternatives Need As set out above, the aim of the Humber Enterprise Zones is to attract large top tier manufacturing companies and associated supply chains to sites around the Humber, to create a renewable energy super cluster. The Humber Enterprise Zones are intended to drive forward the city s economic ambitions particularly with regard to opportunities for growth around renewable energy, ports and innovation Enterprise Zones provide financial benefits to businesses locating within the Zone, but local planning authorities are also encouraged to simplify the planning regime within Enterprise Zones. The Port of Hull LDO will provide this simplified planning regime for the port area Humber Enterprise Zone sites within Hull. Alternative Sites Considered The Humber Enterprise Zones include all sites identified as suitable for development associated with renewable and low carbon industry. These sites offer excellent road, rail and port links. LDOs or other simplified planning procedures are being proposed for all of these sites. No alternative sites have therefore been identified. Do Nothing The do nothing option would mean the Enterprise Zones would be less attractive to potential businesses considering locating themselves within the area. The do nothing option has therefore been discounted. Integrated Environmental Assessment Report Non Technical Summary March

13 Figure A: Site location plan showing LDO sites at the Port of Hull 10

14 Figure B: Site 1 Alexandra Dock indicative proposals 11

15 Figure C: Site 2a Queen Elizabeth Dock North indicative proposals 12

16 Figure D: Site 2b Queen Elizabeth Dock South indicative proposals 13

17 3 Planning Policy The LDO developments are located in the local authority area of Kingston Upon Hull City Council (referred to as Hull City Council) The LDO has been appraised against national, regional, and local planning policy relating to the development of land. In particular the assessment has focussed on economic development aims, land-use policy, freight and transport policies. The policy documents reviewed as part of this study include: The UK Low Carbon Transition Plan: National Strategy for Climate and Energy (Department for Energy and Climate Change, 2009); Transport White Paper - Creating Growth, Cutting Carbon: Making Sustainable Transport Happen (Department for Transport (DfT), 2011); Energy White Paper: Meeting the Energy Challenge (Department for Trade and Industry, 2007); Modern Ports: A UK Policy (DfT, 2000); National Policy Statement for Ports (DfT, 2011); UK Marine Policy Statement (HM Government, 2011); National Planning Policy Guidance notes and Planning Policy Statements; Humber Enterprise Zone (HM Government 2011a and 2011b); Draft National Planning Policy Framework (Department of Communities and Local Government (DCLG, 2011)); Regional Economic Strategy (Yorkshire Forward, 2006); The Yorkshire and Humber Plan - Regional Spatial Strategy to 2026 (Yorkshire and Humber Assembly, 2008); Joint Structure Plan for Kingston upon Hull and the East Riding of Yorkshire (Kingston upon Hull and East Riding of Yorkshire Councils, 2005); Kingston upon Hull Local Plan (Hull City Council, 2000); Hull Core Strategy Publication Version (Hull City Council, 2011); and Hull Core Strategy Publication Version Proposed Changes (Hull City Council, 2012) The development of ports, specifically including the Port of Hull, is supported at all levels of the Statutory Development Plan and in national planning policies. The LDO also promotes renewable energy, which is also strongly supported by planning policy The Draft National Planning Policy Framework published in July 2011 sets out the Government s commitment to ensuring that the planning system supports sustainable economic growth and states that significant weight should be placed on the need to support economic growth through the planning system The three LDO sites are located within both a Regeneration Priority Area and the vast majority of the area is within a Strategic Employment Area in the Hull City Plan (Hull City Council, 2000). This City Plan sets out that appropriate employment uses will be encouraged at the 14

18 Port, and supports the vast majority of the area for port uses. Policies in the Publication Version of the Hull Core Strategy (July 2011) (together with the Proposed Changes published in 2012) are also supportive of this proposed development, in particular Policy CS1 and the Key Diagram, which include the LDO area as being within an area for port and related economic development uses The three LDO sites are located within the Humber Estuary Enterprise Zones (announced August 2011 and November 2011) which is intended to drive forward opportunities for growth around renewable energy, ports and innovation. The proposed Port of Hull LDO is directly related to this Government initiative The National Policy Statement for Ports (DfT, 2011) sets out the presumption in favour of granting consent for port development and acknowledges that there will be an increased demand for the types of development that will be consented under the LDO. It is considered that this policy document supports the LDO. 15

