Appellant's Submissions

APPELLANT’S SUBMISSIONS Proposal Details Proposal Name 100084743 Proposal Description Appeal against refusal of planning application for the installation of gas powered electricity generation plant with associated access, fence and security columns Address Local Authority Renfrewshire Council Application Online Reference 100084743-001

Application Status Form complete Main Details complete Checklist complete Declaration complete Supporting Documentation complete Email Notification complete

Attachment Details Notice of Review System A4 Grounds of Appeal Attached A4 Grounds of Appeal Production 1 Part Attached A4 1 Grounds of Appeal Production 1 Part Attached A4 2 Grounds of Appeal Production 2 Attached A4 Grounds of Appeal Production 3 Attached A4 Notice_of_Review-2.pdf Attached A0 Application_Summary.pdf Attached A0 Notice of Review-001.xml Attached A0 Renfrewshire House Cotton Street Paisley PA1 1JD Tel: 0300 3000 144 Fax: 0141 618 7935 Email: [email protected]

Applications cannot be validated until all the necessary documentation has been submitted and the required fee has been paid.

Thank you for completing this application form:

ONLINE REFERENCE 100084743-001

The online reference is the unique reference for your online form only. The Planning Authority will allocate an Application Number when your form is validated. Please quote this reference if you need to contact the planning Authority about this application.

Applicant or Agent Details

Are you an applicant or an agent? * (An agent is an architect, consultant or someone else acting on behalf of the applicant in connection with this application)  Applicant Agent Agent Details

Please enter Agent details

McInally Associates Ltd Company/Organisation:

Ref. Number: You must enter a Building Name or Number, or both: *

Thomas First Name: * Building Name:

McInally 16 Last Name: * Building Number:

Address 1 Robertson Street Telephone Number: * 01413325181 (Street): *

Extension Number: Address 2:

Glasgow Mobile Number: Town/City: *

Scotland Fax Number: Country: *

G2 8DS Postcode: *

Email Address: * [email protected]

Is the applicant an individual or an organisation/corporate entity? *

 Individual  Organisation/Corporate entity

Page 1 of 5 Applicant Details

Please enter Applicant details

Title: You must enter a Building Name or Number, or both: *

Clyde View (Suite F3) Other Title: Building Name:

22 First Name: * Building Number:

Address 1 Pottery Street Last Name: * (Street): *

Erskine Generation Ltd Riverside Business Park Company/Organisation Address 2:

Greenock Telephone Number: * Town/City: *

Scotland Extension Number: Country: *

PA15 2UZ Mobile Number: Postcode: *

Fax Number:

Email Address: *

Site Address Details

Planning Authority: Renfrewshire Council

Full postal address of the site (including postcode where available):

Address 1:

Address 2:

Address 3:

Address 4:

Address 5:

Town/City/Settlement:

Post Code:

Please identify/describe the location of the site or sites

Site 300m south west of Shilton Cottage, Old Greenock Road, Bishopton

Northing Easting

Page 2 of 5 Description of Proposal

Please provide a description of your proposal to which your review relates. The description should be the same as given in the application form, or as amended with the agreement of the planning authority: * (Max 500 characters)

Installation of gas powered electricity generation plant with associated access, fence and security columns

Type of Application

What type of application did you submit to the planning authority? *

 Application for planning permission (including householder application but excluding application to work minerals).  Application for planning permission in principle.  Further application.  Application for approval of matters specified in conditions.

What does your review relate to? *

 Refusal Notice.  Grant of permission with Conditions imposed.  No decision reached within the prescribed period (two months after validation date or any agreed extension) – deemed refusal.

Statement of reasons for seeking review

You must state in full, why you are a seeking a review of the planning authority’s decision (or failure to make a decision). Your statement must set out all matters you consider require to be taken into account in determining your review. If necessary this can be provided as a separate document in the ‘Supporting Documents’ section: * (Max 500 characters)

Note: you are unlikely to have a further opportunity to add to your statement of appeal at a later date, so it is essential that you produce all of the information you want the decision-maker to take into account.

You should not however raise any new matter which was not before the planning authority at the time it decided your application (or at the time expiry of the period of determination), unless you can demonstrate that the new matter could not have been raised before that time or that it not being raised before that time is a consequence of exceptional circumstances.

Please see attached Grounds of Appeal

Have you raised any matters which were not before the appointed officer at the time the  Yes  No Determination on your application was made? *

If yes, you should explain in the box below, why you are raising the new matter, why it was not raised with the appointed officer before your application was determined and why you consider it should be considered in your review: * (Max 500 characters)

Page 3 of 5 Please provide a list of all supporting documents, materials and evidence which you wish to submit with your notice of review and intend to rely on in support of your review. You can attach these documents electronically later in the process: * (Max 500 characters)

Grounds of Appeal with outlined productions

Application Details

Please provide details of the application and decision.

What is the application reference number? * 17/0663/PP

What date was the application submitted to the planning authority? * 07/09/2017

What date was the decision issued by the planning authority? * 30/11/2017

Review Procedure

The Local Review Body will decide on the procedure to be used to determine your review and may at any time during the review process require that further information or representations be made to enable them to determine the review. Further information may be required by one or a combination of procedures, such as: written submissions; the holding of one or more hearing sessions and/or inspecting the land which is the subject of the review case.

Can this review continue to a conclusion, in your opinion, based on a review of the relevant information provided by yourself and other parties only, without any further procedures? For example, written submission, hearing session, site inspection. *  Yes  No

Please indicate what procedure (or combination of procedures) you think is most appropriate for the handling of your review. You may select more than one option if you wish the review to be a combination of procedures. Please select a further procedure *

Further written submissions on specific matters

Please explain in detail in your own words why this further procedure is required and the matters set out in your statement of appeal it will deal with? (Max 500 characters) To ensure all necessary details are before the Board

In the event that the Local Review Body appointed to consider your application decides to inspect the site, in your opinion:

Can the site be clearly seen from a road or public land? *  Yes  No Is it possible for the site to be accessed safely and without barriers to entry? *  Yes  No

Page 4 of 5 Checklist – Application for Notice of Review

Please complete the following checklist to make sure you have provided all the necessary information in support of your appeal. Failure to submit all this information may result in your appeal being deemed invalid.

Have you provided the name and address of the applicant?. *  Yes  No Have you provided the date and reference number of the application which is the subject of this  Yes  No review? *

If you are the agent, acting on behalf of the applicant, have you provided details of your name  Yes  No  N/A and address and indicated whether any notice or correspondence required in connection with the review should be sent to you or the applicant? * Have you provided a statement setting out your reasons for requiring a review and by what  Yes  No procedure (or combination of procedures) you wish the review to be conducted? *

Note: You must state, in full, why you are seeking a review on your application. Your statement must set out all matters you consider require to be taken into account in determining your review. You may not have a further opportunity to add to your statement of review at a later date. It is therefore essential that you submit with your notice of review, all necessary information and evidence that you rely on and wish the Local Review Body to consider as part of your review. Please attach a copy of all documents, material and evidence which you intend to rely on  Yes  No (e.g. plans and Drawings) which are now the subject of this review *

Note: Where the review relates to a further application e.g. renewal of planning permission or modification, variation or removal of a planning condition or where it relates to an application for approval of matters specified in conditions, it is advisable to provide the application reference number, approved plans and decision notice (if any) from the earlier consent.

Declare – Notice of Review

I/We the applicant/agent certify that this is an application for review on the grounds stated.

Declaration Name: Mr Thomas McInally

Declaration Date: 19/02/2018

Page 5 of 5 PLANNING APPEAL STATEMENT SITE AT OLD GREENOCK ROAD, BISHOPTON

ON BEHALF OF ERSKINE GENERATION LTD

February 2018 Contents

CONTENTS

1 INTRODUCTION...... 1

2 THE PROPOSED DEVELOPMENT...... 3

The Site...... 3

Current Land Use...... 3

Historic Land Use...... 4

3 REASONS FOR REFUSAL ...... 6

Reason for Refusal Number 1 ...... 6

Reason for Refusal Number 2 ...... 7

Reason for Refusal Number 3 ...... 8

Reason for Refusal Number 4 ...... 9

4 CONCLUSIONS...... 12

PRODUCTIONS

Production 1: Application package (consisting of all plans, Planning Statement, Air Quality Impact Assessment (plus 2 updates) and Noise Impact Assessment)

Production 2: Planning Application Refusal Notice

Production 3: Planning Application Report of Handling

i Introduction

1 INTRODUCTION

1.1 This appeal is lodged against the decision taken by officers of the Renfrewshire Council to refuse planning permission for the Installation of a gas powered electricity generation plant with associated access and fencing on a site 300 metres south west of Shilton Cottage, Old Greenock Road, Bishopton.

1.2 The plant is being developed in response to the UK Government’s reform of the UK electricity market and specifically to support and make more efficient use of renewable energy developments by ensuring the grid network has sufficient generation capacity to meet demand during peak times. The proposal is also required as a result of the need to balance the grid using local sources that can react at short notice to deliver electricity to the network. Gas peaking plants, using natural gas as a clean fuel, are generally used at times of ‘stress’ on the network and by offering this balancing mechanism provide the last line of defence to prevent serious fluctuations and blackouts.

1.3 The UK’s electricity supply is undergoing a transition from traditional, ageing, large scale, centrally managed base load thermal (most commonly coal) plants to low carbon sources such as renewables, natural gas and new nuclear. To compensate for the closure of the large and older Coal fired power stations and the future losses form the closure of nuclear generators in Scotland there is an urgent requirement for smaller, more flexible “on demand” plants, such as the Erskine Gas Peaking Plant.

1.4 The development is therefore being proposed in response to the need to guarantee security of electricity supply and prevent future blackouts, particularly during busy periods of peak demand. The proposed Development represents a part of the estimated £100 billion capital investment needed in the UK to meet the projected increases in electricity demand over the next decade. It is also important that the Erskine Gas Peaking Plant will therefore only operate for a limited number of hours a week, on request from National Grid to meet peak hour demands It is also important that the gas powered plant provides a secure source of electricity to balance any shortfalls for renewable resources in times of low wind and solar generation. As the development is proposed as a source of reserve power, which will only operate when the National Grid needs it to, it will not operate continuously, with maximum anticipated operation of 3000 hours per year.

1.5 In relation to the application the locational requirements of gas peaking plants are very specific in that they require to be located :

. close to a suitable point of connection to the national grid i.e. a substation with sufficient available capacity and an appropriate voltage; and

. a gas supply with suitable pressure.

1.6 The site selection process therefore concentrated on identifying suitable areas of land close to these key infrastructure components. Having identified Erskine Substation as having sufficient capacity for a plant of this nature further assessment

1 Introduction

identified a gas pipeline of suitable, intermediate pressure within Old Greenock Road immediately adjacent to the site as well as sufficient land available in the vicinity. Identifying sites suitable for development of this nature is rare there is therefore a strong argument supporting the Development at this location.

1.7 The full justification for the proposal is provided in the Planning Statement which was submitted with the application package (Production 1 refers).

2 The Proposed Development

2 THE PROPOSED DEVELOPMENT

2.1 The proposed development, which will be operational for up to 40 years, will consist of ten modern, highly efficient gas generators within acoustically controlled containerised units and ancillary equipment comprising a control building, transformer units, gas meter, ancillary plant, parking spaces and perimeter fencing. The development will have a maximum electricity generating capacity of 19.9MW from containerised gas engines. The location of the site, close to the national electricity and gas networks is of key importance in maximising the efficiency of the gas engines. The Development will be designed to operate intermittently as instructed by National Grid in order to supply electricity during peak or strained times.

THE SITE

2.2 As outlined above there are few sites suitable for the development of a gas powered generation facility as a result of the locational needs of such an operation and this site was selected on the basis of:

. Proximity to existing 33kV substation with sufficient capacity;

. Proximity to the gas network (at sufficient pressure);

. Availability of suitable, relatively level land;

. Good access direct from the Old Greenock Road;

. Proximity to existing infrastructure – Erskine Substation, electricity pylons and a large motorway junction;

. Low visibility and a degree of existing screening;

. Distance from nearest designated ecological or archaeological sites; and

. Distance to nearest houses.

CURRENT LAND USE

2.3 The site is located within an area of agricultural land between the SPEN Erskine Substation on Old Greenock Road and the M898 slip road at Junction 30 of the M8. The Site is currently used as agricultural grazing land. Land immediately east and north of the site is crossed by electricity pylons associated with the Erskine Substation. There is a degree of existing screening, provided by trees and the motorway itself, between the site and the transport corridors which surround it.

3 The Proposed Development

2.4 A photograph of the proposed site, taken from Old Greenock Road at the proposed site entrance, is included below.

HISTORIC LAND USE

2.5 No previous uses of the land other than for agricultural purposes have been identified. The M8 motorway was constructed to the southeast of the site in the 1960s and forms a distinct boundary to this part of the site. The construction of the motorway and the use as an agricultural site are considered to be the extent of the recent historical use of the site.

2.6 Whilst it has some value as agricultural land for grazing of livestock, this is limited to grazing land, and the site is not prime agricultural land. The design of the proposed development, following existing field boundaries, will allow the majority of the field in which it is located to continue in its current use.

2.7 Further north of the site is the larger Shilton Plantation, which provides more extensive screening of views of the site from the north. The M8 and M898 provide a separation between the site and the more distant settlements of Bishopton and Erskine respectively. Whilst located within an area of farmland, the site is within an area that has clearly been influenced by infrastructure development.

2.8 The gas generators will be fuelled by low carbon natural gas. This fuel is considered to be very clean, resulting in no smoke and negligible emissions of nitrous oxides (NOₓ), carbon monoxide (CO) and particulates and no emissions of sulphur oxides (SOx). The gas is supplied to the application site through the regular, national and local gas distribution network located nearby.

4 The Proposed Development

2.9 The Planning statement submitted with the application (Production 1) provides a comprehensive assessment of current and relevant planning polices particularly in the Renfrewshire Council Local Development Plan and supports the contention of the applicant that the proposal is in full compliance with the Local development plan and as such should have been approved.

5 Reasons for Refusal

3 REASONS FOR REFUSAL

3.1 As outlined above four reasons for refusal were offered in the Report of Handling (see Productions 2 and 3) and a response to each of these reasons is offered below.

REASON FOR REFUSAL NUMBER 1

3.2 The first reason for refusal states that :

The proposal is contrary to Policy ENV1 of the Adopted Renfrewshire Local Development Plan in that it would introduce development into the green belt which, by virtue of its scale, location and design, would not be commensurate with the aims of protecting and enhancing the landscape setting of the area.

3.3 This reason for refusal must be considered against the assessment provided in the report of handling (Production 3) which concluded that “I am satisfied that the proposal constitutes an acceptable form of development in the green belt in principle, and is thus compliant with this aspect of policy ENV1.”

3.4 The assessment states that :

“Assessment

Policy ENV1 states that appropriate development within the green belt will be considered acceptable where it can be demonstrated that it is compatible with the provisions of the New Development Supplementary Guidance. The supplementary guidance sets out several forms of development which are acceptable in the green belt in principle. This includes essential infrastructure where it is demonstrated that a green belt location is required.

In this instance, the application site was chosen primarily for its proximity to the Erskine substation, an electricity transformer which would provide access to the local electricity distribution network and is able to accept the export of electricity from the proposed installation. The need for the proposed development is also considered to be justified with regard to the role such gas powered electricity generation installations will have in the modernising and evolving electricity distribution network. The development will be able to provide on demand back up at times of stress on the electricity network when demand exceeds supply. This is considered to be particularly relevant given the move towards increased generation of electricity from renewable sources which can be intermittent in nature.

In view of the above, I am satisfied that the proposal constitutes an acceptable form of development in the green belt in principle, and is thus compliant with this aspect of Policy ENV1.”

3.5 Against this assessment the reason for refusal cannot be justified and should be set aside.

6 Reasons for Refusal

REASON FOR REFUSAL NUMBER 2

3.6 The second reason for refusal states that:

The proposal is contrary to the Adopted Renfrewshire Local Development Plan New Development Supplementary Guidance – Delivering the Environment Strategy in that it would introduce development into the green belt which would, by virtue of its scale, position and design, undermine the core role and function of the green belt by both individual and cumulative means, and would fail to maintain and enhance the local landscape character of the area.

3.7 Against this refusal it is important that the Core Role and function of the Green belt has been defined, in the Report of Handling as being to support planned growth, maintain the identity of settlements, protect and enhance the landscape setting of an area and protect and promote access opportunities to Open Space.

3.8 In this context the proposed development supports planned growth by providing a secure source of electricity without which further growth of planned urban growth cannot be achieved. It is however relevant that the site of the proposed development is remote from the urban area. It is in a landscape which is defined by existing infrastructure, including the adjacent motorway infrastructure and is not visible from the urban area. As such it has no impact on the identity of any settlement nor the landscape settlement of the area. Whilst the site is currently in agricultural use the proposed development will have no adverse impact on public access to open space.

3.9 In such circumstances it is maintained that the proposal would not undermine the Core Role and function of the green belt.

3.10 With regard to the landscape character of the area the site is part of an agricultural field which is well defined by the existing landscape structure with the proposed development set back against the trees to the south and with an acoustic screen fence 3 metres high which effectively screens the development to the point that it will hardly be visible.

3.11 The refusal focuses on the visibility of the development from the Old Greenock Road as it crosses the M898. The photo below is taken in the direction of the site from this road. It is clear from the photo that even when the trees are without leaves, that the site is barely visible from this location. Whilst views of the site may be apparent further west on this road, they would be largely screened by the proposed planting plan, and in any event only occur for a distance of approximately 250 m. Taking account of the 60 mph speed of this road, these views would be very limited.

7 Reasons for Refusal

3.12 In such circumstances it is maintained that the proposed development will have no adverse impact on the landscape character of the area. If however this was considered to be an issue the applicant would accept a condition, similar to that imposed on other such infrastructure developments in the area, to provide additional landscaping to the satisfaction of the planning authority, prior to work commencing on site. Screening has already been proposed as part of the application process, although the applicant would be happy to agree additional screening in this regard.

3.13 It is maintained that there is no justification for refusal on the basis of reason for refusal number 2.

REASON FOR REFUSAL NUMBER 3

3.14 The third reason for refusal states that:

The proposal is contrary to Policy I6 of the Adopted Renfrewshire Local Development Plan in that the location, siting and design of the development would have a significant and detrimental impact, both individually and cumulatively, on the landscape character of the area.

3.15 Policy I6 of the Adopted Local plan states in relation to Renewable Energy and Low Carbon Energy Developments that:

“Renewable and low carbon energy developments will be supported in principle where they are appropriate in terms of the location, siting and design having regard to any individual or cumulative significant effects on:

8 Reasons for Refusal

. Local environment, landscape character, built, natural or cultural heritage;

. Amenity of existing or allocated uses;

. Visual amenity;

. Outdoor sport and recreation interest; and,

. The safe and efficient use of the airport, flight activity, navigation, flight paths and Ministry of Defence surveillance system. Any development will require to comply with the above criteria as well as the details outlined in the New Development SG.”

3.16 Against these criteria and as outlined above the promotion of the gas powered plant is an important element in the secure supply of electricity during peak periods. It is however important that the proposed development is in one of the rare locations where such a facility can be provided in a relatively small field outwith the urban area and adjacent to major infrastructure that helps to screen any adverse impacts of the proposal. As stated above the proposed development can be developed without any significant effect on the local environment landscape character or built environment with no impact whatsoever on cultural heritage. In addition :

. The proposal will have no adverse impact on existing or allocated uses and indeed will increase the viability of the existing agricultural unit.

. The proposal will not have any significant impact on Visual Amenity.

. The proposal will have no impact whatsoever on outdoor sport or recreation.

. The proposal will have no impact whatsoever on the safe and efficient use of Glasgow Airport or the Ministry of Defence surveillance system.

3.17 As such it is again maintained that there is no justification for refusal on the basis of reason for refusal number 3.

REASON FOR REFUSAL NUMBER 4

3.18 The fourth reason for refusal states that :

The proposal is contrary to the Adopted Renfrewshire Local Development Plan New Development Supplementary Guidance – Delivering the Infrastructure Strategy in that it would introduce a significant visual intrusion in to the landscape which would, by virtue of its scale, position and design, result in an adverse and detrimental impact, both individually and cumulatively, on the landscape character of the area.

3.19 The objectives of the Supplementary Guidance with regard to Delivering the Infrastructure Strategy states that “Renfrewshire’s LDP places an emphasis on investment in infrastructure as it is central to increasing sustainable economic growth as well as supporting the transition to a low carbon economy”. Support

9 Reasons for Refusal

for the transition should have encouraged the support of this application, however, it is also of relevance to this appeal that the Supplementary Guidance Delivering the Infrastructure Strategy also states :

“The transition to a low carbon economy must include maintaining an effective supply of affordable energy and other resources. The aim is not only to adapt to and help mitigate the effects of climate change but also to support the economic opportunities that arise from the implementation of renewable and low carbon energy technologies. The Council is supportive of an increase in the proportion of electricity produced from renewable sources, but will require proposals for development to meet the following criteria:

. There is no significant impact on the amenity of nearby residents, in terms of statutory air quality objectives, noise or other nuisances;

. Significant visual intrusion within the landscape in terms of scale, location, design, etc. has been minimised;

. During the process leading to the selection of the proposed site, consideration must also be given to alternative sites, and the selection of the proposed site justified;

. The individual or cumulative impact of the proposed development along with any other existing and approved similar developments will not lead to an unacceptable impact on the environment, amenity, community or recreational interest;

. The transportation aspects associated with implementation of developments can be accommodated or mitigated against;

. Arrangements are in place to ensure restoration of the site to an acceptable standard after the operation has ceased;

. SEPA’s Thermal Treatment of Waste Guidelines should be referred to where development involves recovering energy from waste;

. Development would be encouraged and supported where thermal treatment plants are co-located with existing energy and heat intensive uses which maximise the opportunities for effective energy use.”

