5. Environmental issues and methodology

Transcription

1 5. Environmental issues and methodology

2 5 Environmental issues and methodology Introduction 5.1 The methodology used to carry out the environmental impact assessment (EIA) is set out in this chapter. This includes defining the scope of the EIA and determining the significance of the environmental effects. Specific methodologies for each of the specialist studies are given in the relevant chapters and technical appendices. 5.2 The Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (hereafter the EIA Regulations) provide a flexible framework for the content of an environmental statement (ES) 1. This flexibility adequately reflects and encompasses the range of characteristics of projects to which the EIA Regulations apply to, and allows variations in the content, style and dimensions of the ES. 5.3 The South London ERF project falls within the types of development listed under Schedule 1 (10) of the EIA regulations, for which EIA is required in every case to support a planning application. Therefore it was not necessary to seek an EIA screening opinion from the planning authority London Borough of Sutton (LBS). Defining the scope of the EIA 5.4 EIA is intended to identify and assess any significant environmental effects arising from a proposed development; it does not set out to address minor or everyday effects. Scoping is the identification of the range of significant environmental issues likely to arise as a result of a proposed development and is an important exercise in the early stages of the EIA process. The identification of the key issues and sensitivities of a proposal defines the extent of an EIA. Scoping ensures that potentially significant issues are addressed in detail, whilst those of less relevance are considered accordingly. 5.5 The factors that influenced the breadth of the scoping exercise and hence the EIA for this project have included: The scale and nature of the project The physical characteristics of the proposals Site characteristics Neighbouring land uses Planning policies and local environmental designations Scoping consultation process Part In December 2010 Mouchel prepared an EIA scoping report on behalf of for the South London ERF proposals. The boundary of the site was as shown in figure 5.1 and included the area required for the ERF and a new access road onto Beddington Lane (approximately 4.4 ha). The report was submitted to LBS for a formal scoping opinion. The scoping document provided a summary description of the proposed development, set out the 1 Schedule 4 of the EIA Regulations contains a list of information to be included in an ES.

3 potential impacts that could arise as a result of the development, listed further survey work required and proposed consultation. 5.7 The preparation of the draft scoping document involved a review of background documents that were current at the time, including: National policy Planning Policy Guidance notes and Planning Policy Statements, and various environmental regulations and legislation The London Plan: Spatial Development Strategy for Greater London (2008) consolidated with alterations since 2004 London Borough of Sutton Unitary Development Plan (adopted April 2003) which was gradually being replaced by the emerging Local Development Framework (LDF) Guidance documents (e.g. Guidelines for Landscape and Visual Assessment, the Design Manual for Roads and Bridges, etc.) 5.8 The scoping report was compiled based on the issues raised by the document review and initial site visits. Further issues were identified at in-house meetings and from additional desk-based assessment work and research. 5.9 LBS issued the scoping report to the following statutory consultees for comment: LBS - environmental health LBS - biodiversity team LBS - planning policy LBS highways Environment Agency Natural England Transport for London 5.10 Following consideration of the scoping report and comments from consultees, the LBS issued an EIA scoping opinion on 23 February Table 5.1 presents an outline of the key issues that were raised during the scoping consultation exercise and are subsequently discussed in each of the study areas of this ES. Environmental aspect Air quality Landscape and visual Key issues identified in scoping report Construction effects (NO 2 and particulate matter) including the potential of excavating hazardous material Operational issues relating to HGV emissions and the output of the incineration process Operational effects on the AQMA Changes to local character zones Changes to views from receptors Additional issues raised during consultation Ongoing monitoring and / or management of air quality The assessment should utilise monitoring data from LDS air quality monitoring sites Odour should be assessed cumulatively and the loss of the Dano building during construction should be considered Landscape and visual impact assessment impact should be set within the context of the Metropolitan Open Land and aims of the Wandle Valley Regional Park

