The Meaford Energy (Gas Fired Power Station) Order

10.7: Applicant’s comments on the Local Impact Report

Planning Act 2008 The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009

PINS Reference Number: EN010064 Document Reference Number: 10.7 Regulation Number: N/A Lead Author: Savills

Revision: Date: Description: 0 October 2015 Submitted version

MEAFORD ENERGY CENTRE u APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT

C o n t e n t s

One Introduction 3

PURPOSE OF THIS DOCUMENT 3 COMMON GROUND 4 STRUCTURE OF THIS REPORT 4

Two Applicant’s comments on the LIR 5

LIR SECTION 1.0: PURPOSE OF THE REPORT 5 LIR SECTION 2.0: SITE DESCRIPTION AND SURROUNDINGS 5 LIR SECTION 3.0: DETAILS OF THE PROPOSAL 5 LIR SECTION 4.0: RELEVANT PLANNING HISTORY 6 LIR SECTION 5.0: POLICY FRAMEWORK 6 LIR SECTION 6.0: PROSPECTIVE IMPACTS OF THE PROJECT 6

Three Conclusion 27

u Appendix 29

Plan reference 5105324-MEA-DRG-086: Illustrative cross-sections through planting strip adjacent to canal

APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT u MEAFORD ENERGY CENTRE

MEAFORD ENERGY CENTRE u APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT

One u Introduction

PURPOSE OF THIS DOCUMENT

1.1 Meaford Energy Limited (MEL) is applying to the Secretary of State for a Development Consent Order (DCO) for the construction, operation and maintenance of a combined cycle gas turbine power station, to be known as the Meaford Energy Centre (MEC or ‘the Scheme’). The proposed site is at Meaford Business Park (MBP) in the Borough of Stafford, between Barlaston and Stone in Staffordshire.

1.2 In response to this Application, Staffordshire County Council and Stafford Borough Council (SCC and SBC) have submitted a Local Impact Report (LIR) in accordance with section 60 of the Planning Act 2008 (as amended). Section 60(3) of the 2008 Act defines an LIR as ‘a report in writing giving details of the likely impact of the proposed development on the authority’s area (or any part of that area)’.

1.3 In April 2012 the Planning Inspectorate (PINS) published Advice note one: Local Impact Reports (version 2) to guide the preparation and submission of LIRs. According to this advice note, topics that might be of assistance for an LIR to cover include:

• site description and surroundings/location

• details of the proposal

• relevant planning history and any issues arising

• relevant development plan policies, supplementary planning guidance or documents, development briefs or approved master-plans and an appraisal of their relationship and relevance to the proposals

• relevant development proposals under consideration or granted permission but not commenced or completed

• local area characteristics such as urban and landscape qualities and nature conservation sites

• local transport patterns and issues

• site and area constraints

• designated sites

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• socio-economic and community matters

• consideration of the impact of the proposed articles and requirements within the draft order (such as the scheme) in respect of all of the above

• DCO obligations and their impact on the local authority’s area.

1.4 Advice note one notes that this list is neither exhaustive nor prescriptive. Local authorities should cover any topics they consider relevant to the impact of the proposed development on their area.

1.5 SCC and SBC submitted their LIR by the specified deadline of 28 September 2015. In a letter of 1 October 2015, PINS set out a revised timetable for the examination of MEL’s application. Comments on the LIR were invited by 22 October 2015, and this report forms MEL’S response to this.

COMMON GROUND

1.6 Concurrently with the preparation of this report, MEL has agreed a Statement of Common Ground (SoCG), dated 16 October 2015, with SCC and SBC. This sets out the matters that are agreed between the parties in relation to the Application. The agreed SoCG addresses issues raised in SCC and SBC’s LIR, SCC’s Written Representation and SCC and SBC’s answers to the ExA’s First Questions, which were submitted at Deadline 2 on 28 September 2015. The SoCG should be read in conjunction with this report.

STRUCTURE OF THIS REPORT

1.7 For ease of cross-reference, this report follows the structure of the LIR. In each section, paragraph numbers from the LIR are cited on the left, with MEL’s comments set out on the right.

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Two u Applicant’s comments on the LIR

LIR SECTION 1.0: PURPOSE OF THE REPORT

1.1 – 1.2 No comment.

LIR SECTION 2.0: SITE DESCRIPTION AND SURROUNDINGS

2.1 – 2.4 No comment.

LIR SECTION 3.0: DETAILS OF THE PROPOSAL

3.1 No comment.

3.2 The LIR suggests that the Scheme is on the site of a former power station. As explained and illustrated on pp 26-27 of the Applicant’s Design and Access Statement (document reference. 5.3) and acknowledged in LIR para. 6.5.2, there were two coal-fired power stations on the site. Meaford ‘A’ closed in 1974 and was demolished in 1982. Meaford ‘B’ closed in 1990 and was largely demolished by the late 1990s.

3.3 – 3.4 No comment.

3.5 The LIR states that ‘. . . the proposed gas connection would be located on the western side of the West Coast Main Line . . .’. Whereas this is generally the case, it should be noted that the Above Ground Installation (AGI) (identified as Work no. 2A in Schedule 1 of the draft DCO (document reference 3.1)) at which the connection with the gas distribution network would be made, and the first section of pipeline between the AGI and the Power Station Complex (a part of Work no. 2B in Schedule 1 of the draft DCO), would be to the east of the West Coast Main Line. The Gas Connection would cross the West Coast Main Line by means of an existing bridge (Railway Bridge 104) over which pulverised fuel ash from the coal-fired power stations was once conveyed.

3.6-3.8 No comment.

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LIR SECTION 4.0: RELEVANT PLANNING HISTORY

4.1-4.2 No comment.

LIR SECTION 5.0: POLICY FRAMEWORK

5.1: National Planning Policy Framework

5.1.1 – 5.1.13 No comment.

5.2: The Plan for Stafford Borough 2011-2031

5.2.1 – 5.2.23 No comment.

5.3: Staffordshire and Stoke-on-Trent Joint Waste Local Plan 2010-2026

5.3.1 – 5.3.3 No comment.

General The Applicant’s Planning Statement (document reference 5.2) reviews the Scheme in the light of relevant planning policies, plans, strategies and guidance, in order to examine the extent to which the Scheme would comply with identified requirements at the national and local level.