3.20 With regard to this reason for refusal it is maintained that

. There is no significant impact on the amenity of nearby residents.

. There is no significant visual intrusion within the landscape in terms of scale, location, design.

. The process leading to the selection of the proposed site, has considered alternative sites, and the selection of the proposed site justified above and in the planning Statement that accompanied the application (see Production 1).

10 Reasons for Refusal

. The impact of the proposed development along with any other existing and approved similar developments will not lead to an unacceptable impact on the environment, amenity, community or recreational interest.

. The transportation aspects associated with implementation of developments can be accommodated.

. There is no recovery from waste involved in the clean gas processes in this proposal.

. The proposed development is co-located with existing energy and heat intensive uses which maximise the opportunities for effective energy use.

3.21 As can be seen from the extracts of the Supplementary Guidance referred to above the there is no justification for refusal on the basis of reason for refusal number 4.

11 Conclusions

4 CONCLUSIONS

4.1 UK Government’s reform of the UK electricity market and specifically to support and make more efficient use of renewable energy developments by ensuring the grid network has sufficient generation capacity to meet demand during peak times.

4.2 Identifying suitable sites of this nature is rare and the appeal site fulfils all necessary specific locational needs for this proposal.

4.3 The Proposed development is necessary to ensure a secure source of electricity and to prevent serious fluctuations and blackouts at peak usage times.

4.4 The proposal constitutes and acceptable form of development in the green belt and complies with Policy ENV 1.

4.5 The proposal has no significant adverse impact on the Core Role and Function of the green belt.

4.6 The proposal complies with Policy I6 and the Supplementary Guidelines on Delivering the Infrastructure Strategy.

4.7 Renfrewshire’s LDP places an emphasis on supporting the transition to a low carbon economy and should encourage the proposal.

4.8 There is no significant impact on the amenity of nearby residents.

4.9 There is no significant visual intrusion within the landscape in terms of scale, location or design. In considering visual impacts, the case officer has focussed on a 250m stretch of a 60mph road, which already has a degree of screening, and offers views towards the M8 motorway where there are breaks in this screening.

4.10 The impact of the proposed development along with any other existing and approved similar developments will not lead to an unacceptable impact on the environment, amenity, community or recreational interest.

4.11 The transportation aspects associated with implementation of the proposals can be accommodated and there is no objection from the head of roads.

4.12 There is no recovery from waste involved in the clean gas processes in this proposal

4.13 The proposed development is co-located with existing energy and heat intensive uses which maximise the opportunities for effective energy use.

4.14 The applicant is prepared to provide additional landscape planting if this is considered necessary by the Council.

4.15 Against these conclusions it is respectfully quested that this application is approved (and this appeal upheld) in the national interest and in full compliance with the Local Development Plan.

12 Production 1 : Application package (consisting of all plans, Planning Statement, Air Quality Impact Assessment (plus 2 updates) and Noise Impact Assessment)

Renfrewshire House Cotton Street Paisley PA1 1JD Tel: 0300 3000 144 Fax: 0141 618 7935 Email: [email protected]

Applications cannot be validated until all the necessary documentation has been submitted and the required fee has been paid.

Thank you for completing this application form:

ONLINE REFERENCE 100064299-001

Type of Application

What is this application for? Please select one of the following: *

 Application for planning permission (including changes of use and surface mineral working).  Application for planning permission in principle.  Further application, (including renewal of planning permission, modification, variation or removal of a planning condition etc)  Application for Approval of Matters specified in conditions.

Description of Proposal

Please describe the proposal including any change of use: * (Max 500 characters)

Seeking permission to construct and operate a small scale gas-fired energy reserve facility for the generation of up to 19.9MW of electricity consisting of: 10 x containerised gas engine units with emission stack and cooling unit, 1 x control building, 1 x gas skid comprising gas meter kiosk and control, 1 x transformer unit, 5 x engine unit transformer, 1 x ancillary plant for storage of spare parts and consumables, 3 x car parking spaces and perimeter fencing.

Is this a temporary permission? *  Yes  No Description of Proposal Cont.

Please state how long permission is required for and why: * (Max 500 characters)

Required for 40 years which is the lifespan of the generators.

If a change of use is to be included in the proposal has it already taken place?  Yes  No (Answer ‘No’ if there is no change of use.) *

Has the work already been started and/or completed? *

 No  Yes – Started  Yes - Completed

Applicant or Agent Details

Are you an applicant or an agent? * (An agent is an architect, consultant or someone else acting on behalf of the applicant in connection with this application)  Applicant Agent

Page 1 of 9 Agent Details

Please enter Agent details

2020 Renewables Limited Company/Organisation:

Ref. Number: You must enter a Building Name or Number, or both: *

Phoebe Clyde View (Suite F3), Riverside First Name: * Building Name: Business Park

Davidson Last Name: * Building Number:

Address 1 22 Pottery Street Telephone Number: * 01475 749 941 (Street): *

Extension Number: Address 2:

Greenock Mobile Number: Town/City: *

UK Fax Number: Country: *

pa152uz Postcode: *

Email Address: * [email protected]

Is the applicant an individual or an organisation/corporate entity? *

 Individual  Organisation/Corporate entity

Applicant Details

Please enter Applicant details

Title: You must enter a Building Name or Number, or both: *

Clyde View (Suite F3), Riverside Other Title: Building Name: Business Park

First Name: * Building Number:

Address 1 22 Pottery Street Last Name: * (Street): *

Erskine Generation Limited Company/Organisation Address 2:

Greenock Telephone Number: * Town/City: *

United Kingdom Extension Number: Country: *

PA15 2UZ Mobile Number: Postcode: *

Fax Number:

[email protected] Email Address: *

Page 2 of 9 Site Address Details

Planning Authority: Renfrewshire Council

Full postal address of the site (including postcode where available):

Address 1:

Address 2:

Address 3:

Address 4:

Address 5:

Town/City/Settlement:

Post Code:

Please identify/describe the location of the site or sites

On land adjacent to Old Greenock Road and M8 Junction 30, Renfrewshire.

670469 244788 Northing Easting

Pre-Application Discussion

Have you discussed your proposal with the planning authority? *  Yes  No Pre-Application Discussion Details Cont.

In what format was the feedback given? *

 Meeting  Telephone  Letter  Email

Please provide a description of the feedback you were given and the name of the officer who provided this feedback. If a processing agreement [note 1] is currently in place or if you are currently discussing a processing agreement with the planning authority, please provide details of this. (This will help the authority to deal with this application more efficiently.) * (max 500 characters)

Email sent to Planning Department on the 11th August 2017. Meeting to be arranged to discuss proposals.

Title: Other title:

First Name: Last Name:

Correspondence Reference Date (dd/mm/yyyy): Number: 07/09/2017

Note 1. A Processing agreement involves setting out the key stages involved in determining a planning application, identifying what information is required and from whom and setting timescales for the delivery of various stages of the process.

Page 3 of 9 Site Area

Please state the site area: 0.50

Please state the measurement type used:  Hectares (ha)  Square Metres (sq.m)

Existing Use

Please describe the current or most recent use: * (Max 500 characters)

The land is currently used for grazing by cattle/sheep.

Access and Parking

Are you proposing a new altered vehicle access to or from a public road? *  Yes  No If Yes please describe and show on your drawings the position of any existing. Altered or new access points, highlighting the changes you propose to make. You should also show existing footpaths and note if there will be any impact on these.

Are you proposing any change to public paths, public rights of way or affecting any public right of access? *  Yes  No

If Yes please show on your drawings the position of any affected areas highlighting the changes you propose to make, including arrangements for continuing or alternative public access.

How many vehicle parking spaces (garaging and open parking) currently exist on the application 0 Site?

How many vehicle parking spaces (garaging and open parking) do you propose on the site (i.e. the 3 Total of existing and any new spaces or a reduced number of spaces)? * Please show on your drawings the position of existing and proposed parking spaces and identify if these are for the use of particular types of vehicles (e.g. parking for disabled people, coaches, HGV vehicles, cycles spaces).

Water Supply and Drainage Arrangements

Will your proposal require new or altered water supply or drainage arrangements? *  Yes  No

Are you proposing to connect to the public drainage network (eg. to an existing sewer)? *

 Yes – connecting to public drainage network  No – proposing to make private drainage arrangements  Not Applicable – only arrangements for water supply required

As you have indicated that you are proposing to make private drainage arrangements, please provide further details.

What private arrangements are you proposing? *

 New/Altered septic tank.  Treatment/Additional treatment (relates to package sewage treatment plants, or passive sewage treatment such as a reed bed).  Other private drainage arrangement (such as chemical toilets or composting toilets).

What private arrangements are you proposing for the New/Altered septic tank? *

 Discharge to land via soakaway.  Discharge to watercourse(s) (including partial soakaway).  Discharge to coastal waters. Page 4 of 9 Please explain your private drainage arrangements briefly here and show more details on your plans and supporting information: *

The drainage scheme will include a septic tank which shall be sized to accommodate drainage inflow rates which adequately reflect the sources serviced by the system during the life of the site. The control building will be founded on free draining stone and will incorporate a drainage membrane around the foundation walls. This will be connected to a positive drainage soakaway.

Do your proposals make provision for sustainable drainage of surface water?? *  Yes  No (e.g. SUDS arrangements) *

Note:-

Please include details of SUDS arrangements on your plans

Selecting ‘No’ to the above question means that you could be in breach of Environmental legislation.

Are you proposing to connect to the public water supply network? *

 Yes  No, using a private water supply  No connection required If No, using a private water supply, please show on plans the supply and all works needed to provide it (on or off site).

Assessment of Flood Risk

Is the site within an area of known risk of flooding? *  Yes  No  Don’t Know

If the site is within an area of known risk of flooding you may need to submit a Flood Risk Assessment before your application can be determined. You may wish to contact your Planning Authority or SEPA for advice on what information may be required.

Do you think your proposal may increase the flood risk elsewhere? *  Yes  No  Don’t Know

Trees

Are there any trees on or adjacent to the application site? *  Yes  No

If Yes, please mark on your drawings any trees, known protected trees and their canopy spread close to the proposal site and indicate if any are to be cut back or felled.

Waste Storage and Collection

Do the plans incorporate areas to store and aid the collection of waste (including recycling)? *  Yes  No

If Yes or No, please provide further details: * (Max 500 characters)

n/a

Residential Units Including Conversion

Does your proposal include new or additional houses and/or flats? *  Yes  No

Page 5 of 9 All Types of Non Housing Development – Proposed New Floorspace

Does your proposal alter or create non-residential floorspace? *  Yes  No

All Types of Non Housing Development – Proposed New Floorspace Details For planning permission in principle applications, if you are unaware of the exact proposed floorspace dimensions please provide an estimate where necessary and provide a fuller explanation in the ‘Don’t Know’ text box below. Please state the use type and proposed floorspace (or number of rooms if you are proposing a hotel or residential institution): *

Not in a Use Class

Gross (proposed) floorspace (In square meters, sq.m) or number of new (additional) 181 Rooms (If class 7, 8 or 8a): *

If Class 1, please give details of internal floorspace:

Net trading spaces: 0 Non-trading space: 181

Total:

If Class ‘Not in a use class’ or ‘Don’t know’ is selected, please give more details: (Max 500 characters) Total floorspace for Gas Kiosk, Control Building and Ancillary Building.

Schedule 3 Development

Does the proposal involve a form of development listed in Schedule 3 of the Town and Country  Yes  No  Don’t Know Planning (Development Management Procedure (Scotland) Regulations 2013 *

If yes, your proposal will additionally have to be advertised in a newspaper circulating in the area of the development. Your planning authority will do this on your behalf but will charge you a fee. Please check the planning authority’s website for advice on the additional fee and add this to your planning fee.

If you are unsure whether your proposal involves a form of development listed in Schedule 3, please check the Help Text and Guidance notes before contacting your planning authority.

Planning Service Employee/Elected Member Interest

Is the applicant, or the applicant’s spouse/partner, either a member of staff within the planning service or an  Yes  No elected member of the planning authority? *

Certificates and Notices

CERTIFICATE AND NOTICE UNDER REGULATION 15 – TOWN AND COUNTRY PLANNING (DEVELOPMENT MANAGEMENT PROCEDURE) (SCOTLAND) REGULATION 2013

One Certificate must be completed and submitted along with the application form. This is most usually Certificate A, Form 1, Certificate B, Certificate C or Certificate E.

Are you/the applicant the sole owner of ALL the land? *  Yes  No

Is any of the land part of an agricultural holding? *  Yes  No Are you able to identify and give appropriate notice to ALL the other owners? *  Yes  No

Page 6 of 9 Certificate Required

The following Land Ownership Certificate is required to complete this section of the proposal:

Certificate B Land Ownership Certificate

Certificate and Notice under Regulation 15 of the Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013

I hereby certify that

(1) - No person other than myself/the applicant was an owner [Note 4] of any part of the land to which the application relates at the beginning of the period of 21 days ending with the date of the accompanying application; or –

(1) - I have/The Applicant has served notice on every person other than myself/the applicant who, at the beginning of the period of 21 days ending with the date of the accompanying application was owner [Note 4] of any part of the land to which the application relates.

Name: Mrs Elizabeth Stevenson

Address: The Barn, Linburn Farm, Erskine, United Kingdom , PA8 6AW

Date of Service of Notice: * 07/09/2017

(2) - None of the land to which the application relates constitutes or forms part of an agricultural holding; or –

(2) - The land or part of the land to which the application relates constitutes or forms part of an agricultural holding and I have/the applicant has served notice on every person other than myself/himself who, at the beginning of the period of 21 days ending with the date of the accompanying application was an agricultural tenant. These persons are:

Name:

Address:

Date of Service of Notice: *

Signed: Phoebe Davidson

On behalf of: Erskine Generation Limited

Date: 07/09/2017

 Please tick here to certify this Certificate. *

Page 7 of 9 Checklist – Application for Planning Permission

Town and Country Planning (Scotland) Act 1997

The Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013

Please take a few moments to complete the following checklist in order to ensure that you have provided all the necessary information in support of your application. Failure to submit sufficient information with your application may result in your application being deemed invalid. The planning authority will not start processing your application until it is valid. a) If this is a further application where there is a variation of conditions attached to a previous consent, have you provided a statement to that effect? *  Yes  No  Not applicable to this application b) If this is an application for planning permission or planning permission in principal where there is a crown interest in the land, have you provided a statement to that effect? *  Yes  No  Not applicable to this application c) If this is an application for planning permission, planning permission in principle or a further application and the application is for development belonging to the categories of national or major development (other than one under Section 42 of the planning Act), have you provided a Pre-Application Consultation Report? *  Yes  No  Not applicable to this application

Town and Country Planning (Scotland) Act 1997

The Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013 d) If this is an application for planning permission and the application relates to development belonging to the categories of national or major developments and you do not benefit from exemption under Regulation 13 of The Town and Country Planning (Development Management Procedure) (Scotland) Regulations 2013, have you provided a Design and Access Statement? *  Yes  No  Not applicable to this application e) If this is an application for planning permission and relates to development belonging to the category of local developments (subject to regulation 13. (2) and (3) of the Development Management Procedure (Scotland) Regulations 2013) have you provided a Design Statement? *  Yes  No  Not applicable to this application f) If your application relates to installation of an antenna to be employed in an electronic communication network, have you provided an ICNIRP Declaration? *  Yes  No  Not applicable to this application g) If this is an application for planning permission, planning permission in principle, an application for approval of matters specified in conditions or an application for mineral development, have you provided any other plans or drawings as necessary:

 Site Layout Plan or Block plan.  Elevations.  Floor plans.  Cross sections.  Roof plan.  Master Plan/Framework Plan.  Landscape plan.  Photographs and/or photomontages.  Other.

If Other, please specify: * (Max 500 characters)

Page 8 of 9 Provide copies of the following documents if applicable:

A copy of an Environmental Statement. *  Yes  N/A A Design Statement or Design and Access Statement. *  Yes  N/A A Flood Risk Assessment. *  Yes  N/A A Drainage Impact Assessment (including proposals for Sustainable Drainage Systems). *  Yes  N/A Drainage/SUDS layout. *  Yes  N/A A Transport Assessment or Travel Plan  Yes  N/A Contaminated Land Assessment. *  Yes  N/A Habitat Survey. *  Yes  N/A A Processing Agreement. *  Yes  N/A

Other Statements (please specify). (Max 500 characters) Covering Letter, Planning Statement, Air Quality Assessment and Noise Assessment.

Declare – For Application to Planning Authority

I, the applicant/agent certify that this is an application to the planning authority as described in this form. The accompanying Plans/drawings and additional information are provided as a part of this application.

Declaration Name: Miss Phoebe Davidson

Declaration Date: 07/09/2017

Payment Details

Cheque: , Created: 07/09/2017 14:53

Page 9 of 9 Erskine Generation Limited

Planning Application Boundary

1:10,000 Scale @ A3

0 200 400m ¯ Produced By: SC Ref: 2817-REP-002

Checked By: SD Date: 25/08/2017

Site Location Drawing 001

Erskine Gas Peaking Site Contains OS data © Crown Copyright and database right 2017 Planning Application R e p ro d u c e d fro m O rd n a n c e S u rv e y d ig ita l m a p d a ta © C ro w n c o p y rig h t 2 0 1 7 . A ll rig h ts re s e rv e d . L ic e n s e n u m b e r 1 0 0 0 4 8 6 0 6

P:\Projects\Planning Projects\Planning Projects.aprx\2817-REP-002 N PLANNING APPLICATION BOUNDARY (0.50 Ha)

6m HIGH SECURITY COLUMN

TRANSFORMER UNIT GAS SKID (INCLUDING KIOSK BUILDING 9.00m x 7.00m x 3.80m 4.20m x 3.0mx 2.60m) OVERALL AREA/SIZE 12.20m x 5.30m x 2.60m

SUBSURFACE RAINWATER HARVESTING TANK WITH SERVICE CHAMBER 6m HIGH SECURITY COLUMN

Drumgreen Cottage SUBSURFACE SEPTIC TANK WITH SERVICE CHAMBER HARDSTANDING ACROSS ENTIRE Little Porton ETL CONTROL BUILDING WELFARE SITE AREA 23.5m STORE Midholm 25.40m x 5.96m x 3.50m 3.0m HIGH NOISE Burn Craigton ROOM Netherdale ATTENUATION FENCING Nursery 6m HIGH SECURITY CONTROL COLUMN ROOM

OLD GREENOCK ROAD PALISADE FENCE

HV/LV SWITCH 3.0m HIGH ROOM

OLD GREENOCK ROAD 1

DNO HV ROOM 2 6m HIGH SECURITY COLUMN Electricity Distribution Site 3 4

Shilton Plantation 5 CAR PARKING x 3 OPTION 6 FB (BAY SIZE 6.00m x 2.50m) 7 M 898 8 TURNING AREA 9

ETL Craigton INTERCOOLER EQUIPMENT 10 INSTALLED ON TOP OF CONTAINER (MAX HEIGHT 6.25m) ENGINE UNIT TRANSFORMER 2.80m x 2.80m x 3.80m

M898

Ward Bdy (5 No. 1 PER 2 GAS ENGINE UNITS)

M8 M 8 CONTAINERISED ENGINE UNIT 15.0m x 3.50m x 3.70m (NOTE STACK 3.30m HIGH FROM TOP OF CONTAINER) ANCILLARY PLANT GAS ENGINE WITHIN 5.80m x 3.00m x 2.60m CONTAINER STACK 7.00m HIGH FROM GROUND LEVEL

Track

Ruin 28.1m

SCALE - 1:5,000 M 898 SCALE - 1:500

Pond Purpose of issue Project Title Drawing Title PLANNING THISDOCUMENT HAS BEEN PREPARED ACCORDANCEIN WITH THE SCOPE OF ARCUS' ERSKINE Arcus Consultancy Services Designed Drawn Checked Approved APPOINTMENTWITH CLIENTITS AND SUBJECT IS TO THE TERMS OF THAT APPOINTMENT. 7th Floor GAS PEAKING SITE ARCUSACCEPTS NO LIABILITYFOR ANY USE OF THISDOCUMENT OTHER THAN BYITS PROPOSED DB DB RM SD CLIENTAND ONLY FOR THE PURPOSES FOR WHICH WAS IT PREPARED AND PROVIDED 145 St. Vincent Street Glasgow, G2 5JF 31 August 2017 15:12:32 P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0001-P9 Arcus Internal Project No. Date SITE LAYOUT PLAN Tel: +44 (0)141 221 9997 Client 2817 Rev 28/08/2017 Drawing Number Scale @ A3 Fax: +44 (0)141 221 5610 ERSKINE GENERATION LIMITED 2817-DR-PLA-0001 9 www.arcusconsulting.co.uk AS SHOWN Plot Date : File Name : Reproduced from Ordnance Survey digital map data © Crown copyright 2017. All rights reserved. License number 100048606 EMISSIONS STACK INTERCOOLER CONTAINERISED GAS EQUIPMENT ENGINE UNIT

