Rugeley B , January 2019

Rugeley B Power Station, Rugeley

Environmental Impact Assessment Scoping Report Volume 1 – Main Statement

On behalf of Rugeley Power Limited

Contents

CHAPTER 1: ...... INTRODUCTION CHAPTER 2: ...... SITE DESCRIPTION CHAPTER 3: ...... PROPOSED DEVELOPMENT CHAPTER 4: ...... EIA APPROACH CHAPTER 5: ...... ALTERNATIVE OPTIONS AND CONSULTATION CHAPTER 6: ...... SOCIO-ECONOMICS CHAPTER 7: ...... AIR QUALITY CHAPTER 8: ...... ARCHAEOLOGY CHAPTER 9: ...... BUILT HERITAGE CHAPTER 10: ...... ECOLOGY CHAPTER 11: ...... WATER ENVIRONMENT (INCLUDING FLOOD RISK) CHAPTER 12: ...... NOISE AND VIBRATION CHAPTER 13: ...... GROUND CONDITIONS CHAPTER 14: ...... LANDSCAPE & VISUAL IMPACT CHAPTER 15: ...... TRANSPORT AND ACCESS

FIGURES

Figure 2.1 – Drawing 01585_SK_003 (Red line Plan) Figure 2.2 – Drawing Skt170316-001 Rev F (Demolition Site Boundary) Figure 2.3 – Drawing MP003 Rev D1 (Eastern Lagoon PFA Extraction) Figure 3.1 – Drawing MP002 Rev D2 (Site Areas) Figure 3.2 – Rugeley Second Access – Site Location Plan Figure 3.3 – Drawing J32-2608-PS-III (Revised Junction Layout) Figure 6.1 – Primary Study Area (Within Socio-Economic Chapter) Figure 10.1 – Phase 1 Habitat Map with Target Notes Figure 10.2 – Pond and Ditch Locations Figure 10.3 – Reptile Refuge Locations Figure 10.4 – Surveyed Bat Transects and Static Locations Figure 12.1 – Noise Monitoring Locations (Within Noise and Vibration Chapter) Figure 13.1 – Plan of Historic Ground Investigation Figure 14.1 – Proposed Viewpoint Locations Figure 15.1 – Junction Study Area Figure 15.2 – Cycling in Cannock Chase Figure 15.3 – Cycling in Lichfield Figure 15.4 – Local Bus Stops Figure 15.5 – Local Railway Stations

APPENDICES

Appendix 4.1 – Committed Schemes Long List Appendix 4.2 – Electromagnetic Field Assessment Appendix 10.1 – Phase 1 Habitat Survey Target Notes Appendix 10.2 – Waterbody and Watercourse Descriptions Appendix 10.3 – Breeding Bird Survey Results Appendix 10.4 – CONFIDENTIAL ANNEX: Badger Survey Results Appendix 14.1 – LVIA Methodology

EIA Scoping Report Chapter 1 Rugeley B Power Station, Rugeley

CHAPTER 1: INTRODUCTION

1.1 INTRODUCTION

1.1.1 This Environmental Impact Assessment (EIA) Scoping Report has been prepared by Savills (UK) Limited (‘Savills’), with input from the EIA project team, on behalf of Rugeley Power Limited (‘the Applicant’). It provides preliminary environmental information in relation to the Proposed Development at Rugeley B Power Station in (the "Site") and suggests the scope of key issues that the subsequent EIA will need to examine.

1.1.2 This report is provided in support of a request for a ‘scoping opinion’ from Lichfield District Council (LDC) and Cannock Chase District Council (CCDC) who are the local planning authorities for the Proposed Development. This ‘scoping opinion’ request is made pursuant to Part 4, Regulation 15 (1) of The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 (EIA Regulations), which came into force on 16 May 2017.

1.1.3 This Scoping Report contains the information to allow LDC and CCDC to consult with relevant stakeholders on the proposed scope of the EIA, including the Environment Agency, Highways and Natural England, so that their comments can be taken into consideration in the EIA undertaken.

1.1.4 Brief details of the Site location and a summary description of the Site are provided in Chapter 2. An overview of the Proposed Development is provided in Chapter 3. Further details are provided in subsequent chapters, along with the proposed technical scope of the EIA which is set out in individual topic chapters (Chapters 6 – 15).

1.1.5 The Proposed Development comprises some site remediation and re-profiling works alongside comprehensive development of the Site, delivering circa 2,300 No. Residential Dwellings, circa 5 hectares (ha) of employment land, the associated access, community facilities including education and supporting amenity space, landscaping, green infrastructure and sustainable drainage systems.

1.1.6 Chapter 4 sets out the proposed approach of the EIA, and Chapter 5 sets out the alternative development options that will be considered by the EIA and the broad scope for future stakeholder engagement.

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EIA Scoping Report Chapter 1 Rugeley B Power Station, Rugeley

1.2 THE PROJECT TEAM

1.2.1 The EIA project team is being led by consultants Savills, with input from other specialists both internal and external to the company. The project team comprises:

EIA Management and Co-ordination Savills Socio-Economics Savills Air Quality AAC Archaeology AECOM Built Heritage AECOM Ecology Atmos Water Environment (including Flood Risk) AECOM Noise and Vibration ACC Ground Conditions AECOM Landscape and Visual JTP Transport and Access Mode

1.3 PROPOSED SCOPE OF EIA

1.3.1 The proposed scope of the EIA is set out in Table 1.3 below. Further details can be found in Chapter 4.

Table 1.3: Environmental Topics considered in the EIA Scoping process Topic EIA Scoping Report Chapter Scoped In / Out Accidents and Natural Disasters (excluding Out 4 flooding) Health and Safety 4 Out Waste 4 Out Soils and Agricultural Land 4 Out Climate Change 4 In Electromagnetic Radiation 4 Out Socio-Economics (includes population) 6 In Air Quality (includes human health) 7 In Archaeology 8 Out Built Heritage 9 In Ecology (Biodiversity) 10 In Water Environment (including Flood Risk) 11 In Noise and Vibration (includes human health) 12 In Ground Conditions (includes human health) 13 In Landscape and Visual Impacts 14 In Transport and Access (includes human health) 15 In

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EIA Scoping Report Chapter 2 Rugeley B Power Station, Rugeley

CHAPTER 2: SITE DESCRIPTION

2.1 INTRODUCTION

2.1.1 This chapter provides a description of the Site and its setting. Further details relevant to the proposed scope of the technical assessments are provided in Chapters 6 – 15.

2.2 SITE DESCRIPTION

2.2.1 The Site, identified on Figure 2.1 – Drawing 01585_SK_003 (Red Line Plan), is an area of land at Rugeley B Power Station, South Staffordshire. The Site is located approximately 1km to the east of Rugeley Town Centre and borders recently developed residential properties (known locally as The Pippins) in the south east corner on part of the former Rugeley A Power Station site.

2.2.2 The A51 runs along the south western boundary of the Site before bearing off south around the aforementioned residential development (The Pippins). Beyond the A51 lies Towers Business Park, comprised of large commercial and industrial units and mixed use employment and business space. The north/western boundary abuts the for approximately 1.4km, after which the Site is bounded by open countryside and agricultural fields to the south west.

2.2.3 The Site is approximately 139 hectares (ha) in size and was formerly a fired power station producing electricity for transmission to the National Grid. This production ceased in 2016. As such, much of the infrastructure associated with the Site’s past use remains in situ, including four cooling towers, a Chimney Stack, plant buildings, electricity substation and network of interlinking access tracks. Demolition of this infrastructure will be undertaken in accordance with a separate, existing planning consent.

2.2.4 The physical infrastructure is largely concentrated to the north westerly section of the Site. Several parcels of green open space and soft landscaping are located towards the middle of the Site which centres around facilities associated with the former Sports and Social Club building, including part of a golf course. To the south east of the Site there are a series of ash lagoons, of varying succession phases, as well as a borrow pit lake, which is surrounded by mature trees and shrubs. A freight railway line, previously used to transport coal to the power Station, intersects the Site from northwest to southeast. Beyond this lies existing leisure and community amenity space currently occupied by what was previously a golf course that abuts the River Trent at the eastern Boundary.

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EIA Scoping Report Chapter 2 Rugeley B Power Station, Rugeley

2.2.5 The topography is broadly flat with some man-made features, such as bunding, currently in situ.

Demolition Works

2.2.6 In advance of the intended redevelopment, demolition works are being carried out at the Site. These works were subject to prior approval from LDC and CCDC granted in October 2018.

2.2.7 The consented demolition works will be completed in advance of the commencement of the Proposed Development. As such, these works are considered to be in place and form part of the baseline environment for the Site and consideration of the Proposed Development.

2.2.8 Following closure of the power station, prior approval was granted in October 2018 by LDC and CCDC (18/01098/FULM and CH/18/268) for the “Demolition of Rugeley B Power Station, including decommissioning, removal of hazardous materials and dismantling of all associated buildings and structures”.

2.2.9 The demolition works were the subject of an EIA Screening Request issued to both LDC and CCDC in April 2017. In May 2017 both LPA’s issued Screening Opinions stating that the demolition works did not comprise EIA development.

2.2.10 The demolition works, which commenced in September 2018, comprise the complete demolition of all structures within the demolition site boundary (Figure 2.2 – Drawing Skt170316-001 Rev F) to ground level. The demolition works are expected to be completed by April 2021.

2.2.11 The main structures to be demolished are split into 8 zones and comprise:

 Zone 1: East Area - Turbine House, GT Planthouse, Water Treatment Plant Room, IAC and Central Compressor House, Sodium Hypo Dosing Plant, No 7 11kv switch room, Hydrogen Storage Manifold, Nitrogen Vie storage vessel, Oil drum cleaning/ disposal area, Junction Tower No 1, Propane Tank Compound, MAG Separator House.

 Zone 2: North Area - Fire Station, Contract Services Office, PJD Mechanical Workshop, Ash Grab Pits, Compressor House, Dust Silo, Ground Reclaim Hopper, Junction Tower No 3, Junction Tower No 2, Aux. Mill Maintenance Workshop, Aux Boiler House, Coal Screen/ Sampler House, Vacuum Planthouse, Ash Pump house, Precipitators, GT Fuel Oil Pump house, Gas Cylinder Store, Coal Stock North Drainage Sump, Steam Boiler Skid, Liquid Sulphur Storage Vessel, Unit 6 & 7 Gas Generation Injection Units, GT4B

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EIA Scoping Report Chapter 2 Rugeley B Power Station, Rugeley

Storage Tank, GT/ Aux Boiler Fuel Oil Tank, E Store, Controlled Waste Disposal Area, Rail Sidings, Track hopper House, Coal Plant Control Room.

 Zone 3: South East Area - Main Control Room, Projects Office, Main Reception, Laboratory Block, Management Block, Canteen/ Amenities Block, FM Office Staff and Gym, Finance and Procurement Offices, Workshop Office, Main Workshops, Engineering and Team Leader Office, Stores Office, Goods Inwards, Main Stores.

 Zone 4: West Area - Road 3 Car Wash, Borehole Water Tank, Light Workshop, Borehole Plant House, Propane Tank Compound, Lorry Wash Water Sump, FGD Absorbers, FGD Pump house, FGD Electrical Switch room FGD Dump Tank, Chimney Stacks and Windshield, Heavy Vehicle Garage and Lorry Wash.

 Zone 5: South West Area - F Stores, Parsons Hut, M Stores, P Stores, N Stores, FGD Gypsum Store, FGD Common Electrical Building, FGD Water Treatment Plant, FGD Slurry Water Tanks, FGD Process Water Tank, FGD Limestone/ Gypsum conveyor.

 Zone 6: South Area - Cooling Towers 6-9, CW Pump house.

 Zone 7: South East Area - Rail Sidings, ORF Transfer Pump house, ORF Fire Protection Pump house, B Make-up Water Pump house, Clubhouse car wash, FGD Limestone/ Gypsum Road and Rail Operations.

 Zone 8: South East Area - Rugeley Sports and Social Club, Model Railway

2.2.12 As shown on Figure 2.2, the 400kV and 132kV Switching Stations and associated buildings are not scheduled for demolition and are to be retained as part of the Proposed Development. In addition, the demolition site boundary does not include the current offices in the centre of the Site and Environmental Education Centre building located in the east of the Site. These buildings will be retained and used during the demolition works and removed as part of the Proposed Development.

Removal of Pulverised Fuel Ash (PFA) from Eastern Lagoons and creation of a level platform

2.2.13 Extraction and management of Pulverised Fuel Ash (PFA) followed by the creation of a level platform as part of the closure of the lagoons in the east of the Site will continue to be carried out subject to the existing Environmental Permit. On completion of PFA extraction the lagoon clay liner and aggregate bunds will be removed or levelled before commencing water monitoring to satisfy the surrender terms of the Permit. The level platform is anticipated to be at a level of circa 66m AoD.

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2.2.14 As shown in Figure 2.3 – Drawing MP003 Rev D1, the intended works comprise of the extraction of approximately 500,000m3 of PFA from the Lagoon area. The removal of PFA and creation of the Permit surrender platform is expected to commence in March 2019 and be completed in 2021 in advance of the commencement of the Proposed Development. These works are considered to be in place and form part of the baseline environment for the Site and consideration of the Proposed Development.

Public Rights of Way

2.2.15 Given its past use, the Site is a closed and private parcel of land and does not contain any public rights of way. The closest public footpaths are well buffered from the Site and are located beyond the River Trent and railway line to the north east at a distance of 310m at the nearest point. To the south and south east, additional public footpaths run along the Trent and Mersey Canal before cutting across the A513. At the nearest point, these are located at a distance of 155m from the Site boundary.

Ground Conditions and Agricultural Land

2.2.16 With reference to the British Geological Survey (BGS) Maps, the Site predominantly lies over Helsby Sandstone Bedrock formation with superficial river terrace deposits of sand and gravel.

2.2.17 The Site does not lie within a groundwater source protection zone (SPZ).

2.2.18 The Site is not currently agricultural land and therefore the redevelopment will not have implications on the availability of agricultural land in the area.

2.2.19 Further details on ground conditions and their assessment are provided within Chapter 13 – Ground Conditions.

Archaeology and Built Heritage

Archaeology

2.2.20 There are no designated Archaeological Assets within the Site or in the immediate surrounds. There is potential for below ground archaeological remains to be present in less developed areas of the Site including potential for palaeoenvironmental remains associated with the nearby River Trent.

2.2.21 The closest designated Archaeological Assets are three scheduled monuments located within a 5km radius are listed below.

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 Circular earthwork 400yrds E of Bishton Hall (Reference 1006074) (3.5km north west) ark pale at Marwell, south of Fisher's Pond (Reference 1012309), located 2.1km north;

 Moated site of Handsacre Hall (Reference 1012430), located 3.5km northwest;

 Manor House (Reference 1006119), located 4.4km west.

Built Heritage

2.2.22 Within the Site itself there are no built heritage assets (of national or local importance). However, the surroundings area contains several listed buildings.

2.2.23 These heritage assets are mainly concentrated in surrounding settlements (Rugeley being the most prominent) although several are scattered across the rural landscape to the east of the Site. The closest, and potentially most exposed to the Site, of these assets are as follows:

 Viaduct over Trent and Mersey Canal at SK 0485, Grade II listed, located 0.28km west;

 Church of St John, Grade II* listed, located 0.67km southwest;

 Spode House and attached coach house, Hawkesyard priory, Grade II listed, located 0.21km south.

2.2.24 Although not listed, the existing cooling towers have an element of historical value given their association with Rugeley town. Historic Building Recording has been undertaken in accordance with the National Planning Policy Framework (NPPF) and consultation with Historic England. An assessment of the ‘B’ station by Historic England, undertaken in October 2017 in respect of an application, under the terms of the Planning (Listed Building and Conservation Areas) Act of 1990, for a Certificate of Immunity from Listing, concluded that the Site did not meet the high threshold necessary to justify the designation of the Site as an exemplar of its type and period. The demolition of these assets has already been consented as part of the prior approval granted in October 2018.

2.2.25 Further details on heritage assets and their assessment are provided within Chapter 8 – Archaeology and Chapter 9 – Built Heritage.

Flood Risk and Drainage

2.2.26 With reference to Environment Agency (EA) flood mapping, the majority of the Site is located in Flood Zone 1 and is therefore considered at low risk from flooding and most suitable for

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EIA Scoping Report Chapter 2 Rugeley B Power Station, Rugeley

residential land use. However, the River Trent, which runs adjacent to part of the eastern boundary, is surrounded by an area of increased flood risk which extends away from the river to the edges of the Site. Flood Zone 3 extends into the Site boundary along the majority of the north eastern edge, whilst patchy areas of Flood Zone 2 encroach further into the Site.

2.2.27 The Site contains a number of waterways comprising of lakes, pools and ditches, which will be considered within the drainage strategy.

2.2.28 Further details on hydrology, flood risk and drainage and their assessment are provided within Chapter 11 – Water Environment (Including Flood Risk).

Nature Conservation

2.2.29 There are no Statutory Designated Sites of Nature Conservation Interest (Site of Special Scientific Interest (SSSI), Special Conservation Areas (SAC), Special Protection Areas (SPA), Ramsar sites, National Nature Reserves) on or within the vicinity of the Site (within 500m).

2.2.30 The closest “Statutory Designated Sites” of nature conservation interest are situated approximately 3.1km to the west within the Cannock Chase AONB.

 Cannock Chase SSSI, designated due to its Dwarf Shrub Heath habitat; and

 Stafford Brook SSSI, designated due to a combination of carr woodland and acidic marshy grasslands and fen. The latter of which includes grassland, characterised by purple moor-grass Molinia caerulea and sweet vernalgrass Anthoxanthum odoratum, which is rare in both lowland Staffordshire and throughout lowland Britain.

2.2.31 Slightly further afield lie several other SSSI’s including Blithfield Reservoir, located 4.5km north, which is nationally important for goosander Mergus Merganser, and Gentleshaw Common, located 4.9km south, which is of interest due to the lowland heathland vegetation across this area, and the biodiversity niches it supports.

2.2.32 The Site itself is largely developed and therefore has little conservation value. However, there are areas of mature trees, open water and green open space towards the south western end of the Site that are of greater biodiversity interest.

2.2.33 Further details on ecological sites and habitats and their assessment are provided within Chapter 10 – Ecology.

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EIA Scoping Report Chapter 2 Rugeley B Power Station, Rugeley

Landscape Character

2.2.34 Whilst no longer an operational power station, in its current form the Site contains a number of different areas, namely; open coal storage area in the north western section, operational/plant buildings and structures concentrated in the central north western section, sport and recreational facilities associated with the closed Sports and Social Club, and Ash Lagoons and a Borrow Pit Lake in the south eastern section.

2.2.35 As set out above, following the completion of the consented demolition and remediation works, the Site will comprise a broadly level site suitable for future redevelopment.

2.2.36 In terms of the wider area, the Site is located on the boundary of the Cannock Chase and Cank Wood National Character Area (NCA) and Needwood & South Derbyshire Clayands NCA, and can therefore be considered to be within the zone of transition between these two NCAs.

2.2.37 Further details on local landscape character and its assessment are provided in Chapter 14 – Landscape and Visual.

Air Quality and Noise

2.2.38 Combined, LDC and CCDC have five Air Quality Management Areas (AQMA). However, none of these are located in Rugeley or in close proximity to the Site (within 7.5km radius).

2.2.39 There are noise sources situated around the Site which may produce audible noise in nearby areas of the Proposed Development, particularly in periods of high road traffic movements. Of particular note are the A51 and A513, which are located to the south of the Site, along with the active railway line between Rugeley Trent Valley and Lichfield Trent Valley Stations which passes the Site to the north, and, at its closest point, is only 55m from the Site boundary.

2.2.40 Further details on air quality and noise and their assessment are provided within Chapter 12 – Noise and Vibration and Chapter 7 – Air Quality.

2.3 SUMMARY OF SENSITIVE RECEPTORS

2.3.1 As described in the following technical scoping chapters a number of sensitive receptors have been identified that have the potential to be significantly affected either directly or indirectly by the Proposed Development. These receptors will be considered in the design and the assessment of the scheme and are outlined below.

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EIA Scoping Report Chapter 2 Rugeley B Power Station, Rugeley

 Occupiers of existing dwellings in proximity to the Site;  The local population in respect of local services, schools, employment opportunities, etc.;  Users of local roads, transport services and public rights of way/bridleways both on and in proximity to the Site;  Buried archaeological remains and historic landscape features of the Site;  Ecological habitats and species present both on and in proximity to the Site;  Surface and groundwater regimes both on and in proximity to the Site, including Site drainage characteristics;  The landscape character of the Site and its surrounding environs; and  Sensitive receptors that would be introduced to the Site as a result of the Proposed Development, including site workers and future residents, school children, tenants and other site users who would be present during the later phases of construction.

2.3.2 Consideration of whether these receptors are likely to be affected, and if so, to what extent, is provided in each technical assessment chapter (Chapters 6 – 15).

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EIA Scoping Report Chapter 3 Rugeley B Power Station, Rugeley

CHAPTER 3: PROPOSED DEVELOPMENT

3.1. DEVELOPMENT DESCRIPTION

3.1.1. The Proposed Development comprises comprehensive development of the Site, delivering circa 2,300 No. Residential Dwellings, circa 5 hectares (ha) of employment land, the associated access, community facilities including education and supporting amenity space, landscaping, green infrastructure and sustainable drainage systems. It will also involve some remediation and site re-profiling.

3.1.2. As set out in Chapter 2, it is important to note that the Proposed Development, does not include demolition works consented under prior approval (18/01098/FULM and CH/18/268) or the removal of Pulverised Fuel Ash (PFA) from the lagoon area and subsequent creation of a level platform for the purposes of Environmental Permit surrender in the east of the Site which are to be completed in advance of the Proposed Development. The baseline for the EIA therefore assumes the completion of these works.