19 4 Socio-Economics 4.1 Introduction The effects of the LDO developments on the local and regional economy and employment levels have been considered Information has been gathered from published national, regional and local statistics and strategies. These include: Office for National Statistics; national energy policy and statistics; and the Yorkshire and Humber Regional Economic Strategy. 4.2 Existing Conditions Hull is one of the most deprived Local Authority Districts in England, as demonstrated by the following key statistics: in the year ending March 2011 unemployment in Hull was 15.8%, the third highest unemployment rate in Great Britain, compared to 7.6% average unemployment of Great Britain as a whole; gross weekly pay in 2010 for full time workers resident in Hull, at was 21.5% less than for Great Britain as a whole, at ; and the latest indices ranks Hull as the 5th most deprived local authority district in England, out of 326 local authorities. 4.3 Construction of the LDO Developments Any existing tenants and occupiers at the three LDO sites will be relocated, which is anticipated to be predominately within the Port of Hull prior to construction. Although existing beneficial uses of the site will be displaced, their new locations will remain suitable for purpose, and their activities are expected to continue. Consequently the overall effect on existing tenants and operators is not considered to be significant Based on similar development proposals, the construction of LDO developments is anticipated to create approximately 391 temporary construction jobs, made up of: approximately 187 jobs at Site 1; approximately 126 jobs at Site 2a; and approximately 78 jobs at Site 2b This is assessed to be a significant beneficial effect. 16

20 4.4 Operation of the LDO Developments Based on similar development proposals, it is anticipated that the LDO developments will employ approximately 1,173 staff during their operation. This is expected to consist of: approximately 562 jobs created at Site 1; approximately 377 jobs created at Site 2a; and approximately 234 jobs created at Site 2b As the LDO developments will lead to increased spending in the area, a large number of jobs and opportunities will also be created indirectly through the provision of supplies and services to the LDO developments and their workforce. This will provide opportunities for the local and sub-regional labour force. Overall employment effects are considered to be significantly beneficial. 17

21 5 Land Use, Public Rights of Way and Recreation 5.1 Introduction Land uses, Public Rights of Way (PRoW) and recreation in and around the LDO sites have been identified and the potential effects of the LDO developments on these uses have been assessed Other effects on surroundings areas, such as noise, air quality and visual effects, are assessed in other specialist sections of this NTS. 5.2 Existing Conditions All sites within the LDO area are located at the Port of Hull and fall within the ownership of ABP. Existing land uses are set out in Section One PRoW (Footpath 22) runs to the south of Site 1 (In February 2012 the Secretary of State confirmed an Order to divert part of this footpath around the perimeter of Alexandra Dock), through the centre of Site 2b and to the east of Site 2a (see Figures B-D) No other recreational uses take place within the LDO area. 5.3 Construction of the LDO Developments As described in Section 4 (Socio-Economics) of this NTS, existing tenants and occupiers at the three LDO sites will be relocated, and the overall effect of the construction of LDO development on these land uses is not considered to be significant At Site 2b, the PRoW through the site may need to be temporarily stopped up or diverted for health and safety reasons during construction (although a separate consent would be required for this). This would result in a temporary significant adverse effect on the use of the PRoW. Visual effects on users of the footpath are considered in Section 13 of this NTS. 5.4 Operation of the LDO Developments No effects on land uses and recreational activities beyond those detailed above for the construction phase have been identified as a result of operation of the LDO developments. Where Footpath 22 passes through the LDO Site 2b, it will be retained and appropriate consideration will be given to ensure the health and safety of footpath users during operation Other potential effects on nearby land uses and occupiers are considered in later sections of this NTS, including noise (Section 7), Air Quality and Dust (Section 8), Flood Risk (Section 10) and Landscape and Visual Effects (Section 13). 18