REINFORCED CONCRETE PLINTH FOUNDATION

3.5m 3.9m

FRONT ELEVATION END ELEVATION 7.0m 6.25m 5.4m 3.7m

15.0m 3.5m

REAR ELEVATION END ELEVATION

0 1 2 3 4 5 6 7 8 9 10m

SCALE 1:100

Purpose of issue Project Title Drawing Title PLANNING THISDOCUMENT HAS BEEN PREPARED ACCORDANCEIN WITH THE SCOPE OF ARCUS' Arcus Consultancy Services PLANNING DRAWING 003 Designed Drawn Checked Approved APPOINTMENTWITH CLIENTITS AND SUBJECT IS TO THE TERMS OF THAT APPOINTMENT. 7th Floor ERSKINE ARCUSACCEPTS NO LIABILITYFOR ANY USE OF THISDOCUMENT OTHER THAN BYITS CONTAINERISED - KL/DB RM SD CLIENTAND ONLY FOR THE PURPOSES FOR WHICH WAS IT PREPARED AND PROVIDED 145 St. Vincent Street GAS PEAKING SITE Glasgow, G2 5JF 29 August 2017 09:02:09 P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0002 Arcus Internal Project No. Date GAS ENGINE UNIT Tel: +44 (0)141 221 9997 Client 2817 Drawing Number Rev 28/08/2017 Scale @ A3 Fax: +44 (0)141 221 5610 ERSKINE GENERATION LIMITED ELEVATIONS 2817-DR-P-0002 www.arcusconsulting.co.uk 1:100 Plot Date : File Name : DOUBLE DOOR WITH SINGLE DOOR SINGLE DOOR LOUVRE WITH BLAST PANEL ROOF JOINT DEMOUNTABLE SECTION FITTED WITH PANIC FITTED WITH PANIC COWL ABOVE BAR BAR 3.50m 3.50m 2.60m

25.40m 5.96m

SOUTH-EAST FACING ELEVATION NORTH-EAST FACING ELEVATION

LOUVRE WITH ROOF JOINT BLAST PANEL COWL

NORTH-WEST FACING ELEVATION SOUTH-WEST FACING ELEVATION

NOTES: 1. LAYOUT OF CONTROL BUILDING AS SHOWN IS INDICATIVE ONLY 2. FOUNDATION REQUIREMENTS TO STRUCTURAL ENGINEERS DESIGN. WELFARE 3. THIS DRAWING HAS BEEN PREPARED FOR HV/LV DNO INFORMATION PURPOSES ONLY. STORE ROOM CONTROL SWITCH HV ROOM ROOM ROOM 5.96m

25.40m 0 1 2 3 4 5 6 7 8 9 10m

LAYOUT PLAN SCALE 1:100 Purpose of issue Project Title Drawing Title PLANNING THISDOCUMENT HAS BEEN PREPARED ACCORDANCEIN WITH THE SCOPE OF ARCUS' Arcus Consultancy Services PLANNING DRAWING 004 Designed Drawn Checked Approved APPOINTMENTWITH CLIENTITS AND SUBJECT IS TO THE TERMS OF THAT APPOINTMENT. 7th Floor ERSKINE ARCUSACCEPTS NO LIABILITYFOR ANY USE OF THISDOCUMENT OTHER THAN BYITS CONTROL BUILDING - DB RM SD CLIENTAND ONLY FOR THE PURPOSES FOR WHICH WAS IT PREPARED AND PROVIDED 145 St. Vincent Street GAS PEAKING SITE Glasgow, G2 5JF 31 August 2017 13:33:02 P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0003-P1 Arcus Internal Project No. Date LAYOUT AND Tel: +44 (0)141 221 9997 Client 2817 Drawing Number Rev 31/08/2017 Scale @ A3 Fax: +44 (0)141 221 5610 ERSKINE GENERATION LIMITED ELEVATIONS 2817-DR-P-0003 1 www.arcusconsulting.co.uk 1:100 Plot Date : File Name : Plot Date : 31 August 2017 14:10:41 File Name :P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0004-P1 Client Project Title

ERSKINE GENERATION LIMITED 2.6m 1.4m GASPEAKINGSITE ERSKINE

END-ELEVATION Drawing Title 4.20m 5.30m PLANNING DRAWING005 PLAN ANDELEVATIONS GAS SKID 1:50 Scale @A3 2817 Arcus InternalProjectNo. - Designed Purpose ofissue 5.30m DB Drawn EXISTING GROUND LEVEL PLANNING Date RM Checked 31/08/2017 SD Approved 2817-DR-P-0004 Drawing Number APPOINTMENT WITHITSCLIENTANDISSUBJECTTOTHETERMSOFTHATAPPOINTMENT. CLIENT ANDONLYFORTHEPURPOSESWHICHITWASPREPAREDPROVIDED THIS DOCUMENTHASBEENPREPAREDINACCORDANCEWITHTHESCOPEOFARCUS' ARCUS ACCEPTSNOLIABILITYFORANYUSEOFTHISDOCUMENTOTHERTHANBYITS INFRASTRUCTURE GAS SKID 12.20m 12.20m ELEVATION PLAN GAS KIOSK Rev 1 0 SCALE 1:50 www.arcusconsulting.co.uk Fax: Tel: Glasgow, G25JF 145 St.VincentStreet 7th Floor Arcus ConsultancyServices 4.20m +44(0)1412219997 +44(0)141221 5610 1 2 3.00m 3.0m 3 4 5m 9.0m

SPARE CABLE ENTRY

GRP ENCLOSURE

CABLE ENTRY LOCATIONS (150mm THROUGH SLAB FOR HV CABLES) REINFORCED CONCRETE SLAB 7.0m

CABLE ENTRY LOCATIONS (90mm DUCTS THROUGH SLAB FOR HV CABLES AND CONTROL CABLING)

DOUBLE DOOR OPENING TO ENCLOSURE PLAN

EXPLOSION RELIEF 7.0m EXPLOSION RELIEF FITTING TO FITTING TO TOP SECTION TOP SECTION OF ENCLOSURE 9.0m OF ENCLOSURE

LH RING SWITCH RH RING SWITCH CABLE BOX CABLE BOX GRP 3.80m TELECONTROL ENCLOSURE CABINET STAR POINT TEST GRP ENCLOSURE ACCESS REINFORCED 90mm DUCTS INTO HV CABLE IN DUCTS CONCRETE SLAB REINFORCED ENCLOSURE 150mm DUCTS INTO ENCLOSURE FOR HV CONCRETE SLAB CABLES ELEVATION END-ELEVATION

0 1 2 3 4 5 6 7 8 9 10m

SCALE 1:100 Purpose of issue Project Title Drawing Title PLANNING THISDOCUMENT HAS BEEN PREPARED ACCORDANCEIN WITH THE SCOPE OF ARCUS' Arcus Consultancy Services PLANNING DRAWING 006 Designed Drawn Checked Approved APPOINTMENTWITH CLIENTITS AND SUBJECT IS TO THE TERMS OF THAT APPOINTMENT. 7th Floor ERSKINE ARCUSACCEPTS NO LIABILITYFOR ANY USE OF THISDOCUMENT OTHER THAN BYITS TRANSFORMER - DB RM SD CLIENTAND ONLY FOR THE PURPOSES FOR WHICH WAS IT PREPARED AND PROVIDED 145 St. Vincent Street GAS PEAKING SITE Glasgow, G2 5JF 31 August 2017 13:46:59 P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0005-P1 Arcus Internal Project No. Date PLAN AND ELEVATIONS Tel: +44 (0)141 221 9997 Client 2818 Drawing Number Rev 31/08/2017 Scale @ A3 Fax: +44 (0)141 221 5610 ERSKINE GENERATION LIMITED 2818-DR-P-0005 1 www.arcusconsulting.co.uk 1:100 Plot Date : File Name : Plot Date : 31 August 2017 13:46:24 File Name :P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0006-P1 Client Project Title ERSKINE GENERATION LIMITED GASPEAKINGSITE ERSKINE

END-ELEVATION 3.00m Drawing Title PLANNING DRAWING007 PLAN ANDELEVATIONS ANCILLARY PLANT 1:50 Scale @A3 2817 Arcus InternalProjectNo. - Designed Purpose ofissue DB Drawn PLANNING Date RM Checked 31/08/2017 SD Approved

ANCILLARY PLANT

ELEVATION 2817-DR-P-0006 Drawing Number APPOINTMENT WITHITSCLIENTANDISSUBJECTTOTHETERMSOFTHATAPPOINTMENT. 5.80m CLIENT ANDONLYFORTHEPURPOSESWHICHITWASPREPAREDPROVIDED THIS DOCUMENTHASBEENPREPAREDINACCORDANCEWITHTHESCOPEOFARCUS' ARCUS ACCEPTSNOLIABILITYFORANYUSEOFTHISDOCUMENTOTHERTHANBYITS PLAN

2.20m 2.60m Rev 1 0 SCALE 1:50 www.arcusconsulting.co.uk Fax: Tel: Glasgow, G25JF 145 St.VincentStreet 7th Floor Arcus ConsultancyServices +44(0)1412219997 +44(0)141221 5610 1 2 3 4 5m NOISE ATTENUATION GATE DETAIL

PLAN 3.0m

EXAMPLE OF SECURITY FENCE ROTATING SPIKES

3.50m 3.50m

END-ELEVATION FRONT ELEVATION

NOISE ATTENUATION FENCE DETAIL

PLAN 3.0m

EXAMPLE OF NOISE ATTENUATION FENCE

0 1 2 3 4 5m 3.0m END-ELEVATION FRONT ELEVATION SCALE 1:50

Purpose of issue Project Title Drawing Title PLANNING THISDOCUMENT HAS BEEN PREPARED ACCORDANCEIN WITH THE SCOPE OF ARCUS' ERSKINE Arcus Consultancy Services PLANNING DRAWING 008 Designed Drawn Checked Approved APPOINTMENTWITH CLIENTITS AND SUBJECT IS TO THE TERMS OF THAT APPOINTMENT. 7th Floor GAS PEAKING SITE ARCUSACCEPTS NO LIABILITYFOR ANY USE OF THISDOCUMENT OTHER THAN BYITS NOISE ATTENUATION DB DB RM SD CLIENTAND ONLY FOR THE PURPOSES FOR WHICH WAS IT PREPARED AND PROVIDED 145 St. Vincent Street Glasgow, G2 5JF 31 August 2017 13:49:34 P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0007-P1 Arcus Internal Project No. Date FENCING AND GATE Tel: +44 (0)141 221 9997 Client 2817 Drawing Number Rev 31/08/2017 PLAN AND ELEVATIONS Scale @ A3 Fax: +44 (0)141 221 5610 ERSKINE GENERATION LIMITED 2817-DR-PLA-0007 1 www.arcusconsulting.co.uk 1:50 Plot Date : File Name : Reproduced from Ordnance Survey digital map data © Crown copyright 2017. All rights reserved. License number 100048606 CIRCULAR STEEL MAST

LIGHT

DIRECTIONAL STATIC CCTV CAMERAS

0.10m ∅ 6.0m

0 1 2 3 4 5m

SCALE 1:50

Purpose of issue Project Title Drawing Title PLANNING THISDOCUMENT HAS BEEN PREPARED ACCORDANCEIN WITH THE SCOPE OF ARCUS' Arcus Consultancy Services PLANNING DRAWING 009 Designed Drawn Checked Approved APPOINTMENTWITH CLIENTITS AND SUBJECT IS TO THE TERMS OF THAT APPOINTMENT. 7th Floor ERSKINE ARCUSACCEPTS NO LIABILITYFOR ANY USE OF THISDOCUMENT OTHER THAN BYITS SECURITY COLUMN - DB RM SD CLIENTAND ONLY FOR THE PURPOSES FOR WHICH WAS IT PREPARED AND PROVIDED 145 St. Vincent Street GAS PEAKING SITE Glasgow, G2 5JF 31 August 2017 13:51:10 P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0008-P1 Arcus Internal Project No. Date DETAIL Tel: +44 (0)141 221 9997 Client 2817 Drawing Number Rev 28/08/2017 Scale @ A3 Fax: +44 (0)141 221 5610 ERSKINE GENERATION LIMITED 2817-DR-P-0008 1 www.arcusconsulting.co.uk 1:50 Plot Date : File Name : Plot Date : 31 August 2017 13:53:27 File Name :P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0009-P1 Client Project Title ERSKINE GENERATION LIMITED

PALISADE FENCE WILL EXTEND UNITS.

IN BANKS OF MULTIPLE TRANSFORMER WHERE NECESSARY3.0mHIGH

TO ACCOUNTFORBEINGPOSITIONED AROUND EXTENT OF TRANSFORMER(S) GASPEAKINGSITE ERSKINE

Drawing Title

3.80m PLANNING DRAWING010 PLAN ANDELEVATIONS TRANSFORMER UNIT GAS ENGINE 1:50 Scale @A3 2817 Arcus InternalProjectNo. - Designed Purpose ofissue ELEVATION PLAN 2.80m DB Drawn PLANNING Date RM Checked 31/08/2017 1.15m SD Approved 2817-DR-P-0010 Drawing Number APPOINTMENT WITHITSCLIENTANDISSUBJECTTOTHETERMSOFTHATAPPOINTMENT. CLIENT ANDONLYFORTHEPURPOSESWHICHITWASPREPAREDPROVIDED THIS DOCUMENTHASBEENPREPAREDINACCORDANCEWITHTHESCOPEOFARCUS' ARCUS ACCEPTSNOLIABILITYFORANYUSEOFTHISDOCUMENTOTHERTHANBYITS

PALISADE FENCE UNIT 3.0m HIGH GAS ENGINE

TRANSFORMER

3.0m Rev 1 END-ELEVATION www.arcusconsulting.co.uk Fax: Tel: Glasgow, G25JF 145 St.VincentStreet 7th Floor Arcus ConsultancyServices +44(0)1412219997 +44(0)141221 5610 2.80m 4.80m

AIR QUALITY IMPACT ASSESSMENT

SMALL-SCALE GAS PEAKING PLANT - ERSKINE

ERSKINE GENERATION LTD

AUGUST 2017

Prepared By: Arcus Consultancy Services

7th Floor, 145 St. Vincent Street, Glasgow, G2 5JF T +44 (0)141 221 9997 l E [email protected] W www.arcusconsulting.co.uk Registered in England & Wales No. 5644976

Air Quality Impact Assessment Small-scale Reserve Power Plant - Erskine

1 INTRODUCTION Arcus Consultancy Services Ltd (Arcus) has been commissioned by Erskine Generation Ltd (the Applicant) to undertake an air quality impact assessment for a proposed small-scale gas peaking plant. This document presents an assessment of the potential impacts of emissions of oxides of nitrogen (NOX) arising from the proposed small-scale gas peaking plant for the generation of electricity from gas engines to provide a backup supply to the National Grid (the Development) at Erskine (the Site). This document has been prepared to assess the effects of the Development on air quality, and inform the determination of the application for planning permission for the Development. The document sets out:  Context of the Site;  The proposed operating scenario for the Development, and the modelled scenario;  Characteristics of the emission of Nitrogen Oxides (NOX) from the gas engine container units;  The input parameters and results of dispersion modelling of NOX emissions using ADMS Roads Extra 4, version 4.1;  An assessment of potential impacts; and  Conclusions.

1.1 NOX Air Quality Objectives The principal air quality legislation in Scotland is the Air Quality (Scotland) Regulations (2010)1, which were enacted as part of the National Air Quality Strategy (NAQS) for Scotland, England, Wales and Northern Ireland (2000, and 2003 and 2007 addendums)2 under Section 80 of the Environment Act 1995.

There are no legal limits or guideline thresholds specifically for NOX, but there are for NO2. The Air Quality Regulations set out that: 3  The 1-hour mean concentration of NO2 must not exceed 200 μg/m (the short-term Environmental Assessment Level, or EAL) more than 18 times per year; and 3  The annual mean concentration of NO2 must not exceed 40 μg/m (the long term EAL). These are referred to as the short- and long-term Air Quality Objectives (AQOs), respectively.

1.2 Assessment of NOX Impacts

NOX typically comprises a mixture of nitrogen monoxide (NO) and NO2. Whilst predominantly NO may be created in a combustion process, this will gradually change to NO2 over time.

1 The Air Quality (Scotland) Regulations, 2010, Scottish Statutory Instrument 204 (2010); available online http://www.legislation.gov.uk/ssi/2010/204/pdfs/ssi_20100204_en.pdf [accessed on 04/08/2017]. 2 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland, Department for Environment, Food and Rural Affairs in partnership with the Scottish Executive, Welsh Assembly Government and Department of the Environment Northern Ireland, July 2007’

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In assessments, it is generally conservatively assumed that all NOX is NO2. When undertaking dispersion modelling of point source emissions of NOX, however, the following conservative assumptions are made, based on best practice and as detailed DEFRA/Environment Agency guidance, in the absence of Scottish Environment Protection Agency (SEPA) guidance, for risk assessments for industrial emissions3:

 For short term NOX emissions, assume 50% of NOX is NO2; and  For long term NOX emissions, assume 100% of NOX is NO2. The Process Contribution (PC) is the concentration of a pollutant emitted from the installation (in this case the Development) at a receptor location, and is typically expressed as a percentage of the relevant AQO. If the PC is less than approximately 1% of the EAL, then it is typically considered to have negligible impact, and isn’t considered further. If the PC has more than negligible impact, the Predicted Environmental Concentration (PEC) should be calculated. The PEC is arrived at by adding the PC to the concentration of a pollutant at a receptor location in the absence of the installation (the background concentration). To meet the relevant AQO, the PEC should not be greater than the relevant EAL more than the specified number of times.

2 CONTEXT OF THE SITE The Site is located in Renfrewshire, at approximate grid location 244780, 670465. The site occupies the southern part of a field that is bounded to the west by the M8 motorway and to the south by the M898 motorway on-slip road from the M8. The remainder of an agricultural field is present north and east, bound by hedges and trees Old Greenock Road beyond. The site lies outside any declared Air Quality Management Areas (AQMAs), the nearest being the Renfrew town centre AQMA, the nearest point of which is approximately 6.5 km to the southeast. The area is generally rural, between the settlements of Erskine and Bishopton, with the M898 and M8 taking substantial local land use along with the Erskine Grid Supply Point. The nearest residential properties are located on Old Greenock Road and at Craigton Farm, approximately 250 m north and west of the closest emission point.

3 DEVELOPMENT OPERATING SCENARIOS 10 container units are proposed, each of which will contain a gas engine and electricity generator. The intention is to export electricity from the Development to the local electrical grid at times of peak demand or when the grid requires various forms of electrical support. As the local network is not continuously in these states, the Development would not be exporting continuously. Whilst the Applicant has no control over when National Grid will call for the use of a specific generating station, the worst-case assumption made for the purposes of the air quality assessment is that the likely maximum operational period would be 3,000 hours per year. This is expected to be an overestimate of the actual operation of the gas engines, but is required for air quality assessment purposes to identify the worst-case scenario for NOX emissions. When the plant is not running it does not generate any emissions to air.

3 Environment Agency (2016). Air Emissions Risk Assessment for Environmental Permits. Available at: https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit#calculate-pc-to-air [accessed on 04/08/2017]

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4 NOX EMISSION CHARACTERISTICS Each container includes a gas engine and electrical generator with output capacity up to 2.0 MegaWatts (MW). Various candidate gas engines are under consideration for the Development at the time of writing. In order to assess the worst-case potential impacts from these, a set of emission parameters has been defined, taking the worst-case value for each parameter from all candidate engines. Modelled emission characteristics are shown in Table 1. Table 1: Worst-case Emission Characteristics of Each Gas Engine at Full Load Characteristic Value Units Height of emission point 7 m above ground level Direction of emission Upwards n/a Diameter of circular flue 0.5 m Efflux velocity 33 m/s Emission temperature 360 oC

3 NOX concentration 250 mg/Nm

NOX emission rate 0.54 g/s

It should be noted that the NOX concentration, normalised to standard reference conditions4, is compliant with the Medium Combustion Plant Directive (MCPD) specification for new gas engines commencing operation after December 2018 (maximum 250 mg/Nm3). The engines are therefore ahead of new industry standards, in terms of emissions of pollutants. In Pollution Prevention and Control (PPC) terminology, they are consistent with Best Available Techniques (BAT). The 10 emission points have been identified at the grid locations shown in Table 2. Table 2: Grid Co-ordinates of the Emission Points Container Number Easting Northing 1 244760 670475 2 244766 670472 3 244771 670469 4 244777 670466 5 244783 670463 6 244789 670461 7 244795 670458 8 244801 670455 9 244807 670452 10 244813 670450

5 DISPERSION MODELLING OF NOX Specialist dispersion modelling software5, was used to represent the emission points and the dispersed concentration of pollutants at relevant receptor locations.