3.1.3. As shown on Figure 2.2 – Drawing Skt170316-001 Rev F, the 400kV and 132kV Switching Stations and associated buildings are not scheduled for demolition and are to be retained as part of the Proposed Development. In addition, the demolition site boundary does not include the current Engie offices in the centre of the Site and Environmental Education Centre building located in the east of the Site. These buildings will be retained during the demolition works and removed as part of the Proposed Development.

Creation of a Suitable Development Platform

3.1.4. As set out in Chapter 2, extraction of PFA prior to the re-profiling and closure of the lagoons in the east under the existing Environmental Permit for the Site will continue and is anticipated to be completed in 2021 in advance of the proposed redevelopment of the Site. This therefore forms part of the assessment baseline for the EIA.

3.1.5. Subsequently, and as part of the Proposed Development further re-modelling will be undertaken in two areas of the Site (Lagoons and Golf Course and Leisure Area) as part of creating a suitable development platform. These areas are shown on Figure 3.1 – Drawing No. MP002 Rev D2.

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EIA Scoping Report Chapter 3 Rugeley B Power Station, Rugeley

Lagoons

3.1.6. As part of the re-profiling works associated with the Proposed Development a level platform will be created within the Lagoon area at a level currently believed to be 67m AoD. These works will be assessed in the EIA as part of the Proposed Development.

Golf Course and Leisure Area

3.1.7. PFA removal and re-modelling will be undertaken in the Golf Course and Leisure Area. The existing PFA material is to be removed from the Golf Course Area and the underlying material re profiled to the surrounding levels. These works will necessitate the removal of vegetation and trees in accordance with the current operating permits and demolition consent. As part of the above works a level platform will be created within the Lagoon area at a level currently believed to be 68m AoD.

3.1.8. At this stage it is not determined whether these works will form part of the site redevelopment works or be progressed separately under any necessary consents. Notwithstanding this, these works will be included within the EIA as part of the assessed project to ensure that all potential impacts and effects of the Proposed Development are identified and appropriately assessed.

3.1.9. The removal of PFA is expected to commence in March 2020 for the golf course and leisure area. The extraction of PFA and creation of suitable platforms in both areas is estimated to complete during 2021.

Combustion Environmental Permit Surrender Works

3.1.10. Rugeley B Power Station is currently in the process of closure prior to formal surrender of the Environmental Permits relating to the Site. The permit surrender process is subject to the Environmental Permitting regime dealt with by the Environment Agency.

3.1.11. Elements of work associated with Permit Surrender activities may constitute development (e.g. removal of sub-surface structures). Below ground works could include the excavation and removal of power station foundations, basements, culverts, ponds, the removal of void covers to the extent such materials are contaminated, removal of equipment from within voids, cleaning to remove debris and backfilling of voids / tunnel entry points. These works are currently anticipated to commence in 2020 and be ongoing during the construction phase of the Proposed Development.

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3.1.12. Similar to the works to be undertaken in the Golf Course and Leisure Area, at this stage it is not determined whether these works will form part of the anticipated planning application or can be progressed separately under permitted development rights or existing consents for the Site. Whilst the precise nature and extent of these works is not currently known an outline of these works will be included within the EIA either as part of the Proposed Development or as committed development in the assessment of cumulative effects.

3.1.13. It should be noted that an initial remediation strategy for the Site will be prepared as part of the Outline planning application and informed by the EIA (see Outline Proposals below). It is anticipated that a Detailed Remediation Strategy will be secured subject to planning conditions and implemented on a phased basis alongside the re-development.

Eastern Access Junction

3.1.14. In September 2017 Lichfield District Council granted planning consent (17/00453/FULM) for a second access to the Site from Rugeley Road (A513) including a new roundabout junction. This junction is associated with the closure of the power station following the cessation of to ensure that suitable access is provided during the decommissioning, demolition and restoration processes.

3.1.15. The location of the access was chosen as it aligned with the access principles to serve the, at that time, anticipated longer term redevelopment of the Site that are now to be delivered through the Proposed Development.

3.1.16. The application was supported by a series of surveys and technical assessments which demonstrated that the design was in accordance with highway standards, provided for the optimum distribution of traffic onto the highway network and, with suitable mitigation in place, would not result in significant environmental effects.

3.1.17. The location and design of the consented access junction is shown in Figure 3.2 – Rugeley Second Access – Site Location Plan and Figure 3.3 – Drawing J32-2608-PS-III.

3.1.18. The construction of this access does not form part of the Proposed Development. However, on the basis that it is assumed to be constructed alongside the Proposed Development it will be assessed in the EIA as committed development in the assessment of cumulative effects.

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Outline Proposals

3.1.19. The planning submission will be an outline application with an illustrative masterplan provided to demonstrate the principles that would govern the design of the detailed scheme as phases of the scheme come forward.

3.1.20. The maximum parameters of the Proposed Development for the purpose of the EIA assessment are anticipated to be (noting that design work is ongoing):

 Site remediation activities (likely to comprise removal of subsurface structures and contamination sources);

 Circa 2,300 dwellings comprising a mixture of market and affordable housing (Use Class C3);

 Circa 5 ha of employment land (Potential Use Classes B1, B2, B8);

 Community facilities, including education (Potential Use Classes A1-5, C2, D1-2);

 Open Space, Formal areas of Play, and associated facilities and amenity space, including, landscaping, green infrastructure and sustainable drainage systems;

 Primary vehicular access to the proposed development will be achieved from the existing access off the A51 and secondary access of the A513;

 Any wider land outside the site boundary needed for development specific infrastructure.

3.1.21. Primary vehicular access to the Proposed Development in the west is anticipated to be achieved from the A51 utilising the existing Site access. In the east primary vehicular access if anticipated to be from the A513 utilising the Site access consented under planning permission 17/00453/FULM.

Construction Methods of Working

3.1.22. It is anticipated that contractor compounds will be located as secure areas within the relevant phase under construction and will be relocated as each phase nears completion onto the subsequent phase. The precise nature and location of the contractor compounds cannot be determined at this time.

3.1.23. The working hours are anticipated to be:

 07:00 - 19:00 hours Monday to Friday inclusive;  08:00 - 13:00 hours on Saturday; and

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 No work to be carried out on Sundays or Bank Holidays.

3.1.24. In order to maintain these working hours, the contractor(s) may require a period of up to half an hour before and up to one hour after normal working hours for start up and close down of activities. This does not include operation of plant or machinery giving rise to noise with the potential to disturb nearby residents or the arrival of any HGV at site before 06:30 hours.

3.1.25. It is currently anticipated that construction will commence in 2022 and continue to 2047.

3.1.26. It is anticipated that development would be undertaken on a rolling programme of site preparation and construction, allowing earlier phases to be completed and occupied while subsequent phases are constructed. All materials and plant storage will occur on the Site and no off-site compounds are necessary. The on-site materials storage compound will be located in a position compatible with the ongoing phases of development.

Construction Environmental Management Plan (CEMP)

3.1.27. Details of measures to protect the environment during the construction of the Proposed Development will be set out in a CEMP. Measures will address hours of working, noise, vibration, dust, light spill, wheel washing and control of runoff. It is anticipated that the implementation of the CEMP will be a condition of the planning permission and that it will be regularly monitored.

3.1.28. Once finalised and approved by the Local Planning Authority, the CEMP would be held on- site. All site personnel would be made aware of its existence and undertake to adhere to the guidance.

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EIA Scoping Report Chapter 4 Rugeley B Power Station, Rugeley

CHAPTER 4: EIA APPROACH

4.1 EIA PROCESS

4.1.1 EIA is a process through which the likely significant environmental effects of a development proposal can be identified as part of the consenting of the development. In addition, it is an opportunity, where possible, for adverse effects to be avoided or mitigated or beneficial effects enhanced. The EIA process is reported in an ES which will be submitted as part of the application for consent.

4.1.2 The overall aim of the proposed EIA is to provide an objective and systematic account of any likely significant environmental effects of the development and for the decision maker to take these into account in determining any application for consent.

4.2 EIA SCREENING

4.2.1 The EIA Regulations require that before consent is granted for certain types of development, an EIA must be undertaken. The EIA Regulations set out the types of development which must always be subject to an EIA (Schedule 1 development) and other developments which will only require assessment if they are likely to give rise to significant environmental effects (Schedule 2 developments). Guidance and thresholds are available to help to decide whether EIA is required for a Schedule 2 development. This decision process is known as ‘screening’.

4.2.2 The selection criteria for screening Schedule 2 development are provided in Schedule 3 of the EIA Regulations. Schedule 2 projects require EIA if they are likely to have significant effects on the environment by virtue of their nature, size or location. The potential for likely significant effects on ‘sensitive areas’, as defined in Regulation 2(1) of the EIA Regulations, is a particularly important consideration.

4.2.3 The Proposed Development falls within Schedule 2 Section 10(b) of the EIA Regulations as an “Urban development project” in which “the development includes more than 1 hectare of urban development which is not dwellinghouse development”, “the development includes more than 150 dwellings”, and “the overall area of the development exceeds 5 hectares”. Owing to the nature and scale of the Proposed Development, the Applicant considers that it is likely to give rise to significant environmental effects. As such, it is considered that the Proposed Development qualifies as EIA Development as defined by the Regulations. The Applicant has not sought a screening opinion and the planning application will be accompanied by an Environmental Statement.

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4.3 EIA SCOPING

4.3.1 Part 4, Regulation 15 (1) of the EIA Regulations provides for an applicant to ask the Local Planning Authority (LPA), in this case CCDC and LDC, to provide a Scoping Opinion in which the information that should be provided within the ES is stated in writing.

4.3.2 When requesting a Scoping Opinion, under Part 4, Regulation 15 (2) the following must be provided:

 a plan sufficient to identify the land;  a brief description of the nature and purpose of the development, including its location and technical capacity;  an explanation of the likely significant effects of the development on the environment; and  such other information or representations as the person making the request may wish to provide or make.

4.3.3 It is the purpose of this EIA Scoping Report to provide sufficient information for CCDC and LDC to consider and consult upon the scope of the EIA to support the application for the Proposed Development.

4.4 SCOPE OF WORK

Technical Scope

4.4.1 In order to determine the likely scope of the EIA, the process has involved the following steps:

 identification of the Site and boundary;  identification of the key characteristics of the Site and the establishment of the environmental baseline through a series of desk and field studies;  identification of where there are gaps in the baseline and the further survey work required to address this;  initial consideration of the potential sources and nature of environmental effects through assessment against the environmental baseline; and  definition of the assessment methodologies to be used in each study area.

4.4.2 A series of baseline studies have been undertaken to establish the baseline environment for this Scoping Report. The baseline and assessment work undertaken as part of preparing this Scoping Report is set out within the relevant technical chapter.

4.4.3 In accordance with Schedule 4 of the EIA Regulations, the proposed ES will include:

 A description of the Proposed Development;

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 A description of the reasonable alternatives studied by the developer and reasons for the selected option;  A description of the baseline environment and likely evolution without the Proposed Development;  A description of the factors specified in specified in Regulation 4(2) likely to be significantly affected by the Proposed Development;  A description of the likely significant effects of the Proposed Development;  A description of the forecasting methods and evidence used in the assessment, including any difficulties experienced;  A description of the measures envisaged to avoid, prevent, reduce or, if possible, offset any identified significant adverse effects and, where appropriate, of any proposed monitoring arrangements; and  Where relevant, a description of the expected significant adverse effects of the development from vulnerability to major accidents or disasters.

4.4.4 Part 1, Regulation 4(2) of the EIA Regulations refers to the following environmental factors to be included in an appropriate manner in an ES: population, human health, biodiversity (fauna and flora), land, soil, water, air, climate, material assets, cultural heritage, and landscape and the interaction between these factors. Regulation 4(4) states that the significant effects to be identified, described and assessed under Regulation 4(2) include the expected significant effects arising from the vulnerability of the proposed development to major accidents or disasters that are relevant to that development.

4.4.5 The factors referred to in Regulation 4(2) are addressed as appropriate in the environmental topics set out in Table 4.1.

4.4.6 Table 4.1 provides a list of the topics that have been considered in the EIA scoping process. The results of the scoping process for each of the topics is presented in this report in Chapters 4, 6 – 15.

Table 4.1: Environmental topics considered in the EIA Scoping Process Topic EIA Scoping Report Chapter Scoped In / Out Accidents and Natural Disasters (excluding Out 4 flooding) Health and Safety 4 Out Waste 4 Out Soils and Agricultural Land 4 Out Climate Change 4 In Electromagnetic Radiation 4 Out Socio-Economics (includes population) 6 In Air Quality (includes human health) 7 In

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Archaeology 8 Out Built Heritage 9 In Ecology (Biodiversity) 10 In Water Environment (including Flood Risk) 11 In Noise and Vibration (includes human health) 12 In Ground Conditions (includes human health) 13 In Landscape and Visual Impacts 14 In Transport and Access (includes human health) 15 In

4.4.7 As part of the EIA scoping process, issues within the topic areas that have been identified as unlikely to give rise to significant environmental effects have been omitted (‘scoped out’) from the EIA.

Soils and Agricultural Land

4.4.8 As described in in Chapter 2 (Site Description), the Site is previously developed and does not comprise agricultural land. Annex 2 of the NPPF defines Best and Most Versatile (BMV) agricultural land as “Land in Grades 1, 2, and 3a of the agricultural land classification”. Therefore, redevelopment of this Site will not have any implications on the availability of BMV agricultural land in the area. As such, impacts related to agricultural land are proposed to be scoped out of the EIA.

4.4.9 Soils are addressed in Chapter 13 – Ground Conditions and is scoped in to the EIA.

Accidents, Fire and Natural Disasters

4.4.10 In the absence of recognised guidance on this subject in the context of EIA, a range of sources providing guidance related to the topic has been reviewed, including:

 Cabinet Office National Risk Register (NRR) of Civil Emergencies 2017 Edition1;  UK Government Emergency Response & Recovery Guidance2; and  International Federation of Red Cross & Red Crescent Societies Disaster and Crisis Management Guidance3.

1 Cabinet Office. (2017) National Risk Register of Civil Emergencies. [Online]. https://www.gov.uk/government/publications/national-risk-register-of-civil-emergencies-2017-edition.

2 International Federation of Red Cross and Red Crescent Societies, "The Red Cross Red Crescent approach to disaster and crisis management: Position paper," http://www.ifrc.org/PageFiles/91314/1209600-DM-Position-Paper-EN.pdf 2011.

3 International Federation of Red Cross and Red Crescent Societies, "What is a disaster?," http://www.ifrc.org/en/what-we- do/disaster-management/about-disasters/what-is-a-disaster/ 2017.

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4.4.11 A disaster can be defined as “a sudden, calamitous event that seriously disrupts the functioning of a community or society and causes human, material, and economic or environmental losses that exceed the community’s or society’s ability to cope using its own resources. Though often caused by nature, disasters can have human origins”.3 An accident can be defined as “an unfortunate incident that happens unexpectedly and unintentionally, typically resulting in damage or injury”4.

4.4.12 The Site’s location within the UK is such that natural disasters are not considered to represent a likely risk to the Proposed Development. For example, it is considered that the likelihood of an earthquake with a magnitude sufficient to cause damage to buildings and/or loss of life occurring and impacting the site is extremely low. Furthermore, the topography of the site is not considered to be sufficiently steep such that a major mass movement disaster could arise.

4.4.13 Given the nature of the Proposed Development, the potential for either large volume storage or frequent passage / delivery of fuels and chemicals during either the construction phase or following completion, is considered to be low when compared to more industrial development proposals such as chemical works, storage depots, docks, or major highways.

4.4.14 The Proposed Development will be designed in accordance with recognised and accepted best practice in terms of highway design, specification of drainage and current building regulations.

4.4.15 It is therefore considered that whilst there is always a potential risk that an accident, fire or natural disaster could result in a significant environmental impact, this risk can be appropriately mitigated through embedded design measures and through compliance with statutory design guidelines. It is therefore proposed that the EIA will not, with the exception of flooding, include accidents, fire and natural disasters.

4.4.16 Flooding is addressed in Chapter 11 – Water Environment and is scoped in to the EIA.

Climate Change

4.4.17 The ES will not include a separate chapter on climate change and greenhouse gas emissions. This assessment will be primarily achieved through the Sustainability Statement which will be appended to the ES. The Sustainability Statement will include consideration of the impact of the Proposed Development upon climate change and emissions. Each chapter will, however,

4 Oxford English Dictionary. 2018. [Online]. https://en.oxforddictionaries.com/definition/accident.

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consider whether and how climate change could affect the findings of the assessments as set out below.

4.4.18 EIA is a key tool for ensuring that future that future development is resilient to the potential effects of climate change and that the proposals do not exacerbate climate change effects on human or natural systems. The Institute of Environmental Management and Assessment (IEMA) has published an ‘EIA Guide to Climate Change Resilience and Adaptation’ (November 2015) which provides a framework for the effective consideration of climate change resilience and adaption in the EIA process. This guidance states that the scoping of a project, taking into account climate change, should focus on general considerations rather than detailed, quantitative analysis.

4.4.19 There are significant uncertainties in the magnitude, frequency and spatial occurrence of climate change projections and information, which make it difficult to assess the impact of climate change in relation to a specific project. IEMA guidance notes that EIAs consider specific sites, whereas climate change models are prepared at a regional or national scale, thus adding uncertainty when with predictions on such a small area.

4.4.20 The EIA will refer to, and rely upon, the UKCP18 (or any subsequent revisions) to conduct a high-level assessment of climate risk and the description of the Proposed Development will include consideration of climate change and greenhouse gases, supported by the proposed Sustainability Statement.

4.4.21 Scheme design and any proposed mitigation or enhancement measures will look to reduce the potential for the proposals to contribute towards climate change and ensure that the development is resilient to the effects of climate change.

4.4.22 In line with IEMA guidance, the impact of climate change on the Proposed Development will be assessed by way of a potential future baseline scenario. Utilising climate change projections, the EIA will qualitatively assess how potential climate change may alter the predicted effects of the development. It is unlikely that completely new direct impacts will arise as a result of climate change based on the current conditions, but the geographic spread or scale of potential impacts might be changed when considered against the future baseline conditions.

4.4.23 As the Proposed Development will be considered as an outline planning application, detailed information about the buildings proposed and construction will not be known. As such, it will not be possible to consider all potential and appropriate adaptive measures and construction methods. However, where appropriate during the masterplanning stage of the project, the designers and project team will consider design features which could contribute to providing

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appropriate resilience to climate change and consider where there may be opportunities to introduce adaptive measures later in the design process. Climate change will be embedded into each stage of project design. These mitigation, resilience and adaption measures will be outlined in the ES.

Electromagnetic Radiation

4.4.24 As stated in Chapters 2 and 3, the 132kV and 400kV Switching Stations present on the Site are not scheduled for demolition and will remain operational alongside the Proposed Development.

4.4.25 In order to ensure that any retained National Grid electrical equipment will continue to operate safely alongside the Proposed Development, an electromagnetic field (EMF) survey and assessment was commissioned by the Applicant. The Electromagnetic Field Assessment is provided in Appendix 4.1 and ascertains ambient levels of EMF radiating from a retained 132 kV Switching Station and a 400 kV Switching Station.

4.4.26 In relation to the operation of electronic equipment, the results of the EMF survey confirm that highest likely power frequency EMF levels at closest locations of the 132 kV and the 400 kV switching stations to future residential dwellings will be sufficiently low and will be well below the EU Standard immunity level of 3.78 uT.

4.4.27 In relation to health and safety, the highest power frequency EMF level was 48.38 uT recorded around the 132 kV Switching Station, which is 2.1 times lower than the Public Health England (PHE)/International Commission on Non-Ionising Radiation Protection (ICNIRP) limit of 100uT. The highest electric field level was 220 V/m recorded around the 400 kV Switching Station, which is almost 23 times lower that the PHE/ICNIRP limit of 5000 V/m.

4.4.28 The Electromagnetic Field Assessment concludes: “EMF results confirmed that highest likely EMF levels were below UK/European recommended health and safety limits for the general public and would also allow the reliable operation of standard IT/communications equipment within any homes that may be built at the residential development.”

4.4.29 Therefore, significant effects related to electromagnetic radiation are not considered likely to result from the Proposed Development. It is therefore proposed that the EIA will not include electromagnetic radiation.

Health and Safety

4.4.30 The Site is not located within or near any sites identified in zones for the Health and Safety Executive (HSE). Such zones are established around major hazard sites and pipelines for the

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purposes of consultation with the HSE upon any potential risks presented to either a proposed development or existing sites.

4.4.31 Therefore, significant effects related to Health and Safety associated with major hazard sites are not considered likely to result from the Proposed Development. It is therefore proposed that the EIA will not include health and safety associated with major hazard sites. Health and safety impacts arising as a result of topic specific impacts (e.g. Ground Conditions, Transport and Access) will be considered as appropriate (See Chapters 6-15).

Waste

4.4.32 Developments result in both construction and operational (municipal & commercial) waste arisings. Waste Disposal Authorities are responsible for ensuring that the Waste Local Plan provides for sufficient facilities to exist to manage anticipated waste arisings (this includes ensuring that sufficient sites exist for merchant facilities for the management of construction and commercial waste). Waste Collection Authorities are responsible for ensuring that sufficient infrastructure exists for the collection of anticipated municipal waste arisings.

4.4.33 Planning permission is granted for a residential / commercial development proposal on the basis that it is, for example, in accordance with the development plan or necessary to meet a housing need. On this basis, the waste arisings of a proposed development are either anticipated because they are already planned for or should be anticipated as the need for additional housing comes out of predictable (and calculated) scenarios that the Waste Collection/ Disposal Authorities should have already taken into account in their forward plans.

4.4.34 Therefore, the management of waste arisings from an urban development project should be considered as a policy issue and not a development specific environmental issue.