LIR SECTION 6.0: ASSESSMENT OF PROSPECTIVE IMPACTS OF THE PROJECT

6.1: Socio-economic

6.1.1 – 6.1.22 No comment.

GENERAL Requirement 18: Local economic benefit in Schedule 2 of the draft DCO (document reference 3.1) makes provision for the submission and approval of ‘a scheme for the promotion of local economic benefit from the authorised development in the area of Staffordshire’.

6.2: Transport and traffic

6.2.1 No comment.

6.2.2 Requirement 10: Construction traffic in Schedule 2 of the draft DCO (document reference 3.1) makes provision for the submission and approval of a Construction Traffic Management Plan that must include:

(b) construction vehicle traffic routing; (c) details of a HGV vehicle booking management system; (d) site access plans and 24 hour access arrangements.

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HGVs will be routed along Meaford Road directly to and from the A34 in accordance with the routing plan included with the Application (document reference 6.3.6, figures 7.3 and 7.4). Upon completion of the Southern Access Road, in particular the new roundabout on the A34/Meaford Road junction, HGVs approaching the Site from the south will turn right at the new roundabout rather than proceeding north and circulating around the Meaford gyratory system as shown on figure 7.3. HGVs leaving the site and heading north will turn right at the new roundabout on the A34/Meaford Road junction rather than turning left and proceeding south to the Stone roundabout, as shown on figure 7.4. The Applicant considers that these provisions represent a satisfactory response to the Councils’ concern to manage construction traffic and its routing.

6.3: Air quality

6.3.1-6.3.6 No comment.

6.4: Noise and vibration

6.4.1 The LIR refers to online research undertaken by the Councils concerning the generic sources of operational noise at a CCGT power station. With one exception, all of the noise sources identified in the LIR are included in table 9.1 of chapter 9 of the Main ES (document reference 6.2.9), which identifies a longer list of noise emitting structures. The exception is what the LIR refers to as ‘gas release vented to the atmosphere’. Gas is a valuable fuel source and would not be vented to the atmosphere. It should be noted also that the Councils’ list of noise sources does not take into account plant design and mitigation to attenuate noise from the Power Station Complex.

6.4.2 Paragraphs 9.148 – 9.151 in chapter 9 of the Main ES (document reference 6.2.9) describe the generic noise mitigation. The MEC will operate subject to noise limits set out in an Environmental Permit (EP). If a DCO is made, MEL will proceed to apply to the Environment Agency (EA) for an EP once the detailed design specification for the Power Station Complex is confirmed and noise mitigation measures can be identified with precision. Responsibility for ensuring that the Power Station Complex operates within acceptable parameters will fall to the EA rather than SBC.

Since the LIR was submitted, the Applicant has agreed a Statement of Common Ground with SBC and SCC which acknowledges in para. 6.15 that:

e). responsibility for setting and enforcing compliance with noise limits during the operational phase of the Meaford Energy Centre will lie with the Environment Agency through its administration of the Environmental Permitting process; and

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f). there are no outstanding issues [concerning noise and vibration] that need to be addressed ay any issue-specific hearing.

The Applicant considers that there is no need for a DCO Requirement for a noise monitoring plan to be submitted to and approved by the relevant planning authority.

6.4.3 Requirement 5: Construction and Environmental Management Plan in Schedule 2 of the draft DCO (document reference 3.1) makes provision for the submission and approval of a Construction and Environment Management Plan (CEMP) that will include amongst other matters:

(d) environmental monitoring (e) roles and responsibilities (f) means of communication, record keeping, reporting, auditing and review (g) complaints procedures (h) nuisance management including measures to avoid or minimise the impacts of construction works (covering dust, lighting, noise and vibration)

The Applicant considers that the CEMP would provide for all of the environmental monitoring and reporting provisions identified in para. 6.4.3 of the LIR.

6.4.4 The noise and vibration assessment in chapter 9 of the Main ES (document reference 6.2.9) is based on construction of the Scheme taking place between the hours of 07:00 and 19:00 Monday to Saturday, with no construction activities taking place on Sundays or public holidays without prior consent from the relevant planning authority. The only difference between the hours assessed in the ES and those specified in Requirement 12: Construction hours of the draft DCO relate to proposed construction hours of 07:00 to 13:00 on Saturdays and on public holidays.

In respect of construction activities on Saturdays, the ES in chapter 9 offers a ‘worst-case’ assessment, concluding in paragraphs 9.178 to 9.180 that the Scheme would not result in any significant adverse noise effects during construction. The assessment is sound.

The MEC Site is suitably separated from residential receptors such that, with the environmental controls provided for in the CEMP and listed in 6.4.3 above, the conclusion of the ES is that construction could take place within the hours proposed by the Applicant without significant adverse effects on local amenity.

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The Councils have not justified why shorter construction working hours are proposed in paragraph 6.4.4 of the LIR. Having regard to the final bullet- point in paragraph 4.4.3 in the Overarching National Policy Statement for Energy (EN-1), the onus should be placed upon the Council to provide a technical justification for their alternative working hours proposal.

The Councils’ reduced construction hours represent a five hour or 7.6% reduction in the proposed working week. A compensatory 7.6% increase in the length of the overall 36-month construction period would amount to approximately twelve weeks. The Councils’ reduced working hours would intensify construction traffic movements during the working day. They also overlook the practical point that the first and final hours of the working day on a construction site rarely give rise to the most significant noise and vibration effects. Instead, they tend to be characterised by staff briefings and the setting up and consolidation of the day’s work. For all these reasons, the Applicant does not consider that local amenity would benefit from the reduced construction hours proposed in the LIR.

6.4.5 This paragraph of the LIR omits to take into account the comprehensive measures proposed by the Applicant to protect residential amenity during construction, as set out in the following Requirements in Schedule 2 of the draft DCO (document reference 3.1):

Requirement 5: Construction and Environment Management Plan Requirement 10: Construction traffic Requirement 12: Construction hours

6.4.6 The Applicant rebuts the suggestion in this paragraph that Barlaston Golf Club and the adjacent public house would suffer ‘particular negative effects’ during the operational phase of the MEC, including ‘the effects of significant noise levels and a loss of amenity’. This is not borne out by the EIA of the Scheme and the Councils have not presented any evidence to substantiate this view. Barlaston Golf Club and the adjacent public house are at least 700 metres from the Power Station Complex, and planning permission has been granted for a substantial business park development (Meaford Business Park) on land between the Power Station Complex and the golf club and public house. In the Applicant’s response to 6.4.2 above, MEL notes that the MEC would operate subject to noise limits set out in an EP that would be granted by the EA. On the basis that the EP would enforce the operation of the Power Station Complex within acceptable noise limits, there is no basis for seeking additional acoustic and amenity protection or for compensation to be provided to the businesses specified in the LIR.