22 6 Transport Assessment 6.1 Introduction The effects of construction and operation of the proposed LDO development on traffic and transport have been considered by JMP Consultants Limited in consultation with the Highways Agency and Hull City Council. A Framework Travel Plan has also been produced Existing conditions at the LDO sites have been established through previous traffic surveys undertaken for other assessments. The future growth in background traffic (traffic currently on or predicted to be on the road network that is not related to the LDO developments) has been estimated using standard growth factors. Traffic flows during construction have been calculated using information based on previous assessments and for operation have been calculated based on previous assessments. 6.2 Existing Conditions At Site 1 there are two existing access points to Alexandra Dock; the western access via the A1033 Mount Pleasant roundabout and the eastern access off the roundabout on the A1033 at the northern end of Northern Gateway. The western access is currently temporarily gated and unused and the eastern access has an existing security gate to control access to the Dock (see Figure E). Access to Sites 2a and 2b is via the existing A1033(T) Hedon Road/ Somerden Road/ dock entrance roundabout There are a number of bus services operating at various points along Hedon Road in the vicinity of the LDO sites, as well as services on South Bridge Road at Mast Drive in Victoria Dock Village immediately to the west of Site 1. There are bus stops that would serve Sites 2a and 2b on each side of Hedon Road Walking and cycling routes to the LDO sites are generally good. There are footways leading to both the western and eastern entrances to Site 1 and along the north side of Hedon Road, leading to Sites 2a and 2b. 6.3 Construction of the LDO Developments The traffic generated as a result of construction of the LDO developments will be variable depending on site activity. The maximum number of traffic movements in and out of the LDO sites for each month of construction has been predicted. The peak of construction is anticipated to be towards the end of 2013 (based on the findings of the GPH TA), when daily construction journeys to and from the LDO sites in total per day are anticipated to be around 800 movements (including around 600 light vehicles and 200 heavy vehicles) The increase in traffic at the peak of construction, assuming all three LDO sites are constructed at the same time, is well within the typical daily variation and therefore the increase will not be noticeable by those potentially affected groups and interests along A63 Castle Street. The effects on construction traffic of key links of the Strategic Road Network (SRN) at the peak of construction are: a daily (AADT) increase no greater than 1.7%; a AM Peak increase no greater than 3.7%; and 19

23 a PM Peak increase no greater than 3.0% No significant adverse effects are identified Each LDO development will be required to prepare and implement a Construction Traffic Management Plan in accordance with the Heads of Terms for the Port of Hull LDO Construction Traffic Management Plan (see Appendix 6A of the IEA Report Volume 2). 6.4 Operation of the LDO Developments The traffic generated as a result of operation of the proposed LDO developments has been assessed based on a range of shift patterns for employees During operation it is anticipated that there will be 382 traffic journeys to and from the LDO three sites in the morning peak (made up of 309 light vehicles and 73 heavy vehicles) and 319 traffic journeys to and from the three LDO sites in the evening peak (made up of 311 light vehicles and 8 heavy vehicles) The increase in traffic caused by operation of the LDO developments is well within the typical daily variation in traffic and will not be noticeable by those potentially affected groups and interests along A63 Castle Street. The effects of operational traffic on key links of the SRN are: a daily (AADT) increase no greater than 1.6%; a AM Peak increase no greater than 5.6%; and a PM Peak increase no greater than 2.7% No significant adverse effects are therefore identified. A sensitivity test considering alternative shift patterns for some staff has also been undertaken. The findings of this test also conclude that there are no significant traffic and transportation effects arising from the operation of the LDO developments A Framework Travel Plan has been prepared for the LDO developments. Each LDO development will be required to prepare and implement an individual Travel Plan and an Operational Traffic Management Plan in accordance with the Heads of Terms for the Port of Hull LDO Operational Traffic Management Plan (see Appendix 6A of the IEA Report Volume 2). Over time the Travel Plan will encourage an increasing proportion of employees to travel to work by sustainable modes of transport and/ or increase the proportion of car share by those who do not have access to sustainable public transport services. 20