4.4.35 Therefore, it is not proposed that a specific waste chapter will be incorporated into the ES. However, in accordance with the EIA Regulations, the Proposed Development description, upon which the EIA will be based, will include estimated volumes of waste associated with construction activities (Construction, Demolition and Excavation waste) and the operational phase of the Proposed Development (Municipal Solid Waste, Commercial Waste).

Geographic Scope

4.4.36 The proposed EIA will include the physical extent of the Site, as shown on Figure 2.1 – Drawing 01585_SK_003 (Red Line Plan). Additionally, the proposed EIA for individual topic chapters will exceed beyond this red line where necessary for the scope of the assessment. This is set out and explained, where relevant, in each of the topic chapters.

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4.4.37 The nature of the current environmental conditions and the manner in which impacts are likely to be generated will mean that the influence of many potential impacts can extend beyond the immediate Site boundary. Where identified and relevant, such impacts will be assessed as part of the EIA.

4.4.38 The geographical extent of the EIA will also consider the potential implications of related and un-related development activities and any other land required for development specific infrastructure outside the current Site boundary.

Temporal Scope

4.4.39 The timing and phasing of the Proposed Development is not currently fixed. However, it is anticipated that construction will commence in 2022 and complete in 2047 with first residential occupations beginning before 2024. The EIA will consider impacts arising from both construction and operational phases of the Proposed Development. Whilst elements will be redeveloped, replaced and renewed over time, the Proposed Development is designed as a permanent provision and therefore a demolition phase of the project is not applicable.

4.4.40 Unless stated otherwise within a technical chapter, the proposed EIA will assess the effects of the Proposed Development arising during the anticipated construction phase and the occupation phase.

4.4.41 Unless stated otherwise within a technical chapter, the proposed EIA will be based upon the following scenarios: Baseline; Baseline + Proposed Development; and Baseline + Proposed Development + Cumulative Development.

Cumulative Scope

4.4.42 The Planning Practice Guidance: Environmental Impact Assessment (Planning Paragraph: 024 Reference ID: 4-024-20170728: Revision date: 28 07 2017) states the following in relation to the assessment of cumulative effects:

‘Each application (or request for a screening opinion) should be considered on its own merits. There are occasions, however, when other existing or approved development may be relevant in determining whether significant effects are likely as a consequence of a proposed development. The local planning authorities should always have regard to the possible cumulative effects arising from any existing or approved development.’

4.4.43 The potential cumulative effects of the Proposed Development in association with other committed developments, both during the construction phase and following completion, will be

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included. These committed developments include those referred to in Chapters 2 and 3 of this Scoping Report.

4.4.44 In accordance with the Planning Practice Guidance, as part of the EIA process Savills proposes to consult with CCDC and LDC to screen for other existing or approved developments that could give rise to significant cumulative effects. Planning Practice Guidance is clear that cumulative assessment in EIA should be based upon ‘existing and approved’ development, as such, the below schedule does not include existing or emerging allocations as these are not existing or approved developments.

4.4.45 Taking into account the proposed technical scope of the EIA, it is proposed that the cumulative assessment will consider residential and other developments within 5km of the Site boundary that are of a substantial size (e.g. 80+ units) that are considered to have the potential to result in significant effects, and which benefit from an extant planning consent. Assessments of likely cumulative effects will be made within the relevant technical chapters of the ES.

4.4.46 Table 4.2 shows existing or approved schemes of a substantial size (50 residential units, 1,000sqm non-residential development) within 5km of the Site. A 5km threshold has been applied on the basis that beyond this distance significant cumulative effects are not considered to be likely. The Applicant seeks to agree a schedule of committed developments in writing with the LPAs as part of the EIA Scoping process. This schedule will be updated as appropriate both before and during the preparation of the EIA.

4.4.47 In addition to Table 4.2, Appendix 4.1 contains a long list of schemes which were considered during the identification of cumulative projects for the purposes of the EIA, including the rationale behind the exclusion of any that are not present within Table 4.2.

4.4.48 It is proposed that these committed schemes form the basis for the proposed assessment of potential cumulative effects alongside high level consideration of related offsite infrastructure provision (highways and drainage) so far as is reasonable taking into account the availability of information at the time of assessment.

Table 4.2: Proposed Cumulative Schemes Approxi Timing Assumptions Residential mate Application Units / Non- Local Site Address Distance Reference Residential Authority to site Floor space (km) Site Eastern Access Concurrent with the 17/00453/FU Junction (see Chapter N/A LDC 0 Proposed Development LM 3) Combustion Concurrent with the Environmental Permit CCDC and Proposed Development N/A N/A 0 Surrender Works (see LDC Chapter 3)

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Former Ultra 52 of 103 dwellings Electronics Site, Main CH/14/0293 120 CCDC 0.5 completed, as of Aug Road, Rugeley 2018. Joint venture between Former Pear Tree Cannock Chase Council Community Primary and Staffs County School, Hardie Avenue, CH/15/0084 72 CCDC 1.0 Council. Liaising with Rugeley and Land potential developers on South of Wharf Road scheme. Land Adjacent Hayes Construction predicted to Meadow Primary start in 20/21 with a build 15/01198/O School, Spode Avenue, 200 LDC 2.4k out rate of 50 dwellings UTM Handsacre, Rugeley, per annum. Staffordshire

NOTE: – the scope of committed developments for the purposes of the Transport Assessment (TA) will be established via the TA scoping process and will differ from the above schedule (e.g. through the inclusion of Local Plan allocated sites and other highways commitments). The assessment of cumulative effects in the Transport, Noise and Air Quality ES chapters will be based upon the committed schemes agreed for the TA to ensure consistency with the agreed transport modelling.

The Baseline

4.4.49 The assessments will be based on the comparison of qualitative and, where possible quantitative, predicted impacts, compared with current or recent baseline environmental conditions. Any significant changes expected in future baselines due to environmental trends will also be described qualitatively, or in certain cases calculated as quantitative future baseline to allow meaningful future year assessment. These future year baselines can take account of cumulative developments not yet built but in the planning system. These approaches are explained in further detail in the relevant chapters concerned.

4.5 EIA TERMS OF REFERENCE AND METHODOLOGY

Proposed Development Parameters

4.5.1 In order for the significant environmental effects of the Proposed Development to be identified and assessed, it is necessary to clearly identify all the components of the Proposed Development. However, in many cases the details of the development have not as yet been decided / agreed at the scoping stage and are reserved for later consideration by the Applicant and CCDC and LDC.

4.5.2 In order to enable the consideration of the scope of the potential effect of the construction and operation of the Proposed Development, the proposals at this stage will be within a maximum envelope defined by the Proposed Development parameters.

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4.5.3 In undertaking the assessment of the EIA, parameters will be fixed which allow some flexibility for the Proposed Development within defined limits. Such parameters include residential unit numbers and building heights, floorspace for particular use classes and the extent of site preparation works. These will be outlined as maximum in order to provide assessment of the ‘worst case’. Thus allowing inherent flexibility for future applications within these parameters. This is known as the ‘Rochdale Envelope’5.

4.5.4 Alongside the Proposed Development description, it is anticipated that, subject to the evolution of the Proposed Development design, the EIA will consider a number of key development parameters, including:

 Land Use Areas;  Movement and Access Strategy;  Maximum Building Heights; and  Areas of Green Infrastructure.

Impact Assessment Guidance

4.5.5 The assessments that will be presented in the ES for the proposed comprehensive single outline application will consider the potential for significant environmental impacts to affect the baseline conditions as a direct/ indirect result of the Proposed Development.

4.5.6 A description of the aspects of the environment likely to be significantly affected by the Proposed Development is a requirement of the EIA Regulations. The baseline conditions are defined as the existing state of the environment and how it may develop in the future in the absence of the proposals and with certain committed developments included.

4.5.7 In order to forecast potential future effects, it is necessary to make predictions. To ensure that predictions are as accurate as possible, a description of the methods used to assess the effects of the Proposed Development is also required by the EIA Regulations.

4.5.8 Unless specifically stated otherwise, the proposed assessments will be undertaken in accordance with best practice guidelines published by the relevant professional bodies. Each technical chapter in this Scoping Report provides brief details of the proposed baseline and assessment methodology to be employed for that topic area. The subsequent ES will provide

5 R. v Rochdale MBC ex parte Milne (No. 1) and R. v Rochdale MBC ex parte Tew [1999] and R. v Rochdale MBC ex parte Milne (No. 2) [2000].

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full details of the assessment criteria and terminology used in the context of that technical discipline.

4.5.9 Where there is no topic-specific guidance available, a generic framework of assessment criteria and terminology has been developed to enable the prediction of potential effects and their subsequent presentation. The development of this framework has drawn upon Savills experience of undertaking EIA.

Generic Assessment Framework

4.5.10 Each technical chapter of the ES will detail the methodology used for its assessment. Unless otherwise specified in the specific technical chapter the ES will generally follow the generic assessment framework detailed below.

Receptor Sensitivity and Impact Magnitude

4.5.11 Receptors are those aspects of the environment sensitive to changes in baseline conditions. The sensitivity of a particular receptor depends upon the extent to which it is susceptible to such changes.

4.5.12 Impact magnitude is determined by predicting the scale of any potential change in the baseline conditions. Where possible magnitude is quantified, however where this is not possible a fully defined qualitative assessment is undertaken. The assessment of magnitude is carried out taking account of any inherent design mitigation in the proposal that forms part of the development description.

Table 4.3: Receptor Sensitivity and Impact Magnitude Receptor Impact Sensitivity to Change Magnitude of Change Very High VH Very High VH High H High H Medium M Medium M Low L Low L Very Low VL Very Low VL Negligible N Negligible N

Effect Significance

4.5.13 As shown in Table 4.4, the effect significance is determined by combining the predicted magnitude of impact with the assigned sensitivity of the receptor. Where two terms are given (e.g. Minor-Neutral) the effect significance is on the boundary between the two assessed effects Table 4.5 sets out the broad definitions of significance. The definition of the level of

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significance at which a significant impact arises will be provided within the topic method section of each chapter of the ES.

Table 4.4: Effect Significance

Receptor Sensitivity Criteria VH H M L VL VH Substantial Substantial Major Moderate Moderate

H Substantial Major Moderate Moderate Minor M Major Moderate Moderate Minor Minor

Positive L Moderate Moderate Minor Minor Minor-Neutral VL Moderate Minor Minor Minor-Neutral Minor-Neutral Negligible Neutral Neutral Neutral Neutral Neutral VL Moderate Minor Minor Minor-Neutral Minor-Neutral

L Moderate Moderate Minor Minor Minor-Neutral

Impact Magnitude M Major Moderate Moderate Minor Minor H Substantial Major Moderate Moderate Minor

Negative VH Substantial Substantial Major Moderate Moderate

Table 4.5: Definition of Significance Significance Definition Substantial These effects represent key factors in the decision-making process. They are generally, but not exclusively associated with sites and features of national importance and resources/features which are unique and which, if lost, cannot be replaced or relocated. Major These effects are likely to be important considerations at a regional or district scale but, if adverse, are potential concerns to the Proposed Development, depending upon the relative importance attached to the issue during the decision-making process. Moderate These effects, if adverse, are important at a local scale, and are considerations for the decision maker. The cumulative effect of such issues may lead to an increase in the overall effects on a particular area or on a particular resource. Minor These effects may be raised as local issues but are unlikely to be of importance in the decision-making process. Nevertheless, they are of relevance in the detailed design of the Proposed Development. Neutral Effects which are beneath levels of perception, within normal bounds of variation or within the margin of forecasting error.

4.5.14 As required by the EIA Regulations, the likely significant effects of the Proposed Development are described as:

 Adverse or beneficial  Direct or indirect  Temporary or permanent

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 Reversible or irreversible  Cumulative

4.5.15 Adverse effects are undesirable and result from negative impacts. Beneficial effects are desirable and result from positive impacts.

4.5.16 Each effect will have a source originating from the Proposed Development, a pathway and a receptor. Effects which operate in this direct way are regarded as direct effects. Effects on other receptors via subsequent pathways are regarded as indirect effects.

4.5.17 Unless stated otherwise, effects of moderate significance or above are considered to be significant in EIA terms.

Initial and Residual Effects

4.5.18 As stated previously, the EIA process enables the likely significant effects of a proposed development to be identified so that, where possible, adverse effects predicted to arise as a result of the proposal can be avoided or mitigated through the adoption of suitable measures. Additionally, enhancement measures can be incorporated to maximise the beneficial effects of the development. The adoption of mitigation and enhancement measures results in initial and residual effects. These can be defined as:

 Initial Effects: Effects occurring as a result of the Proposed Development prior to the adoption of any additional mitigation or enhancement measures.  Residual Effects: Effects occurring as a result of the Proposed Development taking into account the adoption of identified additional mitigation or enhancement measures.

4.5.19 Additional mitigation and enhancement is defined as a measure that is additional to the Proposed Development as initially proposed. Measures that design out significant effects that form an inherent part of the Proposed Development as proposed, known as inherent mitigation, are considered in the initial impact.

4.5.20 For example many environmental constraints, such as flood risk, must be designed out of a project for it to be viable and it would be impractical to consider the Proposed Development without such measures in place.

In-Combination Effects

4.5.21 In-combination effects relate to multiple effects from a single development, which may give rise to a potentially significant impact upon a receptor. Alongside identification as part of individual topic chapters, the assessment of in-combination effects will take the form of a matrix

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identifying the sensitive receptors and the different effects arising from the proposed development likely to be experienced at each – for example, an individual receptor close to the Site boundary may be affected by noise and visual effects.

EIA Assumptions and Limitations

4.5.22 The following key assumptions will be made in preparing the ES:

 All legislative requirements will be met. Therefore, any standard guidance which is provided to ensure minimum legal compliance is not considered to constitute mitigation in the EIA. The assessment of effects prior to the adoption of mitigation measures will assume that all legislative requirements will be met.  The assessment of effects prior to the adoption of mitigation measures will assume that the Proposed Development will be constructed in accordance with industry standard techniques. Such techniques will therefore not be considered as mitigation.  Where further assumptions have been made for individual topic assessments these will be identified within the relevant topic chapters.  Any limitations or uncertainties associated with impact prediction or the sensitivity of receptors due to the absence of data or other factors will give rise to uncertainty in the assessment. Any such limitations will be referred to in the relevant technical chapters of the ES.

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CHAPTER 5: ALTERNATIVE OPTIONS AND CONSULTATION

5.1 DEVELOPMENT ALTERNATIVES

5.1.1 Schedule 4, paragraph 2 of the EIA Regulations requires Environmental Statements to include:

‘A description of the reasonable alternatives (for example in terms of development design, technology, location, size and scale) studied by the developer, which are relevant to the proposed project and its specific characteristics, and an indication of the main reasons for selecting the chosen option, including a comparison of the environmental effects.’

5.1.2 As there are no alternative sites within the Applicants’ control, alternative sites will not been considered by the Applicant or assessed by the EIA.

5.1.3 Given the nature and purpose of the Proposed Development, the assessment of alternatives to the development that will be presented in the ES will consider options within the following categories:

 ‘Do Nothing’: under this scenario no development is implemented at the Site and baseline conditions continue in their current trends;

 A different design: under this scenario the Proposed Development is realised with alternative scales and layouts, often in the context of developmental constraints present at the Site;

5.2 CONSULTATION

5.2.1 In the lead up to the planning application and throughout the development design, a programme of consultation has and will continue to be undertaken with statutory and non- statutory consultees and with members of the public. Further technical consultation will also be undertaken as part of the ongoing EIA process, including consultation with Natural England, Highways England and the Environment Agency.

5.2.2 A summary of relevant consultation will be presented in the introductory sections of the ES. This will provide details of any environmental issues raised and provide an audit trail of how the EIA process has responded to these issues. Consultation that is specific to particular topics will be reported, where relevant, within the corresponding chapters of the ES.

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5.2.3 Details of technical consultation, directly related to the production of this Scoping Report are provided in the methodology and baseline sections of each topic chapter.

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CHAPTER 6: SOCIO-ECONOMICS

6.1 INTRODUCTION

6.1.1 This chapter of the Scoping Report has been produced by Savills and sets out the methodology to assess the potential effects on social infrastructure and the economy that the Proposed Development may have on the Site and the surrounding area during the construction phase and subsequently on completion. Socio-economic effects are scoped in to the proposed EIA.

6.1.2 The consideration of socio-economic conditions within the context of the ES will cover issues such as demographic changes and economic effects, which are generally considered to be medium and long term effects.

6.1.3 The ES will also provide an assessment of the effects of the Proposed Development on a range of community facilities. The analysis will consider the demographic context of the surrounding area and establish the existing levels of provision for a range of facilities and services in the vicinity of the site. The potential impact arising from the Proposed Development will be considered, whilst accounting for facilities which will be provided as part of the scheme.

6.1.4 Finally, a section on mitigation will be provided, which will set out any measures that are designed to bring forward socio-economic and community benefits, and ameliorate potential adverse impacts.

6.2 ASSESSMENT CRITERIA & METHODOLOGY

Previous Assessment

6.2.1 There is no previous assessment relevant to the Site; albeit, there have been a number of Environmental Statements produced in support of planning applications within the locale, see Table 3.2 for a list, which given the nature of socio-economic impacts, will be relevant when undertaking the EIA.

Legislative Context

6.2.2 There is no legislation specifically relevant to the socio-economic assessment.

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Planning Policy and Guidance

6.2.1 There are a range of documents which are relevant to the undertaking of the socio-economic assessment at the national, regional and district-level. In particular :

 National Planning Policy Framework (NPPF) (2018);

 National Planning Practice Guidance (PPG);

 Cannock Chase Local Plan (2014)

 Lichfield Local Plan (2015)

 Lichfield Local Plan Allocations Proposed Submission (2018)

National Planning Policy

National Planning Policy Framework

6.2.3 The revised National Planning Policy Framework (NPPF), published in 2018, is underpinned by the presumption in favour of sustainable development, with a clear objective of supporting the supply of homes and economic growth.

6.2.4 In relation to sustainable communities, the NPPF states at paragraphs 91, 92, 94, and 96-98:

“Planning policies and decisions should aim to achieve healthy, inclusive and safe places which:

 promote social interaction, including opportunities for meetings between people who might not otherwise come into contact with each other – for example through mixed- use developments, strong neighbourhood centres, street layouts that allow for easy pedestrian and cycle connections within and between neighbourhoods, and active street frontages;

 are safe and accessible, so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion – for example through the use of clear and legible pedestrian routes, and high quality public space, which encourage the active and continual use of public areas; and

 enable and support healthy lifestyles, especially where this would address identified local health and well-being needs – for example through the provision of safe and

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accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling.

To provide the social, recreational and cultural facilities and services the community needs, planning policies and decisions should:

 plan positively for the provision and use of shared spaces, community facilities (such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship) and other local services to enhance the sustainability of communities and residential environments;

 take into account and support the delivery of local strategies to improve health, social and cultural well-being for all sections of the community;

 guard against the unnecessary loss of valued facilities and services, particularly where this would reduce the community’s ability to meet its day-to-day needs;

 ensure that established shops, facilities and services are able to develop and modernise, and are retained for the benefit of the community; and

 ensure an integrated approach to considering the location of housing, economic uses and community facilities and services.”

“It is important that a sufficient choice of school places is available to meet the needs of existing and new communities. Local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement, and to development that will widen choice in education. They should:

 give great weight to the need to create, expand or alter schools through the preparation of plans and decisions on applications; and

 work with schools promoters, delivery partners and statutory bodies to identify and resolve key planning issues before applications are submitted.”

“Access to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from the assessments should be used to determine what open

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space, sport and recreational provision is needed, which plans should then seek to accommodate.

Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless:

 an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or

 the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or

 the development is for alternative sports and recreational provision, the benefits of which clearly outweigh the loss of the current or former use.

Planning policies and decisions should protect and enhance public rights of way and access, including taking opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails.”

Local Planning Policy

Current Planning Policy

6.2.5 There are a range of policies in the Cannock Chase Local Plan and Lichfield Local Plan which are relevant to the proposed socio-economic assessment, including:

Cannock Chase Local Plan

 Policy CP2 - Developer Contributions for Infrastructure

 Policy CP5 - Social Inclusion and Healthy Living

 Policy CP6 - Housing Land

 Policy CP7 - Housing Choice

 Policy CP8 - Employment Land

 Policy CP9 - A Balanced Economy

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Lichfield Local Plan

 Core Policy 2: Presumption in Favour of Sustainable Development

 Core Policy 3: Delivering Sustainable Development

 Core Policy 4: Delivering our Infrastructure

 Core Policy 6: Housing Delivery

 Core Policy 7: Employment & Economic Development

 Core Policy 10: Healthy & Safe Lifestyles

 Core Policy 11: Participation in Sport & Physical Activity

Emerging Planning Policy

6.2.6 Both Local Plans are currently under review. The emerging plans are at an early stage, and they, alongside their emerging evidence base, will be considered as appropriate within the socio-economic assessment.