6.4.7 Provisions for environmental monitoring and a nuisance management system during the construction stage of the Scheme are set out in Requirement 5: Construction and Environmental Management Plan in

APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT u MEAFORD ENERGY CENTRE

Schedule 2 of the draft DCO in 5.1 (d), (e), (f), (g) and (h). The draft CEMP (document reference 17.1) provides for community liaison (paragraph 4.3.5) and for an external complaints procedure (section 5.4), making a separate online noise and management system unnecessary. The detailed CEMP will be subject to approval by the relevant planning authority. As noted in the Applicant’s response in 6.4.2 above, the MEC will operate subject to noise limits set out in an EP, which will be agreed with the EA.

6.5: Ground conditions

6.5.1-6.5.13 No comment.

6.6: Flooding and drainage

6.6.1 No comment.

6.6.2 The Applicant acknowledges the change in responsibility for the adoption and maintenance of sustainable urban drainage systems (SUDS) at the MEC Site. The Applicant proposes to assume responsibility for the management and maintenance of the SUDS for the operational lifetime of the MEC or if and when the owner of the MBP requires it to be managed in conjunction with the overall surface water drainage for the MBP as a whole.

6.7: Waste and minerals

6.7.1 No comment.

6.7.2 Provision for a Site Waste Management Plan is set out in Requirement 5: Construction and Environmental Management Plan in Schedule 2 of the draft DCO (document reference 3.1). In addition, section 6.4 of the draft Construction and Environmental Management (Appendix 17.1 of the ES (document reference 6.4.11)) sets out the Applicant’s position on waste and refers to the draft Site Waste Management Plan (SWMP). A draft SWMP has been provided as part of the Application in Appendix 15.2 of the ES (document reference 6.4.10).

The Applicant considers that it is premature to define in detail the content of the decommissioning strategy for the Scheme. Requirement 21: Decommissioning strategy of the draft DCO (document reference 3.1) provides for the submission and approval of a decommissioning strategy that will include the demolition and removal of Work no. 1 (i.e. the Power Station Complex). It is already clear that the management and disposal of demolition waste will need to be addressed in the strategy, and there is no need for a requirement for waste to be considered as part of a decommissioning strategy for the MEC.

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6.7.3 The Councils’ request to be notified about possible opportunities to recover sand and gravel during construction is noted. However, the Site was developed previously and the depth from which any useful material could be recovered is likely to be below the level of the Applicant’s excavations.

6.8: Landscape and visual

6.8.1 The primary policy to be considered in respect of the landscape and visual effects of the Scheme are part 5.9 of the Overarching National Policy Statement for Energy (EN-1) and part 2.6 of the National Policy Statement for Fossil Fuel Generating Infrastructure (EN-2), rather than the NPPF, as suggested (albeit the Secretary of State may consider the NPPF to be important and relevant to her decision).

6.8.2 In addition to the policies identified in this paragraph of the LIR, it is relevant also to note also that policy E5 of the adopted Plan for Stafford Borough 2011-2031 provides for the major redevelopment of the site of the former power stations at Meaford. As noted above, the extant planning permission for the Meaford Business Park (MBP) has recently been extended by SBC. Such a development will inevitably exert landscape and visual effects and it would be inappropriate to apply the local plan policies identified in LIR para. 6.8.2 to the MEC proposals without reference to this wider context.

6.8.3-6.8.6 No comment.

6.8.7 The Applicant considers that this paragraph of the LIR makes a sweeping statement that does not provide a fair and balanced summary of the conclusions of the LVIA. Reference should be made to paragraphs 10.207– 10.219 in the concluding section of chapter 10: Landscape and Visual Effects of the Main ES (document reference 6.2.10) and in particular the following:

• Paragraphs 10.207 and 10.215, which acknowledge the beneficial landscape and visual containment provided by local landform and vegetation;

• Paragraphs 10.211, highlighting the acknowledgement in SCC’s report, Planning for Landscape Change, that the local landscape contains various incongruous elements including electricity pylons, roads and railways. This paragraph notes also that the effect on Canal Bridge 101 (Malkin’s Bridge) ‘is very minor in relation to the extent and landscape character of the Trent and Mersey canal’;

• Paragraphs 10.214 and 10.217, which acknowledge the progressive benefit of the Applicant’s proposed landscape and visual mitigation;

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• Paragraph 10.218, which makes the point that the Scheme has been designed and assessed in accordance with ‘Rochdale Envelope’ principles and that detailed design will afford further opportunities for visual mitigation, such as through the use of an appropriate colour scheme. Requirement 3: Detailed design of the draft DCO (document reference 3.1) provides for the submission and approval of a scheme of colour, materials and surface finishes.

Following submission of the LIR on 28 September 2015, the Applicant has agreed a SoCG with SCC and SBC on 16 October 2015. In respect of landscape and visual effects, paragraph 6.17(c) of the SoCG confirms that the following is agreed:

c). the assessment, and conclusion, of significance (alone and cumulatively) detailed in paragraphs 10.166-10.219 of ES: Main Statement chapter 10 (document reference 6.2.10) . . .

6.8.8 No comment.

6.8.9 The Applicant is concerned that the landscape and visual section of the LIR is treating the current Scheme as an intrusion into an untouched or unspoiled greenfield environment and is overlooking the site’s history, its current condition and the extant planning permission for the development of Meaford Business Park. In considering the height of established vegetation on the site boundary and the level of visual screening and containment it would provide, it is relevant to take account of the following factors.

i). The visual blight presented by the site of the former power stations in its current derelict condition.

ii). The visual prominence of a significant number of existing overhead power lines across the former power station site and on surrounding land.

iii). The mature vegetation and landscaping that surrounds the site.

iv). The presence of the West Coast Main Line railway adjacent to the Trent and Mersey Canal, with its attendant infrastructure including overhead catenary gantries.

v). Variations in terrain – the Power Station Complex would be on lower ground than the Trent and Mersey Canal on the site of the former Meaford ‘B’ power station.

vi). The separation distances between visual receptors outside the site and the principal tall structures in the Power Station Complex.