4 Environmental aspect Noise and vibration Natural heritage Social and community effects Cultural heritage Ground conditions Hydrology Key issues identified in scoping report Changes in noise and vibration levels at sensitive receptors during construction and operation Noise from increased traffic movements associated with construction and operation Potential effects during site preparation and construction Potential effects during the operation of the facility (noise and vibration, liquid and aerial discharges) Potential effects to nearby receptors (in terms of emissions to air and noise) during construction and operation (inclusive of traffic). Impact on buried archaeological remains during construction Potential impact on the setting of built heritage Presence of uncertain depths and quality of made ground Potential requirement for dewatering / sheet piling to build the waste bunker Existing foundation concrete slabs Soft sludge from sewage works Risk to surface and ground water Alterations to drainage regime Potential flood risk due to high ground water levels and standing surface water Additional issues raised during consultation Noise assessment should take into account the loss of the existing waste facilities on site during construction ES should consider the character of the noise, potential intensification of the site Sensitive receptors need to reflect noise sensitive locations (ie residential premises) Noise and vibration relating to all HGV movements and plant, inclusive of the stack Noise levels from the plant should be 5dB below background levels Habitat loss assessment to be carried out against the restored habitat scenario in 2023 not current Assessing impacts on target species must consider future baseline Beddington Farmlands is a SINC (site of importance for nature conservation) of Metropolitan Importance therefore the Greater London Authority should also be consulted Assessment should be undertaken against future baseline Include evaluation of heritage assets and impact on assets Site is within an Archaeological Priority Area The impact on the historic environment should be included Baseline information from previous planning applications Consideration of adjacent Thames Water dewatering operations Detailed site investigations prior to construction Would construction / operation increase the existing risk of contamination of land, ground water or nearby watercourses? Off site flood risk as a result of changes on site Proposal to consider vegetative solutions to flooding where possible to support local amenity and biodiversity Incorporation of measures to promote flood storage, urban cooling, local amenity and biodiversity

5 Environmental aspect Traffic and transport Key issues identified in scoping Additional issues raised during report consultation Separate traffic scoping report produced for consultation. See paragraph 5.12 Table 5.1: Key issues identified during the scoping process 5.12 Work on the traffic and transport aspects of the proposals commenced before the EIA scoping was submitted. The scope of the transport work was therefore ascertained through a separate consultation and scoping exercise with Transport for London (TfL) and local authority transport officers (details of consultation from January 2011 and February 2012 is included in technical appendix B). This process identified the following points: Parking provision Cycle parking and appropriate changing/shower facilities for staff Requirement for a travel plan (following TfL guidance) Minimising vehicle movement on local road network and avoiding peak times TfL recommended use of TEMPRO growth modelling Agreement of the general principles of the interim TA Access arrangements agreeing new access and junction improvements Routing internal and external 5.13 LBS advised that the following transport issues need to be addressed in the ES: Air emissions (including dust) Noise and vibration Proximity to sensitive receptors Suitability of the road network Part Since February 2011 the proposals have evolved to include issues beyond the site boundary used in the 2010 scoping report and it has been considered necessary, for the purposes of producing a robust, thorough EIA, to increase the site boundary to include the entire Beddington landfill and waste management site. The ERF proposal is located in the north east corner of this wider site boundary. The proposed new site boundary, covering an area of hectares, is as shown in figure The key changes to the proposals, which have made the enlargement of the site boundary necessary, include: 1. The provision of underground pipelines for delivery of heat as part of the combined heat and power (CHP) element of the ERF proposals. Two pipelines are proposed leading from the ERF to the east and south west boundaries of the wider landfill site, in order to allow for future connections with CHP customers. The pipeline to the east is proposed beneath the new access road, and so was already included in the smaller, original site boundary. However, the other pipeline will run towards the western edge of the landfill site. It will then be directed southwards, to the south west corner of the landfill site. A third pipeline will connect the existing landfill gas engines to the pipe heading west. These pipelines need