24 Figure E: Traffic and transportation study area and site access points 21

25 7 Noise and Vibration 7.1 Introduction The potential noise and vibration impacts associated with the construction and operation of the LDO developments has been assessed. Previous and new assessments have been used to predict both daytime and night-time construction and operational noise impacts at representative residential properties ( receptors ) closest to the LDO sites. Potential noise effects on birds have also been assessed and this is summarised in Section 11 (Terrestrial Ecology and Nature Conservation) of this NTS Consideration of noise impacts is based on a comparison of predicted and existing noise levels with reference to noise standards, to determine the significance of effects. Previous and new assessments have used noise modelling software to predict operational noise levels at receptor locations based on previous assessments. 7.2 Existing Conditions Results of previous noise monitoring in and around the LDO sites were used to understand the existing noise conditions. Noise is currently generated from the existing port operations, general environmental conditions such as wind and waves and road traffic on Hedon Road. 7.3 Construction of the LDO Developments The greatest noise impact during construction will occur during building construction, which is anticipated to include piling. To minimise disturbance, construction activities are anticipated to take place during normal working hours (08:00-18:00) Monday to Friday All construction activities are temporary in nature and are not anticipated to result in a significant adverse effect on nearby residential receptors The potential effects of construction noise on birds are discussed in summary in Section 11 (Terrestrial Ecology and Nature Conservation) of this NTS With regards to vibration, piling is considered to be the only activity with the potential to give rise to significant vibration. The vibration levels received at receptor locations will depend primarily on the selected piling method, the distance between piling locations and receptors and intervening ground conditions, but these are not anticipated to be significant at the nearest receptor locations given distance. 7.4 Operation of the LDO Developments During operation some higher than average noise levels are predicted to occur during the daytime. A 5 m noise barrier will be built along the western edge of Site 1 to provide some noise shielding to Sites To ensure that minimum disturbance occurs to local residents, particularly at night, a noise mitigation scheme will be developed with Hull City Council for each site. As a result, no significant adverse effects are predicted at any of the closest residential receptors. 22

26 7.4.3 The potential effects of operational noise on birds are discussed in Section 11 (Terrestrial Ecology and Nature Conservation) of this NTS No significant levels of operational vibration are anticipated. 23

27 8 Air Quality and Dust 8.1 Introduction The assessment has considered the potential effects on air quality receptors arising from the construction and operation of the LDO developments. The air quality assessment is based on best practice and guidance, and predicted changes to concentrations of two pollutants (nitrogen dioxide (NO 2 ) and airborne particles of material (PM 10 and PM 2.5 )) from vehicle exhausts at sensitive locations near to the site (e.g. residential properties). Construction dust effects are also assessed Existing conditions at the three LDO sites were established from NO 2 surveys undertaken as part of other assessment work, together with monitoring data provided by Hull City Council. 8.2 Existing Conditions Levels of air pollutants surround the LDO sites are generally of a good standard. Hull City Council has, however identified an area around the A63 Castle Street where NO 2 concentrations are in excess of the air quality objectives at some locations. Consequently, the Council has declared an Air Quality Management Area for this pollutant. 8.3 Construction of the LDO Developments The construction of the LDO developments could give rise to emissions of dust. Standard dust control measures for construction sites, such as the use of water sprays in dry conditions, will be used on site to reduce dust emissions during the construction phase, and no significant adverse effect is predicted at any ecological, commercial or residential receptor During the construction of the LDO developments, annual mean NO 2, PM 10 and PM 2.5 concentrations from construction traffic are predicted to be very small (less than 0.4 μg/m 3 (millionth of a gram per cubic metre)) with no significant adverse effect on sensitive receptors. Pollutant concentrations would remain well below the limits set by air quality objectives at residential properties close to the LDO sites. 8.4 Operation of the LDO Developments The good existing standard of air quality in the vicinity of the LDO sites means that the impact of any new small scale source of industrial emissions would be unlikely to cause a risk of exceeding relevant air quality standards. The operators of any larger scale industrial processes would be required to demonstrate that the impact of the development would be acceptable through the Environmental Permitting regime prior to the opening of the facility. As a result, no significant adverse effects are anticipated No significant adverse effects on local air quality are predicted during the operation of LDO developments due to operational traffic movements. Annual mean NO 2, PM 10 and PM 2.5 concentrations from operational traffic are also predicted to be very small (less than 0.4 μg/m 3 ) with no significant adverse effect on sensitive receptors. Air quality standards in and around the area of the LDO sites will continue to be achieved. 24