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vii). The reinforcement of established vegetation proposed in the landscape strategy, which would enhance the level of visual screening and containment.

viii). The high likelihood that other substantial development will take place around the Power Station Complex, including on land between the Power Station Complex and the Trent and Mersey Canal, as a part of the Meaford Business Park development in accordance with the extant planning permission.

In view of these considerations, the Applicant disagrees with the assertion in paragraph 6.8.9 of the LIR that the Power Station Complex would ‘reduce the buffering of urban development that currently exists and have a local detrimental effect on the landscape character of the area’.

Since the LIR was submitted on 28 September 2015, the Applicant has agreed a SoCG with SCC and SBC. In paragraph 6.17 (c) and (d) of the SoCG, the assessment and conclusion of significance and the proposed mitigation including landscape and planting principles, as described in referenced parts of the ES, are all agreed. On this basis, it may be concluded that the concerns raised in paragraph 6.8.9 have been addressed.

6.8.10 It would be more accurate if this paragraph of the LIR were to read ‘. . . There are limited views of towards the site from Stone, Meaford and Barlaston’. Distance and intervening undulating landform/terrain, vegetation along country lanes and transport corridors and buildings combine to significantly restrict views of the site from surrounding settlements.

6.8.11 Paragraph 6.8.11 of the LIR contradicts the conclusions of the Applicant’s landscape and visual assessment as reported in chapter 10 of the ES (document reference 6.2.10), the methodologies, assessment and conclusions of which are agreed in paragraph 6.17 of the SoCG between SCC, SBC and the Applicant dated 16 October 2015.

Paragraph 10.46 of ES chapter 10: Landscape and visual effects (document reference 6.2.10) confirms that the Applicant agreed the LVIA methodology, identification of visual receptors, photomontage locations, planting principles and the LVIA study area with SCC’s landscape architect in February 2014.

It has been demonstrated that with the implementation of the landscape screening vegetation buffer, substantially in accordance with the Illustrative landscape plan (document reference 2.7.2) and the description of the works contained in paragraph 4.81 of the ES (document reference 6.2.4), views

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from the Trent and Mersey Canal would be substantially screened, with only glimpses being afforded to users of the canal. This is demonstrated in Photosheet M Photomontage 3 (document reference 6.3.9, Figure 10.5c) which shows the landscape planting one year after implementation. Once the MBP is developed and the new vegetation is further established the view of the MEC from the Trent and Mersey Canal will be screened, as shown on Photosheet N Photomontage 3 (document reference 6.3.9, figure 10.5c).

With specific reference to the individual receptors identified in paragraph 6.8.11 of the LIR, the relevant conclusions set out in paragraphs 10.123 to 10.147 and 10.167 of chapter 10 of the Main ES (document reference 6.2.10) for the operational phase of the Scheme are as follows:

Public right of way rural 46 (Downs Banks)

The residual effects of the Scheme would be significant for both Year 1 and 15 based on the Scheme, resulting in a noticeable change to the view, albeit viewed in the context of existing road infrastructure and pylons. Available views would be partially filtered by vegetation along the right of way.

Residences along the A34

At Year 1 the upper sections of the Scheme including the Stacks would be visible, resulting in a partial alteration to the view. The effect at Year 1 has been assessed as significant. Subject to mitigation, the effects at Year 15 will reduce to insignificant due to the screening benefit of maturing vegetation.

Trent and Mersey Canal and towpath

The operational effects at Year 1 would be significant, principally due to the visibility of the Stacks above the intervening vegetation. Views of the rest of the Scheme would be partially filtered by the reinforcement of the retained boundary vegetation. By year 15 the effects are reduced to insignificant due to the screening benefit of maturing vegetation.

The submission, approval and implementation of a landscape scheme is provided for in Requirement 4: Provision of an implementation and maintenance landscaping in the draft DCO (document reference 3.1). In relation to elevated viewpoints, the mitigation measures for views from Downs Banks are set out in Requirement 3: Detailed Design of the draft DCO and provides for the design of the external elevation to be approved prior to the commencement of numbered works 1, 2 and 4 in respect of: (a) the siting, design, external appearance, dimensions and floor levels of all permanent buildings and structures, and (b) the colour, materials and surface finishes of the pipeline and all permanent buildings and structures.

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The Design and Access Statement (document reference 5.3) also sets out the following Design Objective (para 2.80): ‘all buildings and structures within the Power Station Complex should avoid bright, prominent or reflective materials'.

In addition the Scheme is substantially screened by mature existing trees and landscaping surrounding the MBP Site.

6.8.12 The Applicant’s choice of site for the Power Station Complex was informed by consideration of a range of environmental, operational and other considerations, as described in ES chapter 3 (document reference 6.2.3), and by consultations as explained in the Consultation Report (document reference 5.1). The photomontage (Annex 2, Figure 9) in Appendix 10.3 of the ES (document reference 6.4.5) only represents one viewpoint, whereas the Applicant’s choice of site considered landscape and visual factors in the round.

MEL’s approach to site selection was to take account a wide range of considerations, including the need to identify the most appropriate location within the Meaford Business Park without compromising the Business Park’s development in accordance with the extant planning permission, to maximise job creation, rather than simply siting the Scheme in response to – for instance – landscape and visual concerns alone. Nonetheless, in the current context MEL considers that its site selection decision was well justified by landscape and visual considerations as affirmed by the consultation process. The LIR offers no evidence to the contrary.

Paragraph 10.21 of chapter 10 of the ES (document reference 6.2.10) states that the LVIA assumes, as a worst case assessment, that the finished floor level of the Power Station Complex is 99m AOD, although it is likely that the final level will be lower (97m AOD). At this stage, prior to final design, an AOD of 99m represents a realistic worst case upon which the LVIA has been undertaken.