6 to be covered by the planning application boundary and therefore require consideration within the EIA. 2. As part of the ERF proposals, is giving up some of the landfill void, which means that an area in the south eastern part of the landfill site will no longer be filled to the permitted levels. The landfill restoration plan has therefore been amended to take account of this change, which needs to be included in the planning application boundary. 3. The overall landfill restoration proposals have been given a detailed review and a number of improvements have been made to take account of the progress of restoration to date, and to address changes to the distribution of habitats and other features resulting from the ERF proposals and reduction in void space. Whilst not involving any development, these changes need to be taken into account While the change in site area of the planning application is quite large (i.e. from 4.4 hectares to hectares) the actual changes to the wider landfill area beyond the ERF site itself are quite small, comprising: The installation of underground pipelines The re-profiling of future proposed ground levels in part of the landfill to take account of the reduction in void The re-arrangement of some aspects of the proposed footpath network and distribution of habitats 5.17 The main element of development in the wider site area is therefore the pipeline installation, and the changes to the restoration plan are relatively minor (details within chapter 3: proposals). A letter updating LBS on the change to the site boundary and additional elements of the proposals was submitted on 15 March In the letter (see technical appendix B) feedback was requested on any additional areas of study required for the EIA in relation to the CHP pipe routes and the proposed changes to the landfill, where this was over and above that already noted in the February 2011 scoping opinion The March 2012 letter to LBS highlighted that a specific ground investigation was being undertaken to assess the ground conditions and water environment along the routes of the CHP pipelines. A site walkover was also being undertaken along the pipeline routes, which were also covered by a phase 1 habitat survey. It was set out that all potential environmental impacts associated with the installation of the CHP pipelines and the changes to the restoration proposals would be considered during construction and operation, as appropriate, in the environmental statement (ES) LBS responded to the above points in a letter on 24 April 2012, stating that they understood that there would be a number of changes for the proposed scheme. The letter confirmed that these changes would not require a second scoping opinion as LBS was content that no additional environmental issues (beyond those already identified) would arise Following the scoping exercise (parts 1 and 2), a scoping response document has been prepared to summarise the comments made by the consultees and to show how these issues have been addressed in the ES. Further information is included in the scoping consultation document in ES technical appendix B.

7 Additional consultation 5.21 Further to the consultations undertaken as part of the EIA scoping exercise a number of meetings were held with key consultees to discuss key topics in more detail. Table 5.2 provides a summary of these consultations and where appropriate, more detail is provided in the specific topic chapters. Consultee Meeting date Key points Environment Agency Beddington Conservation Science Group Health Impact Assessment Greater London Authority 16 February March 2012 Meeting: 20 March 2011 Workshops: 17 & 19 March April May 2012 CABE 18 April 2012 Table 5.3: Additional consultation Assessment methodology The following issues were discussed by the technical specialist in the project team and appropriate EA officers: Water environment Ground conditions Air quality Building design CHP Permitting EIA scenarios Restoration of the application site, public access, lighting of the building, tree sparrow opportunities Key areas of discussion were air quality, traffic, noise, house prices, employment, natural environment and green space, waste, visual, fly ash (full details set out in the health impact assessment submitted in support of this application) Discussions looking specifically at biodiversity, landscape and CHP Positive about the plant design (horizontal canopy and industrial appearance) Sensitive location of site within metropolitan open land (MOL) therefore long-term management strategy is key Design team should develop a phasing plan for the application site Encourage visualisation of long distance views (especially from residential areas in Croydon and Hackbridge) and night views (CABE s comments are considered further in the design and access statement) 5.22 It is essential that the EIA is comprehensive and focused. The methodology employed must be organised, rigorous, identify all potential significant impacts, predict and measure the degree of effect, as well as identifying mitigation. The method used should be objective, consistent and adaptable It is important that the assessment methodology makes a distinction between the magnitude of change and the sensitivity of the receptor. It should result in an ES that expresses the main argument and findings of the study clearly to the public as well as to other professionals involved with the proposals The methodologies utilised for the assessment of specific issues are discussed in the following chapters of this document and are based around current

8 knowledge. Where appropriate, use has been made of published guidance and information on best practice. Detailed advice on EIA is contained within the following documents: ODPM, Planning Policy Statement 23: Planning and Pollution Control 2004 (PPS23) Environmental Impact Assessment: a guide to procedures (DETR, 2000) Guidelines for Environmental Impact Assessment produced by IEMA, November The advice given in these documents has been considered in conjunction with the EIA Regulations and related guidance in Circular 02/99: Environmental Impact Assessment. EIA assessment scenarios 5.26 Given the range and complexity of operations occurring at the Beddington Lane site currently, it was considered important to set out clearly the different elements of both the existing baseline and proposed development that will be assessed, together with the associated timescales The existing baseline situation (figure 5.2), taken to be , includes: Operational recycling facility Operational IVC Operational landfill Operational landfill gas engines Use of administration building 5.28 Please note that there is a resolution to grant for an AD facility at the site. This is not included in the existing baseline scenario, since although it has permission, it has not been built. The permission is time limited such that the AD facility will be decommissioned and the area restored by Where appropriate the AD facility has been addressed as part of the assessment of potential cumulative effects Site preparation / demolition / construction activities will take place between 2013 and The proposals are assumed to be operational between 2017 and 2042 (figure 5.3) and include the operational ERF (including recycling operations), CHP pipelines, restored landfill and landfill gas engines. All other activities will have ceased Any impacts associated with operations that will take place for part of the operational period but are not referred to above (i.e. the in vessel composting and completion of the landscape restoration) are considered within individual, relevant environmental chapters of the ES under the heading interim potential impacts, as appropriate For further clarity, the proposed revisions to the approved restoration plan are limited to: The re-profiling of future proposed ground levels in part of the landfill to take account of the reduction in void