Guidance/ Best Practice

6.2.7 There are a range of additional documents which will be considered as appropriate during the socio-economic assessment, including:

 Rugeley Power Station Development Brief SPD (2018)

 Cannock Chase Developer Contributions and Housing Choices Supplementary Planning Document (2015)

 Cannock Chase Community Infrastructure Levy Charging Schedule (2015)

 Cannock Chase Infrastructure Levy Regulation 123 List (2016)

 Lichfield Community Infrastructure Levy Charging Schedule (2016)

 Lichfield Community Infrastructure Levy Regulation 123 List (2017)

 Lichfield Developer Contributions SPD (2016)

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 Staffordshire County Council Childcare Sufficiency (2018)

 Staffordshire County Council Sites for Potential New Free Schools (2018)

 Stoke-on-Trent & Staffordshire Strategic Economic Plan (April 2018)

 Fields In Trust Guidance for Outdoor Sport and Play Beyond the Six Acre Standard (2015)

 Homes and Community Agency Additionality Guide (2016)

 Homes and Community Agency Urban Design Compendium (2000)

 The Institution of Highways and Transportation Providing for Journeys on Foot (2000)

 Department for Transport Manual for Streets (2007)

 Department for Transport Manual for Streets (2008)

 South Staffordshire GPFV Delivery Plan 2017/18 to 2018/19 (2017)

Baseline Data Collection

6.2.8 Baseline information on the socio-economic conditions of the area will be collated from a variety of sources including:

 National Census (2001) and (2011) and other ONS-produced sources

 NOMIS labour market statistics

 Indices of Multiple Deprivation

 Cannock Chase District Council

 Lichfield District Council

 Staffordshire County Council

 Stoke-on-Trent & Staffordshire Enterprise Partnership

 Greater Birmingham and Solihull Enterprise Partnership ;and

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 NHS Choices and Cannock Chase Clinical Commissioning Group.

6.2.9 These will provide a broad quantitative ‘baseline’ of socio-economic conditions. It should however be stressed that many social and community effects are by definition complex, interrelated, and difficult to characterise or measure in any precise way. As a result, some judgements are necessarily subjective.

Proposed Assessment Methodology

6.2.10 Quantitative assessment will be used where possible and significance criteria will be produced to ensure that there is a consistent identification of effects applied during the assessment. Due to the complexity of socio-economic issues and the numerous interactions that can occur with neighbouring and more distant communities, it is not possible to predict the precise nature or scale of each impact. Qualitative assessment will therefore also be used where necessary.

6.2.11 The level of significance of an effect will be determined through professional judgement of factors such as the scale or sensitivity of the receptor group and the magnitude of the impact (the amount of change).

6.2.12 The level of significance is determined with reference to planning policy, best practice guidance and relevant contextual factors. For example, employment generation of 100 new jobs could be considered a major beneficial effect in a settlement of 1,000 residents, but it would be a less significant effect in a larger settlement of 100,000 residents.

6.2.13 Where possible, the assessment of significance will be consistent with the Generic Assessment Framework in Chapter 4 and defined as below (Table 6.1):

Table 6.1: Definition of Significance

Significance Definition These effects represent key factors in the decision-making process. They are generally, Substantial but not exclusively associated with resources/ features which are unique and which, if lost, cannot be replaced or relocated. These effects are likely to be important considerations to the receptors but, if adverse, Major are potential concerns to the project, depending upon the relative importance attached to the issue during the decision making process. These effects, if adverse, while important to the receptors, are not likely to be key Moderate decision making issues. Nevertheless, the cumulative effect of such issues may lead to an increase in the overall effects on receptors. These effects may be raised as issues but are unlikely to be of importance in the Minor decision making process. Nevertheless, they are of relevance in the detailed design of the project. Effects which are beneath levels of perception, within normal bounds of variation or Negligible within the margin of forecasting error.

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6.2.14 Impacts that are moderate or larger in scale are considered to be significant in EIA terms.

6.2.15 The methodology for assessing economic impacts will involve the following key stages:

 An analysis of the current state of the local economy including unemployment, skills and occupation profile of residents;

 An assessment of the employment potential of the commercial and residential space included within the proposal; and

 The assessment of employment benefits will follow best practice guidance (for example, the Homes and Community Agency’s Additionality Guide, 2016), applying assumptions to account for leakage, displacement and multiplier effects.

6.2.16 The methodology for assessing the impact of housing will consider:

 The scale in the context of annual housing delivery targets for Cannock Chase and Lichfield District Councils.

6.2.17 The methodology for assessing impacts on users of social infrastructure will involve the following key stages:

 Identification of existing social infrastructure within walking distance of the Site, including access to primary health care facilities

 Assessment of whether there is any spare capacity in the current social infrastructure

 Projection of demand for social infrastructure from the incoming population

 Assessment of whether the Site will meet the needs of the incoming population, accounting for any spare capacity in existing infrastructure.

Geographical Scope

6.2.18 The principal study area for the purposes of this chapter is derived from the research and policy into ‘walkable neighbourhoods’ [(Urban Design Compendium [2000, HCA) Guidelines for Providing Journeys on Foot (Institute of Highways & Transportation, 2000); Manual for Streets (DfT, 2007), Building Sustainable Transport into New Developments (DFT, 2008). This is equivalent to a 10 min walk at an average walking speed (1.4 m/s, see p48 Guidelines for

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Providing Journeys on Foot (Institute of Highways & Transportation, 2000)], or 800m. In Savills experience, this approximately relates to a catchment of 600m with a straight line distance, taking into account street patterns and walking routes. The Manual for Streets (DfT, 2007) states that 800m is not an upper limit and journeys up to 2km could be considered suitable for walking, where the journey would be safe for pedestrians and in attractive surrounds. We therefore also use a catchment area of 2km (1.5km straight line distance) as the maximum parameter of walking distance to local social infrastructure, if the route is safe and attractive. The Site’s principal study area is shown on Figure 6.1.

Figure 6.1 Primary Study Area

6.2.19 The following social infrastructure would be assessed against this ‘walkable’ study area:

 Pre-school and primary schools

 Community centres

 Smaller typologies of open space including child play space; and

 Primary health care – GP surgeries and dental practices.

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6.2.20 Other geographic areas of analysis will be:

 Secondary schools – the average distance travelled to secondary schools in the was 3.4 miles (5.4 km) in the National Travel Survey (2014/15; Table NTS9908).

 Housing impact – Cannock Chase and Lichfield district councils, with housing targets from the relevant local plans derived from relevant housing market areas.

 Economic impact – analysis of Census travel-to-work data shows that those that work in Cannock Chase and Lichfield are principally drawn from those districts and South Staffordshire. We will assess the employment effects of the Proposed Development against this labour market area.

 Larger types of open space - Cannock Chase and Lichfield district councils.

Temporal Scope

6.2.21 Potential impacts and effects upon socio-economic receptors will be assessed in relation to temporary and permanent impacts. As a general rule, temporary impacts relate to construction phases of development and permanent impacts relate to the occupation/operational phase.

6.3 BASELINE ENVIRONMENT

6.3.1 The socio-economic impact assessment assesses the impact of the Proposed Development on the population; a receptor under the 2017 EIA Regulations. The following have been considered as potential receptors and will be discussed under the following headings:

 Residents in the housing market area looking for new housing;

 Residents in the economic impact area that could work on the construction project;

 Residents in the economic impact area that could benefit from employment opportunities associated with the new household expenditure;

 Residents in the economic impact area that could benefit from employment opportunities on the proposed employment land;

 Residents in the Principal Study Area using or planning to use primary education;

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 Residents in the Impact Area Related to Secondary Schools using or planning to use secondary education;

 Residents in the Principal Study Area using or planning to use GP services;

 Residents in the Principal Study Area using or planning to use dental services;

 Residents in the Impact Areas Related to Open Space using open space; and

 Residents in Impacts Areas Related to Child Play Space using child play space.

6.3.2 The baseline will set out the characteristics of the local economy and workforce, such as economic activity, unemployment rates, skills and qualifications, occupation profile. It will also assess the characteristics of the existing population e.g. age, household composition, and levels of deprivation.

6.3.3 The baseline will also consider the current provision of social infrastructure within the Principal Impact Area, setting out any spare capacity of primary and secondary schools, GPs, dentists, and open space.

6.4 POTENTIAL ENVIRONMENTAL IMPACTS & EFFECTS

6.4.1 Potential impacts are likely to relate to:

 The number of new construction jobs created and the capacity of the local construction labour market to meet this construction demand;

 The number of new jobs as a result of the potential local employment land/community facilities, and residential units;

 The potential impact of the additional household spend from new residents, and the resulting induced employment;

 The potential effect of the new housing in Cannock Chase and Lichfield District Councils;

 The impact of new residents on users of primary and secondary schools;

 The impact of new residents on users of primary health services; and

 The impact of new residents on users of open spaces and child play spaces.

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Construction Impacts and Effects

6.4.2 Construction of the proposed scheme would take place over the construction phase and would support the employment of a range of trades and professions in the construction industry. It would also have an indirect economic effect through the sourcing of building materials, services and supplies as well as the local spending of construction workers. Businesses and services will also be supported by the first occupation expenditure of the new householders.

6.4.3 With regard to development being phased, this will be planned in such a way to ensure that essential infrastructure and services are delivered to ensure that those who occupy the development in the early phases are adequately serviced.

Occupation Impacts and Effects

6.4.4 There are a number of operational effects that will result from the Proposed Development. These include the delivery of new homes, new employment floorspace and opportunities for home working. An increase in the local population will bring an associated increase in expenditure within local shops, businesses and services. The new population would also require school places, access to GP services, open space and recreation facilities.

Scoped Out Effects

6.4.5 The potential for businesses and residents to be adversely affected by construction traffic will be considered as part of the assessment of transport impacts. In general, it is considered that disruption during construction would be controlled and managed through implementation of the Construction and Environment Management Plan (CEMP).

6.4.6 The appropriate levels of affordable housing will be dealt with in the wider suite of planning application documents in the context of the viability appraisal. Therefore effects associated with affordable housing provision are scoped out.

6.5 MITIGATION ENVISAGED

6.5.1 In general, it is considered that disruption during construction would be controlled and managed through implementation of the Construction Environmental Management Plan (CEMP).

6.5.2 The development will be phased in such a way to ensure that essential infrastructure and services are delivered to ensure that those who occupy the development in the early phases of the project are adequately served.

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6.5.3 A principal objective of the Proposed Development will be to meet needs of the new residents on-site as much as is feasibly possible.

6.5.4 Proposed mitigation will reflect the impacts of the Proposed Development in accordance with the Community Infrastructure Levy Regulations. Proposed mitigation measures for socio- economic impacts will be directly related to meeting policy and infrastructure requirements as necessary and in a proportionate manner.

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CHAPTER 7: AIR QUALITY

7.1 INTRODUCTION

7.1.1 This chapter of the EIA Scoping Report has been produced by Air & Acoustic Consultants Limited (AAC) and outlines the proposed approach for assessing potential air quality impacts as a result of the Proposed Development which is scoped in to the proposed EIA.

7.1.2 Air quality changes would occur during construction as a result of the construction activities, associated traffic movements and highway interventions. During occupation the main changes in air quality would arise as a result of changes to road layouts and traffic flows.

7.1.3 The assessment will focus on air pollutants that are likely to arise from the construction and

occupation of the Proposed Development. These pollutants are oxides of nitrogen (NOx),

nitrogen dioxide (NO2), particulate matter (PM10, PM2.5) and dust.

7.1.4 Where appropriate the assessment will identify proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development.

7.2 ASSESSMENT CRITERIA & METHODOLOGY

Previous Assessment

7.2.1 A review of the local planning applications for the former land owned by Rugeley Power Station (Planning refs: 10/00420/REMM / 03/00628/FUL for an approved industrial / residential scheme) does not indicate that any air quality assessment works have been undertaken.

Legislative Context

UK Air Quality Strategy

7.2.2 The Government's policy on air quality within the UK is set out in the Air Quality Strategy for England, Scotland, Wales and Northern Ireland (AQS). The AQS provides a framework for reducing air pollution in the UK with the aim of meeting the requirements of European Union Legislation.

7.2.3 The AQS sets out national health-based standards and objectives for nine key air pollutants to protect human health and ecosystems. These pollutants are benzene, 1-3 butadiene, carbon monoxide, lead, nitrogen dioxide, ozone, particulate matter, sulphur dioxide and polycyclic aromatic hydrocarbons.

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7.2.4 The pollutant standards relate to ambient pollutant concentrations in air, set based on medical and scientific evidence regarding how each pollutant affects human health. Pollutant objectives are the future dates by which each standard is to be achieved, considering economic considerations, practical and technical feasibility.

Air Quality Regulations

7.2.5 Many of the air quality objectives set out in the AQS have been made statutory in England through the Air Quality (England) Regulations 2000, and the Air Quality (England) (Amendment) Regulations 2002 for the purpose of Local Air Quality Management (LAQM).

7.2.6 The Regulations stipulate that likely exceedances of the AQS objectives are assessed in relation to:

“[..]

“…the quality of air at locations which are situated outside of buildings or other natural or man- made structures, above or below ground, and where members of the public are regularly present…”

[..]”

Environment Act 1990

7.2.7 Section 79 of the Environmental Protection Act 1990 gives the following definitions of statutory nuisance relevant to dust and particles:

“Any dust or effluvia arising from an industrial, trade or business premises and being prejudicial to health or a nuisance”; and

““Any accumulation or deposit which is prejudicial to health or a nuisance”

7.2.8 Section 80 says that where a statutory nuisance is shown to exist, the local authority must serve an abatement notice. Failure to comply with an abatement notice is an offence and if necessary, the local authority may abate the nuisance and recover expenses.

7.2.9 There are no statutory limit values for dust deposition above which ‘nuisance’ is deemed to exist. Nuisance is a subjective concept and its perception is highly dependent upon the existing conditions and the change which has occurred as a result of the development.

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Environment Act 1995

7.2.10 Part IV of the Environment Act 1995 requires Local Authorities to regularly and systematically review and assess air quality within their boundaries against a series of objectives and appraise development and transport plans against these assessments. Where an air quality objective is unlikely to be met, the local authority must designate an Air Quality Management Area (AQMA) and draw up an Air Quality Action Plan setting out the measures it intends to introduce in pursuit of the objectives within its AQMA.

Planning Policy and Guidance

7.2.11 A summary of the national, regional and local planning policy relevant to the Proposed Development and assessment of air quality impacts is provided below.

National Planning Policy Framework 2

7.2.12 The National Planning Policy Framework 2 was published in July 2018 and sets out the Government’s planning policies for England and how these should be applied. It provides a framework within which locally-prepared plans for housing and other development can be produced. Air quality policy is discussed in a number of paragraphs.

7.2.13 Paragraph 103 states:

“The planning system should actively manage patterns of growth in support of these objectives. Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health. However, opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making.”

7.2.14 Paragraph 170 states:

“Planning policies and decisions should contribute to and enhance the natural and local environment by:

[..]

e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental

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conditions such as air and water quality, taking into account relevant information such as river basin management plans;

[..]”

7.2.15 Paragraph 181 states:

“Planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement. So far as possible these opportunities should be considered at the plan-making stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications. Planning decisions should ensure that any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan”.

National Planning Policy Guidance

7.2.16 The National Planning Policy Guidance was published in March 2014. The guidance states:

“Whether or not air quality is relevant to a planning decision will depend on the proposed development and its location. Concerns could arise if the development is likely to generate air quality impact in an area where air quality is known to be poor. They could also arise where the development is likely to adversely impact upon the implementation of air quality strategies and action plans and/or, in particular, lead to a breach of EU legislation (including that applicable to wildlife)”.

Local Planning Policy

Cannock Chase Current Planning Policy

7.2.17 The Cannock Chase Local Plan was adopted in June 2014.

7.2.18 Policy CP10 Sustainable Transport states:

“Cannock Chase Council will work with bus and rail operators, Staffordshire County Council, the West Midlands Integrated Transport Authority (Centro), Local Enterprise Partnerships (LEPs), local transport bodies and developers to help develop and promote sustainable transport modes that provide realistic alternatives to the car, and which help contribute to

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achieving national climate change targets and reduce air pollution. Developments will be expected to promote sustainable transport and where appropriate.

[..]”

7.2.19 Policy CP13 Cannock Chase Special Area of Conservation (SAC) states:

“Development will not be permitted where it would be likely to lead directly or indirectly to an adverse effect upon the integrity of the European Site network and the effects cannot be mitigated.

[..]”

7.2.20 Policy CP16 Climate Change and Sustainable Resource Use states:

“1. The Council, working with partners, will tackle climate change and ensure sustainable resource use via the promotion and positive consideration of initiatives and development proposals that:

[..]”

d. reduce or mitigate all forms of pollution, based upon air quality modelling where necessary, and having regard to strategic local issues including air quality.

[..]”

Lichfield Current Planning Policy

7.2.21 The Lichfield Local Plan Strategy was adopted in February 2015. Core Policy 3: Delivering Sustainable Development states:

“The Council will require development to contribute to the creation and maintenance of sustainable communities, mitigate and adapt to the adverse effects of climate change, make prudent use of natural resources, reduce carbon emissions, enable opportunities for renewable energy and help minimise any environmental impacts. To achieve this, development should address the following key issues:

[..]

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 minimise levels of pollution or contamination to air, land, soil or water, including noise and light pollution and avoid unacceptable uses within source protection zone 1 areas to safeguard water resources and ensure water quality;

[..]”

7.2.22 Core Policy 5: Sustainable Transport states:

“Accessibility will be improved and transport choice widened, by ensuring that all new development is well served by an attractive choice of transport modes, including public transport, footpaths and cycle routes to provide alternatives to the use of the private car and promote healthier lifestyles.

Development proposals will, either individually or collectively, have to make appropriate provisions for:

[..]

 Reducing the impact of travel upon the environment, in particular reducing carbon emissions that contribute to climate change and not contributing to unacceptable air quality levels.

[..]”

7.2.23 Core Policy 10: Healthy & Safe Lifestyles states:

“The District Council will, with its partners, create an environment where the healthy choice is the easy choice.

[..]

The District Council will ensure that the current high standard of air quality in the District is monitored and maintained and, where possible, improved with no decline in standards being deemed acceptable as a result of new development.

[..]”

7.2.24 Policy BE10: High Quality Development states:

“All development proposals should ensure that a high quality sustainable built environment can be achieved. Development will be permitted where it can be clearly and convincingly demonstrated that it will have a positive impact on:

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[..]

 Amenity, by avoiding development which causes disturbance through unreasonable traffic generation, noise, light, dust, fumes or other disturbance;

[..]”

Emerging Planning Policy

7.2.25 Due to changes to the national planning system (including the requirement for councils to review their plans every five years to see which policies may need updating), some parts of Cannock Chase Local Plan (Part 1) 2014 will soon be out of date. The production of a new Local Plan is being started which will utilise the work to be carried out to date on Local Plan Parts 1 and 2 and incorporate any areas which need reviewing/updating. Until it is replaced, the adopted Local Plan Part 1 will still continue to set planning policy for the District.

7.2.26 LDC are reviewing their local plan and once adopted it will replace the current local plan strategy (adopted in 2015) and the local plan allocations document (on-going, expected to be adopted in 2018). Until the time the new local plan is adopted LDC will continue to use the existing local plan when making planning decisions.

Guidance/ Best Practice

7.2.27 A summary of the publications that will be referred to in the undertaking of the proposed assessment is provided below.

Local Air Quality Management Review and Assessment Technical Guidance

7.2.28 The Department for Environment, Food and Rural Affairs (Defra) has published technical guidance for use by local authorities in their review and assessment work. This guidance, referred to in this document as LAQM.TG16, has been used where appropriate in the assessment presented herein.

Guidance on the Assessment of Dust from Demolition and Construction

7.2.29 The Institute of Air Quality Management have published this guidance. The guidance provides a methodology to undertake a qualitative assessment of the potential dust / emission risks during the construction phase of a Proposed Development. The assessment consists of a five step processes to assess the potential level of risks, (Large, Medium, Small or Negligible),

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regarding the four main phases of development, (demolition, earthworks, construction, and trackout). The assessment includes consideration of pre-mitigation, and post-mitigation impacts, based upon the scale and nature of the development.

Land-Use Planning & Development Control: Planning for Air Quality

7.2.30 The Environmental Protection UK (EPUK) and the Institute of Air Quality Management (IAQM) have published guidance that offers comprehensive advice on: when an air quality assessment may be required; what should be included in an assessment; how to determine the significance of any air quality impacts associated with a development; and, the possible mitigation measures that may be implemented to minimise these impacts.

Guidance on the Assessment of Odour for Planning

7.2.31 The Institute of Air Quality Management have published this guidance. The guidance provides a methodology to undertake a qualitative assessment of the potential impacts an odorous source could have upon human receptors.

Design Manual for Roads and Bridges (DMRB), Volume 11: Environmental Assessment, Section 3: Environmental Assessment Techniques, Part 1, HA 207/07

7.2.32 DRMB have provided published guidance upon when an impact assessment should be undertaken to quantify the potential impacts of nitrogen deposition upon any identified ecological designated sites.

Baseline Data Collection

7.2.33 The existing baseline oxides of nitrogen (NOX), nitrogen dioxide (NO2) and particulate matter

(PM10 & PM2.5) conditions on and in the vicinity of the Site will be assessed using the Lichfield District Council (LDC) and Cannock Chase District Council (CCDC) air quality review and assessment reports and monitoring data. The Defra background mapping website will also be

utilised to provide background nitrogen dioxide (NO2) and particulate matter (PM10 & PM2.5) conditions. The website has mapped background concentrations at a resolution 1x1km for the whole of the UK. Estimated concentrations are available for all years between 2015 and 2030.

7.2.34 To identify any sensitive ecological designated sites, a review of Defra Magic Map website and the UK Air Pollution Information System (APIS) website will be undertaken.

7.2.35 A desktop study will also be undertaken based upon local mapping and the Environment Agency Permitting website to ascertain if any potential odorous sources are within the vicinity of the Site.

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Proposed Assessment Methodology

7.2.36 The scope of the assessment has been determined in the following way:

 A consultation will be undertaken with the environmental health officers at Lichfield District Council (LDC) and Cannock Chase District Council (CCDC) to agree the scope assessment and the methodologies to be applied; and

 A desktop study will be undertaken to confirm the location of the nearby existing receptors that may be sensitive to changes in air quality, and a review of the fixed Parameters Plan for the Proposed Development to establish the location of new sensitive receptors.