6.8.13 Requirement 4: Provision of and implementation and maintenance landscaping in Schedule 2 of the draft DCO (document reference 3.1) provides for the submission and approval of a detailed landscape scheme. MEL considers that a landscape buffer ten metres in width alongside the Trent and Mersey Canal will provide for dense vegetation to contain views along the canal corridor and to screen views from the canal and towpath across the Meaford Business Park site towards the Power Station Complex. The landscape buffer will be substantially in accordance with the Illustrative Landscape Plan (document reference 2.7.2), and the description of the works contained in paragraph 4.81 of chapter 3 of the ES (document reference 6.3.4). MEL agrees that lower level planting is likely to be most effective in these terms and states in paragraph 4.81 of chapter 3 that the

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new vegetation/shrub planting will be up to 4m in height. In the absence of evidence to the contrary the Applicant would query why trees 20 metres in height are considered necessary.

Paragraph 6.17 (f) of the SoCG between SCC, SBC and the Applicant dated 16 October 2015, confirms that the written landscape scheme for the ten metre screening vegetation buffer alongside the canal is agreed between the parties, taking into account the need to protect an existing overhead electricity line (see paragraph below) from encroaching vegetation. The appended plan (reference 5105324-MEA-DRG-086) confirms that an appropriate separation distance can be maintained between the overhead electricity distribution line running along the landscape buffer and vegetation within the buffer, whilst ensuring satisfactory visual screening. Due to the proximity of the vegetation to the canal, the presence of vegetation between the canal and the Order Limits, the distance to the MEC and the relative heights and the topography, the users of the canal would have to look through the landscape buffer to see any part of the MEC.

The Applicant will be responsible for maintaining the landscape buffer including the area under and around the overhead electricity distribution lines. The Distribution Network Operator (WPD) will only have a statutory right of entry to undertake clearance works if the Applicant fails to maintain the statutory vegetation clearances. The maintenance works will comply with the written landscape scheme which will be agreed with the local planning authority in accordance with Requirement 4: Provision of and implementation and maintenance landscaping in the draft DCO (document reference 3.1), which will be amended to reflect the agreed amendments in paragraph 6.29(2) of the SoCG between the Applicant, SCC and SBC.

6.8.14 The ten metre vegetation buffer alongside the canal is the primary means of containing views along the canal corridor and screening views from the canal and towpath across the Meaford Business Park towards the Power Station Complex. The landscape planting elsewhere in the Site is intended to bring benefit from the A34 to the west and from within the Meaford Business Park site itself. The proposed planting adjacent to the MEC is part of this overall landscaping and ecological mitigation. These are all legitimate landscape objectives. For the avoidance of doubt, no landscape and visual mitigation is proposed on land outside the Order Limits.

6.8.15 Requirement 3: Detailed Design in Schedule 2 of the draft DCO (document reference 3.1) makes provision for details of the following to be submitted to and approved by the relevant planning authority:

(a). the siting, design, external appearance, dimensions and floor levels of all permanent buildings and structures;

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(b). the colour, materials and surface finish of the pipeline and all permanent buildings and structures.

The draft DCO provides for the colour scheme of the proposed development to be considered in detail in the light of the design considerations identified in para. 6.8.15 of the LIR.

6.9: Ecology and trees

6.9.1 Paragraph 6.9.1 of the LIR appears to be addressing wider concerns about the development of Meaford Business Park. It is not the purpose of the Application to provide compensatory wildlife habitats for developments outside of the Order Limits or in connection with the employment development of the MBP. The Power Station Complex totals 3.2 ha whereas the area for landscape and ecological mitigation, as proposed and agreed with SCC and SBC in March 2015, totals nearly 3 ha.

The ecological assessment in chapter 11 of the ES (document reference 6.2.11) assumes that ecological mitigation measures would be implemented for the MBP as part of any reserved matters planning approval (paragraphs 11.312 and 11.316 of chapter 11 of the ES). Paragraph 6.19 of the SoCG between the Applicant, SCC and SBC, dated 16 October 2015, confirms that the methodology, assessment, mitigation principles and conclusions of the Applicant’s ecology assessment are agreed.

6.9.2 No comment.

6.9.3 The concerns raised in paragraph 6.9.3 of the LIR are addressed by the following Requirements of the draft DCO:

• Requirement 5: Construction and Environmental Management Plan in Schedule 2 of the draft DCO (document reference 3.1) provides in (j), (o) and (q) that the CEMP will include:

(j. ‘habitats protection measures, including fencing to delineate the Trent and Mersey Canal Local Wildlife Site, protection zones for retained trees and bat roosts, means of escape for badgers and other small mammals’. (o) pre-construction works otter survey to be undertaken beneath Canal Bridge 101 (Malkin’s Bridge). (q) ecology, landscape and visual impact mitigation (covering protection of trees to be retained . . .)

• Requirement 9: Habitat management plan in Schedule 2 of the draft DCO provides for the submission and approval of a Habitat Management Plan. These measures, when viewed alongside the physical separation

APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT u MEAFORD ENERGY CENTRE

that would exist between the canal corridor and proposed development are considered by MEL to be an appropriate safeguarding response to the considerations identified in para. 6.9.3 of the LIR.

The extent of the ten metre screening vegetation buffer, as shown on the Illustrative Landscape Plan (document reference 2.7.2), has been agreed in paragraph 6.17 (f) of the SoCG, dated 16 October 2015, between the Applicant and SCC and SBC.

6.9.4 As noted by SCC and SBC in the LIR, chapter 11 of the ES: Ecology (document reference 6.2.11) explicitly acknowledges the value of the MEC site for biodiversity and as a habitat for invertebrates specifically and does not assume the common misconception that the LIR notes is sometimes made by other developers. As such the Applicant understands paragraph 6.9.4 of the LIR to be acknowledging that the ES deals appropriately with this issue.

Paragraphs 11.264 – 11.303 in chapter 11 of the ES set out a range of habitat and biodiversity mitigation measures for the Scheme, including, in paragraphs 11.278 – 11.294, a range of measures of benefit to invertebrate populations on the site. The balance of habitats lost and gained is summarised in Table 11.23 on page 11-67 of the ES.

The MEC Site is not subject to statutory nature conservation designations. The wider Meaford Business Park site, of which the Scheme forms part, is identified for strategic employment use in policy E5 of the adopted Plan for Stafford Borough 2011-2013. The draft of this plan was the subject of Strategic Environmental Appraisal (SEA) and was scrutinised by nature conservation bodies. Outline planning permission for the development of the Meaford Business Park was recently extended by SBC (reference number 14/21379/EXTO), at which time a further opportunity existed to scrutinise the former Meaford Power Station site from an ecological perspective. Taken together, these considerations reinforce the conclusion of the ES that the Site is capable of accommodating major development from an ecological perspective, subject to the safeguards proposed in Requirements 5: Construction and Environmental Management Plan and 9: Habitat management plan of the draft DCO (document reference 3.1).