4 Standard reference conditions for gas engines specified in the Medium Combustion Plant Directive, Annex C, are 1 atmosphere, 273 K, dry, 5% oxygen. 5 ADMS Roads Extra 4, version 4.1

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A map-based representation of modelled features (described below) is shown in Figure 1. Figure 1: A Map-based Representation of the Model Inputs

Reproduced from Ordnance Survey digital map data © Crown copyright 2017. All rights reserved. License number 100048606. Figure 1 notes:  Red circles: point source emission locations;  Blue lines: modelled road traffic source emissions; and  Green squares: receptor locations.

5.1 On-site Point Source Emissions

The emissions of NOX from the Development were modelled as set out in Section 3 of this document.

5.2 Receptors Receptor locations were those at which individual people may typically be present for significant periods of time, such as a day or more per year. The nearest such receptors were 2 residential properties along Old Greenock Road to the north and east of the M8/M898, Craigton Farm to the west of the M8, Shilton Cottage east (off Shilton Lane) and properties along Lachlan Crescent at the western extent of Erskine, southeast of the M898. The nearest receptors to the Development, Porton Nursery and Craigton Farm, lie approximately 250 m north and west of the Development, with the others all at or more than 330 m. The nearest receptor locations were identified as shown in Table 3 and on Figure 1, and concentrations of NOX were predicted at these locations. Table 3: Receptor Locations Receptor Easting Northing Porton Nursery 244792 670726 Old Greenock Rd 244639 670823

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Receptor Easting Northing Craigton Farm 244511 670463 Lachlan Crescent 245116 670395 Shilton Cottage 245037 670657

5.3 Background NO2 Concentrations Background concentrations of modelled pollutants are values that are typical of the area but away from the specific sources of pollution modelled explicitly.

Background concentrations of NO2 were taken from the DEFRA background air quality database6, for the location 244500, 670500. This is the geographic grid square which includes the Site. The 2013 dataset was used, selecting data for the year 2017. Renfrewshire Council’s 2016 Air Quality Annual Progress Report7 identifies automatic and diffusion tube monitoring locations within Renfrewshire. The nearest is a diffusion tube monitoring location in Bishopton, adjacent to the A8 (Greenock Road), which reported an annual average concentration of 13.1 μg/m3 in 2015. No monitoring locations are in rural areas, however, and none are therefore likely to be representative of the rural location of the Site. The DEFRA data, which is representative of a rural location, was therefore used in preference. 3 The long-term background concentrations of NO2 are 9.27 μg/m . The short-term background concentrations were assumed to be double the long-term values, i.e. 18.54 μg/m3.

5.4 Road Traffic Emission Sources

At roadside receptor locations, emissions of NOX from road traffic can elevate ambient levels of NO2 above those levels identified as the general background concentration in the wider area. The receptors identified in Section 5.2 are within 200 m of a motorway, and hence have the potential to experience elevated concentrations of NO2 as a result of proximity to roads. Road traffic data were obtained for these road sections from the Department for Transport website8. The traffic data, expressed as Annual Average Daily Traffic counts (AADT) are shown in Table 4. Table 4: Traffic Count Data (AADT) Road Section LDV HDV Average Speed (km/h) M8 64,898 3,061 90 M898 48,155 2,276 90

6 DEFRA (2017). Pollutant background concentration map. Available at: https://uk-air.defra.gov.uk/data/laqm-background- home [accessed on 04/08/2017] 7 Renfrewshire Council (2016). 2016 Air Quality Annual Progress Report. Available at: http://www.renfrewshire.gov.uk/airquality [accessed on 05/08/2017] 8 Department for Transport (2017). Traffic counts. Available at: https://www.dft.gov.uk/traffic-counts/cp.php [accessed on 04/08/2017]

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The movements of traffic are not constant throughout the day, and hourly and daily variations in traffic flow relative to the averages presented above were modelled based on Department for Transport statistics9.

5.5 Off-site Point Source Emissions

No off-site point source emissions of NOX have been identified that might have potential to lead to substantially increased levels of NO2 at the modelled receptor locations, and hence no off-site point source emissions have been modelled in this assessment.

5.6 Other Model Parameter Settings Other model input parameters were:  Meteorological data: hourly sequential data for the whole of 1996, from Abbotsinch met station10;  Surface roughness: a value of 0.2 was used for the Development site, corresponding to "agricultural” land use, which is appropriate for an area with a mixture of fields, hedges and occasional medium-sized trees. A value of 0.02 was used for the met data site, given that it is located at an airport with minimal nearby vertical structures; and  No buildings or complex terrain were modelled.

5.7 Predicted Concentrations

PCs and PECs for NO2 are shown in Table 5 for Porton Nursery, in Table 6 for Old Greenock Rd, in Table 7 for Craigton Farm, in Table 8 for Lachlan Crescent and Table 9 for Shilton Cottage.

Table 5: Predicted NO2 Concentrations at Porton Nursery EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 3.6 12.9 32.3% Short term (200 μg/m3) 102.2 120.8 60.4%

Table 6: Predicted NO2 Concentrations at Old Greenock Rd EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL) Long term (40 μg/m3) 3.1 12.4 31.0% Short term (200 μg/m3) 60.0 78.5 39.3%

Table 7: Predicted NO2 Concentrations at Craigton Farm EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL) Long term (40 μg/m3) 4.4 13.7 34.2% Short term (200 μg/m3) 103.0 121.6 60.8%

9 Department for Transport (2016). Department for Transport statistics: Table TRA0307: Traffic Distribution by time of day on all roads in Great Britain 2015. Available at: www.gov.uk/government/organisations/department-for-transport/series/road- traffic-statistics [accessed on 04/08/2017] 10 Data from 1995, 1997 and 1998 was also used, and led to marginally lower concentrations of NOX at receptors, hence 1996 data was used as a worst-case.

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Table 8: Predicted NO2 Concentrations at Lachlan Crescent EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 4.3 13.6 34.0%

Short term (200 μg/m3) 84.7 103.2 51.6%

Table 9: Predicted NO2 Concentrations at Shilton Cottage EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 5.4 14.7 36.7%

Short term (200 μg/m3) 86.2 104.7 52.4%

Generally, at the nearest receptors to the Development, short- and long-term PECs are around 30% to 60% of the air quality objectives. The worst-case long-term PEC is almost 37% of the long-term AQO (Shilton Cottage) and the worst case short-term PEC is almost 61% of the short-term AQO (Craigton Farm). The predicted concentrations are comfortably below the AQOs.

6 CONCLUSIONS A scenario assuming operation of the Development for 3,000 hours per year has been used to predict worst-case concentrations of NO2 at the nearest receptor locations; this is considered to be conservative and operational hours are likely to be less than this. The nearest receptors are Porton Nursery, a property on Old Greenock Rd and Craigton Farm, which are approximately 250 m due north and west of the Development, with others at least 330 m from the Development.

The results show that, after adding background concentrations of NO2 to the dispersed emission from the Development and the dispersed emissions from the nearby M8 and M898 motorways, total concentrations of NO2 would be less than the relevant Environmental Assessment Levels at all sensitive receptor locations, and would therefore comply with all Air Quality Objectives. Furthermore the plant will be designed and will operate in accordance with the new requirements of the MCPD which comes into force in 2018.

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AIR QUALITY IMPACT ASSESSMENT

SMALL-SCALE GAS PEAKING PLANT - ERSKINE

ERSKINE GENERATION LTD

UPDATE - OCTOBER 2017

Prepared By: Arcus Consultancy Services

7th Floor, 145 St. Vincent Street, Glasgow, G2 5JF T +44 (0)141 221 9997 l E [email protected] W www.arcusconsulting.co.uk Registered in England & Wales No. 5644976

Air Quality Impact Assessment Small-scale Reserve Power Plant - Erskine

Nitrogen dioxide (NO2), which is a constituent of NOX, is a pollutant generated in combustion processes. Recognition of this is reflected in national legislation in the form of air quality objectives. The assessment of the potential impacts of emissions of NOX considers the emission of NOX, its dispersion in the atmosphere and the predicted concentrations of NO2 at sensitive receptor locations. These are compared to the air quality objectives to determine acceptability. A description of the impacts is set out in accordance with the IAQM/EPUK guidance1, including an assessment of significance. It should be noted that significance relates principally to the severity of impact combined with the number of receptors affected, rather than to the potential for effects on human health. The air quality objectives are set for the protection of human health, and a significant impact may be acceptable in human health and planning terms if the air quality objectives are not likely to be exceeded.

1.1 NOX Air Quality Objectives The principal air quality legislation in Scotland is the Air Quality (Scotland) Regulations (2010)2, which were enacted as part of the National Air Quality Strategy (NAQS) for Scotland, England, Wales and Northern Ireland (2000, and 2003 and 2007 addendums)3 under Section 80 of the Environment Act 1995.

There are no legal limits or guideline thresholds specifically for NOX, but there are for NO2. The Air Quality Regulations set out that:

3  The 1-hour mean concentration of NO2 must not exceed 200 μg/m (the short-term Environmental Assessment Level, or EAL) more than 18 times per year; and 3  The annual mean concentration of NO2 must not exceed 40 μg/m (the long term EAL).

1 IAQM/EPUK (2012). Guidance on land-use planning and development control: Planning for air quality January 2017 (v1.2). Available at: http://www.iaqm.co.uk/text/guidance/air-quality-planning-guidance.pdf [accessed on 25/10/2017] 2 The Air Quality (Scotland) Regulations, 2010, Scottish Statutory Instrument 204 (2010); available online http://www.legislation.gov.uk/ssi/2010/204/pdfs/ssi_20100204_en.pdf [accessed on 04/08/2017]. 3 The Air Quality Strategy for England, Scotland, Wales and Northern Ireland, Department for Environment, Food and Rural Affairs in partnership with the Scottish Executive, Welsh Assembly Government and Department of the Environment Northern Ireland, July 2007’

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These are referred to as the short- and long-term Air Quality Objectives (AQOs), respectively.

1.2 Assessment of NOX Impacts

NOX typically comprises a mixture of nitrogen monoxide (NO) and NO2. Whilst predominantly NO may be created in a combustion process, this will gradually change to NO2 over time.

 For short term NOX emissions, assume 50% of NOX is NO2; and  For long term NOX emissions, assume 100% of NOX is NO2. The Process Contribution (PC) is the concentration of a pollutant emitted from the installation (in this case the Development) at a receptor location, and is typically expressed as a percentage of the relevant AQO. If the PC is less than approximately 1% of the EAL, then it is typically considered to have negligible impact, and isn’t considered further. If the PC has more than negligible impact, the Predicted Environmental Concentration (PEC) should be calculated. The PEC is arrived at by adding the PC to the concentration of a pollutant at a receptor location in the absence of the installation (the baseline concentration). To meet the relevant AQO, the PEC should not be greater than the relevant EAL more than the specified number of times.

4 Environment Agency (2016). Air Emissions Risk Assessment for Environmental Permits. Available at: https://www.gov.uk/guidance/air-emissions-risk-assessment-for-your-environmental-permit#calculate-pc-to-air [accessed on 04/08/2017]

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call for the use of a specific generating station, the worst-case assumption made for the purposes of the air quality assessment is that the likely maximum operational period would be 3,000 hours per year. This is expected to be an overestimate of the actual operation of the gas engines, but is required for air quality assessment purposes to identify the worst- case scenario for NOX emissions. When the plant is not running it does not generate any emissions to air.

3 NOX concentration 250 mg/Nm

NOX emission rate 0.54 g/s

It should be noted that the NOX concentration, normalised to standard reference conditions5, is compliant with the Medium Combustion Plant Directive (MCPD) specification for new gas engines commencing operation after December 2018 (maximum 250 mg/Nm3). The engines are therefore ahead of new industry standards, in terms of emissions of pollutants. In Pollution Prevention and Control (PPC) terminology, they are consistent with Best Available Techniques (BAT). The 10 emission points have been identified at the grid locations shown in Table 2.

5 Standard reference conditions for gas engines specified in the Medium Combustion Plant Directive, Annex C, are 1 atmosphere, 273 K, dry, 5% oxygen.

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Table 2: Grid Co-ordinates of the Emission Points Container Number Easting Northing 1 244760 670475 2 244766 670472 3 244771 670469 4 244777 670466 5 244783 670463 6 244789 670461 7 244795 670458 8 244801 670455 9 244807 670452 10 244813 670450

5 DISPERSION MODELLING OF NOX Specialist dispersion modelling software6, was used to represent the emission points and the dispersed concentration of pollutants at relevant receptor locations. A map-based representation of modelled features (described below) is shown in Figure 1. Figure 1: A Map-based Representation of the Model Inputs

6 ADMS Roads Extra 4, version 4.1

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5.1 On-site Point Source Emissions

The emissions of NOX from the Development were modelled as set out in Section 3 of this document.

5.3 Background NO2 Concentrations Background concentrations of modelled pollutants are values that are typical of the area but away from the specific sources of pollution modelled explicitly.

Background concentrations of NO2 were taken from the DEFRA background air quality database7, for the location 244500, 670500. This is the geographic grid square which includes the Site. The 2013 dataset was used, selecting data for the year 2017. Renfrewshire Council’s 2016 Air Quality Annual Progress Report8 identifies automatic and diffusion tube monitoring locations within Renfrewshire. The nearest is a diffusion tube monitoring location in Bishopton, adjacent to the A8 (Greenock Road), which reported an annual average concentration of 13.1 μg/m3 in 2015. No monitoring locations are in rural areas, however, and none are therefore likely to be representative of the rural location of the Site. The DEFRA data, which is representative of a rural location, was therefore used in preference.

3 The long-term background concentrations of NO2 are 9.27 μg/m . The short-term background concentrations were assumed to be double the long-term values, i.e. 18.54 μg/m3.

7 DEFRA (2017). Pollutant background concentration map. Available at: https://uk-air.defra.gov.uk/data/laqm-background- home [accessed on 04/08/2017] 8 Renfrewshire Council (2016). 2016 Air Quality Annual Progress Report. Available at: http://www.renfrewshire.gov.uk/airquality [accessed on 05/08/2017]

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5.4 Road Traffic Emission Sources

At roadside receptor locations, emissions of NOX from road traffic can elevate ambient levels of NO2 above those levels identified as the general background concentration in the wider area. The receptors identified in Section 5.2 are within 200 m of a motorway, and hence have the potential to experience elevated concentrations of NO2 as a result of proximity to roads. Road traffic data were obtained for these road sections from the Department for Transport website9. The traffic data, expressed as Annual Average Daily Traffic counts (AADT) are shown in Table 4. Table 4: Traffic Count Data (AADT) Road Section LDV HDV Average Speed (km/h) M8 64,898 3,061 90 M898 48,155 2,276 90

5.5 Off-site Point Source Emissions

5.6 Other Model Parameter Settings Other model input parameters were:  Meteorological data: hourly sequential data for the whole of 1996, from Abbotsinch met station11, as this was the worst-case of the four years of met data initially modelled;  Surface roughness: a value of 0.2 was used for the Development site, corresponding to "agricultural” land use, which is appropriate for an area with a mixture of fields, hedges and occasional medium-sized trees. A value of 0.02 was used for the met data site, given that it is located at an airport with minimal nearby vertical structures; and  No buildings or complex terrain were modelled.

5.7 Predicted Concentrations

PCs for NOX were predicted by ADMS. The long-term PC was assumed to be the same for NO2. The short-term PCs were halved when converting to NO2, in accordance with guidance, as set out in Section 1.2 of this document. The PECs comprised the background concentrations, plus the modelled road traffic contributions, plus the contribution from the Development. Road traffic contributions were

9 Department for Transport (2017). Traffic counts. Available at: https://www.dft.gov.uk/traffic-counts/cp.php [accessed on 04/08/2017] 10 Department for Transport (2016). Department for Transport statistics: Table TRA0307: Traffic Distribution by time of day on all roads in Great Britain 2015. Available at: www.gov.uk/government/organisations/department-for-transport/series/road- traffic-statistics [accessed on 04/08/2017] 11 Data from 1995, 1997 and 1998 was also used, and led to marginally lower concentrations of NOX at receptors, hence 1996 data was used as a worst-case.

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12 provided as a separate output from ADMS, and the DEFRA NOx to NO2 calculator was used to convert NOx, as modelled by ADMS, to NO2, as required for the contribution to the PECs.

PCs and PECs for NO2 are shown in Table 5 for Porton Nursery, in Table 6 for Old Greenock Rd, in Table 7 for Craigton Farm, in Table 8 for Lachlan Crescent and Table 9 for Shilton Cottage.

Table 5: Predicted NO2 Concentrations at Porton Nursery EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 2.1 13.5 33.9% Short term (200 μg/m3) 90.0 120.4 60.2%

Table 6: Predicted NO2 Concentrations at Old Greenock Rd EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL) Long term (40 μg/m3) 0.7 13.7 34.3% Short term (200 μg/m3) 50.5 88.8 44.4%

Table 7: Predicted NO2 Concentrations at Craigton Farm EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL) Long term (40 μg/m3) 2.7 14.4 35.9% Short term (200 μg/m3) 89.0 125.7 62.9%

Table 8: Predicted NO2 Concentrations at Lachlan Crescent EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 2.2 14.4 36.1%

Short term (200 μg/m3) 69.5 106.2 53.1%

Table 9: Predicted NO2 Concentrations at Shilton Cottage EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 3.6 15.1 37.7%

Short term (200 μg/m3) 75.5 106.2 53.1%

5.8 Description of Impacts The IAQM/EPUK guidance, “Land-Use Planning & Development Control: Planning For Air Quality”13, details appropriate recommendations for describing impacts in paragraphs 6.27 to 6.40.

12 DEFRA (2017). Background maps: NOX to NO2 calculator. Available at: https://laqm.defra.gov.uk/review-and- assessment/tools/background-maps.html#NOXNO2calc [accessed on 25/10/2017] 13 IAQM/EPUK (2017). Land-Use Planning & Development Control: Planning For Air Quality. Available at: http://www.iaqm.co.uk/text/guidance/air-quality-planning-guidance.pdf [accessed on 25/10/2017]

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5.8.1 Long-term Impacts Paragraph 6.33 provides suggestions relevant for the study of long-term concentrations: “6.33 The suggested framework for describing the impacts on the basis set out above is set out in Table 6.3. The term AQAL is used to include air quality objectives or limit values, where these exist. Users of the impact descriptors set out in Table 6.3 are encouraged to follow the explanatory notes carefully and recognise the spirit in which they apply. In particular, the intention is that the descriptors should not be applied too rigidly and assessors should recognise the inevitable uncertainties embedded within the process of their determination.” The notes in Table 6.3 state “the table is only designed to be used with annual mean concentrations”. Applying the guidelines in Table 6.3 of the IAQM/EPUK guidance to the Development and using NO2 AQOs as the Air Quality Assessment Levels (AQAL) leads to the following assessment: Long term average concentrations at the receptors (the PECs shown in Tables 5 to 9, above) are between 33% and 38% of the AQO, which is less than 75% of the AQAL and hence the top row of the Table 6.3 in the guidance applies. As per the notes to Table 6.3, these total concentrations indicate that “the degree of harm is likely to be small”. The long term impacts, taken from Tables 5 to 9, above, are assessed as:  Porton Nursery: PC is 2.1 μg/m3, which is 6-10% of AQAL (40 μg/m3), Slight impact.  Old Greenock Rd: PC is 0.7 μg/m3, which is 2% of AQAL (40 μg/m3), Negligible impact.  Craigton Farm: PC is 2.7 μg/m3, which is 6-10% of AQAL (40 μg/m3), Slight impact.  Lachlan Crescent: PC is 2.2 μg/m3, which is 6-10% of AQAL (40 μg/m3), Slight impact.  Shilton Cottage: PC is 3.6 μg/m3, which is 6-10% of AQAL (40 μg/m3), Slight impact.

5.8.2 Short-term Impacts Paragraph 6.39 of the IAQM/EPUK guidance provides for the description of short-term, peak concentrations of pollutants: “6.39 Where such peak short term concentrations from an elevated source are in the range 11-20% of the relevant AQAL, then their magnitude can be described as small, those in the range 21-50% medium and those above 51% as large. These are the maximum concentrations experienced in any year and the severity of this impact can be described as slight, moderate and substantial respectively, without the need to reference background or baseline concentrations. That is not to say that background concentrations are unimportant, but they will, on an annual average basis, be a much smaller quantity than the peak concentration caused by a substantial plume and it is the contribution that is used as a measure of the impact, not the overall concentration at a receptor. This approach is intended to be a streamlined and pragmatic assessment procedure that avoids undue complexity.” The short term impacts are assessed as:  Porton Nursery: PC is 90 μg/m3 = 45% of AQAL (200 μg/m3), medium magnitude, Moderate impact.  Old Greenock Road: PC is 50.5 μg/m3 = 25% of AQAL (200 μg/m3), medium magnitude, Moderate impact.  Craigton Farm: PC is 89.0 μg/m3 = 45% of AQAL (200 μg/m3), medium magnitude, Moderate impact.  Lachlan Crescent: PC is 69.5 μg/m3 = 35% of AQAL (200 μg/m3), medium magnitude, Moderate impact.

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 Shilton Cottage: PC is 75.5 μg/m3 = 38% of AQAL (200 μg/m3), medium magnitude, Moderate impact.