7.2.37 The scope of the assessment will include consideration of the potential impacts on local air quality resulting from:

 Dust and particulate matter generated by on-site activities during the construction phase;

 Increases in pollutant concentrations as a result of exhaust emissions arising from construction traffic and plant; and

 Increases in pollutant concentrations as a result of exhaust emissions arising from traffic generated by the Proposed Development once occupied.

Construction Phase

7.2.38 Dust is the generic term used in the British Standard document BS 6069 (Part Two) to describe particulate matter in the size range 1–75μm (micrometres) in diameter. Dust nuisance is the result of the perception of the soiling of surfaces by excessive rates of dust deposition.

7.2.39 An assessment of the likely significant impacts on local air quality due to the generation and

dispersion of dust and PM10 during the construction phase will be undertaken using: the relevant assessment methodology published by the IAQM; the available information for this phase of the Proposed Development provided by the Project Team; and, professional judgement.

7.2.40 The IAQM methodology assesses the risk of potential dust and PM10 impacts from the following four sources:

 Demolition;

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 Earthworks;

 General construction activities; and

 Track-out.

7.2.41 The assessment considers the nature and scale of the activities undertaken for each source

and the sensitivity of the area to an increase in dust and PM10 levels, resulting in a risk rating. Risks are described in terms of there being a low, medium or high risk of dust impacts. Once the level of risk has been ascertained, then Site specific mitigation proportionate to the level of risk is identified, and the significance of residual effects determined.

7.2.42 It is noted that as part of approved Planning Application 18/01098/FULM, a large part of the site is currently being cleared. However, it is anticipated some minor ‘demolition’ works will be required and therefore this element has not been scoped out of the assessment.

7.2.43 Further to impacts on local air quality from on-site construction activities, emissions of stationary plant and construction vehicles may have impacts upon local air quality. A qualitative assessment of their impact on local air quality will be undertaken using professional judgement and by considering the following:

 The duration of the construction phase and the type of construction activities being undertaken;

 The number and distance from the source causing an impact; and

 The number and type of construction traffic and plant likely to be generated by the construction phase.

Operational Phase

7.2.44 Of the nine pollutants included in the AQS, concentrations of nitrogen dioxide (NO2) and

particulate matter (PM10 & PM2.5) will be considered in the assessment as road traffic is a major source of these pollutants.

7.2.45 The predictions of the impacts associated with emissions arising from the Proposed Development will be undertaken using the dispersion model ADMS-Roads (version 4.1.1.0). The model uses detailed information regarding traffic flows on the local road network, surface roughness, and local meteorological conditions to predict pollutant concentrations at specific receptor locations, as determined by the user.

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7.2.46 Meteorological data, such as wind speed and direction, is used by the model to determine pollutant transportation and levels of dilution by the wind. Meteorological data will be used in the model and is obtained from the observation station at Birmingham Airport meteorological station. This station is considered to provide representative data for the assessment.

Selection of Sensitive Receptors

7.2.47 Sensitive receptors / locations are places where a human receptor or ecological habitat may be exposed to pollutants from the Proposed Development during the construction and operational phases. These include locations which are sensitive to an increase in dust deposition and

particulate matter (PM10) exposure as a result of on-site construction activities, locations sensitive to exposure to gaseous pollutants emitted from the exhausts of construction, and operational traffic associated with the fully operational Proposed Development.

Construction Phase

7.2.48 The selection of the human / ecological receptors during the construction phase is determined by the IAQM criteria set out in the Geographical Scope section of this chapter.

Operational Phase

7.2.49 In terms of locations that are sensitive to pollutants emitted from engine exhausts, these will include places where members of the public are likely to be regularly present over the period of time prescribed in the AQS. For example, on a footpath where exposure will be transient (for the duration of passage along that path) comparison with a short-term standard (i.e. 15 minute mean or 1 hour mean) may be relevant. At a school or adjacent to a private dwelling, where exposure may be for longer periods, comparison with a long-term standard (such as 24 hour mean or annual mean) may be more appropriate. Box 1.1 of LAQM.TG16 provides examples of the locations where the air quality objectives should/should not apply.

7.2.50 To complete the assessment of operational phase impacts, a number of ‘receptors’ representative of locations of relevant public exposure will be identified and predicted pollution concentrations will be provided. Receptors will be located adjacent to highways where the Proposed Development vehicular traffic exceed the EPUK & IAQM thresholds set in the Geographical Scope section of this chapter.

Significance Criteria

Construction Phase

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7.2.51 The IAQM does not provide a method for assessing the significance of effects before mitigation and advises that pre-mitigation significance should not be determined. It is considered that with appropriate mitigation in place, the IAQM guidance is clear that the residual effect will normally be ‘not significant.’

7.2.52 For the assessment of the impact of exhaust emissions from plant used on-site and construction

vehicles accessing and leaving the Site on local concentrations of nitrogen dioxide (NO2) and

particulate matter (PM10 & PM2.5), the significance of residual effects will be determined using professional judgement and the principles outlined in the EPUK & IAQM guidance, set out below.

7.2.53 The selection of the human / ecological receptors during the construction phase is determined by the IAQM criterion set out in the Geographical Scope section of this chapter.

Operational Phase

7.2.54 Currently there is no formal guidance on the absolute magnitude and significance criteria for the assessment of air quality impacts upon ecological and human receptors. However, the approach provided in the EPUK & IAQM guidance will be used within this assessment to assist in describing the air quality effects of additional traffic emissions from the Proposed Development once fully occupied.

7.2.55 The guidance recommends that the degree of an impact is described by expressing the magnitude of incremental change in pollution concentration as a proportion of the relevant assessment level and examining this change in the context of the new total concentration and its relationship with the assessment criterion, as summarised in Table 7.1.

Table 7.1: Impact Descriptors for Individual Receptors Long term average % Change in concentration relative to Air Quality Assessment Level (AQAL) Concentration at Receptor in 1 2-5 6-10 >10 Assessment Year 75% of less of AQAL Negligible Negligible Slight Moderate 76-94% of AQAL Negligible Slight Moderate Moderate 95-102% of AQAL Slight Moderate Moderate Substantial 103-109% of AQAL Moderate Moderate Substantial Substantial 110% or more of AQAL Moderate Substantial Substantial Substantial

7.2.56 The EPUK & IAQM advice provides guidance on the severity of an impact as a descriptor. However, although the impacts might be considered ‘Slight’, ‘Moderate’ or ‘Substantial’ at one

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or more receptor location, the overall effects of a Proposed Development may not always be judged as being significant. The overall significance should be based on professional judgement, taking into account several factors, including:

 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.

Geographical Scope

7.2.57 The geographical scope is of the assessment has been defined by the following criteria.

Construction Phase

7.2.58 The IAQM assessment guidance sets out the following criteria for recommended requirements for the undertaking of a qualitative assessment of dust and emissions associated with the construction phase:

 a ‘human receptor’ within:

o 350m of the boundary of the site; or

o 50m of the route(s) used by construction vehicles on the public highway, up to 500m from the site entrance(s).

 An ‘ecological receptor’ within:

o 50m of the boundary of the site; or

o 50m of the route(s) used by construction vehicles on the public highway, up to 500m from the site entrance(s).

7.2.59 It is considered that within these distances that the impacts of dust soiling and increased particulate matter in the ambient air will have the greatest impact on local air quality at sensitive receptors.

Operational Phase

7.2.60 The EPUK & IAQM assessment guidance sets thresholds for the recommended requirements for the undertaking of full impact assessment on sensitive human receptors due to the changes

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in daily vehicular traffic due to a Proposed Development when the daily traffic movements change by the following:

 A change of LGV (light goods vehicle) flow of:

o More than 100 AADT within or adjacent to an AQMA; or

o More than 500 AADT elsewhere.

 A change of HGV (heavy goods vehicles) flow of:

o More than 25 AADT within or adjacent to an AQMA; or

o More than 100 AADT elsewhere.

7.2.61 It is considered that below these thresholds the impacts would be ‘negligible’ upon sensitive receptors.

7.2.62 The DMRB guidance sets out for when a full impact assessment on sensitive ecological receptors are to be undertaken due to the changes in the following highway conditions (if within 200m of the centre of the affected highway):

 Horizontal road alignment will change by 5m or more;

 Daily traffic flows will change by more than 1,000 Annual Average Daily Traffic (AADT);

 Heavy Duty Vehicle (HDV) flows will change by more than 200 AADT;

 Daily average speed will change by more than 10kph; or

 Peak hour speed will change by more than 20kph.

Temporal Scope

7.2.63 The assessment of air quality effects due to changes in traffic during construction of the Proposed Development will be undertaken for the following scenarios:

 future ‘without the scheme’ traffic emissions for the peak years during the construction period; and

 future ‘with the scheme’ traffic emissions for the peak year during the construction period.

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7.2.64 The assessment of air quality effects due to changes in traffic during full occupation of the Proposed Development will be undertaken for the following scenarios:

 Model Verification, in line with the latest monitoring data available from LDC & CCDC;

 Opening Year without the Proposed Development (inclusive of all committed development within the assessment extents); and

 Opening Year with full occupation of the Proposed Development.

Limitations & Assumptions

7.2.65 There are many uncertainties when considering both measured and predicted pollution concentrations. The model is dependent upon the traffic data provided for the project, and should this be subject to change, so may the resulting pollution concentrations.

7.2.66 In order to reduce the uncertainty associated with predicted concentrations, model verification will be carried out following guidance set out in LAQM.TG16.

7.2.67 Furthermore, it has been widely known for some time that NOx/NO2 levels are not reducing as quickly as anticipated and this was identified by Defra in 2011. This was recently reiterated in an IAQM Interim Position Statement released in October 2016, recognising that emissions from diesel vehicles have not declined as expected by Defra. It states:

“it has been known since around 2011 that [NOx] emissions from diesel vehicles have not declined as expected despite the introduction of increasingly more stringent European Union (EU) emission limits”

7.2.68 Consequently, a ‘Calculator Using Realistic Emissions for Diesels’ (CURED) sensitivity test has been included to provide a reasonable worst-case set of emission factors for modelling. The CURED emission factors take account of recent real-world emissions test data. This method has been used as part of the modelling process to reduce the model uncertainty for both vehicular and background air quality concentrations.

7.3 BASELINE ENVIRONMENT

Local Air Quality Management

7.3.1 The Site is located within the jurisdictions of Cannock Chase District Council and Lichfield District Council. Cannock Chase District Council have three declared Air Quality Management

Area’s (AQMA’s) for exceedances of the nitrogen dioxide (NO2) annual mean objective. Lichfield

District Council also have two AQMA’s declared for exceedances of the nitrogen dioxide (NO2)

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annual mean objective. The closest AQMA to the Site ‘AQMA 3 (Five Ways Island) which is located approximately 8km south of the Site.

7.3.2 Table 7.2 provides details of the closest monitoring location to the Site, which is located in the centre of Rugeley.

Table 7.2: Local Authority Air Quality Monitoring Data (μg/m3) Site Monitoring Type Pollutant 2012 2013 2014 2015 2016

Horsefair, Rugeley Passive NO2 - - - 30.8 35.2

7.3.3 The annual mean concentrations for the closest monitoring have not approached or exceeded the AQ objective of 40ug/m3.

Defra Background Mapping

7.3.4 The background pollutant concentrations for site for 2019 have been taken from the four closest 1km x 1km grids have been taken from the Defra background mapping. All are well within the air quality objectives as presented in Table 7.3. All of the annual mean background concentrations are well below the relevant objectives.

Table 7.3: Background Pollutant Concentrations

Grid Reference NO2 NOx PM10 PM2.5 405500, 317500 11.46 16.04 13.10 8.74 405500, 316500 11.86 15.48 12.52 8.49 406500, 317500 9.25 12.28 12.08 8.19 406500, 316500 10.44 13.98 11.87 8.16

Ecological Sites

7.3.5 A review of the Defra Magic Map website indicates the closest ecological receptor to the Site is the Cannock Chase Site of Special Scientific Interest / Special Area of Conservation. A number of other Sites of Special Scientific Interest and Local Nature Reserves are also located within the Cannock Chase area.

Odour Sources

7.3.6 A review of the Site and the surrounding area, and Environment Agency website indicates no potential odorous sources which would adversely impact the Proposed Development. In addition, the Proposed Development does not include any uses likely to result in odour generation. Therefore, on this basis this element can be scoped out of the assessment.

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7.4 POTENTIAL ENVIRONMENTAL IMPACTS & EFFECTS

Construction Impacts and Effects

7.4.1 The remaining construction activities that have the potential to generate and/or re-suspend dust

and PM10. Include:

 Demolition

 Preparation of temporary access/egress to the Site and haulage routes;

 Earthworks;

 Movement of construction vehicles around the Site;

 Emissions from stationary plant;

 Construction of buildings;

 Internal and external finishing and refurbishment; and

 Site landscaping after completion.

7.4.2 The majority of releases will occur during the ‘working day’ and will be limited by the agreed daily working hours as set out in the Construction Environmental Management Plan.

Operational Impacts and Effects

7.4.3 The main impacts associated with the operational phase of the Proposed Development are expected to be:

 The introduction of new exposure to the Site resulting in increased exposure to local pollutant levels;

 Impacts associated with emissions generated by operational traffic on local air quality. The main effect on air quality will result from changes in local concentrations of nitrogen

dioxide (NO2) and particulate matter (PM10 and PM2.5) due to traffic generated by the Proposed Development; and

 The impact of emissions to air from any on-site plant that may be provided as part of the Proposed Development.

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7.4.4 During the operation phase of the Proposed Development, the principal source of emissions to air is likely to be road transport. The assessment will take into account the current baseline air quality concentrations and the location of the ecological sites and quantify if this increase is likely to result in a significant deterioration in local air quality / habitats.

7.5 MITIGATION ENVISAGED

Construction Phase

7.5.1 It is anticipated that through the development of a detailed Construction Environmental Management Plan, that the impacts associated with the construction phase will be of a temporary nature and not significant. A set of site-specific mitigation measures will be proposed within the assessment relating to the following areas:

 Communication with stakeholders;

 Dust Management;

 Demolition;

 Earthworks;

 Construction; and

 Trackout;

Operational Phase

7.5.2 Based upon professional judgement and the existing air quality concentrations in that vicinity of the Site, it is not anticipated that the air quality impacts associated with the Proposed Development will be of a magnitude and significance that will require mitigation measures. However, due to a Proposed Development of this size and nature it is anticipated to breach the thresholds set out in the EPUK & IAQM (2017) for the requirements of full impact assessment.

7.5.3 Through the development of the following measures within the Proposed Development it is anticipated that the level of potential air quality impacts can be reduced:

 Provide sustainable transport initiatives through the development of a Travel Plan that future residents will use sustainable methods instead of the motor vehicle; and

 Future proof the Proposed Development by providing a good provision of electric charging points.

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CHAPTER 8: ARCHAEOLOGY

8.1 INTRODUCTION

8.1.1 This chapter of the EIA Scoping Report has been produced by AECOM and sets out the consideration of potential effects on the archaeological resource from the Proposed Development. This chapter sets out the rational for archaeology being scoped out as a topic from the EIA under the terms of the National Planning Policy Framework (NPPF).

8.1.2 To assist with the scoping assessment, a desk-top review of non-designated archaeological assets within a 500m study area, and designated assets within a 1km study area, has been carried out in order to gain an understanding of the nature of the existing cultural heritage landscape. This includes analysis of historic maps, previous assessments and other relevant sources.

8.1.3 The following data sources have been used in order to inform the proposed assessment of archaeological impacts:

 Heritage Gateway website available online via www.heritagegateway.org.uk/gateway;  Available historic mapping;  Borehole and other geotechnical data as appropriate and available;

8.2 BASELINE ENVIRONMENT

8.2.1 There are no designated archaeological assets within 1km of the red line boundary of the Proposed Development.

8.2.2 There are eight recorded non-designated archaeological assets within 500m of the red line boundary of the Proposed Development. These comprise:

 Rugeley ‘B’ Power Station (HER No. 58696)  Hawksyard Hall moated site (HER No. 00962)  Former water meadow, south of Cawarden Springs Wood, Brereton (HER No. 54830)  Cawarden Spring, Mavesyn Ridware, holy well (HER No. 00966)  Cropmark enclosure, Cawarden Springs, Mavesyn Ridware (HER No. 55114)  Mound, Colton (HER No. 05258)  Ring ditch, Colton (HER No. 05216)  Water meadow, north of Brereton (HER No. 54840)

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8.2.3 A review of geotechnical and historical map analysis for the site of the Rugeley Power Station has been carried out.1

8.2.4 The findings of the Phase I Environmental Review by Whitworth2 is summarised as follows.

8.2.5 The Site was predominantly agricultural land, up to and including the 1880s. A sewage works was present in the north of Site from at least the turn of the 20th century until the late 1960s, with a possible infilled quarry depicted on mapping in the south-east of the Site from the 1920s to the late 1960s. The cooling towers for the Rugeley ‘A’ Power Station and the ash lagoons were constructed on-site during the 1960s. Rugeley ‘B’ Power Station was constructed in the late 1960s, and completed in 1970 when it first operated as a coal fired power station. Rugeley ‘A’ Station was closed in 1996, and the towers subsequently demolished. The Site has been in Engie’s (formerly GDF Suez) ownership since 2011. A flue gas desulphurisation plant was added to the north-west of the Site between 2006 and 2009. Six historical landfills were present on-site, one of which was known to have accepted domestic waste from 1960; this was located in the north of the current coal storage yard. Historical data suggests that a Victorian landfill, completed in 1896, was present beneath the location of No1 ash lagoon, and accepted bottles.3

8.2.6 The Rugeley Power Station Phase I Environmental Assessment4 states that there are six historical landfill sites recorded on the Site, which are as follows:

 ‘Landfill to the East of Power Station Road’; a strip of land in the north of the Site, in the north of the current coal storage yard, accepted household waste from 1960.

 ‘Rugeley Power Station’ located in the centre north of the Site in part of the operational area and a section along the western boundary.

1 Tim Clifford, Rugeley Power Station. Addendum to Interpretative Phase II. Geotechnical Design Report (Redevelopment). Ramboll Environ. October 2017; Mohammad Fazal, Rugeley Power Station Interpretative Phase II Geotechnical Design Report (Redevelopment). Ramboll Environ. March 2017; Kate Whitworth, Rugeley Power Station Phase I Environmental Assessment. Ramboll Environ. July 2016; Series of Ordnance Survey 1:10:560 and 1:10,000 maps collated by Ramboll Environs in June 2016 (1884-85, 1924, 1938, 1955, 1965-68, 1981-86, 2000 & 2016 map editions).

2 Whitworth, Rugeley Power Station Phase I Environmental Assessment, p. 40.

3 Whitworth, Rugeley Power Station Phase I Environmental Assessment, pp 32-33.

4 Whitworth, Rugeley Power Station Phase I Environmental Assessment, pp 21-22.

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 ‘Rugeley Power Station’ located in the south of the central operational portion on-site and incorporates the golf course (former lagoons nos. 1 and 2), the demolition and construction waste storage area.

 ‘Rugeley A and B’ located in the current location of the ash storage lagoons (nos 3 and 4), accepted waste including industrial waste from 1956 to 1992.

 ‘Hawkesyard Lane’ located to the east of the borrow pit / amenity lake.

 ‘Rugeley Power Station’, license held by Central Electricity Generating Board, Solihull is located predominantly off-site to the south-west but encroaches onto the southern site boundary. The landfill accepted waste including industrial waste from 1979 to 1982.

8.2.7 It is likely that previous land uses at the Site through the course of the 20th century will have resulted in extensive and significant disturbance or removal of subsurface archaeological remains.

8.3 RATIONALE FOR SCOPING OUT OF ARCHAEOLOGY FROM EIA

8.3.1 A review of geotechnical and historical map analysis for the site of the Rugeley Power Station has been carried out.

8.3.2 The following have been identified as the natural subsoil conditions on the Site:

 Alluvium – Soft to firm consolidated, compressible silty clay, but can contain layers of silt, sand, peat and basal gravel. A stronger desiccated surface layer may be present.

 River Terrace Deposits – Sand and gravel with lenses of silt, clay or peat.5

8.3.3 The Alluvium is seen to be present only in the north-eastern part of the Site, whilst the remainder of the Site is underlain by the River Terrace Deposits. Although not indicated on the geological map it is likely that a significant proportion of the Site will be overlain by made ground or modern fill of varying composition.6 Made ground was encountered in all boreholes across the Site (previous and recent ground investigation) and was found to typically comprise brick fragments, ceramics, tile, coal, ash, clinker, gravel of sandstone and mudstone.7 Made ground was encountered to depths ranging from 0.6m bgl to 8.5m bgl, with the deepest encountered in BH310 situated in the east of the Site. This borehole was carried out within the

5 Fazal, Rugeley Power Station Interpretative Phase II Geotechnical Design Report, p. 4.

6 Fazal, Rugeley Power Station Interpretative Phase II Geotechnical Design Report, p. 4.

7 Fazal, Rugeley Power Station Interpretative Phase II Geotechnical Design Report, p. 10.

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ash lagoon area where the land has been raised to approximately 6m above natural ground level.8

8.3.4 The lagoon areas of Rugeley Power Station were historically excavated to extract sands and gravels. The voids were subsequently used to allow hydraulically transported PFA to settle out of suspension. The ground conditions in these areas are therefore significantly different to those which have been observed in other parts of the larger Rugeley Power Station Site.9

8.3.5 According to Whitworth, online BGS historical records have recorded more than sixty boreholes across the Site dating from the 1950s to the 1980s.10 The following general lithology was described:

 Made ground down to between 1.0 to 2.4m bgl, overlying;

 Sand and gravel, to between 9.9m to 14m bgl, overlying;

 Sandstone proven to be at least 214m bgl

8.3.6 Borehole logs11 provided by site staff and acquired through Local Authority Planning departments for locations in the east of the Site (PFA Lagoons and Borrow Pit) to inform the Phase I Environmental Assessment record the following:

 Made ground (comprising sands, gravels and FPA) down to between 1.0 to 7.5m bgl, overlying;

 Sand and gravel, to between 4.0m to 15.5m bgl, overlying;

 Sandstone and mudstone to depths of at least 18.5m bgl.

