Appendix 1.2: EIA Scoping Opinion
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Appendix 1.2: EIA Scoping Opinion EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) Communities and Housing Civic Offices, Euclid Street Swindon, SN1 2JH Tel: 01793 445503 Fax: 01793 463306 DX: 133055 Swindon 16 Minicom: 01793 436659 Donna Palmer Please ask for: Mr Edward Snook Turley Direct Dial No: 01793 466427 The Pinnacle Email: [email protected] 20 Tudor Road Our Ref: S/EIA/18/1472 Reading Date: 16th October 2018 RG1 1NH Dear Ms Palmer, Town and Country Planning Act 1990 Town and Country Planning (Environmental Impact Assessment) Regulation 2017 Re: Request for Environmental Impact Assessment (EIA) Scoping Opinion for proposed development. At: Inlands Farm, The Marsh, Wanborough I refer to the submission and email dated 31st August 2017 seeking a Scoping Opinion pursuant to Section 15 of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017. Whilst this is not an application for a Screening Opinion, after careful consideration of the matters contained within your submission and email dated 31st August 2018 and having regard to the relevant provisions of the Town and Country Planning (Environmental Impact Assessment) Regulations 2017, the Local Planning Authority considers that the proposed development is an EIA development as it would have a significant environmental impact. The Council concurs with your view that an EIA is required for the development. 1 Proposal 1.1 The proposal comprises the development of a science park comprising up to 32,381 sqm of Use Class B1b (research and development) floor space and 49,907 sqm of use class B1c (light manufacturing), as well as associated highway improvements, green infrastructure and drainage systems. 1.2 The application site extends to approximately 40.2 hectares and is currently in agricultural use. It is situated within the administrative boundaries of Swindon Borough Council and Wanborough Parish Council. Swindon Urban Area is located to the west of the application site, whilst the New Eastern Villages (‘NEV’) Strategic 1 EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) Allocation, brought forward through Policy NC3 of the Swindon Borough Local Plan 2026 (‘Local Plan’), is to the north. To serve the new communities at the NEV, the Southern Connector Road (‘SCR’) is currently proposed to run immediately to the west of the site. 2 Scoping Opinion 2.1 The LPA has consulted with various statutory consultees as well as other third parties and received a number of comments which have been summarised below. Full consultee responses are available on the Swindon Public Access website using the application reference number. 3 Consultee Comments 2.1 Statutory & External Consultee Comments 3.1.1 Campaign for the Protection of Rural England (CPRE) The proposed development, for which the above Opinion is sought, conflicts with Swindon Local Plan Policy NC3 which covers development to the east of the A419 as defined on the Policies Map. The site lies within the Indicative Non-Coalescence area of NC3 and outwith the allocated development area. The designation was established for express reasons. a) To prevent villages like Wanborough from the impact of the creeping development and to b) protect the area close to the boundary of the AONB from the cumulative effect of creeping development. There are no planning considerations which support development of this greenfield site. Para 23 of NPPF July 2018 underlines the need to have objectively assessed land use designations and allocations identified on a policies map. This Science Park is in reality an industrial site with some specialised manufacturing. There is no estimated number of jobs to be created. It appears to be a hybrid application of low density. A Science and Technology centre is being developed at the former Hullavington Airfield, being brownfield this would be a more appropriate site. 3.1.2 Environment Agency We consider the following areas necessary for inclusion within the Environmental Statement / planning submission: Surface Water Drainage and Flood Risk Water Resources (supply) and Water Efficiency Wastewater Groundwater Protection Impact on protected species and habitat 2 EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) Construction Environment Management Plan, including pollution prevention measures, and Waste management Surface Water Drainage / Flood Risk The site falls within Flood Zone 1, as shown on the Flood Map for Planning. Although the site is outside flood zones 2 and 3 it does not mean the site is free from flood risk. The Environment Agency flood maps are indicative in nature and do not show flood zones (2 & 3) associated with watercourses where the catchment size is smaller than 3 square kilometres. The site may be at risk from other sources of flooding (e.g. groundwater, surface water), which are not considered in the mapping of flood zones. The Lead Local Flood Authority can also advise on this matter. If the site is greater than 1 hectare, under National Planning Policy Framework, a FloodRisk Assessment (FRA) will be required to deal with surface water runoff from the site. The surface water drainage strategy should include pollution control measures. Further advice can be found on our website at: https://www.gov.uk/flood-risk-assessment-for-planning- applications Surface water matters are the remit of the Lead Local Flood Authority, therefore they should be consulted on this issue. Water Supply and Waste Water Adequate water and wastewater infrastructure is needed to support sustainable development. National Planning Policy Framework (NPPF) identifies that a healthy water environment will also deliver multiple benefits, such as helping to enhance the natural environment generally and adapting to climate change. The EU Water Framework Directive applies to surface waters and groundwater. It requires member states to prevent deterioration of aquatic ecosystems and protect, enhance and restore water bodies to ‘good’ status. When drawing up wastewater treatment proposals for any development, the first presumption is to discharge foul drainage into a public sewer to be treated at a public sewage treatment works (those provided and operated by the water and sewerage companies). This should be done in consultation with the local sewerage company. Where a connection to a public foul sewer is not feasible (in terms of cost and/or practicality) a package sewage treatment plant can be considered. This should offer treatment so that its final discharge meets the standards set by the required Environment Agency Environmental Permit A proposal for a package sewage treatment plant and infrastructure should set out clearly the responsibility and means of operation and management to ensure that the Permit is not likely to be breached during the life of the plant. Sustainable Construction Sustainable design and construction should be implemented across the proposed development. This is important in limiting the effects of, and adapting to climate change. Running costs for occupants can also be significantly reduced. 3 EIA Scoping Opinion - Inlands Farm, Swindon (S/EIA/18/1472) Biodiversity The National Planning Policy Framework is clear that pursuing sustainable development includes moving from a net loss of biodiversity to achieving net gains for nature, and that a core principle for planning is that it should contribute to conserving and enhancing the natural environment and reducing pollution. Information on biodiversity impacts and opportunities should inform all stages of development including, for instance, site selection and design including any pre-application consultation as well as the application itself. Groundwater Protection / Contaminated Land If historic use of the site may have caused land contamination then paragraph 109 of the NPPF states that the planning system should help prevent both new and existing development from contributing to, or being put at risk from unacceptable levels of water pollution. Thorough site investigation information must be prepared and presented by a competent person. Further guidance on what should be contained in the investigation and issues associated with groundwater protection can be found here: https://www.gov.uk/government/collections/groundwater-protection Pollution Prevention during Construction Safeguards should be considered for implementation during the construction phase to minimise the risks of pollution from the development. Such safeguards should cover: the use of plant and machinery; oils/chemicals and materials; the use and routing of plant and vehicles; the location and form of work and storage areas and compounds; the control and removal of spoil and wastes. The applicant should refer to the Environment Agency's Pollution Prevention Guidelines at: https://www.gov.uk/government/collections/pollution-prevention-guidance-ppg Waste Should this proposal be granted planning permission, then in accordance with the waste hierarchy, we wish the applicant to consider reduction, reuse and recovery of waste in preference to offsite incineration and disposal to landfill during site construction. If you require more specific guidance it is available on our website: www.environment- agency.gov.uk/subjects/waste/. 3.1.3 Highways England Highways England (“we”) are a Statutory Consultee on Planning Applications under the Town and Country Planning (Development Management Procedure) Order 2015. In discharging this responsibility we act as a proactive partner and therefore welcome Pre- Application