Whereas it is the case that brownfield sites can develop their own ecology, the general preference for brownfield over greenfield land, acknowledged for example in paragraph 5.10.3 of the Overarching National Policy Statement for Energy (EN-1), can have an ecological benefit by reducing demand for greenfield development sites.

6.9.5 It is noted that the Illustrative Landscape Plan 5105324-MEA-DRG-081 (document reference 2.7.2) is ‘agreed as appropriate’ in paragraph 6.9.5 of

MEAFORD ENERGY CENTRE u APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT

the LIR and this has been confirmed in the SOCG between the parties dated 16 October 2015.

The Applicant does not consider that the area proposed for ecological mitigation is small in comparison to areas of habitat to be lost, as shown in Table 11.23 on page 11-67 of the ES. Whilst the Order Limits extend over an area of 16.6 ha, only the Power Station Complex site and the AGI will remain as above ground structures. These areas represent 3.2 ha. As such, the total area that the Applicant intends to provide as mitigation (totalling c.3 ha) is, in its view, more than adequate and no further mitigation is required for the Scheme.

Once the Gas Connection has been constructed it will be subject to a ten metre wide permanent easement. The land above the easement, together with the remaining land within the Gas Connection Corridor, will be returned to the owner of MBP. Subject to the permanent easement and the detailed development plan for the MBP, it might be used for car parking and/or service yard areas for the development of Meaford Business Park in accordance with the extant planning consent to deliver the overall combined socio-economic benefits of the MEC and MBP.

The works required to the Northern Access Road (Works No 4) are limited to improving the physical access. There is a possibility that the Northern Access Road will cease to be the access to the MEC, at some future date, if the owner of MBP provides the Applicant with an alternative access to either the Northern Access Road or the new Southern Access Road. Applying ecological mitigation along this route would be inappropriate and impractical as it would restrict development of the MBP in accordance with the extant planning permission and could compromise the overall combined socio-economic benefits of the MEC and MBP.

The Applicant considers it has made appropriate provision for ecological mitigation, which will be the subject of detailed submissions under Requirement 5: Construction and Environmental Management Plan part (j) and Requirement 9: Habitat management plan in the draft DCO (document reference 3.1). These should be considered in conjunction with DCO Requirement 4: Provision of and implementation and maintenance landscaping, which requires details of:

(i) a 10 metre screening vegetation buffer as shown on the indicative landscaping plan;

APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT u MEAFORD ENERGY CENTRE

(j) surface water attenuation pond designed to incorporate native marginal planting; (k) the locations of low fertility [habitats] (where applicable for invertebrates, and; (l) butterfly bank planting.

6.9.6 Paragraph 6.9.6 refers to paragraph 4.8.1 of the ES but the Applicant assumes that this is actually intended to refer to paragraph 4.81 of the ES (document reference 6.2.4). This paragraph does not refer to a 10m wide band of ‘woodland’. Paragraph 4.81 is set out below:

The illustrative landscaping for the Scheme is shown on plan 'Illustrative Landscape within MEC Site' (see document reference 2.7.2). It includes mitigation areas that reflect landscape, ecological and heritage considerations - integrating the MEC and MBP into the local context, providing screening to protect the historic character of the Trent and Mersey Canal Conservation Area and to mitigate the effects of the development on visual receptors, and enhancing broadleaf woodlands, woodland edge and shrub planting and habitat diversity. The landscape and planting strategy thus includes:

• where possible retaining existing tree groups and woodland through the Scheme design;

• implementing open amenity grass, meadow and wildflower grassland, woodland, woodland edge and shrub planting (less than 4m high) that will be able to integrate into the wider landscape framework of the MBP master plan;

• actively managing existing tree groups and woodland and undertaking new planting of native species to reinforce the screening effect of linear areas located on the edge of the MEC and a 10m buffer strip adjacent to the Mersey and Trent Canal to protect the historic character of the Conservation Area and visual amenity of recreation users and to contain views along the Trent and Mersey Canal corridor.’

Paragraph 4.81 confirms the Applicant’s view that the most effective way of screening the MEC from the Trent and Mersey Canal is shrub planting up to a height of 4m.

Plan reference 5105324-MEA-DRG-086, appended to this report, confirms that the proximity of an existing overhead electricity distribution line to the landscape buffer would not present a significant constraint for ecological enhancement within the buffer.

MEAFORD ENERGY CENTRE u APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT

The extent of the landscape and ecological buffer, with a width of 10m, as shown on the Illustrative Landscape Plan (document reference 2.7.2), has been agreed in paragraph 6.17 (f) in the SOCG between the Applicant and SCC and SBC, dated 16 October 2015.

6.9.7 DCO Requirement 4: Provision of and implementation and maintenance landscaping part (h) in Schedule 2 of the draft DCO requires the submission and approval of ‘implementation timetables for all landscaping works'. DCO Requirement 9: Habitat management plan part (2) states that ‘the habitat management plan must include an implementation timetable and must be carried out as approved’. The programme of works that the LIR recommends as necessary for ecological reasons is therefore provided for in the draft DCO.

Works No. 5A (referred to as ‘Area 5A’ in the LIR) is not available for ecological mitigation as it will be returned to the owner of MBP after construction has been completed. This is a temporary construction laydown and car parking area. Works No. 5B is the permanent construction laydown and car parking area forming part of the Power Station Complex and landscaping and ecological mitigation measures for this area are shown in the Illustrative landscape plan 5105324-MEA-DRG-081 (document reference 2.7.2).

6.9.8 Details such as those identified in LIR paragraph 6.9.8 would be submitted for approval in response to Requirement 4: Provision of and implementation maintenance landscaping; Requirement 5: Construction and Environmental Management Plan; and Requirement 9: Habitat management plan of the draft DCO (document reference 3.1) and as explained above.

6.9.9 Requirement 9: Habitat management plan part (1) of the draft DCO includes measures for the provision of ‘. . . ecological monitoring and management included in the environmental statement’ to be included in the Habitat Management Plan that the Applicant must submit for approval.