8.3.7 No previously recorded significant archaeological remains are known on the Site which may be affected by the Proposed Development. When this is considered against the known levels of truncation from previous land use it is unlikely that any archaeological remains would survive, that would constrain or prevent development. The Proposed Development at the Site can be accommodated without significant environmental effects on the archaeological resource. As such, significant effects related to archaeology are not considered to be likely

8 Fazal, Rugeley Power Station Interpretative Phase II Geotechnical Design Report, pp 10 & 29.

9 Clifford, Rugeley Power Station. Addendum to Interpretative Phase II. Geotechnical Design Report.

10 Whitworth, Rugeley Power Station Phase I Environmental Assessment, pp 26-27.

11 Whitworth, Rugeley Power Station Phase I Environmental Assessment, pp 26-27.

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EIA Scoping Report Chapter 8: Archaeology Rugeley B Power Station, Rugeley

and, in accordance with the EIA Regulations, it is appropriate to scope this topic out from the EIA. No further assessment is recommended. Similarly, there are unlikely to be any effects to the setting of any recorded assets that will result in effects on their significance.

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EIA Scoping Report Chapter 9: Built Heritage Rugeley B Power Station, Rugeley

CHAPTER 9: BUILT HERITAGE

9.1 INTRODUCTION

9.1.1 This chapter of the ES Scoping Report has been produced by AECOM. It presents the proposed approach to the assessment of the likely significant environmental effects of the Proposed Development on built heritage.

9.1.2 The assessment will consider potential impacts on built heritage and will identify preliminary issues associated with the Proposed Development. Specifically, it will consider potential impacts on designated heritage assets, including listed buildings, conservation areas and registered park and gardens. Additionally, potential impacts on non-designated historic buildings and structures including any locally listed buildings will also be considered.

9.1.3 Built heritage has been scoped in to the EIA due to the potential for the Proposed Development to affect the historic environment including listed buildings and conservation areas.

9.2 ASSESSMENT CRITERIA & METHODOLOGY

Previous Assessment

9.2.1 Planning permission has been granted for demolition of the existing buildings and structures on the Site. All impacts on the existing buildings and structures were considered as part of the application. Currently, works are being undertaken in order to facilitate the demolition and remediation works.

9.2.2 Currently, a Level II Historic Building Recording report is being prepared as part of the planning permission for the demolition works.

Legislative Context

9.2.3 A summary of legislation, planning policy and guidance relevant to the assessment is listed below.

The Planning (Listed Buildings and Conservation Areas) Act 1990

9.2.4 The Act sets out the principal statutory provisions which must be considered in the determination of any application affecting either listed buildings or conservation areas.

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9.2.5 Section 72 of the Act states that with respect to buildings or land within a conservation area, special attention should be paid to the desirability of preserving or enhancing the character or appearance of that area.

Planning Policy and Guidance

National Planning Policy

9.2.6 The revised National Planning Policy Framework (NPPF) was published 24 July 2018. It sets out the Government’s planning policies for England and how these should be applied to contribute to the achievement of sustainable development. There are policies protecting the historic environment throughout the revised NPPF. Section 12 highlights the importance of good design as a key aspect of sustainable development. Paragraph 127c draws attention to the importance of the design being “sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation or change (such as increased densities)”.

9.2.7 Section 16 of the revised NPPF deals specifically with “conserving and enhancing the historic environment”. The NPPF sets out the importance of being able to assess the significance of heritage assets that may be affected by a development. Significance is not only derived from an asset's physical presence, but also from its setting.

9.2.8 Paragraph 189 of the NPPF states that in determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets affected, including any contribution made by their setting.

Local Planning Policy

9.2.9 The Site falls within the boundaries of two local authorities, Cannock Chase District Council (CCDC) and Lichfield District Council (LDC). The relevant local planning documents and policies are relevant to the Proposed Development.

Cannock Chase Local Plan (Part 1) 2014

9.2.10 Local Plan (Part 1) 2014 is the statutory development plan for Cannock Chase Council and forms the principal basis for which development is promoted and controlled. The plan was adopted in 2014 and includes the Core Strategy (section 1), which contains the strategic context and core policies, and the Rugeley Town Centre Area Action Plan (section 2).

9.2.11 In Section 1, Policy CP3 (Chase Shaping – Design) points out 13 key requirements that will need to be addressed in development proposals in order to ensure high quality design while

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Policy CP15 (Historic Environment) states how the district’s historic environment will be protected and enhanced.

9.2.12 Section 2 of the Local Plan includes the Rugeley Town Centre Area Action Plan and Policy RTC10 which seeks to improve access to the canal and the Chase Heritage Trail.

Lichfield District Local Plan Strategy, 2008 – 2029

9.2.1 The Lichfield District Local Plan strategy 2008-2029 was adopted in 2015. The local plan strategy is the first part of the new local plan for Lichfield District and will be followed by the local plan allocations document, currently being prepared. Core Policy 14 - Our Built and Historic Environment and Policy BE1 - High Quality Development are relevant to the built and historic environment.

Supplementary Planning Documents

9.2.2 The following SPDs are relevant to the historic environment and the Proposed Development: Design Guide SPD (2016); the Rugeley Power Station SPD (produced by Cannock Chase and Lichfield District Councils); and a number of conservation area appraisals and management plans with the most relevant being the Trent and Mersey Canal Conservation Area Appraisal. A draft conservation management plan for the Trent and Mersey Conservation Area Appraisal has also been produced.

9.2.3 Other relevant documents produced by Lichfield District Council include the Historic Environment SPD (2015) and the Sustainable Design SPD (2015). Additionally, the Mavesyn Ridware Conservation Area Appraisal and Management Plan (2014) and the Colton Conservation Area Appraisal and Management Plan (2012) are of relevance.

Emerging Planning Policy

9.2.4 Cannock Chase District Council is reviewing the existing Local Plan and has started the production of a new Local Plan which will utilise the work to be carried out to date on the existing Local Plan and incorporate any areas which need reviewing and updating. The Local Plan Issues and Scoping consultation took place in July and August 2018. The Issues and Options consultation is scheduled to be published early in 2019.

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Guidance/ Best Practice

Policy Guidance

9.2.5 The Planning Practice Guidance (PPG) is a government produced interactive on-line document that provides further advice and guidance that expands the policy outlined in the NPPF.

Historic England Good Practice Advice Notes

9.2.6 Historic England have published a series of Good Practice Advice (GPA) of which those of most relevance to the proposed assessment are GPA2 Managing Significance in Decision- taking (March 2015) and GPA3 The Setting of Heritage Assets (Second Edition, 2017).

Baseline Data Collection

9.2.7 The following data sources will be used in order to inform the proposed assessment of built heritage impacts:

 Historic England’s National Heritage List for England (NHLE);  Heritage Gateway website available online via www.heritagegateway.org.uk/gateway;  Staffordshire Historic Environment Record including the Lichfield District and Cannock Chase Historic Environment Assessments;  Staffordshire County Record Office;  Cannock Chase District Council and Lichfield District Council websites for information on conservation areas and local lists;  Historic Ordnance Survey and pre-Ordnance Survey mapping;  the ZTV produced to inform the LVIA;  a site walkover survey and setting assessment; and  various internet and documentary sources.

Proposed Assessment Methodology

9.2.8 The built heritage assessment will be carried out in accordance with the NPPF relevant guidance published by Historic England including their Good Practice Advice Notes, Conservation Area Designation, Appraisal and Management (2016) and Conservation Principles (2008).

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Baseline assessment

9.2.9 A detailed assessment of the built heritage assets will be necessary in order to assess the potential impacts of the Proposed Development. The heritage baseline for the Proposed Development Site will set out the built heritage assets within the wider 1km study area to place the Site in its full historical context. The baseline will include the review of the data sources mentioned above and will inform the impact assessment, which will be completed within the ES chapter to determine the effects of the Proposed Development on built heritage.

9.2.10 Professional judgement, in conjunction with consultation with Conservation Officers at LDC and CCDC and Historic England, will determine if all the identified listed buildings and conservation areas within the study area need to be taken through to assessment within the ES chapter. Any assets of the highest significance beyond the defined study area will be identified, but only discussed where the wider landscape forms a key contributing factor in their significance and where this has the potential to be affected by the development. This will ensure that the assessment is proportionate, in accordance with the requirements of the NPPF. Assets with grouped significance will be discussed together. This includes listed buildings located within conservation areas where they will be assessed for the contribution that they make to the historic and architectural interest of that area. Those assets which have significance that transcends the wider grouping will be discussed separately.

Significance criteria

9.2.11 An assessment of the significance of the potentially affected assets will be undertaken according to relevant policy, guidance and good practice advice issued by Historic England. The significance (heritage value) of a heritage asset is derived from its heritage interest which may be archaeological, architectural, artistic or historic (NPPF Annex 2, Glossary). The NPPF also notes that the significance of a heritage asset derives not only from its physical presence, but also from its setting. Therefore, an assessment of the setting of heritage assets will also be undertaken to establish whether the setting contributes to their identified significance. Taking these criteria into account, each identified heritage asset can be assigned a level of significance (heritage value) in accordance with a three-point scale as set in Table 9.1.

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Table 9.1 Criteria for determining the significance (heritage value) of heritage assets Significance (heritage value) Criteria High World Heritage Sites, Grade I and II* listed buildings, Grade I and II* registered historic parks and gardens Medium Grade II listed buildings, Grade II listed registered historic parks and gardens, Conservation Areas, Locally listed buildings included within a conservation area Low Non-designated historic buildings and structures, Locally listed buildings

Assessing the magnitude of impact and significance of effects

9.2.12 Having identified the significance of the heritage asset, the next stage in the assessment is to identify the level and degree of impact to an asset arising from the Proposed Development. Impacts may arise during construction or operation and can be temporary or permanent. Impacts can occur to the physical fabric of the asset or affect its setting.

9.2.13 The level and degree of impact (impact rating) is assigned with reference to a four-point scale as set out in Table 9. 2. In respect of cultural heritage an assessment of the level and degree of impact will be made in consideration of any scheme design mitigation (embedded mitigation).

Table 9.2 Criteria for determining the magnitude of impact on heritage assets Magnitude of Impact Description of Impact Change such that the significance of the asset is totally altered or destroyed. Comprehensive change High to setting affecting significance, resulting in a serious loss in our ability to understand and appreciate the asset. Change such that the significance of the asset is affected. Noticeably different change to setting Medium affecting significance, resulting in erosion in our ability to understand and appreciate the asset. Change such that the significance of the asset is slightly affected. Slight change to setting affecting Low significance resulting in a change in our ability to understand and appreciate the asset. Changes to the asset that hardly affect significance. Minimal change to the setting of an asset that have Very low little effect on significance resulting in no real change in our ability to understand and appreciate the asset.

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9.2.14 An assessment of the level of significant effect is determined by cross-referencing between the significance (heritage value) of the asset (Table 9.1) and the magnitude of impact (Table 9.2). The resultant level of significant effect (Table 9.3) can be negligible, adverse or beneficial.

Table 9.3 Criteria for determining the significance of effect Significance (heritage value) Magnitude of impact High Medium Low Very low High Major Major Moderate Minor Medium Major Moderate Minor Minor Low Moderate Minor Minor Negligible

9.2.15 The ES will report on the significance of effect in accordance with EIA regulations. Effects of major or moderate significance are considered to be significant. Within the NPPF, impacts affecting the significance of heritage assets are considered in terms of harm and there is a requirement to determine whether the level of harm amounts to ‘substantial harm’ or ‘less than substantial harm’. There is no direct correlation between the significance of effect as reported in this ES and the level of harm caused to heritage significance. A major significant effect on a heritage asset would, however, more often be the basis by which to determine that the level of harm to the significance of the asset would be substantial. A moderate significant effect is unlikely to meet the test of substantial harm and would therefore more often be the basis by which to determine that the level of harm to the significance of the asset would be less than substantial. In all cases determining the level of harm to the significance of the asset arising from development impact is one of professional judgement.

Geographical Scope

9.2.16 It is proposed for the assessment of potential impacts to built heritage assets that a study area of 1km from the site boundary is used. The study area will be refined or expanded following the site visit and following the assessment of the baseline setting of heritage assets and in collaboration with the landscape and visual assessment to reflect the ZTVI for the Proposed Development

Temporal Scope

9.2.17 The impact assessment will assess potential impacts arising from the construction and operational phases of the Proposed Development.

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9.3 BASELINE ENVIRONMENT

9.3.1 Due to the semi-rural location of the Site and in order to assist with the scoping assessment, designated heritage assets within a study area of approximately 1km around the Site has been considered in order to gain an understanding of the nature of the existing historic environment. Non-designated historic buildings will be considered within 500m of the Site.

9.3.2 There are 431 listed buildings within 1km of the Site boundary. The listed buildings that are in closer proximity to the Site boundary include the Viaduct over Trent and Mersey Canal (Grade II, NHLE 1051990) approximately 100m west of the site; the Bridge no 64 off Road (Grade II, NHLE 1248258) approximately 300m south-west of the site; buildings associated with Hawkesyard Priory approximately 100m to the south; the Old Farmhouse restaurant (Grade II, NHLE 1038771) approximately 250m south-east; and buildings to the east including the Grade II* Old Hall (NHLE 1248906) and the Grade I Church of St Nicholas (NHLE 1249035).

9.3.3 There are no World Heritage assets, registered parks and gardens or registered battlefields within the study area.

9.3.4 There are no conservation areas within the Site, however there are several conservation areas that fall wholly or partly within the study area2. The conservation areas that are in closer proximity to the site include the Trent and Mersey Canal Conservation Area (partly within the Cannock Chase and Lichfield District Councils) and the Mavesyn Ridware Conservation Area to the east.

9.3.5 Cannock Chase and Lichfield District Councils do not hold a list of locally listed buildings. However, the conservation areas that fall within the study area include a series of important unlisted buildings as identified on the available conservation area appraisals.

9.4 POTENTIAL ENVIRONMENTAL IMPACTS & EFFECTS

9.4.1 It is anticipated that impacts may include changes to the setting of heritage assets during construction and upon the completion of the Proposed Development.

1 This number is subject to change upon the creation of accurate mapping of the exact boundaries of the development area.

2 An accurate red line boundary and mapping of the conservation areas is necessary so as to confirm the exact number of the conservation areas that fall within the study area.

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EIA Scoping Report Chapter 9: Built Heritage Rugeley B Power Station, Rugeley

Construction Impacts and Effects

9.4.2 The south-eastern boundary of the Site is adjacent to the Trent and Mersey Canal Conservation Area. Construction of the Proposed Development has the potential to result in temporary impacts to this designated heritage asset. This will be assessed in more detail during the EIA.

9.4.3 Additionally, the construction of the Proposed Development may result in changes to the setting of a number of designated and non-designated heritage assets in the study area. This will be assessed in more detail during the EIA.

Occupation Impacts and Effects

9.4.4 The operational development has the potential to increase traffic numbers in the study area, which may result in changes to the setting of designated assets. This will be assessed in more detail during the EIA.

9.5 MITIGATION ENVISAGED

9.5.1 At the time of writing, a masterplan is being prepared. It is proposed that the Proposed Development and masterplan will be developed taking into consideration and with appreciation of built heritage considerations. Mitigation will be inbuilt in the design of the Proposed Development to minimise impacts to built heritage assets and their setting as far as possible. Mitigation will be developed and refined during the EIA process and agreed with stakeholders including Historic England and the Conservation Officers. Additional potential mitigation measures include landscape planting and other landscape mitigation in order to avoid or reduce impacts on built heritage assets.

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EIA Scoping Report Chapter 10: Ecology (Biodiversity) Rugeley B Power Station, Rugeley

CHAPTER 10: ECOLOGY (BIODIVERSITY)

10.1 INTRODUCTION

10.1.1 This chapter of the ES Scoping Report has been produced by Atmos Consulting Ltd (‘Atmos’) based on ecological surveys and a review of existing information for the Site and surrounding area to an appropriate buffer.

10.1.2 It is proposed that an ecological assessment is scoped in to the EIA. Details of the designated sites, habitats and species proposed to be assessed in the context of the Proposed Development are detailed further in Section 10.3.

10.2 ASSESSMENT CRITERIA & METHODOLOGY

Previous Assessment

10.2.1 There have been a number of previous assessments undertaken in relation to the Site.

10.2.2 It is necessary to note that, as set out in Chapters 2 and 3, the baseline for consideration of the Proposed Development in this EIA will be the Site following:

 completion of the demolition of all buildings on Site, with the exception of the substation, Engie Offices and Environmental Education Centre. The Engie Offices and Environmental Education Centre will be demolished as part of the Proposed Development and the substation will remain; and

 completion of permit surrender works, specifically extraction of the pulverised fuel ash (PFA) from the eastern ash lagoons followed by the creation of a level platform.

10.2.3 It is therefore expected that some elements of the current available survey data cannot strictly reflect the conditions on Site which will be present prior to development. As such, effort is made in the baseline description to consider how these changes may affect the baseline conditions. Where these habitat changes result in them becoming unsuitable for use by certain dependent species (for example peregrine Falco peregrinus on power station buildings and sand martin in ash lagoons), the impact assessment for the Proposed Development does not consider the effects of their direct loss but does provide for the agreed mitigation/compensation measures to be ongoing in the Proposed Development and for habitat enhancements to include these species as relevant.

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EIA Scoping Report Chapter 10: Ecology (Biodiversity) Rugeley B Power Station, Rugeley

10.2.4 The previous reports are listed below and will be considered in the ecological assessment as part of the EIA:

 Parsons Brinckerhoff (July 2015) Rugeley Power Station Updated Extended Phase 1 Assessment Final. Report to Engie. Ref. 3512427H  Bird Brain UK (September 2015) Rugeley Power Station Breeding Bird Survey Final. Report to WSP Parsons Brinckerhoff. Ref. 3512427H-BB-0001  Parsons Brinckerhoff (May 2010) Extended Phase 1 Habitat Assessment Report for Rugeley Power Station, Staffordshire. Report to International Power. Ref. 63959A  Parsons Brinckerhoff (February 2011) Bat Surveys Rugeley Power Station Staffordshire Final. Report to International Power. Ref. FSE97373A  Parsons Brinckerhoff (November 2010) Badger Survey Rugeley Power Station Staffordshire. Draft. Report to International Power. Ref. FSE97373A  Parsons Brinckerhoff (November 2010) Great Crested Newt Surveys Rugeley Power Station Staffordshire Draft. Report to International Power. Ref. FSE97373A  Parsons Brinckerhoff (November 2010) Reptile Surveys Rugeley Power Station Staffordshire. Report to International Power. Ref. FSE97373A  Parsons Brinckerhoff (September 2010) Borrow Pit Otter Survey. Final. Report to Rugeley Power Ltd. Ref. FSE97373A  Arbtech (July 2017) Bat Survey – Preliminary Roost Assessment (with emergence and activity surveys). Rugeley Power Station. Report to Mr Rob Campbell, Rugeley Power Ltd.  Jacobs (February 2009) Baseline Bat Surveys, B Station Borrow Pit Landfill, Rugeley Power Station, Staffordshire. Report to International Power Rugeley. Ref. J24151C0  Jacobs (May 2007) Environmental Statement: Volumes 1, 2 and 2. Proposal to Restore Rugeley ‘B’ Station Borrow Pit through Landfill using Pulverised Fuel Ash. Rugeley Power Station. Report to International Power Rugeley  The Environmental Dimension Partnership (EDP) Ltd (August 2017) Rugeley Power Station Ecological Appraisal Updated (proposed access route). Report to Rugeley Power Ltd. Ref. EDP3422_02d  Badger licence for sett closure – no details held by Atmos

Legislative Context

10.2.5 National legislation for the special protection of selected species is provided in the Wildlife and Countryside Act (WCA) 1981, as amended. Under Section 1(1) and 1(2), all British bird species, their nests and eggs (excluding some pest and game species) are protected from intentional killing, injury or damage. Under Sections 1(4) and 1(5), special penalties are applied to bird species included in Schedule 1 of the Act and protection is extended for these species to disturbance to birds whilst building, in or near a nest and disturbance to dependant young. Schedule 5 provides special protection to selected animal species other than birds, through Section 9(4) of the Act, against damage to “any structure or place which any [wild animal

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included in the schedule] uses for shelter and protection” and against disturbance whilst in such places.

10.2.6 Non-native invasive plants are listed on Schedule 9 of the WCA which makes it an offence to spread or enable them to be spread in the wild. The list includes species such as Japanese knotweed Fallopia japonica and Himalayan balsam Impatiens glandulifera.

10.2.7 A number of animals, known as European protected species (EPS), are provided full protection through inclusion in Schedule 2 of The Conservation of Habitats and Species Regulations 2017, as amended. The Regulations provide protection against deliberate disturbance to those animals wherever they are present, and provides tests against which the permission for a development that may have an effect on a Schedule 2 protected species must be assessed before permission can be given.

10.2.8 In addition to species protection, the Wildlife and Countryside Act 1981 (as amended) and Habitats Regulations also set out requirements/procedures for the notification, designation and protection of a range of statutory site designations in order to preserve important nature conservation resources.

10.2.9 All public authorities have a requirement to pay due regard to the conservation and enhancement of habitats and species through Section 41 of the Natural Environment and Rural Communities Act 2006 (NERC), which states, “Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity”. To this end, Section 41 of the NERC Act provides for the establishment of a list of habitat and species that are considered to be of “principal importance for the conservation of biological diversity in England”.