28 9 Water Quality and Hydrology 9.1 Introduction The effects of the proposed development on water quality and hydrology have been assessed. Flood risk issues are considered separately in Section 10 (Flood Risk Assessment) of this NTS The water quality and hydrology conditions at the LDO sites were determined by a desk-based study using previously available information from other assessments. 9.2 Existing Conditions The main surface water features surrounding the site are the River Hull, Holderness Drain, Old Fleet Drain and the Humber Estuary (see Figure F) The Environment Agency classifies the underlying geology of the LDO sites as a Principal Aquifer, which means there is a high level of groundwater storage beneath the site. 9.3 Construction of the LDO Developments Potential impacts during construction include pollution of surface water, transport of sediments into waterbodies in runoff from the construction site, and pollution from sewage. Mitigation measures include suitable storage of materials on site and spillage prevention to minimise risks to water There is the potential for very localised significant adverse effects to result if contaminated runoff was to enter the Humber Estuary, but the likelihood of this occurring is very low due to the drainage and site management systems that will be in place in accordance with standard Environment Agency standards and guidance. 9.4 Operation of the LDO Developments Highly localised significant adverse effects are possible if there was an accidental leakage from an LDO development s foul drainage system into the Humber Estuary, Holderness Drain or Old Fleet Drain or if contaminated site runoff entered the Humber Estuary or Old Fleet Drain. The likelihood of these impacts occurring is very low due to the drainage and site management systems that will be in place in accordance with standard Environment Agency standards and guidance. 25

29 Figure F: Main surface water features 26

30 10 Flood Risk Assessment 10.1 Introduction The effects of the proposed development on flood risk within and outside the LDO area have been assessed Existing Conditions Surface water features in the vicinity of the proposed development site are described in Section Flood zone maps produced by the Environment Agency indicate that Sites 1, 2a and 2b lie entirely within Flood Zone 3a, meaning that the sites are considered to have a high risk of flooding. The more detailed Strategic Flood Risk Assessment undertaken by Hull City Council (2007) concludes that some parts of the LDO sites are located in lower flood risk zones Site 1 is currently protected from flooding from the Humber Estuary by a flood defence wall approximately 1.5 m high located along the bank of the Estuary. Site 2b is currently protected from flooding from the Humber Estuary by a flood wall approximately m AOD located along the Estuary and along the western boundary of the Site 2b, towards Site 2a which is protected by the same defence Construction of the LDO Developments At Site 1 a new flood defence approximately 6.8 m Ordnance Datum Newlyn (ODN) around the perimeter of Site 1 will increase the level of protection provided by the existing flood defence wall At Site 2b, a new flood defence structure, including a raised crest level and rock armour approximately 6.5 maod will increase the existing level of protection at Sites 2a and 2b The risk of flooding from other sources, including surface water flooding, groundwater flooding and from artificial sources is also low Operation of the LDO Developments An appropriate drainage strategy will be designed (including an allowance for climate change) and installed, where required, prior to the discharge of surface water to the surrounding watercourses Impermeable areas within the LDO developments will either decrease or attenuation storage will be provided post development to allow a minimum 50% reduction in surface water run-off rates in order to meet the requirements of Hull City Council s Surface Water Management Plan (Hull City Council, 2009) A number of flood risk mitigation measures will be employed such as emergency evacuation procedures and flood resilient and resistant construction techniques incorporated into building designs. These measures will ensure no significant adverse effects are anticipated. 27