5.8.3 Significance The approach to the assessment of significance is set out in section 7 of the IAQM/EPUK guidance. This states that: “Impacts on air quality, whether adverse or beneficial, will have an effect on human health that can be judged as ‘significant’ or ‘not significant’.” The AQOs referred to in this document are set by the government for the protection of human health. Paragraph 7.5 of the guidance states that: “… a ‘moderate’ or ‘substantial’ impact may not have a significant effect if it is confined to a very small area and where it is not obviously the cause of harm to human health.” The assessment of significance of effects takes into account the following factors:  “the existing and future air quality in the absence of the development;  the extent of current and future population exposure to the impacts; and  the influence and validity of any assumptions adopted when undertaking the prediction of impacts.” In the case of the Development:  Baseline air quality is substantially below the AQOs in the absence of the Development, and remains so with the Development;  The population exposure is very small: Porton Nursery, Craigton Farm and Shilton Cottage are all single properties; Old Greenock Road represents c. 4 properties, and while Lachlan Crescent, Linburn, is on a wider housing estate, the nearest (worst- case) property has been modelled and the predicted, worst-case concentrations are 36% (long-term) and 53% (short-term) of the AQOs set to protect human health;  The assumptions made when undertaking the prediction of impacts have been a combination of best-estimate (i.e., most accurate) and worst-case assumptions. The influence these will have is to over-estimate impacts. This has been done in order to account for uncertainties inherent in modelling; the results are therefore conservative, and in reality the impacts are expected to be lower than predicted. Given that predicted air quality is well below the AQOs, that the affected population is small, and that the modelling assumptions and approach are worst-case, the effects on human health are assessed as not significant.

The results show that, after adding background concentrations of NO2 to the dispersed emission from the Development and the dispersed emissions from the nearby M8 and M898 motorways, total concentrations of NO2 would be less than the relevant Environmental Assessment Levels at all sensitive receptor locations, and would therefore comply with all Air Quality Objectives. The effects are assessed as not significant. Furthermore the plant will be designed and will operate in accordance with the new requirements of the MCPD which comes into force in 2018.

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AIR QUALITY IMPACT ASSESSMENT

SMALL-SCALE GAS PEAKING PLANT - ERSKINE

ERSKINE GENERATION LTD

UPDATE - NOVEMBER 2017

Prepared By: Arcus Consultancy Services

7th Floor, 145 St. Vincent Street, Glasgow, G2 5JF T +44 (0)141 221 9997 l E [email protected] W www.arcusconsulting.co.uk Registered in England & Wales No. 5644976

Air Quality Impact Assessment Small-scale Reserve Power Plant - Erskine

There are no legal limits or guideline thresholds specifically for NOX, but there are for NO2. The Air Quality Regulations set out that:

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These are referred to as the short- and long-term Air Quality Objectives (AQOs), respectively.

1.2 Assessment of NOX Impacts

NOX typically comprises a mixture of nitrogen monoxide (NO) and NO2. Whilst predominantly NO may be created in a combustion process, this will gradually change to NO2 over time.

 For short term NOX emissions, assume 50% of NOX is NO2; and  For long term NOX emissions, assume 100% of NOX is NO2. The Process Contribution (PC) is the concentration of a pollutant emitted from the installation (in this case the Development) at a receptor location, and is typically expressed as a percentage of the relevant AQO. If the PC is less than approximately 1% of the EAL, then it is typically considered to have negligible impact, and isn’t considered further. If the PC has more than negligible impact, the Predicted Environmental Concentration (PEC) should be calculated. The PEC is arrived at by adding the PC to the concentration of a pollutant at a receptor location in the absence of the installation (the baseline concentration). To meet the relevant AQO, the PEC should not be greater than the relevant EAL more than the specified number of times.

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exporting continuously. Whilst the Applicant has no control over when National Grid will call for the use of a specific generating station, the worst-case assumption made for the purposes of the air quality assessment is that the likely maximum operational period would be 3,000 hours per year. This is expected to be an overestimate of the actual operation of the gas engines, but is required for air quality assessment purposes to identify the worst-case scenario for NOX emissions. When the plant is not running it does not generate any emissions to air.

3 NOX concentration 250 mg/Nm

NOX emission rate 0.54 g/s

5 Standard reference conditions for gas engines specified in the Medium Combustion Plant Directive, Annex C, are 1 atmosphere, 273 K, dry, 5% oxygen.

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6 ADMS Roads Extra 4, version 4.1

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5.1 On-site Point Source Emissions

The emissions of NOX from the Development were modelled as set out in Section 3 of this document.

5.3 Background NO2 Concentrations Background concentrations of modelled pollutants are values that are typical of the area but away from the specific sources of pollution modelled explicitly.

3 The long-term background concentrations of NO2 are 9.27 μg/m . The short-term background concentrations were assumed to be double the long-term values, i.e. 18.54 μg/m3.

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5.4 Road Traffic Emission Sources

At roadside receptor locations, emissions of NOX from road traffic can elevate ambient levels of NO2 above those levels identified as the general background concentration in the wider area. The receptors identified in Section 5.2 are within 200 m of a motorway, and hence have the potential to experience elevated concentrations of NO2 as a result of proximity to roads. Road traffic data were obtained for these road sections from the Department for Transport website9. The traffic data, expressed as Annual Average Daily Traffic counts (AADT) are shown in Table 4. Table 4: Traffic Count Data (AADT) Road Section LDV HDV Average Speed (km/h) M8 64,898 3,061 90 M898 48,155 2,276 90

5.5 Off-site Point Source Emissions

5.7 Predicted Concentrations

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12 were provided as a separate output from ADMS, and the DEFRA NOx to NO2 calculator was used to convert NOx, as modelled by ADMS, to NO2, as required for the contribution to the PECs.

PCs and PECs for NO2 are shown in Table 5 for Porton Nursery, in Table 6 for Old Greenock Rd, in Table 7 for Craigton Farm, in Table 8 for Lachlan Crescent and Table 9 for Shilton Cottage.

Table 5: Predicted NO2 Concentrations at Porton Nursery EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 2.1 13.5 33.9% Short term (200 μg/m3) 90.0 120.4 60.2%

Table 6: Predicted NO2 Concentrations at Old Greenock Rd EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL) Long term (40 μg/m3) 0.7 13.7 34.3% Short term (200 μg/m3) 50.5 88.8 44.4%

Table 7: Predicted NO2 Concentrations at Craigton Farm EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL) Long term (40 μg/m3) 2.7 14.4 35.9% Short term (200 μg/m3) 89.0 125.7 62.9%

Table 8: Predicted NO2 Concentrations at Lachlan Crescent EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 2.2 14.4 36.1%

Short term (200 μg/m3) 69.5 106.2 53.1%

Table 9: Predicted NO2 Concentrations at Shilton Cottage EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 3.6 15.1 37.7%

Short term (200 μg/m3) 75.5 106.2 53.1%

5.8 Allowance for Uncertainty from Using Historic Meteorological Data During consultation on the above results, the view was expressed that the use of historic meteorological data could under-represent future impacts, because of differences in climatic conditions between 1995-1998 (the data used in this assessment) and 2012-2016 (the most recent data available). In particular, the LAQM Helpdesk advised that there can be up to 35% difference in dispersed concentrations between different years of meteorological data.

12 DEFRA (2017). Background maps: NOX to NO2 calculator. Available at: https://laqm.defra.gov.uk/review-and- assessment/tools/background-maps.html#NOXNO2calc [accessed on 25/10/2017]

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The principle of variation between years is well understood, as is the principle of using measured (historic) meteorological data to predict future dispersion; both of these lead to uncertainty in predictions of dispersed concentrations. It was to address this uncertainty that 4 years of meteorological data were used, and the worst-case results reported above. Consultees have advised that 35% could be added to dispersed concentrations in order to account for the uncertainty resulting from the variation between years. Noting that this uncertainty has already been accounted for, by using the worst-case year, adding 35% to the worst-case values would be predicting the scenario that future concentrations could be 35% worse than the worst-case year during the period 1995-1998. For reference, the difference in dispersed concentrations (considering predicted concentrations at all locations) between the best-case and worst-case years during the period 1995-1998 was between 4% and 9% for short-term concentrations, and 4% and 37% for long-term concentrations, and the worst-case of these was reported above. The authors consider adding a further 35% to the worst-case to be an excessive precaution, even before considering the other conservative assumptions made in the modelling exercise, such as the emission concentrations and operating scenario for the plant. This is particularly the case for short-term impacts, where the PC comprises the majority of the PEC. A 35% increase in PC therefore makes a larger difference to the PEC for short-term impacts than long-term impacts. As noted, the difference between best-case and worst-case modelled short-term PCs was between 4% and 9%; the short-term PCs are fairly consistent between years, and the addition of 35% is even less appropriate than for long-term values. Notwithstanding the above, 35% has been added to the PC values (the dispersed concentrations of emissions from the plant) output from the model, as requested by consultees. Revised values are shown in Tables 10-14, below. In addition, following a request from consultees, isopleth (pollutant concentration contour) maps are shown in Appendix 1 for the predicted short- and long-term PC and PEC values.

Table 10: Predicted NO2 Concentrations at Porton Nursery EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 2.9 14.3 35.7% Short term (200 μg/m3) 121.5 151.9 76.0%

Table 11: Predicted NO2 Concentrations at Old Greenock Rd EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL) Long term (40 μg/m3) 1.0 14.0 34.9% Short term (200 μg/m3) 68.2 106.5 53.2%

Table 12: Predicted NO2 Concentrations at Craigton Farm EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL) Long term (40 μg/m3) 3.6 15.3 38.3% Short term (200 μg/m3) 120.2 156.9 78.4%

Table 13: Predicted NO2 Concentrations at Lachlan Crescent EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 2.9 15.2 38.0%

Short term (200 μg/m3) 93.8 130.5 65.2%

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Table 14: Predicted NO2 Concentrations at Shilton Cottage EAL PC (μg/m3) PEC (μg/m3) PEC (% of EAL)

Long term (40 μg/m3) 4.8 16.3 40.8%

Short term (200 μg/m3) 101.9 132.6 66.3%

5.9 Description of Impacts The IAQM/EPUK guidance, “Land-Use Planning & Development Control: Planning For Air Quality”13, details appropriate recommendations for describing impacts in paragraphs 6.27 to 6.40. Predicted concentrations from Section 5.8, above, have been used in these descriptions, noting that in addition to the worst-case meteorological year and conservative model assumptions, 35% has been added to the dispersed concentration of pollutants emitted from the Development. The authors re-iterate that this was at the specific request of consultees, and that the authors consider this to be excessive precaution.

5.9.1 Long-term Impacts Paragraph 6.33 provides suggestions relevant for the study of long-term concentrations: “6.33 The suggested framework for describing the impacts on the basis set out above is set out in Table 6.3. The term AQAL is used to include air quality objectives or limit values, where these exist. Users of the impact descriptors set out in Table 6.3 are encouraged to follow the explanatory notes carefully and recognise the spirit in which they apply. In particular, the intention is that the descriptors should not be applied too rigidly and assessors should recognise the inevitable uncertainties embedded within the process of their determination.” The notes in Table 6.3 state “the table is only designed to be used with annual mean concentrations”. Applying the guidelines in Table 6.3 of the IAQM/EPUK guidance to the Development and using NO2 AQOs as the Air Quality Assessment Levels (AQAL) leads to the following assessment: Long term average concentrations at the receptors (the PECs shown in Tables 5 to 9, above) are between 33% and 38% of the AQO, which is less than 75% of the AQAL and hence the top row of the Table 6.3 in the guidance applies. As per the notes to Table 6.3, these total concentrations indicate that “the degree of harm is likely to be small”. The long term impacts, taken from Tables 5 to 9, above, are assessed as:  Porton Nursery: PC is 2.9 μg/m3, which is 6-10% of AQAL (40 μg/m3), Slight impact.  Old Greenock Rd: PC is 1.0 μg/m3, which is 3% of AQAL (40 μg/m3), Negligible impact.  Craigton Farm: PC is 3.6 μg/m3, which is 6-10% of AQAL (40 μg/m3), Slight impact.  Lachlan Crescent: PC is 2.9 μg/m3, which is 6-10% of AQAL (40 μg/m3), Slight impact.  Shilton Cottage: PC is 4.8 μg/m3, which is 6-10% of AQAL (40 μg/m3), Moderate impact.

5.9.2 Short-term Impacts Paragraph 6.39 of the IAQM/EPUK guidance provides for the description of short-term, peak concentrations of pollutants:

13 IAQM/EPUK (2017). Land-Use Planning & Development Control: Planning For Air Quality. Available at: http://www.iaqm.co.uk/text/guidance/air-quality-planning-guidance.pdf [accessed on 25/10/2017]

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“6.39 Where such peak short term concentrations from an elevated source are in the range 11-20% of the relevant AQAL, then their magnitude can be described as small, those in the range 21-50% medium and those above 51% as large. These are the maximum concentrations experienced in any year and the severity of this impact can be described as slight, moderate and substantial respectively, without the need to reference background or baseline concentrations. That is not to say that background concentrations are unimportant, but they will, on an annual average basis, be a much smaller quantity than the peak concentration caused by a substantial plume and it is the contribution that is used as a measure of the impact, not the overall concentration at a receptor. This approach is intended to be a streamlined and pragmatic assessment procedure that avoids undue complexity.” The short term impacts are assessed as:  Porton Nursery: PC is 121 μg/m3 = 61% of AQAL (200 μg/m3), large magnitude, Substantial impact.  Old Greenock Road: PC is 68.2 μg/m3 = 35% of AQAL (200 μg/m3), medium magnitude, Moderate impact.  Craigton Farm: PC is 120.2 μg/m3 = 61% of AQAL (200 μg/m3), large magnitude, Substantial impact.  Lachlan Crescent: PC is 93.8 μg/m3 = 47% of AQAL (200 μg/m3), medium magnitude, Moderate impact.  Shilton Cottage: PC is 101.9 μg/m3 = 51% of AQAL (200 μg/m3), large magnitude, Substantial impact.

5.9.3 Significance The approach to the assessment of significance is set out in section 7 of the IAQM/EPUK guidance. This states that: “Impacts on air quality, whether adverse or beneficial, will have an effect on human health that can be judged as ‘significant’ or ‘not significant’.” The AQOs referred to in this document are set by the government for the protection of human health. Paragraph 7.5 of the guidance states that: “… a ‘moderate’ or ‘substantial’ impact may not have a significant effect if it is confined to a very small area and where it is not obviously the cause of harm to human health.” The assessment of significance of effects takes into account the following factors:  “the existing and future air quality in the absence of the development;  the extent of current and future population exposure to the impacts; and  the influence and validity of any assumptions adopted when undertaking the prediction of impacts.” In the case of the Development:  Baseline air quality is substantially below the AQOs in the absence of the Development, and remains so with the Development;  The population exposure is very small: Porton Nursery, Craigton Farm and Shilton Cottage are all single properties; Old Greenock Road represents c. 4 properties, and while Lachlan Crescent, Linburn, is on a wider housing estate, the nearest (worst- case) property has been modelled and the predicted, worst-case concentrations are 38% (long-term) and 65% (short-term) of the AQOs set to protect human health;  The assumptions made when undertaking the prediction of impacts have been a combination of best-estimate (i.e., most accurate) and worst-case assumptions. The influence these will have is to over-estimate impacts. This has been done in order to account for uncertainties inherent in modelling; the results are therefore conservative, and in reality the impacts are expected to be lower than predicted.

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Given that predicted air quality is well below the AQOs, that the affected population is small, and that the modelling assumptions and approach are worst-case (arguably excessively precautionary), the effects on human health are assessed as not significant.

The results show that, after adding background concentrations of NO2 to the dispersed emission from the Development and the dispersed emissions from the nearby M8 and M898 motorways, total concentrations of NO2 would be less than the relevant Environmental Assessment Levels at all sensitive receptor locations, and would therefore comply with all Air Quality Objectives. The effects are assessed as not significant. Furthermore the plant will be designed and will operate in accordance with the new requirements of the MCPD which comes into force in 2018.

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APPENDIX 1: ISOPLETH MAPS As requested via the consultation process, Appendix 1 has been prepared to support this updated report, and includes isopleth maps derived from the air quality modelling undertaken to assess the Development. The figures included in this appendix include the following:

 Figure 2 which shows the predicted long-term (annual average) NO2 PC values (concentrations resulting from the emissions from the Development only);  Figure 3 which shows the predicted long-term (annual average) NO2 PEC values (concentrations resulting from the emissions from the Development, emissions from road traffic and background concentrations);  Figure 4 which shows the predicted short-term (annual average) NO2 PC values (concentrations resulting from the emissions from the Development only); and  Figure 5 which shows the predicted short-term (annual average) NO2 PEC values (concentrations resulting from the emissions from the Development, emissions from road traffic and background concentrations).

Figure 2: Long-term NO2 PC isopleths

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Figure 3: Long-term NO2 PEC isopleths (including modelled road traffic emissions and the background concentration)

Reproduced from Ordnance Survey digital map data © Crown copyright 2017. All rights reserved. License number 100048606. Note that the isopleths are generated based on gridded data output from ADMS. PEC values along the roads are shown as a series of peaks, these corresponding to grid locations close to the roads, and the gaps between the peaks corresponding to where the nearest grid point is further from the road. On, or extremely close to, the roads, realistic PEC values would be those at the peak locations. Further from the roads, including at receptor locations, the isopleths report concentrations more accurately. The results reported at specific receptor locations in the main report are output explicitly by ADMS, and do not rely on the gridded data used to generate the isopleths.

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Figure 4: Short-term NO2 PC isopleths

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Figure 5: Short-term NO2 PEC isopleths (including modelled road traffic emissions and the background concentration)

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NOISE IMPACT ASSESSMENT

SMALL SCALE GAS PEAKING PLANT – ERSKINE

ERSKINE GENERATION LTD

SEPTEMBER 2017

Prepared By:

Arcus Consultancy Services

1C Swinegate Court East 3 Swinegate York North Yorkshire YO1 8AJ

T +44 (0)1904 715 470 l E [email protected] w www.arcusconsulting.co.uk

Registered in England & Wales No. 5644976

Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

TABLE OF CONTENTS

1 INTRODUCTION ...... 1

2 DEVELOPMENT OVERVIEW ...... 1

3 RELEVANT GUIDANCE ...... 1 3.1 Planning Advice Note 1/2011: Planning and Noise ...... 1 3.2 Technical Advice Note: Planning and Noise ...... 2 3.3 BS4142:2014 ...... 2

4 ASSESSMENT CRITERIA ...... 2

5 IDENTIFICATION OF NOISE-SENSITIVE RECEPTORS ...... 3

6 BACKGROUND SURVEY ...... 4 6.1 Measurements ...... 4 6.1.1 Old Greenock Road ...... 4 6.1.2 Shilton Cottage ...... 6 6.1.3 Property at Porton Nursery ...... 8 6.1.4 Other Receptors ...... 8 6.2 Contextual Factors ...... 8

7 NOISE MODELLING ...... 8 7.1 Rating Level Corrections ...... 9

8 ASSESSMENT OF IMPACT ...... 9 8.1 Uncertainty ...... 10

9 CONCLUSION ...... 10

10 GLOSSARY OF TERMS ...... 10

APPENDIX 1 – DEVELOPMENT LAYOUT

APPENDIX 2 – SURVEY RECORD SHEETS

APPENDIX 3 – NOISE MAP

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1 INTRODUCTION Arcus Consultancy Services Ltd (Arcus) has been commissioned by Erskine Generation Ltd (the Applicant) to undertake a noise assessment in relation to the development of a small-scale gas peaking plant (the Development) at Old Greenock Road, Erskine (the Site). The aim of this assessment is to determine the existing acoustic climate, predict the sound levels due to the operation of the Development, and to assess these levels against relevant guidance. Where appropriate, mitigation measures have been recommended to ensure that the amenity of residents in the locality of the Development is not unreasonably impacted by the Development.

2 DEVELOPMENT OVERVIEW The Development consists of 10 acoustically insulated containerised gas engine-generator (genset) units and associated infrastructure including a gas skid, electrical switchgear (client side and DNO), transformers, attenuation fencing and access track. The plant will generate additional power for export to the national grid during periods of peak demand. The Development will therefore not operate continuously, and will produce no noise when not operating. Nonetheless, there is potential for the plant to operate during any time of day, including night-time periods. The Development is located in the south of a field adjacent to Old Greenock Road, Erskine, near to an existing large-scale Electricity Substation, and in close proximity to Junction 30 of the M8, which leads to the M898 Erskine Bridge approach road. The Site is bounded by a 3 m high acoustic fence in order to minimise noise levels at nearby receptors and to enhance site security. A figure detailing the Development layout is presented in Appendix 1.

3 RELEVANT GUIDANCE The following guidance and standards are pertinent to the assessment:  Planning Advice Note 1/2011: Planning and Noise (PAN 1/2011);  Technical Advice Note: Planning and Noise (TAN); and  BS4142:2014 Method for Rating and Assessing Industrial and Commercial Sound.

