Rugeley B Power Station – EIA Scoping Consultation Response
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Rugeley B Power Station – EIA Scoping Consultation Response March 2019 Brereton and Ravenhill Parish Council Comment Response The EIA must include Appropriate steps in respect of asbestos removal Asbestos removal predominately relates to the consented demolition works which do not form part of the Proposed Development. However, asbestos removal will be considered as appropriate in the EIA. Appropriate mitigation measures for dealing with asbestos materials encountered during the Proposed Development will be identified in the Remediation and Reclamation Strategy. Appropriate steps to protect neighbouring land, including homes and other buildings and Noted, these receptors will be considered in all relevant assessments in the EIA. roads Predominantly through the assessments of Transport, Noise, Air Quality, Ground Conditions, Water Environment. Appropriate steps to ensure that material from the demolition does not enter the air or The consented demolition works do not form part of the Proposed Development. the River Trent Measures to ensure that unacceptable impacts do not occur during the demolition works are secured under Planning Permissions 18/01098/FULM and CH/18/268. Measures to ensure nature conservation is fully addressed and the need to consult Noted, nature conservation will be fully addressed in the EIA. Predominantly bodies with expertise in this field through the Ecology assessment. Canal and River Trust Comment Response Ecology Request effects on the canal are included in the ES Ecology assessment and Potentially increased recreational usage of the canal will be considered in terms opportunities are considered for biodiversity enhancement. of ecology effects in the ES. Heritage The assessment should also include the undesignated heritage assets along the stretch Noted, the ES Built Heritage Chapter will consider all the designated and non- canal. designated built heritage assets along the canal that fall within the study area, including the Trent and Mersey Canal. The significance of these assets including any contribution made by their setting and the impact of the proposed development on that significance will be assessed. With regard to the specific views that might be affected, it is considered that a main Noted, the viewpoints suggested by the Canal and River Trust will be viewpoint to consider will be 100m west of Bridge 61, Church Bridge. The landscape considered. The built heritage team will work closely with the landscape team to falls away from the canal to the north while flanking vegetation, providing an open rural make sure that all key views from the Canal have been included. 1 view towards the site from the navigations outward perspective. Views to and from St John’s church and Church Bridge itself should be included. It is also recommended that a viewpoint 100 metres before Armitage Tunnel (passes underneath the A513) is included, there may be similar views over to the site from this point, which is a broader stretch of canal. Transport The proposed development both during construction and operation has the potential to The assessments to be carried out as part of the TA and ES will consider traffic significantly impact on the canal from increased traffic adjacent to the canal corridor, on impacts on the road network. The canal network is segregated from the road bridge crossings and on the towpath itself. network; however, it is acknowledged that some of the affected roads cross the canal, run parallel to the canal or have pedestrian/cycle access points to and In addition, any assessment should consider the wider impacts of increased traffic and from the canal which may require users to cross the road to continue their this should specifically include reference to existing canal crossings within the wider journey. vicinity of the site. The assessment of specific environmental effects in relation to either construction or development traffic will be carried out on affected links with reference to the canal/bridges and crossings where relevant. Those environmental effects of most relevance in this instance are likely to be those of severance, pedestrian/cyclist delay and pedestrian/cyclist amenity. The document does not acknowledge waterborne traffic as a potential sensitive receptor The assessment of construction traffic will assume that all activity is carried out and subsequently does not identify the potential impacts to boat movements or by road. It is suggested that flexibility is retained for the potential movement of navigational safety which may be particularly affected during construction. The materials on and off site by water should an agreement be reached between the feasibility of utilising the waterway for freight/construction should also be included. developer and the Canal and Rivers Trust at the appropriate time. It is proposed that such a statement is included in the CEMP. LVIA The approach to the Landscape and Visual Assessment appears reasonable, Para Para 14.3.5 notes that the Trent and Mersey Conservation Area is a notable 14.3.7 does mention the Trent & Mersey Canal, though this is only under the umbrella of feature, further within 14.3.6 it states that where there is potential intervisibility the 'The Way for the Millennium Footpath'. Whilst it appears that this footpath follows the this will be considered further as part of the LVIA. Viewpoints 3a,3b and 3c are towpath for much of the section through Rugeley it is considered that further specific from along the footpath. references to the Trent & Mersey Canal as a receptor should be included to ensure the assessment takes in all viewpoints along the canal corridor. With regard to the specific views that might be affected, it is considered that a main view A view has been added into the assessment from this location which will show point to consider will be 100m west of Bridge 61, Church Bridge. The landscape falls the relationship between the site, bridge and church. away from the canal to the north with little flanking vegetation, providing an open rural view towards the site from the navigations outward perspective. Views to and from St View 5 has been taken from the church. The combined views should illustrate John's church and Church Bridge itself should also be included. the interrelationship between all the noted features. It is also recommended that a view point 100 meters before Armitage Tunnel (passes A view from this location has been added to the LVIA assessment. The mature 2 underneath the A513) is included, there may be similar views over to the site from this woodland that flanks Borrow Pit lake does provide a robust screen towards the point, which is a broader stretch of canal. West of the Armitage Tunnel the canal is well site due to its elevated nature. buffered by vegetation aside of the A513 and reads as sitting lower in the landscape, and therefore this is likely to be less sensitive in terms of long ranging views towards the site, which would be obscured by existing landscape features. Water Environment Advice is given regarding the need to ensure that impacts upon the canal and users (as The Trent & Mersey Canal (as well as any other sensitive controlled waters a sensitive receptor) are considered across all topics. receptors), including the presence of users of the waterway corridor, will be The response notably states: ‘The assessments should not only consider the ecological considered and accounted for in further detail as part of the ES Ground impacts to the canal network but also the potential impacts on land stability and users of Conditions Chapter. the waterway corridor’ As stated in Paragraph 13.2.29: ‘…a Remediation and Reclamation Strategy is being prepared and will be implemented prior to the commencement of the Proposed Development. Whilst some reference to land stability may be included within the baseline of the EIA, the Remediation and Reclamation Strategy will identify and mitigate any land stability issues associated with the Proposed Development.’ Due to the scale of the proposed development the works have the potential to impact on The water environment assessment will determine potential for any adverse the canal in this location. impacts to water receptors, including the Trent and Mersey Canal. Appropriate Due to their overall scale and nature the proposals have the potential to impact on the mitigation is to be provided where any significant adverse effects are identified. wider canal network. The trust would wish to be assured that the development would not Furthermore, as a WFD designated waterbody, the potential for deterioration or impact on the canal and would still allow for it to be enjoyed by residential, leisure and prevention of future improvement in the status of the Trent and Mersey Canal business users. (currently at Good Ecological Potential) will be assessed within a separate WFD Directive Assessment, which will be appended to the Environmental Statement. The assessments should not only consider the ecological impacts to the canal network These impacts will be assessed in the relevant chapters of the Environmental but also the potential impacts on land stability and users of the waterway corridor. Statement, with impacts on navigation considered within the water environment Consideration should be given to boaters, including leisure and residential moorings in assessment. the vicinity of the site It should be clarified that users of the Trent and Mersey Canal, boaters, both leisure Potential impacts on navigation will be considered in the water environment users and residential along with towpath users are sensitive receptors both during assessment contained within the Environmental Statement. construction and future operation of the site. In addition, residential moorings should be Impacts to residential moorings and towpath users will be considered within the afforded equal consideration as a sensitive receptor as dwelling houses. EIA as appropriate as residential receptors. In assessing the impact of the development, the EIA should also identify any The canal is not within the application site, thereby limiting opportunity for opportunities to improve the canal corridor to enhance biodiversity.