31 11 Terrestrial Ecology and Nature Conservation 11.1 Introduction This section considers the potential impacts of the LDO developments on terrestrial ecology and nature conservation receptors Existing Conditions Sites 1 and 2b are adjacent to the following protected sites: Humber Estuary SAC, Humber Estuary SPA, Humber Estuary Ramsar site and Humber Estuary SSSI (see Figure G). The Estuary as a whole is an important habitat for migratory and wintering waterbirds and this is recognised through the above designations and its listing as an Important Bird Area In Site 1 semi-natural habitat is limited to a small area of shrubs and grass in the south-west of the site. Site 1 lies next to a small area of intertidal mudflat habitat (Alexandra Docks mudflats) that attracts small numbers of feeding waterbirds. Intertidal mudflats are areas of mud that are covered by water at high tide and exposed at low tide, which may provide feeding habitat for waterbirds. The disused West Jetty adjacent to Alexandra Dock, although outside the development boundary, is also included within the study area for Site 1 because this is used by roosting and loafing waterbirds in the Humber Estuary The northern part of Site 2a comprises hardstanding and vegetation typical of disused industrial sites. Habitat south of the Salt End railway line is less disturbed and has developed into more natural long grassland with scattered shrubs. There is a large area of hardstanding in the southern part of Site 2a, and areas in the northern part of the site are used for parking and storage, including container storage. Temporary seasonal shallow rainwater pools are also present in Site 2a where surface water does not drain away Site 2b is mostly disused and has become progressively overgrown with grassland and scattered shrubs. Waterbirds have been recorded roosting and loafing on the less overgrown areas of Site 2b. As on Site 2a, there are several seasonal rainwater pools in the poorly drained areas of the site. Site 2b is bound to the east by the mouth of Old Fleet Drain and the Salt End intertidal mudflats, which are used by large numbers of feeding waterbirds Construction of the LDO Developments No part of the LDO area lies within the boundary of the Humber Estuary SAC/ SPA/ Ramsar/ SSSI and therefore there will be no loss of habitat within the internationally designated site Construction of the LDO development at Site 2a will result in the loss of seasonal rainwater pools that are used by breeding common toad and common newt, and local Biodiversity Action Plan habitat (industrial land). No significant adverse effect is anticipated to result from the loss of this habitat Construction of the LDO development at Site 2b will result in the loss of terrestrial habitat used by roosting and loafing birds, which will be mitigated by the creation of an undisturbed roosting and loafing area at the eastern end of Site 2b (closest to Salt End mudflats) away from the LDO building footprint. This is therefore assessed to result in no significant adverse effects. 28

32 Based on noise predictions and the locations of waterbirds in relation to construction activities, noise and visual disturbance due to construction of the LDO developments is not assessed to result in any significant adverse effects on waterbirds feeding on the Alexandra Dock and Salt End mudflats or roosting and loafing on West Jetty Operation of the LDO Developments Based on noise predictions and the locations of waterbirds in relation to operational activities in open areas, noise and visual disturbance due to operation of the LDO developments is not assessed to result in any significant adverse effects on waterbirds feeding on the Alexandra Dock and Salt End mudflats or roosting and loafing on West Jetty No other operational impacts are assessed to result in adverse effects on terrestrial ecology or nature conservation receptors. 29

33 Figure G: Protected nature conservation sites close to the LDO sites 30

34 12 Cultural Heritage 12.1 Introduction Potential impacts from the LDO developments on cultural heritage features have been assessed. Cultural heritage includes historic buildings and structures together with archaeological sites The existing cultural heritage conditions have been established through a review of available information sources, including the relevant Sites and Monuments Records, local planning authorities, historic maps and aerial photographs, which are already presented as part of other assessments undertaken Existing Conditions At Site 1 the grade II* Steam Crane and grade II Hydraulic Engine House and Tower are located with the located within site, with the grade II listed Alexandra Dock walls, lock gates, graving docks and extension dock on the boundary of Site 1. The grade II listed Pumping Station is located within Alexandra Dock, but falls outside Site No listed structures are present at Sites 2a and 2b Within the wider study area there are a number of locally important archaeological sites, several listed buildings and structures and a conservation area. No important archaeological sites are located within the LDO area Construction of the LDO Developments There will be no significant adverse effect on listed structures or archaeological features within and close to the LDO sites during construction. However, foundation design deeper than 5.4 m below current ground level may require additional archaeological investigation Operation of the LDO Developments The LDO developments will be visible from a number of built heritage assets. However, taking into consideration the existing industrial context of the sites, there will not be any significant effects as a result of the LDO developments. 31