The ecological management of land outside of the Scheme’s Order Limits is a matter for consideration in connection with the extant planning permission for the Meaford Business Park. It would be inappropriate for this to be incorporated in the DCO for the MEC. The DCO Requirements referred to above address the necessary ecological mitigation for the MEC.

6.9.10 No comment.

6.9.11 Requirement 4: Provision of an implementation and maintenance landscaping in Schedule 2 of the draft DCO (document reference 3.1) in part (g) makes provision for the submission and approval of ‘an arboricultural method statement including details of existing trees and tree groups

APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT u MEAFORD ENERGY CENTRE

identified for retention, management and reinforcement with the type and extent of protection to be in accordance with BS 5837:2012’. Requirement 5: Construction and Environmental Management Plan in the draft DCO in part (q) makes provision to include measures for ‘ecology. landscape and visual impact mitigation (covering protection of trees to be retained . . .’. The Applicant considers that adequate provision has been made for tree protection, including along the Gas Connection Corridor and any outfall pipe to the River Trent.

6.9.12 Please see the response to LIR paragraph 6.9.6 above.

The maintenance works will comply with the written landscape scheme that will be agreed with the local planning authority in accordance with Requirement 4: Provision of an implementation and maintenance landscaping of the draft DCO (document reference 3.1).

6.9.13 No comment.

6.10: Historic environment and archaeology

6.10.1-6.10.2 No comment.

6.10.3 In respect of the historic environment and archaeology, the SoCG agreed by the Applicant, SCC and SBC, dated 16 October 2015, confirms that the parties agree with the relevant technical assessment contained in chapter 12: Historic environment of the ES (document reference 6.2.12), including the assessment, methodology, the assessment of significance (alone and cumulatively), and the identified mitigation.

6.10.4 No comment.

6.10.5 The assessment of effects on cultural heritage assets at Meaford Hall was informed by the Applicant’s landscape and visual impact assessment, including reference to the Zone of Theoretical Visibility (ZTV) reproduced in Figure 10.1 of the ES (document reference 6.3.9) and a site visit undertaken in January 2014, when deciduous trees are free of foliage.

MEAFORD ENERGY CENTRE u APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT

The ZTV indicates that the there are few areas in the vicinity of Meaford Hall from which the Power Station Complex Stack/s would be visible. The site visit indicated that, once the screening effect of intervening terrain and woodland are taken into account, the Stack/s would not become a notable feature in views from Meaford Hall and its immediate environs, or in views towards the listed building from the former historic parkland to the west, southwest and south. There may be a very small number of locations within the parkland where glimpses of the tops of the Stack/s may be visible over or through trees in the winter months but these will not affect the contribution that the historic parkland makes to the setting and significance of the listed building.

6.10.6 The ES assessments were undertaken during winter and represent the worst case scenario. The assessment in chapter 12 of the ES (document reference 6.2.12) acknowledges that the significance of the group of assets relating to Meaford Hall has been diminished slightly by their conversion to flats, and that their setting has been modified by other residential developments in the immediate locality. Their setting and significance has also been compromised by the loss of the Hall’s formal gardens (see Table 12.8 in chapter 12 of the ES). The ES assessment recognises that views to and from the group of assets are generally constrained by dense tree growth.

6.10.7 The additional information provided in the Trent and Mersey Canal Conservation Area Appraisal (August 2014) does not alter the assessment of the effects of the Scheme on this conservation area.

6.10.8 The Trent and Mersey Canal Conservation Area Appraisal does not acknowledge the views that can be gained from some parts of the canal over the large expanse of brownfield land occupied formerly by the Meaford ‘A’ and ‘B’ power stations and crossed by several tall overhead electricity transmission lines. In addition, this stretch of canal has diverse types of infrastructure on both sides including the West Coast Main Line railway together with its gantries, an electricity substation and, as previously mentioned, overhead electricity lines and pylons. However, the landscape buffer beside the canal will help to screen views to the west and contain views along the canal corridor.

6.10.9 These are the views that the proposed canal side landscape buffer would help to screen.

6.10.10 Whilst there would be some views of the Power Station Complex when crossing the grade II listed Turnover Bridge (Canal Bridge 100) from east to west, the planting proposed in the Illustrative Landscape Plan (document reference 2.7.2) would lessen the visual prominence of the Scheme in these views.

APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT u MEAFORD ENERGY CENTRE

The key aspects of the setting of the Turnover Bridge in terms of the contribution that the setting makes to the significance of the structure, namely its visual and functional relationship with the canal, would not be adversely affected by the presence of the Scheme to the west. Any effect on the significance of the Turnover Bridge due to the presence of the Scheme in westerly views from the bridge is very limited and assessed at worst as a minor adverse impact.

6.10.11 In respect of Canal Bridge 101 (Malkin’s Bridge), part (2) of Requirement 16: Bridge plinths in the draft DCO (document reference 3.1) provides that ‘the crown of the pipeline over canal bridge 101 must not protrude above the repaired parapet by more than 150 mm in height’. Allowing for the setback between the pipe and the repaired parapet, the pipe should not be visible from the canal or towpath at close quarters as the maximum protrusion above the bridge parapet will be 150 mm. The effect on long views will be limited.

Requirement 3: Detailed design in the draft DCO in part (4) provides that the Applicant has to provide written details of the design, external appearance as provided for in (4) (a) as well as colour and surface finishes of the pipeline in (4) (b).

The LIR’s observations about the security fence are acknowledged. However, the fence is necessary for security and it was observed on the ExA Accompanied Site Visit on 22 September 2015 that similar security fencing is visible alongside the West Coast Main Line railway from extensive lengths of the canal corridor nearby. The design and colour of any fencing is subject to approval of the relevant planning authority in accordance with Requirement 8: Fencing and other means of enclosure of the draft DCO.

6.10.12 Please refer to MEL’s response to LIR paragraph 6.10.5 - 6.10.6 above

6.10.13 Chapter 12: Historic Environment of the Main ES (document reference 6.2.12) acknowledges in Table 12.8 that the Scheme would slightly increase the intrusion of modern infrastructure into the setting/character of the Trent and Mersey Canal Conservation Area. However, the overall effect of the Scheme in isolation has been assessed as slight adverse and therefore not significant. The ES finds that the cumulative effects of the MBP would have an minimal additional effect on the setting of the Trent and Mersey Canal (paragraph 12.99) resulting in no significant cumulative effects on the canal as a historic receptor.