3.1 Planning Advice Note 1/2011: Planning and Noise PAN 1/2011 provides advice on the role of the planning system in helping to prevent and limit the adverse effects of noise, with information and advice on assessment methods provided in TAN. The PAN promotes the principles of good acoustic design and the appropriate location of new noise-generating development. The selection of a site, the design of a development and conditions which may be attached to a planning permission can all play a part in preventing, controlling and mitigating the effects of noise. The level of detail required of a noise assessment should be balanced against the degree of risk to environmental quality, public health and amenity. Issues which may be relevant when considering noise in relation to a development proposal include:  The type of development and the likelihood of significance of its noise impact;  The sensitivity of the location;  Existing noise levels and the likely change in noise levels;

Erskine Generation Ltd Arcus Consultancy Services September 2017 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

 The character (tonality, impulsivity etc.), duration, frequency of any repetition and time of day that noise is likely to be generated; and  Absolute level and possible dose-response relationships. In relation to industrial sources, the PAN advises that as background noise levels vary throughout a 24 hour period, it will usually be necessary to assess the acceptability of noise levels for separate periods, e.g. day, evening, night and weekend.

3.2 Technical Advice Note: Planning and Noise The TAN provides guidance which may assist in the technical assessment of noise, although it is neither prescriptive nor exhaustive. It provides a summary of relevant and current (at the time of publication) technical standards, guidance and codes of practice, including BS4142 (at the time the 1997 version was current, which has been superseded by the 2014 version). Due to the small-scale nature of the Development, the detailed assessment methods described in TAN are not considered applicable.

3.3 BS4142:2014 BS4142:2014 describes methods for rating and assessing sound in order to provide an indication its likely impact upon nearby premises (typically residential dwellings).

The specific sound emitted from the Development (dB, LAeq) is rated by taking into account both the level and character (i.e. tonal elements, impulsivity, intermittency and distinctiveness) of the sound. This is achieved by applying appropriate corrections to the specific sound level externally at the receptor location, which gives the rating level of the sound in question. This is then assessed against the existing prevailing background sound level (dB, LA90) at that location in order to determine a likely level of impact. The level by which the rating level exceeds the prevailing background sound level indicates the following potential impacts:  A difference of 10 dB or more is likely to be an indication of a significant adverse impact, depending on the context;  A difference of around 5 dB is likely to be an indication of an adverse impact, depending on the context; and  Where the rating level does not exceed the background level, this is an indication of the specific sound source having a low impact, depending on the context. When considering the level of impact, BS4142:2014 emphasises the importance of the context in which a sound occurs. The standard therefore takes great care in the use of the words “sound” and “noise”. Sound can be measured by a sound level meter or other measuring system, whereas noise is related to a human response and is routinely described as unwanted sound, or sound that is considered undesirable or disruptive.

4 ASSESSMENT CRITERIA Based upon BS4142:2014 criteria, the following assessment criteria have been adopted for the purposes of this assessment:  Significant Impact: BS4142:2014 rating level of around 10 dB above the prevailing background level;  Moderate Impact: BS4142:2014 rating level of around 5 dB above the prevailing background level; and  Low Impact: BS4142:2014 rating level equal to, or below the prevailing background level.

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A design criterion of mitigating any adverse impacts to no more than 5 dB above background will be applied.

5 IDENTIFICATION OF NOISE-SENSITIVE RECEPTORS Figure 1 shows the location of the closest noise-sensitive receptors to the Development. Figure 1: Location of Development and Receptors

Porton Nursery is described as a children’s nursery / crèche in the Ordnance Survey Address Layer data used in preparing Figure 1. However, during a site visit, the building was verified as an inhabited residential property. As a result, it is therefore included within this assessment a noise-sensitive receptor for both daytime and night time. Provided that appropriate noise levels are achieved at the closest receptors, the effects at these more distant receptors would also be acceptable.

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6 BACKGROUND SURVEY In order to establish the ambient sound environment in the locality of the Development, a background survey was undertaken between 4th and 14th August 2017, in positions considered representative of the closest residential receptors, as detailed in Appendix 2. The monitoring equipment consisted of Class 1 sound level meters, calibrated to traceable standards and housed in an all-weather case with long-life batteries. The microphone was positioned at a height of 1.4 m above ground level, with a suitable proprietary windshield. The sound level meter was field-calibrated at the start and end of the survey period; no significant calibration drift was found. Indices measured included LA90,15mins (i.e. the background sound level). Weather information for the period of the survey has been obtained from publically available online data1 located close to the Site, at Inchinnan. Wind speeds during the survey were within an acceptable range2 for all but a very short period of the survey. Rain showers occurred at various times during the survey, but these did not result in significantly elevated noise levels.

6.1 Measurements

6.1.1 Old Greenock Road Chart 1 provides a summary of the background sound levels measured during the survey period, detailing LA90,15min sound levels. Chart 1: Background Sound Survey: Time History

75 Measured Sound Level, LA90,15min 70 Rainfall 65

40 SoundPressure Level dB(A) 35

When determining typical daytime and night-time background sound levels, BS4142:2014 advises against assuming that the prevailing background level can be determined using any single approach (e.g. mean, median, mode etc.). Therefore, in order to aid the determination of the representative daytime and night-time background levels, Charts 2 and 3 present the range of LA90,15min noise levels recorded, along with the percentage of periods for which they occurred, for daytime (0700-2300) and night time (2300-0700) periods respectively.

1 https://www.wunderground.com/personal-weather- station/dashboard?ID=IRENFREW4#history/s20170804/e20170811/mweek. Accessed 16/08/2017 2 Below 5 ms-1 / 18 kph

Arcus Consultancy Services Erskine Generation Ltd September 2017 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

Chart 2: Background Sound Survey Statistical Analysis (0700 – 2300)

6 Percentage % 4

0 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 LA90,15min

As can be seen, the most commonly occurring background sound levels (the mode average) are 59 and 60 dB, LA90, with the mean and median averages being 56 and 57 dB LA90 respectively. As the most commonly occurring values are toward the top of the range of levels measured, it is considered appropriate select a more conservative value within the main body of the dataset. Despite the median value being relatively uncommon in this particular dataset, it lies in a well-balanced position when taking the spread of data into account. It is therefore considered that a background sound level of 57 dB, LA90 is the most appropriate for the purposes of this assessment. Chart 3: Background Sound Survey Statistical Analysis (2300 – 0700)

4 Percentage %

0 25 27 29 31 33 35 37 39 41 43 45 47 49 51 53 55 57 59 61 63 65 LA90,15min

Erskine Generation Ltd Arcus Consultancy Services September 2017 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

With regard to night-time periods, the most commonly-occurring background sound level (the mode average) is 36 dB, LA90, with the mean and median averages falling at a level considered more representative of the dataset as a whole (41 and 42 dB, La90 respectively). The most likely time for the Development to operate during the night-time period is in the early morning when people are getting up and the demand on the electrical grid is greatest. As can be seen from Chart 1, this coincides with a substantial increase in background sound level due to increased road traffic. As such, a background sound level in line with the mean average of 41 dB, LA90 is considered most appropriate in this context.

6.1.2 Shilton Cottage Chart 4 provides a summary of the background sound levels measured during the survey period, detailing LA90,15min sound levels. Chart 4: Background Sound Survey: Time History

75 Measured Sound Level, LA90,15min 70 Rainfall 65

40 SoundPressure Level dB(A) 35

Charts 5 and 6 (over) present the range of LA90,15min noise levels recorded, along with the percentage of periods for which they occurred, for daytime (0700-2300) and night time (2300-0700) periods respectively.

Arcus Consultancy Services Erskine Generation Ltd September 2017 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

Chart 5: Background Sound Survey Statistical Analysis (0700 – 2300)

Percentage % 6

0 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 LA90,15min

As can be seen, the most commonly occurring background sound levels (the mode average) is 50 dB, LA90, with the mean and median averages both found to be 49 dB LA90. Despite the mean and median value being relatively uncommon in this particular dataset, it lies in a well-balanced position when taking the spread of data into account. It is therefore considered that a background sound level of 49 dB, LA90 is the most appropriate for the purposes of this assessment. Chart 6: Background Sound Survey Statistical Analysis (2300 – 0700)

Erskine Generation Ltd Arcus Consultancy Services September 2017 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

With regard to night-time periods, the most commonly-occurring background sound level (the mode average) is 37 dB, LA90, with the mean and median averages falling at a level considered more representative of the dataset as a whole (39 and 40 dB, LA90 respectively). As previously noted, the Development is most likely to operate during those periods of the night where background sound levels are highest. As such, a background sound level in line with the median average of 40 dB, LA90, still toward the lower end of the measured range, is considered most appropriate in this context,.

6.1.3 Property at Porton Nursery As the property at Porton Nursery lies at a distance from the motorways in between those of the above monitoring locations, it is considered appropriate to apply and average of the background noise levels measured at each in the assessment for this property, i.e.:

 Daytime: 54 dB, LA90,15min  Night-time: 41 dB, LA90,15min

6.1.4 Other Receptors For the remaining two assessed receptors, 65 Lachlan Crescent, and Craigton Farm, prevailing background levels have been assumed to be the same as those at Shilton Cottage, being the quietest location where monitoring took place. This is considered a conservative assumption, as Shilton Cottage is situated in a more isolated position, further from the motorway than either 65 Lachlan Crescent, or Craigton Farm.

6.2 Contextual Factors The Site is located in close proximity to Junction 30 of the M8, which leads to the M898 Erskine Bridge approach road. The area is therefore subject to high levels of road traffic noise, as indicated by the high daytime background noise levels recorded and detailed in Section 6.1 of this document. A substation is also located nearby, which anecdotally is audible during quiet night-time periods when traffic noise is at its lowest. It is likely that traffic noise would mask sound from the Development during daytime; however, depending on the level of sound from the Development, this may be audible at night.

7 NOISE MODELLING A typical specification for an acoustically insulated containerised gas genset unit is for a maximum sound pressure level of 65 dB(A) at a distance of 10 m. For modelling purposes, it has been assumed that the noise emitted from each containerised gas engine will be evenly divided between the exhaust stack of each unit and the inlet and outlet louvres on the containers. As the exact location of the louvres is not known at this stage, it has been assumed that sound would be emitted equally from each vertical surface of the containers. The height of the exhaust stacks is 7 m AGL3. As no frequency spectrum for a containerised unit is available, it has been assumed for the purposes of modelling that all sound is emitted at a frequency of 500 Hz, as recommended in ISO 9613. The specific sound level4 at the façade of the nearest noise-sensitive properties at a height of 4 m, equivalent to the height of a first-floor window has been calculated in SoundPlan 7.4, using the environmental noise propagation model ISO 9613-2:1996 – Acoustics; Attenuation of sound during propagation outdoors – Part 2: General method of

3 Above Ground Level 4 The sound level produced by a source, without corrections for acoustic features as discussed in Section 3.3.

Arcus Consultancy Services Erskine Generation Ltd September 2017 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

calculation5. Levels at head height (approximately 1.5 m AGL) in external amenity areas will be lower than those presented. A noise map showing predicted specific levels (i.e. noise levels prior to any rating corrections) is presented in Appendix 3.

7.1 Rating Level Corrections BS 4142 states that corrections should be applied in order to account for certain acoustic features which have the potential to increase the level of noise impact at nearby dwellings. The four acoustic features to be considered in the application of rating corrections are as follows:  Impulsivity: As the character of the sound will be that of a typical combustion engine, no impulsive characterises are anticipated;  Tonal Elements: The sound due to the Development is likely to be of a broadband character with no significant tonal features;  Intermittency: The Development will only operate when required, for a maximum period of a few hours on each occasion. As such, it will not operate in a defined regular cycle but is likely to have identifiable on/off conditions. As such, a penalty of 3 dB for intermittency is considered appropriate; and  Distinctiveness: Due to the existing waste, haulage and motor engineering business in the area, it is considered that sound due to the Development is unlikely to have a character which differs substantially from that of the existing environment, and is therefore not considered distinctive in this context. In light of the above, a total correction of 3 dB is considered appropriate to derive the rating level for the Development at the closest residential receptors.

8 ASSESSMENT OF IMPACT An assessment of the likely impact has been made based upon the difference between the rating levels and prevailing background levels for daytime and night-time periods, as detailed in Table 3. Table 3: Assessment of Impact Background Sound Difference, dB Specific Rating Level, dB, L Receptor A90 Level, Level, Location dB, L dB(A) Aeq Daytime Night-time Daytime Night-time

65 Lachlan 40 43 49 40 -6 +3 Crescent

Craigton Farm 36 39 49 40 -10 -1

Old Greenock Road 39 42 57 41 -15 +1 (Netherdale)

Property at 43 46 54 41 -8 +5 Porton Nursery

Shilton Cottage 41 44 49 39 -5 +5

5 ISO 9613-2:1996 Acoustics; Attenuation of sound during propagation outdoors – Part 2: General method of calculation.

Erskine Generation Ltd Arcus Consultancy Services September 2017 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

As Table 3 shows, the rating level of the Development, determined accordance with BS4142:2014, is compliant with the criterion of 5 dB above the prevailing daytime and night-time background levels, with a worst-case impact of +5 dB during night-time periods.

8.1 Uncertainty As previously discussed, each genset will be housed within an appropriate acoustically-treated container. As no details of the frequency-specific performance of these containers are available, noise predictions have been made on the basis that all sound is emitted at a frequency of 500 Hz. Predictions of the specific noise level have been undertaken at a height of 4 m, representing a first floor window. Levels at head height (approximately 1.5 m AGL) in external amenity areas will be lower than those presented. As such, it is considered that the assumptions made in this assessment are likely to result in an over-prediction of noise levels, thereby presenting a worst case, and that the uncertainties inherent in the assessment will not have a significant impact on the outcome of the assessment.

9 CONCLUSION An assessment of noise impact has been undertaken in accordance with BS4142:2014. It has been found that when operational, the rating level of the Development is no more than 5 dB above the prevailing daytime and night-time background levels at the most noise-sensitive receptors, and is therefore compliant with the assessment criterion. The Development is therefore considered acceptable in terms of noise impact.

10 GLOSSARY OF TERMS Ambient Sound: Sound which comprising all sources, including the source under investigation. Background Sound: The background sound level is the underlying level of noise present at a particular location for the majority (usually 90%) of a period of time. Decibel (dB): The decibel is the basic unit of noise measurement. It relates to the cyclical changes in pressure created by the sound and operates on a logarithmic scale, ranging upwards from 0 dB. 0 dB is equivalent to the normal threshold of hearing at a frequency of 1000 Hertz (Hz). Each increase of 3 dB on the scale represents a doubling of the Sound Pressure, and is typically the minimum noticeable change in sound level under typical listening conditions. dB(A): Environmental noise levels are usually discussed in terms of dB(A). This is known as the A-weighted sound pressure level, and indicates that a correction factor has been applied, which corresponds to the human ear’s response to sound across the range of audible frequencies. The ear is most sensitive in the middle range of frequencies (around 1000-3000 Hz), and less sensitive at lower and higher frequencies. The A weighted noise level is derived by analysing the level of a sound at a range of frequencies and applying a specific correction factor for each frequency before calculating the overall level. In practice this is carried out automatically within noise measuring equipment by the use of electronic filters, which adjust the frequency response of the instrument to mimic that of the ear. Frequency: The frequency of a sound is equivalent to its pitch in musical terms. The units of frequency are Hertz (Hz), which represents the number of cycles (vibrations) per second.

Arcus Consultancy Services Erskine Generation Ltd September 2017 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

LA90,t: This term is used to represent the A-weighted sound pressure level that is exceeded for 90% of a period of time, t. This is used as a measure of the background noise level.

LAeq,t: This term is known as the A-weighted equivalent continuous sound pressure level for a period of time, t. It is similar to an average, and represents the sound pressure level of a steady sound that has, over a given period, the same energy as the fluctuating sound in question.

LAFmax: The maximum A-weighted sound pressure level measured over a given period, with a fast time weighting. Noise: Unwanted sound. May refer to both natural (e.g. wind, birdsong etc.) and artificial sounds (traffic, industrial noise, aircraft etc.). Rating Level: Sound levels which have been corrected for certain acoustic features, as required under BS4142 methodology. Sound pressure (P): The fluctuations in pressure relative to atmospheric pressure, measured in Pascals (Pa).

Sound pressure level (Lp): Sound pressure measured on the decibel scale, relative to a sound pressure of 2 x 10-5 Pa. Specific Level: In terms of BS4142 methodology, the specific level is the sound level produced by a source, without corrections for acoustic features. Time Weighting: Time weightings determine how quickly the sound level meter responds to changes in noise level, and is generally set to ‘Fast’ or ‘Slow’. A fast time weighting resulting in in the sound level meter sampling every 1/8th second: a slow time weighting results in a sample measurement being taken by the sound level meter every 1 second.

Erskine Generation Ltd Arcus Consultancy Services September 2017 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

APPENDIX 1 – DEVELOPMENT LAYOUT

Erskine Generation Ltd Arcus Consultancy Services August 2017 N PLANNING APPLICATION BOUNDARY (0.50 Ha)

6m HIGH SECURITY COLUMN

TRANSFORMER UNIT GAS SKID (INCLUDING KIOSK BUILDING 9.00m x 7.00m x 3.80m 4.20m x 3.0mx 2.60m) OVERALL AREA/SIZE 12.20m x 5.30m x 2.60m

SUBSURFACE RAINWATER HARVESTING TANK WITH SERVICE CHAMBER 6m HIGH SECURITY COLUMN

OLD GREENOCK ROAD PALISADE FENCE

HV/LV SWITCH 3.0m HIGH ROOM

OLD GREENOCK ROAD 1

DNO HV ROOM 2 6m HIGH SECURITY COLUMN Electricity Distribution Site 3 4

Shilton Plantation 5 CAR PARKING x 3 OPTION 6 FB (BAY SIZE 6.00m x 2.50m) 7 M 898 8 TURNING AREA 9

ETL Craigton INTERCOOLER EQUIPMENT 10 INSTALLED ON TOP OF CONTAINER (MAX HEIGHT 6.25m) ENGINE UNIT TRANSFORMER 2.80m x 2.80m x 3.80m

M898

Ward Bdy (5 No. 1 PER 2 GAS ENGINE UNITS)

Track

Ruin 28.1m

SCALE - 1:5,000 M 898 SCALE - 1:500

Pond Purpose of issue Project Title Drawing Title PLANNING THISDOCUMENT HAS BEEN PREPARED ACCORDANCEIN WITH THE SCOPE OF ARCUS' ERSKINE Arcus Consultancy Services Designed Drawn Checked Approved APPOINTMENTWITH CLIENTITS AND SUBJECT IS TO THE TERMS OF THAT APPOINTMENT. 7th Floor GAS PEAKING SITE ARCUSACCEPTS NO LIABILITYFOR ANY USE OF THISDOCUMENT OTHER THAN BYITS PROPOSED DB DB RM SD CLIENTAND ONLY FOR THE PURPOSES FOR WHICH WAS IT PREPARED AND PROVIDED 145 St. Vincent Street Glasgow, G2 5JF 31 August 2017 15:12:32 P:\PROJECTS\2817 ERSKINE GAS PEAKING PLANT\CAD\01-WORKING\01_01-DRAWINGS\2817-DR-P-0001-P9 Arcus Internal Project No. Date SITE LAYOUT PLAN Tel: +44 (0)141 221 9997 Client 2817 Rev 28/08/2017 Drawing Number Scale @ A3 Fax: +44 (0)141 221 5610 ERSKINE GENERATION LIMITED 2817-DR-PLA-0001 9 www.arcusconsulting.co.uk AS SHOWN Plot Date : File Name : Reproduced from Ordnance Survey digital map data © Crown copyright 2017. All rights reserved. License number 100048606 Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

APPENDIX 2 – SURVEY RECORD SHEETS

Arcus Consultancy Services Erskine Generation Ltd August 2017 Noise Survey Record Sheet – Page 1: Location and Equipment Details

Project No. 2817 Project Name: Erskine Location (x of y) 1 Installed By: MR Lat/Long 55.90529, -4.48732 Location Name Old Greenock Road Start Date 04/07/2017 Start Time 1600

Equipment Details Make/Model Serial No. Sound Level Meter: Rion NL-52 510114 Calibrator: Rion NC-74 34372738 Source of Equipment: Arcus Meter Timestamp (Start/End, GMT/BST): Start BST

Description of Location: grass verge opposite houses

Distance from façade:: Free-field

Noise sources observed: traffic, vegetation

Weather conditions dry, overcast, breezy

Additional notes:

th Arcus Consultancy Services 7 Floor, 145 St. Vincent Street, Glasgow, G2 5JF T +44 (0)141 221 9997 l E [email protected] l w www.arcusconsulting.co.uk Registered in England & Wales No. 5644976 Noise Survey Record Sheet – Page 2: Visit Record

Project No. 2817 Location (x of y) 1

Installation (Visit 1)

Date: 04/07/2017 Time: 1600 Filename: AU2_0101 Calibration level: 94 Range setting: 20-120 Meas. period: 15min Freq weighting: A Weather station? No Lp Logging No Audio/ 8ve bands? No Notes:

Visit 2

Date: 09/08/2017 Time: 0 Visited by: MR Calibration level: 94 Level pre-calibration 93.6 Batts replaced? 0 Equipment Removed? Yes Notes: mainly road noise

Project No. 2817 Location (x of y) 1

Paste Image Right-Click Format Picture Size Width = 6cm

Project No. 2818 Project Name: Erskine Location (x of y) 2 Installed By: MR Lat/Long 55.90399, -4.4804 Location Name Shilton Cottage Start Date 09/08/2017 Start Time 1530

Equipment Details Make/Model Serial No. Sound Level Meter: Rion NL-52 510131 Calibrator: Rion NC-74 34104515 Source of Equipment: Arcus Meter Timestamp (Start/End, GMT/BST): Start BST