9 The re-arrangement of some aspects of the proposed footpath network and distribution of habitats (the proposals chapter sets out more details on the habitat rearrangements) Provision of bird hides in key areas around the lakes, reed beds and within the wet grassland areas to the north and south 5.33 It is worth noting that while the majority of chapters follow this approach, a few chapters assess slight variations on these scenarios. For example the landscape and visual assessment chapter considers the potential effects during construction, at the beginning of operations (2017), 10 years following completion ( in order to take into account the effects of maturing planting), and the effects during winter, summer and night-time Where there is the potential for the South London ERF to give rise to cumulative impacts with other proposed, permitted (but not implemented) developments or developments for which land is allocated, these will be assessed using all available relevant information/data. LBS requested that the following schemes (as shown on figure 5.4) should be included in an assessment of cumulative impacts: One51 recycling site (Country Waste Skips) Application submitted in 2009 for the redevelopment of the site. The proposal included the demolition and clearance of existing waste transfer station (WTS) and the construction of a new enclosed waste management facility (sorting, screening, compacting, shredding, crushing and storage), welfare facilities, access and landscaping. An environmental statement was submitted with the applications, the key EIA issues were identified as natural heritage, cultural heritage, landscape and visual, community, traffic and transport, air quality, noise, hydrology and ground conditions, and waste. Approved in Bioflame gasification (Beddington Heat and Power) Application submitted in 2010 for a small-scale gasification plant with 23m stack, (taking low grade wood and other high biomass waste), replacing two existing buildings. No environmental statement was submitted but the application included technical reports on the following subjects: flood risk, land contamination, odour, natural heritage, traffic, air quality and noise. Approved in Dewatering plant (Thames Water) Application (September 2011) for the construction of two new Dutch Barns (covering 1120m 2 and m 2 ) for the dewatering of sludge cake. This application is not yet determined. Hackbridge master plan (London Borough of Sutton) Produced for consultation in January The projects in the master plan have since been incorporated into the Sutton Sites and Development Management DPD adopted in March The range of projects includes: Traffic management Improving pedestrian and cycle network Greenspaces A gateway to the Wandle Trail

10 Development of land to the north of BedZED A mixed-use district centre (retail, café, restaurants, community, health, employment and housing) on the Felnex site Other redevelopment projects Felnex redevelopment An outline planning application (supported by an environmental statement) was submitted in December 2009 for the redevelopment of the Felnex site (7.7ha) as set in the Hackbridge master plan: Office and workshop space 4,000m 2 foodstore Retail floorspace Residential care home Approximately 792 residential units Community building (including doctors surgery) Open space Associated infrastructure, landscaping and access roads 5.35 This application was approved in Figures 5.2, 5.3 and 5.4 show the relevant elements to be considered as part of the baseline, operational and cumulative assessments respectively. Assessment of the proposals against a future baseline 5.37 Consideration has also been given to the future baseline, the do-nothing scenario, taking account of likely future trends. In the absence of the proposals the application site will be restored in line with the restoration plan agreed under the current landfill consent. Each of the topic chapters includes a brief description of the likely specific conditions expected in the future in the absence of the proposed ERF In the February 2011 scoping opinion LBS requested an assessment of the proposals against a baseline that assumed restoration of the site is complete (as would be expected under the current restoration scheme). It is important to note that there are considerable difficulties in being definitive about what baseline conditions at a future point will be, given that this cannot be objectively measured and will have to be subject to professional judgement and a degree of speculation. It is considered important to ensure that this assessment remains separate from the more rigorous and quantifiable conclusions within the EIA context. This issue has been addressed as requested and the findings have been presented in Assessment of ERF development proposals against 2023 restored baseline, which has been submitted in support of the planning application. Assessment of significance 5.39 An environmental impact is an alteration, positive or negative, to some aspect of the environment occurring as a result of a development The evaluation of effect significance is fundamental to the EIA process. The degree of an effect determines the resources that should be deployed in avoiding or mitigating any adverse effect, and identifies the actual value of a