In respect of Turnover Bridge the ES assessment in Table 12.8 states that the setting of the receptor is localised, reflecting its position in the shallow ravine of the canal with thickly wooded and vegetated sides. Table 12.8

MEAFORD ENERGY CENTRE u APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT

states that ‘development in the wider landscape would have little or no impact on the setting and significance of these assets’. On this basis the historic receptor of the Turnover Bridge is not predicted to experience significant adverse effects.

The assessment of significance of the effects on heritage assets is agreed by the Applicant, SBC and SCC in the SoCG paragraph 6.21, dated 16 October 2015.

6.10.14 MEL would be receptive to an additional provision in Requirement 16: Bridge plinths of the draft DCO (document reference 3.1) requiring the submission and approval of a method statement to include the extent and nature of the repairs for the parapet of Canal Bridge 101 (Malkin’s Bridge). The amended DCO submitted for examination Deadline 3 reflects this position.

6.10.15 Please refer to the second part of the Applicant’s response to paragraph 6.10.11 above.

6.10.16-6.10.22 No comment.

6.11: Public rights of way

6.11-1-6.11.7 No comment.

APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT u MEAFORD ENERGY CENTRE

MEAFORD ENERGY CENTRE u APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT

Three u Conclusion

3.1 Several general themes run though this response to the LIR for the Meaford Energy Centre Scheme. These can be summarised as follows.

i). There is extensive agreement on the methodology, assessment, mitigation and conclusions of the Environmental Statement for the Scheme. The extent of this agreement has been highlighted in this document and is codified in the Statement of Common Ground that has been agreed my MEL, SBC and SCC since the LIR was completed.

ii). Similarly, there is widespread agreement about the planning policy context for the Scheme and the means by which the current proposals would support a wider regeneration of the Meaford Business Park site.

iii). Where some specific aspects of the environmental impact assessment of the Scheme have been questioned in the LIR under the technical headings of landscape, ecology and cultural heritage, etc, this response has sought to provide relevant clarification and to demonstrate that, in most cases, MEL correctly identified the issue and is proposing appropriate safeguards in the draft DCO. It appears that not all sections of the LIR were written in cognisance of what these safeguards are.

iv). Similarly, a few sections of the LIR do not, in MEL’s view, give sufficient recognition of the wider development context for the Scheme – notably, the development of the Meaford Business Park, which has the benefit of a local plan allocation, an outline planning permission and a new road access under construction from the A34.

3.2 As the Statement of Common Ground with SBC and SCC completed on 16 October 2015 demonstrates, since the publication of the LIR the Applicant has continued to engage constructively with the local authorities in order to satisfy outstanding concerns.

* * *

APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT u MEAFORD ENERGY CENTRE

MEAFORD ENERGY CENTRE u APPLICANT’S COMMENTS ON THE LOCAL IMPACT REPORT

Appendix

Plan reference 5105324-MEA-DRG-086 Illustrative cross-sections through planting strip adjacent to canal

0 10 Millimetres 100 Ordnance Survey,(c)CrownCopyright.Allrightsreserved.Licencenumber0100031673

Elevation 108.00 102.00 104.00 110.00 112.00 114.00 116.00 118.00 106.00

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13.00 LANDSCAPE MITIGATION-MANAGEMENTOFEXISTING 1.6m CABLE STAND-OFF TREE GROUPSANDWOODLANDTOPROVIDEA10M

OH-ELEC 15.00 OH-ELEC

OVERHEAD ELECTRICALCABLES OH-ELEC

BUFFER TOPROTECTCHARACTERANDSCREENVIEWS LANDSCAPE MITIGATION-MANAGEMENTOFEXISTING

TREE GROUPSANDWOODLANDTOPROVIDEA10M OH-ELEC 1.6m CABLE 17.00 STAND-OFF

Cross SectionA-A

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Scale 1:100 19.00

Distance OH-ELEC

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EXISTING SL EXTENT OFORDERLIMITS

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27.00

PATH Pipe

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OH-ELEC Lines HEIGHT 1.6m EYE Turnover 29.00 Bridge

TURNOVER BRIDGE

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True

N MP 26 DO NOTSCALE Drawing Number Original Size Scale Drawing Title Project Title Client Drawing Status Copyright CAtkinsLimited( 1. NOTES: 5. 3. 2. 4.

SL KEY: INCLUDES ANALLOWANCEOF1.27mFORCABLESWING FOR SAGATMID-SPANAND1.2mCLEARANCETOALLOW %(7:((17+(9(57,&$/$1'3/86P)25*52:7+ DOCUMENT ENERGYNETWORKSASSOCIATIONTECHNICAL DEVELOPMENTS LTD. POSITION OFOVERHEADCABLESBASEDON BASED ONDRGNO.5105324-MEA-DRG-081 OF ANYPROPOSEDPLANINGBENEATH. GROWTH OFANYADJACENTPROPOSEDPLANTING. SPECIFICATION 43-8ISSUE3,2004,PLUS1.0mALLOWANCE CABLES CONSISTSOF0.8mCLEARANCEREQUIREDUNDER SHEET MPHOTOMONTAGE3,DOCUMENTNO. CROSS SECTIONA-ALOCATIONBASEDONTHATFORPHOTO 5105324-MEA-ENV-121 THE 1.6mHORIZONTALCLEARANCETOOVERHEADCABLES THE 3.0mTOTALVERTICALCLEARANCETOOVERHEAD TOPOGRAPHICAL SURVEYPROVIDEDBYSTMODWEN OH-ELEC A1 EXISTING PYLONSANDOVERHEADDISTRIBUTION LINES PROPOSED PLANTING. MAINTAINED BETWEENOVERHEADCABLESAND ORDER LIMITS OVERHEAD HIGHVOLTAGEELECTRICCABLES AND VERTICALCLEARANCEOF3.0mWILLBE ZONE INWHICHAHORIZONTALCLEARANCEOF1.6m Date Designed 2014 Date Drawn ) Fax: 10 HollidayStreet, B1 1TF Birmingham, Tel: www.atkinsglobal.com The Axis, West Midlands. +44 (0)1214835252 +44 (0)1214835000 Date Checked Date Authorised Revision Suitability