Description of Location: corner of patio

Distance from façade:: 3m

Noise sources observed: traffic, trees, birds

Weather conditions sunny

Additional notes:

Project No. 2818 Location (x of y) 2

Installation (Visit 1)

Date: 09/08/2017 Time: 1530 Filename: AU2_0101 Calibration level: 94 Range setting: 20-120 Meas. period: 15min Freq weighting: A Weather station? No Lp Logging No Audio/ 8ve bands? No Notes:

Visit 2

Date: 14/08/2017 Time: 1509 Visited by: kl Calibration level: 94 Level pre-calibration 94 Batts replaced? No Equipment Removed? Yes Notes:

Project No. 2818 Location (x of y) 2

th Arcus Consultancy Services 7 Floor, 145 St. Vincent Street, Glasgow, G2 5JF T +44 (0)141 221 9997 l E [email protected] l w www.arcusconsulting.co.uk Registered in England & Wales No. 5644976

Noise Impact Assessment Small-Scale Gas Peaking Plant - Erskine

APPENDIX 3 – NOISE MAP

Erskine Generation Ltd Arcus Consultancy Services August 2017

Planning Statement Erskine Gas Peaking Plant

Land adjacent to Old Greenock Road and M8 Junction 30, Renfrewshire

September 2017

Applicant Erskine Generation Ltd

TABLE OF CONTENTS

1 Introduction ...... 5

1.1 APPLICANT ...... 5 1.2 FORMAT OF PLANNING STATEMENT...... 5 2 Need and Benefits of Development ...... 6

2.1 ELECTRICITY MARKET REFORM ...... 6 2.1.1 The Capacity Market ...... 6 2.2 BENEFITS OF THE DEVELOPMENT ...... 7 2.2.1 Employment Benefits ...... 7 2.2.2 Sustainable Grid Management ...... 7 2.2.3 Clean and Efficient Energy Source ...... 8 3 Site Description ...... 9

3.1 SITE SELECTION ...... 9 3.2 CURRENT LAND USE ...... 9 3.3 HISTORIC LAND USE ...... 10 3.4 SITE PLANNING HISTORY ...... 10 4 Development Proposals...... 11

4.1 PLANNING APPLICATION SUBMISSION ...... 11 4.2 DEVELOPMENT DESCRIPTION ...... 11 4.3 ACCESS AND TRAFFIC ...... 12 4.3.1 Construction ...... 12 4.3.2 Operations ...... 13 4.4 CONSTRUCTION DURATION AND ESTIMATED EMPLOYMENT ...... 13 4.5 CONSTRUCTION HOURS ...... 13 4.6 OPERATIONS ...... 13 5 Development Plan Policy Framework ...... 14

5.1 INTRODUCTION ...... 14 5.2 GLASGOW AND THE CLYDE VALLEY STRATEGIC DEVELOPMENT PLAN 2012 ...... 14 5.3 RENFREWSHIRE LOCAL DEVELOPMENT PLAN ...... 15 5.3.1 ENV1 Green Belt ...... 15 5.3.2 ENV2 Natural Heritage ...... 17 5.3.3 ENV3 Built Heritage ...... 18 5.3.4 ENV4 The Water Environment ...... 18 5.3.5 I5 Flooding and Drainage ...... 19 5.3.6 ENV5 Air Quality ...... 19 5.4 ENVIRONMENTAL CONSIDERATIONS ...... 20 5.4.1 Landscape and Visual ...... 20 5.4.2 Hydrology and Flood Risk ...... 20 5.4.3 Ecology and Habitat ...... 21 5.4.4 Historic Environment ...... 21 5.4.5 Noise ...... 21 5.4.6 Air Quality ...... 21 5.4.7 Access, Transport and Traffic ...... 22 5.4.8 Public Rights of Way ...... 22 5.4.9 Existing Infrastructure ...... 22 6 Relevant Material Considerations ...... 23

6.1 NATIONAL PLANNING FRAMEWORK 3 ...... 23

Issue: 01 1

6.2 SCOTTISH PLANNING POLICY ...... 23 7 Conclusion ...... 25

Issue: 01 2

Executive Summary

Erskine Generation Limited (“the Applicant”) proposes to construct a small scale gas-fired energy reserve facility “gas peaking plant” (the “Development”) for the generation of electricity to provide a backup supply to the National Grid. The Development will be located on land opposite the Scottish Power Energy Networks (SPEN) Erskine Substation and adjacent to Junction 30 of the M8 Motorway, being situated between Old Greenock Road and the M898 slip road. The proposed Development site is currently used for grazing.

The proposed development, which will be operational for up to 40 years, will consist of ten modern, highly efficient gas generators within acoustically controlled containerised units and ancillary equipment comprising a control building, transformer units, gas meter, ancillary plant, parking spaces, perimeter fence and security columns.

The application for planning permission, accompanied by this Planning Statement, is being made under the Town and Country Planning (Scotland) Act 1997 (as amended by the Planning etc. (Scotland) Act 2006 to Renfrewshire Council.

The plant is being developed in response to the UK Government’s reform of the UK electricity market and specifically their identified aim of supporting the deployment of renewable energy development by ensuring the grid network has sufficient flexible generation capacity to meet demand during peak times. The Capacity Market has been created as a result of the need to balance the grid using local sources that can react at short notice to deliver electricity to the network. Gas peaking plants, using natural gas as a clean fuel, are generally used at times of ‘stress’ on the network and by offering this balancing mechanism provide the last line of defence to prevent serious fluctuations and blackouts. The Erskine Gas Peaking Plant will therefore only operate for a limited number of hours a week, on request from National Grid.

The proposed development will provide the following benefits:  19.9MW gas peaking plant capacity providing vital support to the national electricity grid network by providing on-demand back up to any grid destabilisation;  Connecting to the local electricity distribution network will improve the local security of supply in the local area; and  The flexible, reserve generation will support the further development of intermittent renewable generation.  Access, Transport and Traffic;  Public Rights of Way.

The locational requirements of gas peaking plants are very specific in that they require to be located close to a suitable point of connection to the national grid i.e. a substation with sufficient available capacity and appropriate voltage and a gas supply with suitable pressure. The site selection process therefore concentrated on identifying suitable areas of land close to these key infrastructure components. Having identified Erskine Substation as having sufficient capacity for a plant of this nature further assessment identified a gas pipeline of suitable, intermediate pressure within Old Greenock Road immediately adjacent to the site as well as sufficient land available in the vicinity. Identifying sites

Issue: 01 3

suitable for development of this nature is rare there is therefore a strong argument supporting the Development at this location.

This Planning Statement is intended to provide the Council with sufficient information to allow determination of the planning application. The Development has been assessed against the relevant planning policies and the clear locational need, surrounding landuse and limited development area all justify the Development within Green Belt. The proposed development is considered to comply with the relevant heritage, environmental and amenity considerations and overall it is considered that the application site is suitable with regard to locational requirements. In addition, it is considered that the visual impact of the development on the site and its surroundings is acceptable.

Issue: 01 4

1 Introduction

This Planning Statement has been prepared to accompany an application for planning consent to Renfrewshire Council for the construction and operation of a gas peaking plant. The Erskine Gas Peaking Plant is on land opposite the Scottish Power Energy Network’s (SPEN) Erskine Substation, west of Old Greenock Road and east of the M8 Motorway, being immediately north of Junction 30 of the M8.

The development will have a maximum electricity generating capacity of 19.9MW from containerised gas engines. The location of the site, close to the national electricity and gas networks is of key importance in maximising the efficiency of the gas engines. The Development will be designed to operate intermittently as instructed by National Grid in order to supply electricity during peak or strained times.

1.1 Applicant The applicant is Erskine Generation Limited a wholly owned subsidiary of Forsa Energy CM Holdings Ltd based in Greenock, Inverclyde.

1.2 Format of Planning Statement The Planning Statement comprises the following:

Section 2 Need and Benefits of Development Section 3 Site Description Section 4 Development Proposals Section 5 Development Plan Policy Framework Section 6 Relevant Material Considerations Section 7 Conclusion

Issue: 01 5

2 Need and Benefits of Development The Development is being brought forward as a result of changes to the UK electricity market outlined below.

2.1 Electricity Market Reform The UK’s electricity supply is undergoing a transition from traditional, ageing, large scale, centrally managed base load thermal (most commonly coal) plants to low carbon sources such as renewables, natural gas and new nuclear. As part of this transition there is a requirement for smaller, more flexible “on demand” plants, such as the Erskine Gas Peaking Plant. The development is therefore being proposed in response to the need to guarantee security of electricity supply and prevent future blackouts, particularly during busy periods of peak demand. The proposed Development represents a part of the estimated £100 billion capital investment needed in the UK to meet the projected increases in electricity demand over the next decade.

Electricity Market Reform is a UK government policy designed to:

 Incentivise investment in secure, low carbon electricity;  Improve the security of Great Britain’s electricity supply; and  Improve affordability for consumers.

Over the past decade renewable energy developments have accounted for the biggest increase in new capacity in the UK. Whilst the deployment of renewables is positive in terms of de-centralisation of supply and a reduction in greenhouse gas emissions, it presents challenges in relation to intermittency of supply. The electricity generation from renewable sources does not always tie in with the times of peak demand. To ensure that the grid network has sufficient capacity to meet demand during peak times there is therefore a need to fill the gap in generation with a flexible source that can react at short notice to deliver electricity to the network - whilst keeping the cost to the consumer low.

The proposed Development contributes to balancing the network by filling this gap. It is intended that the scheme will compete in the 2018 Capacity Market Auction (outlined in Section 2.1.1) to secure a contract to provide electricity to the grid at times when it is most needed and would ultimately be required to respond almost instantly to any request from National Grid to start generating.

2.1.1 The Capacity Market The government has established the Capacity Market (CM) as part of its Electricity Market Reform policy. It is intended to incentivise investment in more sustainable, flexible, low- carbon electricity capacity at the least cost for energy consumers. This is needed to help secure electricity supplies for the future. The aim of the capacity market is therefore to efficiently bring forward new investment while maximising current generation capabilities

Issue: 01 6

and to balance the difference between demand and supply. The Capacity Market Auction is the competitive process to award Capacity Market Agreements to meet the target capacity for the relevant Delivery Year. Only generators (known as Capacity Market Units (CMUs)) which have successfully prequalified will be able to take part in the auction process.

In order to qualify to enter the auction process sites must have secured planning consent. The timeframe to determine the planning application has direct implications on meeting the auction deadlines and to enable entry into the 2018 auction the applicant is therefore seeking a determination from Renfrewshire Council no later than 1st December 2017.

2.2 Benefits of the Development

2.2.1 Employment Benefits The proposed development will result in contract opportunities for local and regional contractors both directly, during construction, and indirectly through the supply chain.

Construction contracts will be placed for services and materials, which will be subject to competitive tendering, with a preference to appoint local contractors where possible. Contracting opportunities include:

 Construction o Accommodation; o Earth excavation works; o Fencing; o Plant; o Haulage; o Landscape and Renovation; o Civil Engineering; and o Surveying etc.  Operations and Maintenance o Plant maintenance; o Facilities Management; o Security etc.

2.2.2 Sustainable Grid Management As outlined above the Development will supply instant, on demand electricity to the National Grid. The generators are very flexible and can be turned on almost instantly, as required by National Grid’s balancing services. Such rapid response is offered by very few other forms of power generation. Developments such as these are increasingly required throughout the grid network and play an important and strategic role in supporting the growth of renewable energy generation by ensuring the UK’s national electricity supplies are operated and managed in a sustainable, long term manner.

Issue: 01 7

2.2.3 Clean and Efficient Energy Source The gas generators will be fuelled by low carbon natural gas. This fuel is considered to be very clean, resulting in no smoke and negligible emissions of nitrous oxides (NOₓ), carbon monoxide (CO) and particulates and no emissions of sulphur oxides (SOx). The gas is supplied to the application site through the regular, national and local gas distribution network located nearby.

Issue: 01 8

3 Site Description 3.1 Site Selection

A site selection exercise has been carried out to identify suitable development sites. The key requirement during this process was the identification of a suitable connection point on the local distribution network connecting to the national grid. A review of the Scottish grid network was undertaken by the applicant in order to identify substations with sufficient capacity to accommodate gas peaking plants between 10 and 50MW. SPEN’s Erskine Substation was identified as offering sufficient capacity, and correct voltage, to accommodate a 19.9MW generator and was therefore subject to further investigation.

Further investigation showed sufficient and suitable land available next to the substation and a nearby suitable gas pipe within Old Greenock Road, adjacent to the site, providing gas at the required, intermediate, pressure. An offer from SGN to supply gas to the site has been received. A sufficient gas supply can therefore be obtained to supply the appropriate quantity of gas at short notice without affecting the supply to other customers on the network. The proposed site, close to the existing substation, will allow connection by an underground cable.

It should be noted that the Scotland wide site search has shown that identification of available sites close to a good local gas supply and an appropriate gas connection is relatively uncommon and in most instances sites will need either the gas or electricity supply to be extended.

The site has been identified as a suitable location based on:

 Proximity to existing 33kV substation with sufficient capacity;  Proximity to the gas network (at sufficient pressure);  Availability of suitable, relatively level land;  Good access direct from the Old Greenock Road;  Proximity to existing infrastructure – Erskine Substation, electricity pylons and a large motorway junction;  Low visibility and a degree of existing screening;  Distance from nearest designated ecological or archaeological sites; and  Distance to nearest houses.

3.2 Current Land Use The site is located within an area of agricultural land between the SPEN Erskine Substation on Old Greenock Road and the M898 slip road at Junction 30 of the M8. The Site is currently used as agricultural grazing land. Land immediately east and north of the site is crossed by electricity pylons associated with the Erskine Substation. There is a degree of existing screening, provided by trees and the motorway itself, between the site and the transport corridors which surround it.

Issue: 01 9

Further north of the site is the larger Shilton Plantation, which provides more extensive screening of views of the site from the north. The M8 and M898 provide a separation between the site and the more distant settlements of Bishopton and Erskine respectively. Whilst located within an area of farmland, the site is within an area that has clearly been influenced by infrastructure development.

The site is relatively flat, with elevation ranging between 20 m and 25 m Above Ordnance Datum (AOD).

3.3 Historic Land Use No previous uses of the land other than for agricultural purposes have been identified. The M8 motorway was constructed to the southeast of the site in the 1960s and forms a distinct boundary to this part of the site.

The construction of the motorway and the use as an agricultural site are considered to be extent of the recent historical use of the site.

Whilst it has some value as agricultural land for grazing of livestock, this is limited to grazing land, and the site is not considered to be prime agricultural land. The design of the proposed development, following existing field boundaries, will allow the majority of the field in which it is located to continue in its current use.

3.4 Site Planning History A search of Renfrewshire Council’s online planning portal has shown that there are no live or historic planning applications within the proposed site.

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4 Development Proposals 4.1 Planning Application Submission Planning Consent is being sought for a gas peaking plant facility with a maximum operational capacity of 19.9MW. The total application area is 0.43 ha. The development will be operational for 40 years.

Consent is being sought for a gas peaking plant consisting of: 10 x gas generators each comprising a containerised turbine unit, inter cooler equipment and emission stack; and associated infrastructure consisting of a control building, transformer unit, gas skid (comprising gas meter and control), ancillary plant, parking facilities and security columns.

The following drawings have been submitted alongside the application via e-planning:  Planning Drawing 001 – Site Location Plan  Planning Drawing 002 - Site Layout  Planning Drawing 003 – Containerised Gas Engine Unit Elevations  Planning Drawing 004 – Control Building Layout and Elevations  Planning Drawing 005 – Gas Meter  Planning Drawing 006 – Transformer Plan and Elevations  Planning Drawing 007 – Ancillary Plant and Engine Unit Transformer Plan and Elevations  Planning Drawing 008 – Palisade Fence and Gate Access Detail  Planning Drawing 009 – Security Column Detail

The following documents have been submitted alongside the application via e-planning:  Air Quality Report  Noise Report

4.2 Development Description

The proposed development will comprise 10 containerised, modern and highly efficient engine units, and ancillary infrastructure a shown on Planning Drawing 002 and detailed in Table 1 below.

The development will comply with the use of appropriate Sustainable Urban Drainage Systems (SUDS), to limit and control the rate of surface water run-off.

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Equipment Length Width Height No. Description Function Containerised Containerised units within To provide visual and noise Engine Unit 15 3.6 3.7 10 the site containment of gas engines Highest elements of the development comprising To provide dispersion and cylindrical steel exhaust dilution of the residual gas Emission Stacks n/a n/a 7 10 flues combustion emissions Cooling Radiators On top of each To provide a cooling system Unit - - - 10 containerised unit for the gas engine units Includes welfare facilities, store room, control room, High and Low (HV/LV) switch room and the HV Control Building 25.40 5.96 3.5 1 Low level building room. Small element of ancillary To pre-treat natural gas Gas Skid (including plant including gas meter, prior to injecting into kiosk) 12.2 5.3 2.6 1 housed in a simple kiosk engines Low level ancillary component to house the The transformer transfers Transformer Unit 9 7 3.8 1 transformer unit electrical energy Low level ancillary Engine Unit component to house the The transformer transfers Transformer 2.8 2.8 3.8 5 transformer unit electrical energy Storage of consumables & Ancillary Plant 5.8 3 2.6 Small low level building spare parts Provide a secure fence to the site and to provide noise Perimeter fence - - 3.0 - Noise attenuation fence attenuation. Parking for maintenance Car Parking 5 2.5 - 3 Allocated Parking Spaces staff Table 1: Development Components

4.3 Access and Traffic 4.3.1 Construction The proposed development is situated off Old Greenock Road, which readily connects to the M898 and M8 motorway. Access to the development will utilise an existing field access, which will be upgraded as shown on Planning Drawing 002. The road network is deemed capable of accommodating the increase in vehicle movements associated with the short term construction phase of the proposed development which is anticipated to last approximately 6-9 months.

The maximum number of Heavy Good Vehicle (HGV) deliveries in any one day will be 20 and will be confined to the early earthworks / civils phase of the project, typically 4 weeks. For the majority of the works duration the number of HGV deliveries will be below ten. The

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number of abnormal loads will ultimately depend on the final configuration of the engines but will be limited in number.

Once delivered equipment will be stored in a construction laydown area until it is required within the construction site, however much of the equipment will arrive pre-assembled to be installed directly on arrival.

4.3.2 Operations The gas fuel source will be provided by a direct connection into the local gas pipe network therefore no fuel delivery or storage will be required. The generating equipment will be remotely controlled and routine maintenance will typically consist of one visit per week and one annual service.

4.4 Construction Duration and Estimated Employment The construction period is anticipated to last 6-9 months with an average workforce of up to 12 personnel, although this may peak briefly at 20 personnel for particular milestones during the construction period.

4.5 Construction Hours Construction hours will be:  Monday to Friday – 7am to 6pm  Saturdays – 9am to 1pm

Works will not take place on Sundays, bank holidays or after 13.00 on a Saturday unless such work is associated with an emergency or with the prior written consent of the local authority.

4.6 Operations Operations of the peaking plant will be co-ordinated with National Grid and will typically be switched off, waiting for instruction to power-up. These instructions could come as a result of system instability or peaks in demand which would require generation support from the facility for between 1-7 hours per day, between 6am – 8pm, typically on weekdays.

Outside of these hours, such as during a major power shortage or system stress events, National Grid may require the facility to step-in and support in an emergency situation. Events such as these are extremely rare.

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5 Development Plan Policy Framework

5.1 Introduction This section assesses the proposal against the relevant Development Plan policies. In this case the Development Plan is made up of:

 Glasgow and the Clyde Valley Strategic development Plan (Adopted 2012) (SDP);  Renfrewshire Local Development Plan (LDP) (adopted August 2014); and  Renfrewshire Local Development Plan – New Development Supplementary Guidance (adopted November 2014) (New Development SG).

The LDP sets out the Council’s strategy, policies and proposals for the use of land and buildings within Renfrewshire, and, together with the SDP, is the document the Council uses to determine planning applications and provide advice on development proposals. The LDP recognises where the main areas of change should be and includes policies and proposals which provide the framework upon which all planning applications can be determined. It provides guidance to developers, investors and all other stakeholders, including the general public.

Section 25 of the Town and Country Planning (Scotland) Act 1997 (as Amended) requires that applications for planning permission are determined in accordance with the development plan, unless material considerations indicate otherwise.

The application for planning permission, accompanied by this Planning Statement is being made under the Town and Country Planning (Scotland) Act 1997 (as amended by the Planning etc. (Scotland) Act 2006) to Renfrewshire Council.

The Development is a ‘local development’ in terms of The Town and Country Planning (Hierarchy of Developments) (Scotland) Regulations 2009 which sets the following applicable threshold ‘construction of an electricity generating station’, ‘The capacity of the generating station is or exceeds 20MW’, for ‘major’ development. As this application is seeking permission for a peaking power plant with a maximum capacity of 19.9 MW it is classed as a local development.

5.2 Glasgow and the Clyde Valley Strategic development Plan 2012 The SDP sets out the long-term strategic direction for Glasgow and the Clyde Valley, and is designed to deliver economic growth, shape high quality places and enhance the quality of life within the region.