11 positive effect. The degree of an effect is determined by the interaction of two factors: Magnitude (scale or severity of the effect or change); and Value (importance or sensitivity of the environmental resource being affected). This is then used to determine whether an effect is significant in the context of the EIA Regulations As far as possible, standard words have been used to define degrees of effect (i.e. very substantial, substantial, moderate, slight, and negligible ), but not so rigorously as to stifle flexibility or particular individual requirements Sensitivity and magnitude categories have been developed for the majority of environmental topics, based on a combination of best practice guidance and expert judgement. These are provided in the specialist topic chapters, though in some instances issue specific methods are regarded as being the industry standard, in which case these will be used e.g. the determination of air quality impacts, or the IEEM 2 methodology for the natural heritage assessment. Any assumptions made during the assessment process have been reported in the text Figure 5.5 shows the general matrix (developed by Terence O'Rourke Ltd) used (unless otherwise stated) to determine the degree of each identified effect, and thus whether it is significant. For those chapters that apply this matrix the following approach to significance has been adopted: if the degree of effect for each individual impact is moderate or above then the effect is considered to be significant. Slight or moderate effects are not considered to be significant The assessment of the potential effects also takes account of timescale, permanence and whether the effects are adverse or beneficial, as appropriate (for example, a long term but reversible, substantial, significant adverse effect ) Where appropriate, the results of the assessment of significance have helped to guide the mitigation measures proposed. At the end of each of the environmental assessments, where relevant, there is a residual effect table, which summarises the significant beneficial and adverse environmental effects remaining after mitigation. This includes a measure of confidence placed on the prediction of each potential residual effect, such as absolute, reasonable or limited and distinguishes between certain and circumstantial effects. General format of the environmental chapters 5.46 The remaining chapters in this ES address each of the environmental issues identified during the scoping process. Each chapter is generally structured as follows: Introduction Legislation and policy Methodology Baseline 2 Institute of Ecology and Environmental Management

12 Potential effects - during construction - during operation Mitigation measures Residual effects Summary 5.47 Where there is additional and/or supporting information that is deemed too specialist or detailed for the ES, it can be found in the various technical appendices, a list of which is given in ES chapter 1: introduction.

13 Key I Original site boundary 0.2 km Based upon the 2012 Ordnance Survey 1:10000 scale raster map with the permission of the Ordnance Survey on behalf of Her Majesty's Stationery Office, Crown copyright. Terence O'Rourke Ltd. Licence No. AL South London Energy Recovery Facility Environmental Impact Assessment Fig 5.1 Original scoping site boundary

14 Key Landfill site IVC Landfill gas engines Admin building Recycling facility Site boundary I 0.1 km Based upon the 2012 Ordnance Survey 1:10000 scale raster map with the permission of the Ordnance Survey on behalf of Her Majesty's Stationery Office, Crown copyright. Terence O'Rourke Ltd. Licence No. AL South London Energy Recovery Facility Environmental Impact Assessment Fig 5.2 Existing baseline situation

15 Key Energy recovery facility CHP pipeline Site boundary Landfill gas engines Restored landfill / country park 0.2 km Based upon the 2012 Ordnance Survey 1:10000 scale raster map with the permission of the Ordnance Survey on behalf of Her Majesty's Stationery Office, Crown copyright. Terence O'Rourke Ltd. Licence No. AL South London Energy Recovery Facility Environmental Impact Assessment Fig 5.3 Operational assessment

16 Key Gasification plant - Beddington Heat & Power Waste management facility - Country Waste Recycling Ltd Sludge dewatering - Thames Water Felnex - Hackbridge Unit Trust Hackbridge masterplan Site boundary I 0.2 km Based upon the 2012 Ordnance Survey 1:10000 scale raster map with the permission of the Ordnance Survey on behalf of Her Majesty's Stationery Office, Crown copyright. Terence O'Rourke Ltd. Licence No. AL South London Energy Recovery Facility Environmental Impact Assessment Fig 5.4 Cumulative schemes

17 Determination of significance matrix Sensitivity of receptor High Medium Low Negligible Large Very substantial Magnitude / scale of change Medium Small Substantial Moderate Slight Negligible Negligible Significance If the degree of effect is moderate or above, then the effect is considered to be significant. South London Energy Recovery Facility Environmental Impact Assessment Fig 5.5. Significance matrix