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POWER COURT Environmental Statement Volume I Chapter 14 - Cumulative Effects

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POWER COURT Environmental Statement Volume I Chapter 14 - Cumulative Effects 2020 Developments (Luton) Ltd POWER COURT Environmental Statement Volume I Chapter 14 - Cumulative Effects MARCH 2021 PUBLIC 2020 Developments (Luton) Ltd POWER COURT Environmental Statement Volume I Chapter 14 - Cumulative Effects (ISSUE 1) PUBLIC PROJECT NO. 70075872 DATE: MARCH 2021 WSP Aldermary House 10-15 Queen Street London WSP.com CONTENTS 14. CUMULATIVE EFFECTS 1 14.1. INTRODUCTION 1 14.2. SCOPE AND METHODOLOGY 1 14.4. ASSESSMENT OF CUMULATIVE EFFECTS 5 14.5. DIFFICULTIES AND UNCERTAINTIES 20 14.6. SUMMARY OF CUMULATIVE EFFECTS 20 14.7. REFERENCES 23 TABLES Table 14-1 - Summary of the interaction between common sensitive receptors 5 Table 14-2 - Intra-Project Receptors and Effects 12 Table 14-3 – Short-list of Committed Developments 13 Table 14-4 - Summary of inter-project cumulative effects (with effects of minor significance or above) 19 POWER COURT WSP Project No.: 70075872 March 2021 2020 Developments (Luton) Ltd 14. CUMULATIVE EFFECTS 14.1. INTRODUCTION 14.1.1. This chapter reports the likely significant cumulative environmental effects (both effect interactions and in-combination effects) associated with the Proposed Development. Cumulative effects comprise the combined effects of reasonably foreseeable human induced changes within a specific geographical area over a certain period of time, which can be both direct and indirect. 14.1.2. For the purposes of this ES, the following types of cumulative effects have been considered in accordance with the EIA Regulations 2017 and best practice guidance: ▪ Intra-project combined effects – the interaction and combination of different environmental effects from within the Proposed Development affecting a receptor; and ▪ Inter-project cumulative effects – the combined effects of the Proposed Development and other projects on a receptor. 14.2. SCOPE AND METHODOLOGY 14.2.1. This section should be read in conjunction with the cumulative effects section of Chapter 2: EIA Methodology. 14.2.2. At present, there is no widely accepted methodology or best practice for the assessment of cumulative effects although there are a number of guidance documents available, including: ▪ The European Commission (May 1999) Guidelines for the Assessment of Indirect and Cumulative Impacts as well as Impact Interactions (Ref 14.1); and ▪ The Planning Inspectorate (August 2019) Cumulative Effects Assessment (Advice Note 17) (Ref 14.2). 14.2.3. The approach to this assessment is based on previous experience and professional judgement, the types of receptors being assessed, the nature of the Proposed Development and the environmental information available to inform the assessment. 14.2.4. The ‘Guidelines for the Assessment of Indirect and Cumulative Impacts as well as Impact Interactions’ (Ref 14.1) provides the following guidance on cumulative effects: ‘In practical terms, the extent of the assessment in terms of how far into the past and into the future will be dependent upon the availability and quality of information…’; and ‘…it is only reasonable to consider current events and those that will take place in the foreseeable future. Furthermore, the assessment can only be based on the data that is readily available’. 14.2.5. Schedule 4, Paragraph 5(e) of the EIA Regulations 2017 (Ref 14.3) states that an ES should include a description of the likely significant effects of the Proposed Development on the environment resulting from ‘the cumulation of effects on with other existing and / or approved projects, taking into account any existing environmental POWER COURT WSP Project No.: 70075872 March 2021 2020 Developments (Luton) Ltd Page 1 of 23 problems relating to areas of particular environmental importance likely to be affected or the use of natural resources’. 14.2.6. Part 1, Paragraph 4, 2 (e) of the EIA Regulations 2017 refers to the need to assess ‘the interaction between factors referred to in sub-paragraphs (a) to (d)’ which includes: population and human health, biodiversity (with particular attention to species and habitats protected under Directive 92/43/EEC and Directive 2009/147/EC, land, soil, water, air and climate, material assets, cultural heritage and the landscape). 14.2.7. There are principally two types of cumulative impact in environmental impact assessment (‘EIA’) Process. These are: ▪ Cumulative impacts and indirect effects of a single project affecting the same receptor within the site or local area (Intra-project Effects); and ▪ Cumulative impacts from the proposed development and different developments affecting the same receptor (in combination with the project being assessed) (Inter- project Effects). 