35 13 Landscape and Visual Amenity 13.1 Introduction The effects of the LDO developments on the surrounding landscape and sensitive visual receptors (locations such as residential properties, local roads and footpaths with views of the development) have been assessed Ten key viewpoints have been chosen based on the previous assessments of the Zone of Theoretical Visibility of the other three proposed developments. These viewpoints are representative of sensitive receptors located within the local area (see Figure H) The viewpoints considered in the assessment are shown in Figure H and comprise: Viewpoint A - Victoria Pier / The Deep; Viewpoint B - Victoria Dock Village; Viewpoint C - Hedon Road (A1033) junction of Southcoates Lane; Viewpoint D - Marfleet Flyover; Viewpoint E - Hedon Road (A1033) junction of Elba Lane; Viewpoint F - Flood defence wall to the Port of Hull; Viewpoint G - Hedon Road (A1033) junction of Tower House Lane; Viewpoint H - Western edge of Hedon; Viewpoint I - Village of Paull; and Viewpoint J - Goxhill Haven Existing Conditions The LDO sites are located on the eastern edge of the city of Hull, an area dominated by docks and industry, and where there are a number of existing tall structures. Beyond the industrial edge of the city the landscape is largely rural and agricultural, low lying and flat with large open skies, long distance views and limited vertical structures. Views towards the city are heavily influenced by the industrial landscape of east Hull and Salt End, including the dockland activities. All these factors have a strong influence on landscape character Construction of the LDO Developments The construction works associated with the LDO developments will blend into the industrial surroundings and are considered to have no significant adverse effect on landscape character Viewpoints B, C and G will experience a temporary significant adverse visual effect during construction. No significant adverse visual effects are predicted during construction for the other viewpoints assessed. 32

36 13.4 Operation of the LDO Developments The LDO developments will be in keeping with the industrial surroundings and are considered to have no significant adverse effect on landscape character during operation Whilst the majority of the works fall within the usual activities of the working port, the height of some activities and the short distances to receptors result in significant adverse effects. Viewpoints A, B, C and G will experience a significant adverse effect on visual amenity. Landscape planting is proposed as part of the LDO developments (details to be considered at the reserved matters application stage), but this will not be able to screen the development given the height of buildings and structures. No significant adverse visual effects are predicted during operation for the other viewpoints assessed. 33

37 Figure H: Viewpoints for visual assessment 34

38 14 Land Quality 14.1 Introduction Soil quality at the LDO sites and the potential for effects of land contamination on people and the environment has been assessed The assessment has considered potential sources of contamination, receptors (i.e. people and environmental features that could be affected by contamination) and pathways (i.e. the means by which any contamination could reach a receptor) between the two. Effects are only possible where a source, receptor and pathway are all present Historic data has been reviewed, and data has been gained from ground investigation undertaken for other assessments at the LDO sites Existing Conditions The three LDO sites are located within an industrial area of the Port. There are a number of historic uses on the sites, including railway sidings, reclaimed land, general storage, timber storage and treatment, oil tanks and workshops, and service pipes run across the LDO sites As described in Section 9 (Water Quality and Hydrology) of this NTS, the underlying geology of the LDO sites is classified as a Principal Aquifer, which provides a high level of groundwater storage beneath the site Recent site investigations have determined that ground gases in parts of Sites 1 and 2a are at a level that has the potential to pose a risk to site users and buildings. Ground gases have not been monitored at Site 2b and parts of Site 2a, so as a precaution it is assumed that ground gas levels may also pose a risk within these sites No ground investigation has taken place to the north and west of the railway lines in Site 2a Construction of the LDO Developments Possible sources of contamination include previous land uses such as railway sidings, the use and storage of chemicals on the construction site A range of possible receptors have been identified, including people working on the site during construction, ecological habitats and species near to the site, watercourses (the Humber Estuary and Holderness Drain) and groundwater Pathways could be created between the site and groundwater when the ground is disturbed during construction, for example during piling Prior to construction, an intrusive ground investigation will be undertaken within to the north and west of the railway lines in Site 2a (where no such investigation has previously been undertaken),, and appropriate mitigation measures will be developed and implemented as necessary There is a potential hazard associated with the presence of ground gases within parts of the LDO area, but this will be mitigated with the implementation gas monitoring (as appropriate), gas protection measures in building design and suitable training of staff. 35