Whilst there are no site specific plans or policies relating to Gas Peaking Plants in the SDP, it does contain an overarching policy relating to energy, stating “as an adjunct to centralised generation, decentralised distributed power plants, based on alternative technologies, will be located across the city-region exploiting opportunities to develop biomass, combined heat and power and other forms of renewable energy. In the long term,

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the balance should shift from decarbonised centralised energy from the National Grid to decentralised energy generation based on alternative renewable sources.”

Policy Analysis The proposed development, by its very nature, would provide a reliable, decentralised source of electricity generation. Although not renewable energy, the proposed development compliments the deployment of renewable energy across the Region by being able to be called upon to provide electricity to the grid when renewable sources are unable to meet electricity demand e.g. at times when there is not sufficient wind. The proposed development would only be operational during such periods, being shut down when not required. In decentralising generation and providing security of supply, complementing the deployment of renewables, and offering economic opportunities, it is considered that the proposed development complies with the overarching principles of this policy.

5.3 Renfrewshire Local Development Plan

The LDP does not allocate the application site for any specific use; however, the application site is designated as Green Belt (ENV1). There are no specific policies in the LDP regarding gas peaking plants, although Policy ENV1, along with other key policies relevant to the proposed development, are set out below:

5.3.1 ENV1 Green Belt This policy sets out the aims of the Green Belt, stating that it is not to restrict appropriate development, but to direct development and the use of land to locations that will support sustainable growth, development and regeneration. Appropriate development within the green belt will be considered acceptable where it can be demonstrated that it is compatible with the provisions of the New Development SG. Support will be given to developments that are able to demonstrate diversification within green belt and rural areas which promote new employment opportunities and / or community benefits. The New development SG states that the green belt designation is not in place to prevent development from happening, but is to maintain the identity of settlements with a clear definition of their physical boundaries as well as their landscape setting, preventing coalescence. The green belt is intended to direct planned growth to appropriate areas. The New Development SG details a number of development types which are considered to be appropriate in principle within the green belt. This includes:  Essential infrastructure where it is demonstrated that a green belt location is required for walking, cycling, public transport or road networks, or for other communications infrastructure such as electricity or telecoms equipment

It further sets out a number of criteria which development proposals will be assessed against, including:  No loss of prime quality agricultural land or land or lesser quality that is locally important;  Traffic and access infrastructure can be sensitively accommodated;

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 No significant effects on public water supply and water courses from any pollution risk;  Appropriate proposals to protect and provide access to open space have been incorporated;  Development layout will respect important local landscape features, incorporating them into the design;  It can be demonstrated that there is careful consideration of the design, scale and grouping of any buildings;  Appropriate landscaping proposals have been incorporated;  There are adequate services available for the development; and  There is no significant detrimental effect on identified nature conservation interests, including species and habitats.

Policy Assessment One of the key characteristics of green belt is openness and the maintenance of separation between settlements. This is often considered to be an absence of built form within the green belt. In the case of the development site, its location adjacent to the motorway and associated infrastructure, along with the adjacent electricity pylons and substation, provide an existing infrastructure context, and whilst not within a built up area, is not free of built form. The existing screening afforded by the motorway and existing screening to the south of the site will limit the visibility of the development and minimise its visual impact. Taken together these factors reduce the influence that the development will have on the openness of the green belt at this location. The criteria set out in the New Development SG for new development in the green belt are considered in turn below:  Although used for grazing, the development site is not prime agricultural land, nor is it considered to be locally important and is of limited area 0.43ha;  The location of the development results in good links to the motorway network, and access to the development via Old Greenock Road makes use of the existing road network. This would limit the requirement for vehicles accessing the development during construction or operation to travel through any built up areas between the site and the motorway network;  The development is located away from watercourses, with no watercourse crossings required, and poses no risk of the pollution of watercourses or supply. Regardless, good practice pollution prevention measures would be employed during construction and operation;  The development site is within an area not currently accessed by the public, and it is unlikely that there would be any requirement or desire for public access to the development should it proceed. There is an existing core path following the pavement on the north eastern side of Old Greenock Road. The development will not affect access to this route;  The proposed development is located within a single field and makes use of the existing access to this field from Old Greenock Road. The layout follows the existing field boundary, utilising the existing planting to provide screening where this is present;  The design of the development is dictated to a degree by its function. However, the layout of the elements of the development has been undertaken to minimise the its footprint and to respond to the existing field pattern;

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 The development makes use of the existing landscaping at the site in the form of mature field boundaries and the motorway infrastructure where these are present. The requirement for further landscaping is therefore not considered to be necessary;  The location of the development has been chosen by virtue of its proximity to the Erskine Substation to minimise the grid transmission infrastructure required. It has also been selected for its proximity to the existing gas and road networks, resulting it in utilising the existing services in the area; and  The proposed development will not have any effects on any identified nature conservation interests, habitats or species.

There is a specific locational requirement for this development, close to an appropriate point of connection to the national electricity grid and appropriate gas supply point. This grid connection is provided by the Erskine Substation and the adjacent, intermediate gas supply within Old Greenock Rod.

The proposed Development will deliver both local and national needs. A site such as Erskine - close to both gas and electricity networks capable of accommodating the proposal – is a rare occurrence and as such the opportunities the site presents in delivering this required infrastructure are exceptional.

Whilst it is acknowledged that the proposed development will introduce a degree of built form into the green belt, which has the potential to reduce the openness, the location of the site in this part of the green belt is such that the effect will be very limited. The location makes use of existing infrastructure already located in this part of the green belt, and there would be no effect of coalescence between the settlements of Erskine and Bishopton. The existing infrastructure surrounding the development site, including the motorway and substation, provides context to the location of the site and affords a separation from the surrounding areas of green belt. The proposed development would not undermine the core principles of the green belt.

The development is required to be close to existing electrical and gas infrastructure, at the same time as maintaining appropriate separation distances from residential areas to protect amenity. The potential to locate the development in an already built-up area is therefore limited. The importance and contribution of the development to the security of electricity supply means that it should be considered to be essential electricity infrastructure.

Taking all of the above into account, considering the proposed development against Policy ENV1 and the relevant provisions of the New Development SG, it is considered that the development does accord with Policy ENV1 and constitutes appropriate development within the green belt at this location.

5.3.2 ENV2 Natural Heritage This policy makes it clear that new developments must not affect the integrity of sites protected for their natural conservation interest or which have the potential to protect and enhance designated sites and the wider biodiversity and geodiversity of the area. This

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includes cumulative effects arising from a proposed development. Where a development does affect a designated site it will be assessed against criteria set out in the New Development SG.

Policy Assessment No local, national or international designations relating to natural conservation interest are present on the site or in the immediate area. The Inner Clyde Special Protection Area (SPA), Site of Special Scientific Interest (SSSI) and Ramsar site is the closest nationally or internationally designated nature conservation site, being located adjacent to the River Clyde, approximately 2 km to the northeast of the development. These are designated on account of their saltmarsh coastland habitats and assemblages of wintering birds. Given the separation distance and the lack of connectivity between the site and these designated areas, no effects are anticipated on them as a result of the development. The proposed development is considered to comply with PolicyENV2.

5.3.3 ENV3 Built Heritage This policy sets out that the built heritage will be safeguarded, conserved and enhanced, where appropriate. Developments that are within or close to built heritage assets will be required to demonstrate that they will have no negative impact upon it and are in accordance with the provisions set out in the New Development SG.

Policy Assessment There are no buildings or sites within the development site that are designated for their built heritage or archaeological value, and no listed buildings are located within 1 km of the site. A scheduled monument at Dumcross Enclosure is located approximately 500 m northwest of the site. There would be no visibility of the development from the scheduled monument as there is existing screening between the two. There would therefore be no effect on the scheduled monument. The proposed development is considered to comply with Policy ENV3.

5.3.4 ENV4 The Water Environment This policy sets out that the council will support new development which encourages protection of the existing water environment as well as improvements to the control and management of water along with the enhancement of biodiversity, flora and fauna surrounding blue corridors.

Policy Assessment Based on SEPA’s online flood risk maps, there are no areas identified as being at risk of river or surface water flooding. Craigton Burn is the closest named watercourse, being located approximately 100 m to the northwest of the site boundary. No watercourse crossings are required to accommodate the development. The proposed development will not adversely affect the existing water environment. It is not located within an area identified as being at risk of flooding and will not result in a risk of flooding at the application site or elsewhere in the area.

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5.3.5 I5 Flooding and Drainage This policy sets out that new development should avoid areas susceptible to flooding and will be required to demonstrate the provision of sustainable flood risk management measures through the implementation of sustainable urban drainage systems (SUDS). Where necessary, applications may be required to provide a flood risk assessment.

Policy Assessment As set out in consideration of Policy ENV4, the proposed development is not within an area at risk of flooding and is not considered likely to result in a risk of flooding at the application site or in the wider area. The site selection, in avoiding areas at risk of flooding, complies with the first part of this policy. SUDS will form an integral part of the site design, satisfying the second part of this policy. As the site is not within an area at risk of flooding and will utilise SUDS, it is considered to comply with policy I5. In line with policy I5 there is no requirement for a detailed flood risk assessment to be undertaken for the proposal.

5.3.6 ENV5 Air Quality This policy sets out that development proposals should not have an adverse effect on air quality and that where required, applications should be accompanied by an air quality assessment that demonstrates the effects on air quality and how these will be mitigated. New development will be required to be in accordance with the provisions of the New Development SG.

Policy Assessment As the proposed development will produce electricity through the combustion of natural gas, there is a requirement to consider the potential air quality impacts of the development. An air quality assessment has been undertaken has been carried out by Arcus Consultancy Services and the report is submitted in support of this application (Air Quality Impact Assessment Small-Scale Gas Peaking Plant – Erskine).

The development will be able to respond instantly to demand from the grid network to ensure that reliable electricity is generated at the times it is most needed, and when the demand cannot be met by existing conventional or renewable sources of generation. At times when these do meet demand, the development will not be required to operate and will not result in any emissions.

The Air Quality Assessment carried out by Arcus Consultancy Services (Air Quality Impact Assessment Small-Scale Gas Peaking Plant – Erskine) assesses the proposed development in accordance with the Air Quality (Scotland) Regulations 2010, which set out that:  The 1 hour mean concentration of NO2 must not exceed 200 ug/m3 (the short- term Environmental Assessment Level) more than 18 times a year: and  The annual mean concentration of NO2 must not exceed 40 ug/m3.

The proposed development comfortably complies with these limits, and is also compliant with the Medium Combustion Plant Directive specification for new gas engines commissioning after December 2018, putting it ahead of current industry standards in

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terms of emissions. In Pollution Prevention Control terminology, the proposal is consistent with Best Available Technology.

Given the nature of the proposed developments, some emissions to air are inevitable. However, the site has been selected to an appropriate distance from receptors and the design utilises the best available technology to ensure emissions are limited and comply with both current and future guidelines. It is considered therefore, that the proposed development is compliant with Policy ENV5.

5.4 Environmental Considerations

The following provides a consideration of the development in relation to a range of environmental criteria. Some of these overlap with the Development Plan Policies set out in the preceding sections, although the following provides a more general overview in relation to environmental considerations.

5.4.1 Landscape and Visual The application site is not afforded any protection under statutory landscape designations, such as National Parks or National Scenic Areas, nor does it fall within a Special Landscape Area. The development site is located adjacent to Junction 30 of the M8 Motorway and is opposite the Erskine Substation. To the east of the development site, electricity pylons and cables from the Erskine Substation cross the M898 Motorway. The development site itself is used as a grazing field and is generally bordered by trees and hedgerow, although these are sporadic in places.

Whilst the development site occupies a rural location, it is seen in the context of existing infrastructure development and is not within an area of the countryside protected for its landscape or visual characteristics, nor is it an area commonly used as a recreation resource.

The proposed development would introduce built form into the area, as outlined in section 5.3.1. However, the impacts of the development are likely to be very limited, and would generally be restricted to views from the main transport corridors surrounding the development site where there are gaps in existing screening. From further afield, the development is likely to be screened by the motorways to the south, east and west, and by more extensive tree cover to the north.

It is not considered that the development would have an unacceptably adverse effect on the landscape due to the existing infrastructure context around the site, the limited extent of the visual influence of the development and existing screening from further afield.

5.4.2 Hydrology and Flood Risk As highlighted in sections 5.3.4 and 5.3.5, it is not anticipated that there would be any effects on watercourses, water quality or an increase in flood risk as a result of the development. The location has been selected in part because it is outwith any areas

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considered to be at risk of flooding, and incorporates SUDS measures as part of the design in accordance with the requirements of the Development Plan. Good practice construction measures will be adopted during the construction of the development to ensure that the risk of accidental pollution events is minimised. 5.4.3 Ecology and Habitat There are no designated ecological sites at or close to the proposed development site. The closest sites designated for their ecological value are at a sufficient distance from the development site, and have no connectivity with it. As a result, there will be no effect on these as a result of the development.

It is not anticipated that any trees within the site will need to be felled to accommodate the development, with the site access utilising an existing point of access into the field.

5.4.4 Historic Environment Section 5.3.3 sets out the closest historic features to the development site. Given the separation between these and the development site there will no impact upon them as a result of the development.

5.4.5 Noise A detailed assessment of the potential noise effects from the development at the closest residential properties has been undertaken by Arcus Consultancy Services and the report (Noise Impact Assessment, Small Scale Gas Peaking Plant - Erskine) is included in support of this application. The noise assessment has been undertaken in accordance with BS4142:2014 Method for Rating and Assessing Industrial and Commercial Sound, which is the relevant legislation for assessing the noise impacts of the development. The existing noise environment of the immediate area is heavily influenced by the proximity to the M8 and M898 motorways.

The noise assessment concludes that, subject to appropriate mitigation measures being implemented, including acoustic insulation and screening, the development will not unacceptably effect the amenity of nearby residents. At the most likely times of operation, the development is unlikely to be audible above the motorway traffic at the closest receptors.

5.4.6 Air Quality As set out in section 5.3.6, a detailed air quality assessment has been undertaken for the development and it has been shown to comfortably comply with the requirements of the Air Quality (Scotland) Regulations 2010.

The Development will be regulated under the Medium Combustion Plant Directive (MCPD) which comes into force in December 2018 and the Development will be designed to meet 3 3 the MCPD emission limit values for NOx set at 95 mg/m at 15% O2 or 250mg/Nm at 5% O2 for natural gas fired generators.

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There will be no emissions to air when the development is not operational.

Taking the above, it is considered that the development will have a very limited effect on air quality, which is localised to the site and complies with both current limits and future regulatory standards.

5.4.7 Access, Transport and Traffic The majority of traffic associated with the development will occur during the construction phase. The construction period is likely to last 6-9 months, with a maximum of 20 HGV vehicle movements in the initial period of construction associated with earthworks and preparation of the site. For the majority of the construction phase it is anticipated that there will be up to 10 HGV movements per day.

Given the proximity to the motorway network and the access from Old Greenock Road, the road network surrounding the development is suitable to accommodate the small increase in traffic during the construction period without adverse effects on other road users. If required, a construction traffic management plan will be prepared to ensure that any effects are limited. This will also include people travelling to site by car during construction.

During operation of the site, traffic movements are expected to be limited to service vehicles, with limited, if any HGV access being required.

The site access point is an existing entrance into the field and is located in an area of good visibility from Old Greenock Road.

The traffic associated with the construction and operation of the Development, would not adversely affect the existing transport network.

5.4.8 Public Rights of Way There are no Core Paths or rights of way within the application site. The closest path follows the route of the pavement on the opposite side of Old Greenock Road to the development and will not be affected.

5.4.9 Existing Infrastructure There is no known existing infrastructure on the site that will be affected by the development. In accordance with good practice, a services and, if necessary a survey, will be undertaken prior to construction to ensure that any buried services are protected

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6 Relevant Material Considerations The following key material considerations are considered to be relevant to the assessment of the proposed development as detailed below.

 The National Planning Framework 3  Scottish Planning Policy

6.1 National Planning Framework 3 The Scottish Government published the National Planning Framework 3 on the 23rd June 2014. The NPF sets out the Scottish Government’s central purpose which is “to create a more successful country, with opportunities for all of Scotland to flourish, through increasing sustainable economic growth.”

NFP3 sets out the Government’s “vision” for Scotland which is referred to as a successful, sustainable place, a low carbon place, a natural resilient place and a connected place.

The principle of the proposed use and the redevelopment of the former landfill site can draw support from the NPF3. NPF3 notes that “Planning has an important role to play in finding new and beneficial uses for previously used land”.

NPF3 is supportive of energy developments in appropriate locations and the development fully accords with these aims and objectives.

Paragraph 3.8 of NPF3 reaffirms the Scottish Government’s energy targets and states (page 31):

“By 2020, we aim to reduce total final energy demand by 12%. To achieve this, and maintain secure energy supplies, improved energy efficiency and further diversification of supplies will be required.”

The proposed Development will employ modern, highly efficient generators fuelled by clean, natural gas which will provide flexible generation which will operate when required. Designed to operate at peak times the Development will help improve the overall efficiency of the Scottish electricity network.

6.2 Scottish Planning Policy The 2014 Scottish Planning Policy supersedes the previous SPP (published in 2010) and is a non-statutory document which outlines the Scottish Government’s priorities for land use planning and therefore should be afforded significant weight in the determination of applications.

It is clear that the Scottish Government is committed to appropriately sited energy projects.

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Outcome 2 is especially relevant of ‘A Low Carbon Place’ – reducing our carbon emissions and adapting to climate change, reiterates the Scottish Government’s targets of reducing greenhouse gas emissions and paragraph 12 states that (page 7):

“The SPP sets out how this should be delivered on the ground. By seizing opportunities to encourage mitigation and adaptation measures, planning can support the transformational change required to meet emission reduction targets and influence climate change. Planning can also influence people’s choices to reduce the environmental impacts of consumption and production, particularly through energy efficiency and the reduction of waste.”

The development has been strategically located to allow access to both the existing electricity and gas networks, and carefully planned and designed to minimise environmental impacts and comply with local development plan policies to achieve an efficient and deliverable energy development.

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7 Conclusion By necessity, a strategic approach has been taken in the identification of sites suitable for the development of Gas Peaking Plants in Scotland. This involved an assessment of the national and local grid network to identify areas which have appropriate capacity to support new connections, during which the Scottish Power substation at Erskine near Bishopton was identified as having the capacity to support new generation. Once a suitable connection point (substation) was identified further investigations were made to establish the availability of piped natural gas tat sufficient pressure and the availability of land around the substation site. In the case of Erskine it was established that as well as providing a suitable point of connection to the grid, there was also a nearby gas connection of appropriate pressure and sufficient, suitable land available for development of a gas peaking plant. The site also benefits from good road access and distance from residential housing.

The Development will utilise a small area of agricultural grazing land sandwiched between Junction 30 of the M8 motorway and Old Greenock Road, being located opposite the Erskine substation. The Development has been designed to avoid unacceptable environmental and amenity effects, whilst ensuring that the development will contribute to the management of a stable electrical grid network. The application site is visually well contained and is set within the context of existing infrastructure development.

The UK’s electricity supply is undergoing a transition from traditional, ageing, large scale, centrally managed base load thermal (most commonly coal) plants to low carbon sources such as renewables, natural gas and new nuclear. As part of this transition there is a requirement for smaller, more flexible “on demand” plants, such as the Erskine Gas Peaking Plant to replace old, large power stations that, due to their inflexibility, increasingly operated between demand peaks even when the system did not require them and to balance generation from renewables. The electricity network is increasingly becoming better designed to manage the peaks and troughs associated with electricity supply and demand and reduce the strain on transmission and distribution networks and ensure there are no power blackouts. This Development is designed to support this more flexible approach to grid management and to smooth over the troughs in electricity supply caused by intermittent generation providing a critical service by being able to respond at short notice to requests from National Grid to generate electricity.

The Development is being promoted in response to the UK Government’s Electricity Market Reforms and in particular their introduction of a UK wide Capacity Market. The Capacity Market has been designed to ensure security of electricity supply by providing a payment for reliable sources of capacity to ensure they deliver energy when needed. The aim is to encourage the investment needed to replace older power stations and provide backup for more intermittent and inflexible low carbon generation sources. The Capacity Market will help the UK deliver its obligations under the Climate Change Act (2008) to reduce carbon emissions and through the Renewable Energy Directive 2009/28/EC to increase electricity consumption from renewable resources.

The Development has been considered against the relevant Development Plan policies set out in the LDP. The Application site is located in Green Belt, however, the Development is considered appropriate in the setting proposed because it constitutes a utility installation

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and requires to be located adjacent to the national grid electricity and gas networks, and at a suitable distance from properties to ensure the protection of amenity. The site, adjacent to the existing Erskine substation and M8 Motorway would have limited impact on the landscape and character of the area and would be reversible at the end of a 40 year operational period.

The Development is also considered acceptable in regards to ecology and habitat; the historic environment; hydrology and flood risk; coal mining risk; noise; air quality; access and, transport and traffic.

It is integral to planning decision-making that a balancing exercise has to occur in respect of considering the benefits of the development against the impact. In this case, there are clear benefits which arise from the delivery of energy generation services which clearly outweigh the modest impacts.

The Development is supported by NPF3 and SPP and also accords with the LDP and as such it is respectfully requested that it be approved by Erskine Council.

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Production 2 : Planning Application Refusal Notice

Production 3 : Planning Application Report of Handling