Bats

10.2.10 All bat species are protected through the Wildlife and Countryside Act (1981) (as amended); the Countryside and Rights of Way Act, 2000; the Natural Environment and Rural Communities Act (NERC, 2006); and by the Conservation of Habitats and Species Regulations (2017). Bats are commonly referred to as European Protected Species (EPS).

10.2.11 It is an offence to deliberately or recklessly:

 capture, injure or kill a bat;  harass an individual or group of bats;  disturb a bat while it is occupying a structure or place used for shelter or protection;

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 disturb a bat while it is rearing or otherwise caring for its young;  obstruct access to a breeding site or resting place, or otherwise deny the animal use of the breeding site or resting place;  disturb a bat in a manner that is, or in circumstances which are, likely to significantly affect the local distribution or abundance of the species to which it belongs;  disturb a bat in a manner that is, or in circumstances which are, likely to impair its ability to survive, breed or reproduce, or rear or otherwise care for its young; and  disturb a bat while it is migrating or hibernating.

10.2.12 It is also an offence of strict liability to:

 damage or destroy a breeding site or resting place of a bat even if they are not in use at the time (i.e. a summer roost during the winter period).

Otter

10.2.13 The otter Lutra lutra is listed in Annexes II and IV of the EC Habitats Directive and is fully protected along with its habitat in the UK under the Conservation Regulations 2017 (the Habitat Regulations). The legislation specifies a number of offences which include to deliberately or recklessly capture, kill, injure or disturb otters (while using a resting place), or to damage and destroy a breeding site or resting place for otters. It is also an offence to disturb an otter in a manner that is, or in circumstances which are, likely to significantly affect the local distribution or abundance of the species or to impair its ability to survive, breed or reproduce, or rear of otherwise care for its young.

10.2.14 Otters are listed as a Species of Principal Importance in England (NERC Act 2006).

Great crested newt

10.2.15 Great crested newts Triturus cristatus are afforded full statutory protection as a European protected species listed on Schedule 2 of The Conservation (Natural Habitats, &c.) Regulations 20171994, as amended, which transpose into British law the European Community’s Habitats Directive (92/43/EEC).

10.2.16 Under the terms of Regulation 39(1), with certain exceptions, a person commits an offence if he/she:

 “(a) deliberately captures, injures or kills any [a great crested newt];  (b) deliberately disturbs wild [great crested newts].  (1A) For the purposes of paragraph (1)(b), disturbance of animals includes in particular any disturbance which is likely —

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 (a) to impair their ability –  (i) to survive, to breed or reproduce, or rear or nurture their young; or  (ii) in the case of animals of a hibernating or migratory species, to hibernate of migrate; or  (b) to affect significantly the local distribution or abundance of [great crested newts];  (c) deliberately takes or destroys the eggs of [a great crested newt]; or  (d) damages or destroys a breeding site or resting place of [a great crested newt].”

10.2.17 It is also an offence under Regulation 39 to keep, transport, sell or exchange, or offer for sale or exchange, any live or dead wild Great crested newt, or any part of, or anything derived from one.

10.2.18 All of the above protections apply regardless of the stage of the life of the animal in question.

10.2.19 Protection of great crested newts’ is also provided for in the Wildlife and Countryside Act 1981, as amended. The great crested newt is listed on Schedule 5 of the Act, and is afforded partial protection under the terms of section 9(4)(b) and (c) and (5). This makes it an offence if any person:

 9(4) “… intentionally or recklessly … (b) … disturbs any [great crested newt] while it is occupying a structure or place which it uses for shelter or protection; or (c) … obstructs access to any structure or place which any [great crested newt] uses for shelter or protection.”  9(5) “… (a) sells, offers or exposes for sale, or has in his possession or transports for the purpose of sale, any live or dead [great crested newt], or any part of, or anything derived from, such an animal; or (b) publishes or causes to be published any advertisement likely to be understood as conveying that he buys or sells, or intends to buy or sell, any of those things”.

10.2.20 There are provisions in the above legislation for the licensing of activities to facilitate development that would otherwise constitute an offence. However, the statutory agency Natural England (NE) advises that the requirement for licensing should be carefully considered by developers, on a site/activity-specific basis, and recommends consideration of non-licensed mitigation such as reasonable avoidance measures relating to timing of works and sensitive site clearance to minimise potential for adverse impacts to this species where this can be achieved.

Water vole

10.2.21 Water voles are listed on Schedule 5 of the Wildlife and Countryside Act (WCA) 1981 (as amended) and consequently are subject to the provisions of Section 9, which makes it an offence to:

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 intentionally capture, kill or injure water voles;  damage, destroy or block access to their places of shelter or protection (on purpose or by not taking enough care);  disturb them in a place of shelter or protection (on purpose or by not taking enough care); and  possess, sell, control or transport live or dead water voles or parts of them (not water voles bred in captivity).

10.2.22 Activities that can harm water voles include:

 destroying or disturbing their habitat;  destroying or disturbing places used for shelter or protection; and  changing water quality

White-clawed crayfish

10.2.23 The white-clawed crayfish is protected under Schedule 5 of the Wildlife and Countryside Act 1981 (as amended) making it illegal to harm, disturb and take (including to handle), this species without an appropriate licence, or to buy or sell white-clawed crayfish whether alive or dead

Badger

10.2.24 The Protection of Badgers Act 1992, as amended, provides protection to badgers and their setts.

Reptiles

10.2.25 All common reptile species, including slow worm Anguis fragilis, common lizard Lacerta vivipara and grass snake Natrix natrix, are partially protected under Sections 9(1) and 9(5) of Schedule 5 of the Wildlife and Countryside Act 1981 (as amended). The legislation provides protection for these species from:

 Intentionally killing and injury; and  Selling, offering for sale, possessing transporting for the purpose of sale or publishing advertisements to buy or sell a protected species.

10.2.26 This partial protection does not directly protect the habitat of these reptile species; however, where these animals are present on land that is to be affected by development, the implications of the legislation are that providing that killing can reasonably be avoided then an operation is legal. Guidance provided by Natural England (English Nature, 2004) and the Amphibian and Reptile Groups of the UK (Herptofanual Groups of Britain and Ireland, 1999) recommends that this should be achieved by ensuring that:

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 The animals must be protected from injury or killing;  Mitigation is provided to maintain the conservation status of the species; and  Following operations, the population should be monitored.

10.2.27 All common reptile species are listed under Section 41 of the NERC Act 2006.

Planning Policy and Guidance

National Planning Policy

10.2.28 The National Planning Policy Framework (NPPF) was first published by the government on 27th March 2012 and provided new guidance for local authorities, replacing the existing planning policy guidance, including that relating to biodiversity, Planning Policy Statement 9 (PPS9): Biological and Geological Conservation. In July 2018 an updated version of the NPPF was published.

10.2.29 The Government Circular 06/05: Biodiversity and Geological Conservation - Statutory Obligations and their impact within the Planning System, which accompanied PPS9, remains valid at the time of writing however.

10.2.30 Section 15 of the NPPF specifies the requirements for conserving and enhancing the natural environment. While a key aim of the NPPF is to assist plan-makers, it also provides advice for the determination of planning applications, much of which reaffirms the protection previously afforded by PPS9 to designated sites, priority habitats and species and ancient woodland. The NPPF places a greater emphasis on ecological networks and states that the planning system should provide net gains for biodiversity, by “ minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures” (Paragraph 170).

Local Planning Policy

Current Planning Policy

10.2.31 The western part of the Site is within CCDC and the Proposed Development would be assessed against the Cannock Chase Local Plan (Part 1) 2014. The following policies are of relevance to the ecological assessment:

 CP12 Biodiversity and Geodiversity  CP13 Cannock Chase SAC

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10.2.32 The eastern part of the site is within LDC and the Proposed Development would be assessed against The LDC Local Plan Strategy 2008-2029 (adopted February 2015). The following policies are of relevance to the ecological assessment:

 Strategic Priorities SP12 and SP13  CP13: Our Natural Resources  NR3: Biodiversity, Protected Species and their Habitats  NR4: Trees, Woodland and Hedgerows  NR5: Natural and Historic Landscapes  NR6: Linked Habitat Corridors and Multi-functional Greenspaces  NR7: Cannock Chase Special Area of Conservation

10.2.33 The Rugeley Power Station Development Brief Supplementary Planning Document (SPD) (adopted by both authorities 20th February 2018) forms a material consideration when determining any future planning application for the Site. Specific considerations in relation to ecology are provided in Sections 2.39 – 2.44, and are summarised as follows:

 Industrial areas of the Site are likely to be of low ecological value, with landscape features and waterways key ecological assets

 Surveys and a preliminary ecological assessment are required to establish the presence of protected species on site and in line with NPPF, any impacts on these species should be avoided, then mitigated against, or if this is not possible, compensated for.

 Identifies opportunities to biodiversity enhancement through redevelopment of the Site. It recommends a quantitative assessment is undertaken to demonstrate the Proposed Development achieves both 'no net loss' to biodiversity and 'net gains to biodiversity'.

 The Site lies within the Cannock Chase Special Area of Conservation (SAC) Zone of Influence and will require Appropriate Assessment under the Habitats Directive. New developments are required to ensure no harm arises to the SAC. Specific guidance on this matter has been published by LDC and CCDC and is referred to below.

 The mature vegetation along the site boundaries form part of the Area TPO, where trees will be retained unless their removal is required for development, management or stability purposes.

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10.2.34 LDC have produced a Biodiversity and Development SPD (2016) which sets out the biodiversity in the context of the Lichfield district and specific requirements for assessments accompanying planning applications.

Emerging Planning Policy

10.2.35 CCDC are in the process of a local plan review, which will eventually seek to replace the 2014 Local Plan detailed above. At the time of writing, a Local Plan Issues and Scoping Consultation took place in summer 2018, with the results being incorporated into the next step, an Issues and Options consultation scheduled for early 2019.

Guidance/ Best Practice

10.2.36 The following publications will also be referred to as part of the EIA:

 Guidelines for Ecological Impact Assessment in the UK and Ireland: Terrestrial, Freshwater and Coastal (Chartered Institute of Ecology and Environmental Management (CIEEM, 2018); and

 Staffordshire Biodiversity Action Plan; and

 Guidelines for the Selection of Local Wildlife Sites in Staffordshire. Staffordshire Wildlife Trust and Staffordshire Wildlife Sites Partnership, 2017 (version 6)

10.2.37 CCDC and LDC have published guidance to mitigate the impact of residential development on the Cannock Chase SAC (May 2017). Evidence produced to inform CCDC Policy NR7 showed that “in combination” impact of proposals involving a net increase of one or more dwellings within a 15 kilometre radius of the SAC would have an adverse effect on its integrity unless avoidance and mitigation measures are in place; with a significantly higher proportion of visitors coming from within 8km. Cannock Chase SAC Partnership therefore acknowledge a 15km Zone of Influence, with financial contributions for the required mitigation being sought in the 0-8km Zone only, in which the Proposed Development lies.

Baseline Data Collection

Desk Study

10.2.38 A desk study has been undertaken, with data obtained from a combination of available sources. Staffordshire Ecological Records Centre (SERC) provided existing records for the Site and up to a 2km buffer for protected and Priority Species and locally designated sites. In addition, information on statutory designated nature conservation sites was obtained from the

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Government mapping portal ‘Magic’. The desk study also included review of previous published and unpublished reports relating to the Site or nearby as listed above in Section 10.2.4.

Field Survey Methodology

10.2.39 The field surveys proposed to be used as the baseline for the ecological assessment are outlined in Table 10.1 below.

10.2.40 These include surveys that have been undertaken on the Site in late summer/autumn 2018 commissioned specifically for the Proposed Development. Furthermore, surveys are proposed to be undertaken during spring 2019 and the results included in the EIA.

10.2.41 In addition to the 2018 and early 2019 surveys, as detailed in Section 10.2, there is a wealth of historic ecological data relating to the Site collected between 2006 and 2017. As well as providing context for the Site, in some cases it was not possible to undertake surveys for some species during the summer/autumn of 2018 due to seasonal constraints. It is therefore proposed to utilise some of the existing survey results as part of the EIA.

10.2.42 Further details including full methodologies and an assessment of the continued relevance of this data is provided below.

Table 10.1: Pre-submission - Ecology field survey data proposed to form the baseline for the EIA

Survey type Survey area Date(s) Comments on timing and use in EIA Site and 100m buffer Up to date, undertaken in recognised Extended Phase 1 21st and 22nd August where access survey window and pond HSI 2018 possible Areas of Site 7 visits on non- Undertaken towards end of recognised assessed as suitable consecutive days survey window but surveys during late Reptiles and potentially between 17th summer/autumn can detect reptiles presence/absence affected by Proposed September and 16th when population is at its largest with Development October 2018 juveniles as well as adults Watercourses and Up to date, undertaken in recognised Otter and water waterbodies on Site 24th September 2018 survey window vole including River Trent White-clawed Watercourses and Up to date, undertaken in recognised crayfish habitat waterbodies on Site 19th September 2018 survey window. Further survey of River assessment including River Trent Trent proposed (see below) Undertaken to gather data on species Two transects utilising site as not possible to cover Bat activity 24th and 25th covering differing 2018 active season. To be transect September 2018 habitats on Site supplemented with previous 2017 survey data for EIA (see below) Deployed to record bat activity in an Bat static September and Two static detectors open area and habitat feature for 5 detectors October 2018 nights per location

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Bat activity Three transects Up to date, undertaken in recognised transect and roost covering main power 6th July 2017 dusk survey window. Carried out by a third surveys station Site party (Arbtech) for demolition works Emergence survey of Up to date, undertaken in recognised Bat roost survey Environmental 25th May 2017 dusk survey window. Carried out by a third Education Centre party (Arbtech) for demolition works. Bat roost Trees and some 12th to 14th November Up to date, undertaken in recognised assessment buildings on Site 2018 survey window Site and 100m buffer Up to date, undertaken in recognised 12th to 14th November Badgers where access survey window 2018 possible Up to date for EIA submission prior to end of 2019 season based on Site and buffer where 4 survey visits April to timescales in published guidance on Breeding birds access possible June 2015 ornithology data longevity (SNH 2017) and habitat present. Carried out by a third party (Bird Brain UK). Covering habitats Will be undertaken prior to ES Tbc when information Extended Phase 1 around highway submission when proposed highway available amendments amendments (if any) are known Will be undertaken prior to ES Great crested All waterbodies on From 15th April 2019 submission and incorporated in newt eDNA Site onwards ecological assessment Will be undertaken prior to ES White-clawed River Trent adjacent From 1st April 2019 submission and incorporated in crayfish eDNA to Site and buffer onwards ecological assessment

10.2.43 Further surveys are proposed to be undertaken post-submission of the ES to update the ecological baseline and would be submitted to LDC and CCDC during the determination period. These are listed in Table 10.2 below and further information is provided in the survey methodologies.

Table 10.2: Post-submission - Ecology field surveys proposed during determination period

Survey type Survey area Survey period Comments Two transects To be undertaken following BCT Bat activity transect covering differing April to October 2019 guidance during bat active season surveys habitats on Site based on a moderate potential Site Of trees or buildings To be undertaken following BCT with roost potential May to September guidance during bat active season Bat roost surveys are to be 2019 removed/affected Site and buffer To be undertaken using a modified 4 survey visits April to Breeding birds where access Common Bird Census methodology June 2019 possible (Gilbert et al 1998) Great crested newt Waterbodies with a Dependent on eDNA survey result. From 15th April 2019 population size positive eDNA Only carried out if positive onwards class assessment result (if any) White-clawed River Trent adjacent From 1st July 2019 Dependent on eDNA survey result. crayfish trapping to Site and buffer onwards Only carried out if positive

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Survey Methodology to Inform EIA Baseline and Assessment

Extended Phase 1 Habitat Survey of Site and Highway Amendment Buffers

10.2.44 An extended Phase 1 habitat survey was undertaken on 21st and 22nd August 2018 covering the Site and a buffer of approximately 100m depending on access, as shown in Figures 10.1 and 10.2. The Phase 1 method is a standardised method of recording habitat types and characteristic vegetation, as set out in the Handbook for Phase 1 Habitat Survey – a technique for Environmental Audit (JNCC, 2010), and which has been adopted by the agencies and planning authorities nationwide. The habitat survey is ‘extended’ through the additional recording of specific features indicating the presence, or likely presence, of protected species or other species of nature conservation significance.

10.2.45 In particular a Habitat Suitability Index (HSI) assessment was undertaken on accessible waterbodies for great crested newt, following Oldham et al. This assesses the presence of features of importance for great crested newt, such as pond size, presence of aquatic vegetation, shading and predation such as fish and waterfowl, to provide an overall suitability index, as follows:

 <0.5 = poor  0.5 – 0.59 = below average  0.6 – 0.69 = average  0.7 – 0.79 – good  >0.8 = excellent

10.2.46 Habitats were mapped and ‘target notes’ were made to describe characteristic habitats, features of ecological interest, or other features which may present a potential constraint to the Proposed Development. Whilst not a full protected species or botanical survey, the extended Phase 1 method enables a suitably experienced ecologist to undertake a baseline ecological appraisal of the site in order to form a professional judgement on whether or not further specialist survey are required. Following on from this survey, further surveys were undertaken in September and October 2018 as described below.

10.2.47 An extended Phase 1 habitat survey will be undertaken in spring 2019 of areas proposed for highway amendments where these involve widenings or additional access points.

10.2.48 The 2018 extended Phase 1 habitat survey did not include the area of the power station buildings as they were in the process of demolition and access was not possible due to specific health and safety arrangements in place. The area was therefore not fully surveyed and is illustrated as such on Figure 1. However, this was not considered to be a significant limitation

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as the baseline for EIA purposes is for these power station buildings to be demolished and bare ground/hardstanding to remain.

Reptiles Presence/Absence

10.2.49 Presence/absence surveys were undertaken in areas of the Site assessed as providing suitable habitat for reptiles during the extended Phase 1 habitat survey. These were undertaken following published guidance (Froglife, 1999) and employed artificial refuges of carpet tiles and corrugated tin 0.5m2 in size placed across the Site in suitable (such as rough grassland, woodland, edge habitats) and less suitable (open grassland, bare ground) habitats. These were spaced at a density of approximately 10/ha. The refuges were deployed and allowed time to ‘bed in’ before the survey commenced. The locations of the refuges are shown in Figure 10.3.

Table 10.3 Reptile Survey Conditions

Survey visit Date Times Weather Temperature (ͦC) 1 24/09/2018 12:30 – 17:00 Clear, no rain 16 – 20 2 26/09/2018 09:30 – 14:30 Clear, no rain 14 – 16 3 02/10/2018 08:45 – 15:00 Cloudy, intermittent light rain 14 – 16 4 04/10/2018 08:50 – 15:30 Cloudy, no rain 14 – 18 5 09/10/2018 09:00 – 15:30 Clear, no rain 13 – 17 6 11/10/2018 09:00 – 15:30 Cloudy, no rain 17 – 19 7 16/10/2018 09:00 – 15:30 Cloudy, no rain 12 - 16

10.2.50 The surveyed areas and density of refuges were as follows. In total 233 refuges were deployed giving an overall density of 10/ha. In addition to specifically surveying refuges, other natural and man-made areas of cover were also checked for signs or sightings of reptiles. There were discarded rolls of rubber matting by the model railway, log piles in the rubble of power station A and railway sleepers along the siding. The surveyor was also vigilant for sightings of reptiles in natural cover during the walkover survey. As such, the actual density of the refuges for the reptile survey was greater than the 10/ha of the artificial refuges deployed.

Table 10.4: Reptile Survey Artificial Refuge Locations3: Reptile Presence/Absence Survey Areas

Area Approx size (ha) No. of refuges Density Rubble of Power Station A; grassland by 5 ha 53 10.6 ‘S-shaped’ ditch Recreation pitches, rough grassland, 10 ha 100 10 woodland and small overgrown golf course Verges of the Site access road and along 2.5 ha 23 9.2 railway siding

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Ash lagoons – focussing on those with 3.6 ha 39 10.8 thicker vegetation cover at ground level Woodland and grassland south of Borrow 1.8 ha 18 10 Pit pond where 2nd site access located Total 22.9 ha 233 refuges 10.1(average)

Survey Limitations and Considerations

10.2.51 All survey areas were covered to the recommended density of 10/ha with the exception of the Site access road verges. These could not be sampled as densely due to regular mowing regime restricting the refuges along the margins and ‘edge habitats’ between the mown and unmown areas. However this is not considered to be a limitation as these edge habitats are typically more suitable for reptiles and therefore the likelihood of finding them, if present, would be greater.

10.2.52 Reptile surveys of the large golf course area alongside the River Trent were not included in the survey scope, as no significant effects on this area are likely to occur as part of the Proposed Development.

10.2.53 The reptile surveys were timed during the late summer and autumn of 2018. This time of year is when reptile populations are typically at their highest when juveniles complement the adult population. The surveys were undertaken during suitable weather conditions where reptiles could reasonably have been expected to be basking on and/or sheltering beneath the refuges. Other species were observed to be using the refuges (see baseline below) indicating that they had been found and could reasonably be used by reptiles, if present. Therefore whilst the survey would ideally have covered the early summer as well as late summer/autumn, it is considered that the methodology is sufficient to provide confidence in the data obtained.

Otter and Water Vole

10.2.54 A combined otter and water vole survey was undertaken during suitable weather conditions on 24th September 2018 by two suitably experienced ecologists. It was undertaken following accepted methodologies. The survey assessed all waterbodies and watercourses on the Site for their suitability for the species and searched for characteristic signs of activity. It also included the southern banks of the River Trent where it borders the Site.

White-clawed Crayfish Habitat Assessment and eDNA

10.2.55 A white-clawed crayfish habitat assessment was undertaken by a licensed ecologist and an assistant on 19th September 2018. It assessed the watercourses and waterbodies on the Site

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for their suitability for the species, and carried out in-channel searches via turning over stones where the conditions were suitable and the watercourses/bodies were accessible.