39 Based on the assessment of all available data, and assuming the implementation of a number of detailed design and impact avoidance measures together with the mitigation measures identified above none of the potential effects on land quality are considered to result in no significant adverse effects Operation of the LDO Developments During operation, materials that will be stored on site have the potential to adversely affect land quality due to accidental leakage or spillage (e.g. fuels and oils) and risks to users of the site associated with the presence of ground gases The potential hazard associated with the presence of ground gases the LDO sites will be mitigated through gas protection measures and suitable training of staff Appropriate storage of potentially contaminating materials on site will ensure there are also no significant adverse effects on land quality during operation. 36

40 15 Waste Management 15.1 Introduction The types and volumes of waste from the LDO developments have been estimated using data from a range of similar facilities within the UK and Europe The potential effects of waste generated by the LDO developments have been considered in terms of relevant legislation, the amounts of waste to be produced, the regional capacity to treat or dispose of this waste and the methods by which the waste will be managed Existing Conditions Information on current waste at the Port of Hull is contained within the Port s Waste Management Plan. This Plan includes details of relevant legislation, port waste reception facilities and the prior notification system for waste brought into the Port by ships, including waste data collection Construction of the LDO Developments Based on information from similar developments it is estimated that approximately 2,624 tonnes of waste will be produced during the construction phase of LDO developments. In comparison, waste of approximately 13 million tonnes per year is produced in the Yorkshire and Humber region as a whole. In this context the construction waste associated with GPH is considered to be immaterial, and hence, will not result in a significant adverse effect Measures will be put in place to reduce the impacts such as using recycled construction materials and re-using construction waste on-site, where feasible. A Site Waste Management Plan will be prepared and implemented for the construction phase Operation of the LDO Developments Approximately 2,726 tonnes per year is predicted to be generated by the operation of the LDO developments (although it is anticipated that a large proportion of this will be recycled) and waste produced from staff working at the LDO sites is predicted to be approximately 235 tonnes per year The LDO developments will be operated in accordance with the Port Waste Management Plan. UK legislation, policies and principles of waste management will be followed, including the principles of the waste hierarchy (reduce, re-use, recycle, recover, dispose) Sufficient capacity within the region to manage the anticipated waste arisings from LDO developments has been identified. No significant adverse effects are, therefore, anticipated. 37

41 16 Cumulative and Combined Effects 16.1 Introduction Cumulative effects arise when impacts from two or more proposed developments affect the same environmental receptor, for example noise from two proposed developments affecting a residential property located between the two development sites. It is only possible to consider the effects of other proposed developments when the assessment of these effects has been published. Existing developments are not considered because they are already taken into account as part of the existing conditions. All the technical specialists as listed in Table 1 have contributed to this assessment Combined effects arise when two or more types of impact from the same development affect the same environmental receptor in a particular way e.g. effects of noise and dust on nearby residents Existing Conditions A number of other developments are proposed in the vicinity of the LDO sites (see Figure I) that could give rise to cumulative effects with the LDO developments. These are: Vivergo Bioethanol Plant at Salt End, for which consent has been granted; Trinity Quays at the city centre of Hull, for which consent has been granted, but construction has not started; Marfleet Environmental Technology Park which is located nearby along Hedon Road, for which consent has been granted and construction will be completed prior to construction of the LDO developments; and Biomass Plant King George Dock for which consent has been granted, but construction has not started Construction of the LDO Developments If the construction periods of any of the proposed developments identified above overlap with LDO development construction, there is the potential for cumulative effects during construction. Cumulative construction impacts will be temporary in nature and have been assessed to be not significant No significant adverse combined effects that has been identified Operation of the LDO Developments Following consideration of each specialist assessment topic, no significant combined or cumulative effects have been identified during the operational phases of the LDO developments. 38

42 Figure I: Other developments close to the LDO sites Integrated Environmental Assessment Non Technical Summary February