14.2.8. This chapter draws on information presented in chapters 3 - 14 of the ES Volume 1 and should be read in conjunction with these chapters. 14.2.9. The Luton Local Plan (2011–2031) (Ref 14.4) considers cumulative assessment in the following policies: ▪ Policy LLP17 – Houses in Multiple Occupation: i. ‘the proposal, or cumulative impact of the proposal (including operational and management requirements) with other similar proposals,k would not adversely affect the character of the area, particularly in conservation areas,’ ▪ Policy LLP36 – Flood Risk: iiii. ‘ensuring that development does not increase the risk of flooding elsewhere, including cumulative impact on adjoining and surrounding land and in the wider catchment,’; ▪ Policy LLP38 – Pollution and Contamination: ‘Evidence on the impacts of development will need to demonstrate whether the scheme (individually or cumulatively with other proposals) will result in any significantly adverse effects with regard to air, land or water on neighbouring development, adjoining land, or the wider environment’ and ▪ Policy LLP39 – Infastructure and Developer Contributions: iii ‘take account of the cumulative impact of the requirements on the viability of development, especially where the development meets a particular local need or provides particular benefits’. 14.2.10. Consultation was undertaken with LBC to confirm the short-list of committed developments. Where further consultation for inter-project effects has been undertaken, this has been discussed in the relevant technical chapters. 14.2.11. No consultation was undertaken for inter-project effects, apart from consultation with specialists, due to the nature of this assessment. INTRA-PROJECT CUMULATIVE EFFECTS 14.2.12. The approach to the assessment of interactions of environmental effects considers the changes in baseline conditions at common sensitive receptors (i.e. those receptors that have been identified as experiencing likely significant effects by more than one POWER COURT WSP Project No.: 70075872 March 2021 2020 Developments (Luton) Ltd Page 2 of 23 environmental factor) due to the Proposed Development. The assessment is based upon residual effects only (considered to be effects of ‘slight’ or greater significance). The study area for the assessment is informed by the study areas for the individual factor assessments, as set out in technical chapters 4 to 13. 14.2.13. The assessment of the intra-project combined effects has been undertaken using a two-stage approach: Stage 1 - Screening 14.2.14. Screening has been undertaken to determine whether a sensitive receptor is exposed to more than one type of residual effect during the construction and/or operational phases of the Proposed Development. The sensitive receptors identified in technical chapters 4 to 13 and the predicted residual effects on these following the application of additional (secondary) mitigation are presented in Chapter 15: Summary (Table 15-1). Residual effects of ‘negligible’ or ‘neutral’ significance in the technical chapters have not been included within the Stage 1 assessment. Those common sensitive receptors exposed to two or more types of residual effects, with significance of effect greater than ‘negligible’ (i.e. ‘slight’ or greater) have been taken forward to Stage 2 of the assessment. 14.2.15. If there is only one type of effect on a sensitive receptor (i.e. only one technical chapter has identified effects on that sensitive receptor), then it is considered that there are no potential intra-project combined effects and the sensitive receptor has not been taken forward to Stage 2 of the assessment. Stage 2 – Assessment for Intra-Project Combined Effects 14.2.16. A qualitative assessment of the overall significance of the cumulative effects on common sensitive receptors identified at the screening stage has been undertaken based on technical information provided in the technical chapters and supporting appendices as well as professional judgement. Given that the types of effects are very different in some cases, a quantitative assessment was not possible, and it was necessary to apply professional judgement in determining the level of significance. INTER-PROJECT CUMULATIVE EFFECTS 14.2.17. The approach to the assessment of inter-project effects considers the deviation from the baseline conditions at common sensitive receptors as a result of changes brought about as a result of the Proposed Development in combination with one or more other approved developments. The assessment of the inter-project effects has been based upon the residual effects that have been identified in technical chapters 4 to 13 as well as available environmental information for the approved developments. 14.2.18. For the purposes of this assessment, approved development is defined as those developments meeting one or more of the following criteria: ▪ Has obtained planning permission and is currently under
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