10.2.56 The survey assessed the River Trent from the southern banks on the Site but access into the water to actively search for the species was not possible due to the fast flow rate and depth of the river. An eDNA survey of the water within the river will therefore be carried out in the recognised season from 1st April 2019. It will follow the methodology established by Surescreen Scientifics which requires the water samples from the river using a specially designed kit.

Bat Activity Surveys

2017 Surveys

10.2.57 The 2017 activity surveys were undertaken by Arbtech and covered the areas around the main power station buildings and the northern access road and railway siding up to the small golf course. They utilised three transects which were all walked slowly and bat activity observed and detected by broadband bat detection equipment. The transects were undertaken at dusk on 6th July 2017 (commencing 30 minutes before sunset and until approximately 2 hours afterwards). They were undertaken in suitable weather conditions - daytime peak temperature was 25.5°C and evening low was 13.1°C. Relative humidity was 73% at commencement. There was no rain. Average wind speed was 0.7mph and was south-westerly. Cloud cover was 2/8 oktas.

2018 Surveys

10.2.58 The 2018 activity surveys were undertaken by Atmos and covered the northern and eastern parts of the Site using two transects. Hand-held Anabat detectors were utilised, with the calls recorded and subsequently analysed using Analook software. Two static detectors were also deployed, one within the rubble of power station A as an ‘open habitat’ and one within the small golf course as a ‘habitat feature’. The detectors were each set to record for five nights, totalling ten nights of data.

10.2.59 Transect 1 (TR1) was a walked transect and covered the large golf course between the railway siding and River Trent. TR2 was a combined walked and driven transect. It utilised a vehicle driving at no more than 5mph on the Site roads with diversions on foot to areas inaccessible by vehicle. Both transects included five-minute listening points to record and observe bat activity at selected locations, as shown in Figure 10.4.

10.2.60 Together, the 2017 and 2018 surveys provide coverage of all the differing habitat types present at the time across the Site in the summer (July) and autumn (September). These are times

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when bat populations tend to be at their peak where new young are leaving maternity colonies. Whilst they are not fully in accordance with the BCT guidance (Collins, 2016), they are still considered to provide reliable data on the species utilising the Site and the flightline and foraging activity exhibited by bats. As such, they are considered suitable for use in the EIA for the proposed development, where a precautionary approach to impact assessment and mitigation will be taken to address the lower level of available data.

10.2.61 To further develop the data set, full bat activity surveys will be undertaken in 2019 in accordance with BCT guidance (see Section 10.2.73 below).

Bat Roost Assessment and Roost Surveys

2017 Surveys

10.2.62 The 2017 surveys were undertaken by Arbtech of buildings within the power station demolition zones. Of these, all will be demolished for the EIA baseline, with the exception of the Environmental Education Centre. One further building is outwith the demolition zone – the current Engie Offices. This will be part of the EIA baseline and will be demolished as part of the Proposed Development. The bat surveys for this building are provided in subsequent sections as it was not surveyed in 2017.

10.2.63 The former Environmental Education Building near the Borrow Pit Lake, referred to as Building B62, was surveyed for bats. A roost assessment was carried out with a subsequent single emergence survey undertaken on 25th May 2017 in suitable weather conditions by three surveyors.

10.2.64 Specific details of the bat assessment and surveys for the buildings to be demolished will not be relevant for the EIA. However the generalised results are of contextual value to aid the evaluation of the bat species recorded on Site during the 2018 surveys and will be referred to in the EIA.

2018 Surveys

10.2.65 In November 2018 a bat roost assessment was undertaken by Atmos following BCT guidance (Collins, 2016). This assessed the trees on Site and Environmental Education Centre for their roost potential. Where areas of trees were present that were even aged and the same or a limited mix of species, these were often grouped in their assessment of bat roost potential due to being similar in character. As the Engie Offices will be part of the EIA baseline and are

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scheduled for demolition in the Proposed Development, a bat roost assessment of this building will be undertaken in early 2019 and will be included in the assessment.

Badgers

10.2.66 A badger survey of the Site was undertaken during 24th – 26th November 2018 by two experienced ecologists. It covered all accessible areas of the Site but not a wider buffer due to access constraints. The timing during late November meant that most of the leaves had fallen from the trees and vegetation was dying back such that views into wooded and scrubby areas were clearer and signs of activity were more noticeable. Signs searched for included setts, latrines, hairs and pathways. Where a sett was identified, this was classified as active, inactive or disused based on the evidence, and whether it was main sett, outlier or subsidiary sett. The results are shown in Figure 10.5 provided in a confidential annex supplied separately to CCDC and LDC.

Breeding Birds

10.2.67 A breeding bird survey was undertaken over four visits April to June 2015 by Bird Brain UK. It covered the whole Site starting one hour before sunrise and was completed within four hours. All birds were recorded on maps with their behaviour noted. Particular attention was paid to breeding birds or those that showed signs of breeding. The route taken was varied and surveys were completed in optimum field conditions (little or no wind or rain). Weather conditions during the surveys are provided in Table 10.5 below.

Table 10.5: Breeding Bird Survey Timing and Weather Conditions

Date Time Weather Conditions Survey Conditions 28th April 2015 04:58 to 08:53 hrs 2-11 C, no cloud cover and Very good southwest wind up to 11kph 19th May 2015 04:45 to 08:19 hrs 12 C, 50% cloud cover and Very good west wind up to 24kph 9th June 2015 03:45 to 07:07 hrs 5-7 C, no cloud cover and no Very good wind 30th June 2015 03:38 to 07:50 hrs 16-19 C, 25% cloud cover and Excellent no wind

10.2.68 Whilst this survey was carried out during the breeding season of 2015, it is considered to still reflect the current habitat conditions present on the Site and falls within the acceptable period in which data is considered current (e.g. SNH 2017 which indicates ornithology data is considered valid for five years.). Moreover, it is necessary to highlight that due to the ongoing demolition works and permitted PFA extraction works in the ash lagoons (scheduled to

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commence winter of 2019/2020 and be completed by the end of 2021), there will be further more significant changes to the Site which would in any case likely change the baseline breeding bird populations present. As such, it is considered that the 2015 data is no less relevant than any collected more recently up to planning submission as the habitats present in 2015 still largely remain.

Great Crested Newt eDNA

10.2.69 A great crested newt eDNA survey will be carried out from 15th April 2019, which is the recognised survey period. All potentially suitable waterbodies will be sampled across the Site following the required methodology by licensed and experienced ecologists. The samples will then be analysed by Surescreen Scientifics, with the returned result either negative (no great crested newt present) or positive (great crested newt present).

10.2.70 Should great crested newt DNA be found present in one or more of the waterbodies sampled, further surveys would be undertaken, as appropriate based on the guidance provided by Natural England (www.gov.uk). The waterbodies selected for survey would be assessed on the basis of proximity to the Proposed Development and proximity to waterbodies with a positive result (e.g. waterbodies within 250m of one another can reasonably have exchange of individuals).

Proposed 2019 Surveys during Determination Period

10.2.71 As per Table 10.2, the following surveys will be undertaken during the active season of 2019.

Bat Activity Surveys 2019

10.2.72 Based on the habitats present across the Site, it is considered to be of moderate potential for commuting and foraging bat habitat. The tree lines, open grassland and waterbodies provide suitable connected habitat for bats, but in some places these are separated by the open habitats in more disturbed areas (e.g. ash lagoons, rubble of power station A). Whilst the site includes the large golf course and River Trent to the north, this area will be minimally affected by development and is proposed as a Country Park.

10.2.73 For a moderate potential Site, one survey visit per month will be undertaken (April to October inclusive, totalling seven months) utilising the same two transect routes as in 2018. Two static bat detectors will be deployed per transect (i.e. four in total). The survey results will be analysed and interpreted and provided as a supplementary report to the ES during the determination period, with any assessments, mitigation, compensation and enhancement updated as a result, if necessary.

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Bat Roost Surveys 2019

10.2.74 The 2018 bat roost assessment identified trees and buildings with low, moderate or high bat roost potential. If the Proposed Development involves works in proximity to these features such that direct or indirect impacts are predicted, further roost surveys will be carried out post- submission between May and September 2019. A precautionary assessment and best practice mitigation will be presented in the ES, with this updated by a supplementary report provided in the determination period. As bat roosts in trees with features such as those recorded on the Site, are often transient in nature, a precautionary assessment would be taken in the ES even if surveys had been carried out and returned a negative result, as the use of trees by roosting bats can vary across the year.

Breeding Birds 2019

10.2.75 Breeding bird surveys will be undertaken across the Site in 2019 using a modified Common Bird Census methodology. They will comprise four visits between April and June spread approximately 3 weeks apart. Each survey would commence one hour before sunrise and the survey route would be walked in opposite directions each time to maximise detection across the Site. Following each survey, results would be analysed to determine the number of confirmed, probable and possible territories present within the survey area.

White-clawed Crayfish Trapping 2019

10.2.76 Should the white-clawed crayfish eDNA test return a positive result in the River Trent, we would assess the implications and if relevant, undertake further survey. Crayfish traps would be deployed in suitable weather conditions using a methodology agreed with Surescreen Scientifics to account for the depth and fast flow of the river. The traps would be deployed during the night time from 1st July 2019 and collected in the morning to check for any crayfish trapped. Prior to a survey being undertaken, a trapping permit would be obtained from the Environment Agency.

Proposed Assessment Methodology

10.2.77 The CIEEM Guidelines for Ecological Impact Assessment in the UK and Ireland (CIEEM, 2018) (henceforth referred to as the CIEEM guidelines) will be followed for the EIA. These guidelines set out a process of identifying the value of each ecological receptor and then characterising the impacts that are predicted, before discussing the effects on the integrity or conservation status of the receptor, proposed mitigation and residual impacts.

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10.2.78 The initial action for any assessment of impacts will be to determine which features should be subject to detailed assessment. The ecological receptors to be the subject of more detailed assessment should be of sufficient value that impacts upon them may be significant in terms of either legislation or policy. The receptors should also be vulnerable to significant impacts arising from the Proposed Development.

10.2.79 All designated nature conservation sites, plant and animal species, habitats and integrated plant and animal communities that occur within the ‘zone of impact’ of the Proposed Development will be defined as potential ecological features (as described below).

Determining Value

10.2.80 The CIEEM guidelines recommend that the value of ecological features is determined based on a geographic frame of reference. For this project the following geographic frame of reference is used:

 International (nature conservation designation, habitat or populations of species of international importance, e.g. a Special Area of Conservation (SAC) or significant numbers of a designated population outside the designated site);

 National (nature conservation designation, habitat or populations of species of English importance, e.g. a Site of Special Scientific Interest (SSSI) or a National Nature Reserve (NNR), a nationally important population/ assemblage of a European Protected Species (EPS) and/or a species listed on Schedule 5 of the Wildlife and Countryside Act 1981);

 Regional (nature conservation designation, habitat or populations of species of Cannock/Lichfield importance, e.g. a site/population that meets SSSI designation criteria but has not been designated due to better examples being present in the regional area or a regionally important population/area of a priority species/habitat);

 Local (i.e. within 5 km) (a nature conservation site, habitat or species of importance in the local or district area, e.g. a breeding population/viable area of local BAP species/ habitat); and

 Less than local (unremarkable habitat/common species of little/no intrinsic nature conservation value).

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Valuing Habitats

10.2.81 The value of habitats, according to the CIEEM guidelines, is measured against published selection criteria where available. Reference may therefore be made to Habitat Action Plans (HAPs) contained within the Staffordshire LBAP. As the guidelines notes, the presence of a HAP reflects the fact that the habitat concerned is in a sub-optimal state and hence the action plan is required and a HAP does not, therefore, necessarily imply any specific level of importance for the habitat. It must be noted, in accordance with the guidance, that features may be assigned greater value if there is reasonable chance that they can be restored to a higher value in the future.

Valuing Species

10.2.82 In assigning a level of value to a species, it is necessary to consider its distribution and status, including a consideration of trends based on available historical records. Rarity is an important consideration because of its relationship with threat and vulnerability although, because some species are inherently rare, it is necessary to look at rarity in the context of status. A species that is rare and declining should be assigned a higher level of importance than one that is rare with a stable population. Reference may also be made to Species Action Plans (SAPs) contained within the Staffordshire LBAP and other indicators of conservation status, as appropriate, however, as above with HAPs, the existence of a SAP does not necessarily imply any specific level of importance.

Predicting and Characterising Impacts

10.2.83 In accordance with the CIEEM guidelines, when describing impacts, reference is made to the following, where appropriate:

 Confidence in predictions - the level of certainty that an impact will occur as predicted, based on professional judgement and where possible evidence from other schemes – this is based on a four point scale: certain/near certain; probable; unlikely; and extremely unlikely;  Magnitude – the size of an impact in quantitative terms where possible;  Extent – the area over which an impact occurs;  Duration – the time for which an impact is expected to last;  Reversibility – a permanent impact is one that is irreversible within a reasonable timescale or for which there is no reasonable chance of action being taken to reverse it. A temporary impact is one from which a spontaneous recovery is possible; and  Timing and frequency – i.e. whether impacts occur during critical life stages or seasons.

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10.2.84 Both direct and indirect impacts will be considered: direct ecological impacts are changes that are directly attributable to a defined action, e.g. the physical loss of habitat occupied by a species during the construction process. Indirect ecological impacts are attributable to an action, but which affect ecological resources through effects on an intermediary ecosystem, process or receptor, e.g. external sourcing of stone for road surfaces may cause growth of plant species not generally found in that area of the Site.

Significance Criteria

10.2.85 In accordance with the CIEEM guidelines, a significant impact, in ecological terms, is defined as;

“…an impact (whether negative or positive) on the integrity of a defined site or ecosystem and/or the conservation status of habitats or species within a given geographical area, including cumulative and in-combination impacts”.

10.2.86 The approach that will be adopted in the EIA aims to determine an impact to be significant or not on the basis of a discussion of the factors that characterise it, i.e. the ecological significance of an impact is not dependent on the value of the feature in question. The value of a feature that will be significantly affected is used to determine the geographical scale at which the impact is significant, e.g. an ecologically significant impact on a feature of local importance would be considered to represent a significant impact at a local area level. This in turn is used to determine the implications in terms of legislation, policy and/or development control.

10.2.87 Any significant impacts remaining after mitigation (the residual impacts), together with an assessment of the likelihood of success of the mitigation, are the factors to be considered against legislation, policy and development control in determining the application.

Mitigation, Compensation and Enhancement

10.2.88 It is important as part of any EIA, wherever possible, to clearly differentiate between mitigation, compensation and enhancement and these terms are defined here as follows:

 Mitigation is used to refer to measures to avoid, reduce or remedy a specific negative impact in situ. Mitigation is only required for negative impacts assessed as being significant or where required to ensure compliance with legislation.  Compensation is used to refer to measures proposed in relation to specific negative impacts but where it is not possible to fully mitigate for negative impacts in situ. Compensation is only required for negative impacts assessed as being significant or where required to ensure compliance with legislation.

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 Enhancement is used to refer to measures that will result in positive ecological impacts but which do not relate to either specific significant negative impacts or where measures are required to ensure legal compliance.

Geographical Scope

10.2.89 The geographic scope of the assessment areas can differ according to the nature of the receptor. For designated sites, Natural England determine buffers termed Zones of Influence, where developments within a particular geographical area around a site are considered to have the potential for effects. This depends on features including the scale of the Proposed Development, designating features of the site and their sensitivity to the development, duration of the development, connectivity to the designated site and presence of impact pathways. For the Cannock Chase SAC 3.6km south of the Site, this falls within the Zone of Influence.

10.2.90 For habitats within the Proposed Development area, the geographical scope will be the Site and an appropriate buffer, dependent on the sensitivity of the receptor. For example, features such as wetlands, watercourses and waterbodies are linked to the wider habitats on which they depend for water and thus effects on these resources could be wider reaching than on drier habitat types. The habitats surveyed for the EIA reflect the Site area and a buffer of up to 250m dependent on access.

10.2.91 The geographical scope of assessment for species can be wider than that for habitats, due to their inherent mobility and potentially use of multiple areas of the Site. The species surveys cover the Site and a wider buffer up to features which represent likely barriers to movement for terrestrial species, for example the A51 main road to the south of the Site and River Trent to the north. For these and more mobile species (such as birds and bats), the ability to utilise several sites and thus to respond to change caused by the Proposed Development can also be considered in the assessment.

Temporal Scope

10.2.92 The assessment presented in the EIA will consider potential effects occurring during the following temporal phases:

 Pre-construction site clearance;  Construction period; and  Post-construction occupation period.

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10.3 BASELINE ENVIRONMENT

Statutory Designated Sites

10.3.1 There are no statutory designated sites within the Site itself. The desk study highlighted the presence of the following statutory designated sites within 5km of the Proposed Development.

Table 10.6 Statutory Designated Sites within 5km of the Proposed Development

Site Name Designation Qualifying Features Distance and Direction Stafford SSSI Broadleaved woodland, acidic marshy grassland 3km north west Brook and fen Cannock SAC The Annex I habitat European dry heaths is the 3.6km west Chase primary reason for selection, with the Annex I habitat Northern Atlantic wet heaths with Erica tetralix a qualifying feature Cannock SSSI Vegetation including woodland, scrub, lowland 3.6km west Chase heath and floristically rich valley mire/wet heath communities. These support a nationally significant population of nightjar Caprimulgus europaeus as well as red squirrel Sciurus vulgaris, bats, adder Vipera berus and common lizard Lacerta vulgaris Blithfield SSSI Staffordshire’s largest area of standing water, of 4.2km north Reservoir particular importance for goosander Mergus merganser, supporting more than 1% of the total British wintering population. Gentleshaw SSSI Lowland heathland 4.7km south Common

Non-statutory Designated Sites

10.3.2 There are no non-statutory sites within the Site itself. Within 2km of the Site there are 10 Local Wildlife Sites (LWS), one Biodiversity Alert Site (BAS) and four retained BAS. Whilst BAS is not a designation as such, these are areas considered by Staffordshire to currently be of less than local value that have been identified through the county’s regular biodiversity site review process as having the potential to develop to LWS status. Some of the woodlands designated as LWS are also Ancient Woodland Inventory (AWI) sites, indicated by an ‘AWI’ in Table 10.6 below.

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Table 10.6: Non-statutory Designated Sites within 2km of the Proposed Development

Designation Site Name Description Distance and Direction LWS Brereton A disused sandstone quarry which is 15m north on Works (South) important for invertebrates and contains opposite side of vegetated areas that are species rich River Trent LWS (AWI) Cawarden Mostly an ancient semi-natural woodland 230m north on Springs Wood remnant now used as a pheasant covert and opposite side of disturbed by extensive felling roughly 100 River Trent years ago, leaving standards LWS Lawnmeadow A shallow lake with extensive marginal 500m north east Covert and vegetation, submerged woodland and semi- on opposite Ridgware Hall improved grassland side of River Trent Retained St John the Churchyard with semi-improved neutral 550m south BAS Baptist grassland and acid flushes. Star of east, on Churchyard, Bethlehem, wild daffodil and silver grass opposite side of Armitage have previously been recorded here the Canal LWS Trent and A long stretch of canal with large patches of 600m south Mersey Canal, botanically diverse marginal vegetation in east Armitage parts Church to Tuppenhurst Road LWS (AWI) Gorsy Bank Part ancient replanted and part ancient semi- 675m south natural woodland, with some diversity in the ground flora, along with pools, streams and ditches Retained Trent and A stretch of the Trent and Mersey canal 800m north BAS Mersey Canal, west Rugeley LWS Bardy Lane A hedge valued for its species diversity as 1km south (Hedge 1) well as standards and a hedge bank Retained Slitting Mill A linear tree-lined stretch of water and pools 1km west BAS Brook flowing north feeding Elmore Park pool in Rugeley centre. The floral diversity is poor, with ruderal species dominating much of the riparian zone Retained Chetwynd’s An area of ancient woodland identified by old 1.4km south BAS (AWI) Coppice coppice and banking. The coppice includes west sessile oak Quercus petrea and sweet chestnut Castanea sativa. LWS Hood Lane A network of four species-rich hedgerows 1.6km south hedgerows with a considerable range of species, as well east as good structure and connectivity LWS Bailey Bridge Bailey Bridge Wetland is an area of semi- 1.8km east on Wetland and improved grassland, newly planted opposite side of Sitch Covert woodland, and a recently created wetland River Trent with swamp and standing water, while Sitch

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Covert is a birch dominated broad-leaved woodland LWS (AWI) Brereton Ancient alder woodland with rich ground flora 2km south west Hayes (North) occupying a sloping site next to a small stream BAS Horsey Lane A hedge valued for its species rich canopy 2km south (Hedge 16) with 16 species LWS Rugeley Fen An acidic marsh with some scattered trees 2km north west and scrub, which has a high diversity of wetland species.

Habitats

10.3.3 The Site contains a number of distinct areas reflecting its current or historic industrial use, with each supporting a characteristic variety of habitat types. Overall, the following habitats are found:

 Coniferous broadleaved woodland  Broadleaved plantation woodland  Scattered trees  Dense scrub  Scattered scrub  Poor semi-improved grassland  Standing water  Wet ditch  Dry ditch  Spoil  Amenity grassland  Ephemeral/short perennial  Hardstanding and buildings Coniferous and Broadleaved Plantation Woodlands and Scattered Trees

10.3.4 Tree cover is found across the Site, particularly in the eastern and northern parts and flanking the Site transport routes. Some of these areas may constitute the priority habitat type ‘deciduous woodland’, which will be further considered as part of the ES. The former large golf course adjacent to the River Trent supports scattered trees of varying ages and small areas of broadleaved plantation woodland, with species including willow Salix spp, birch Betula spp, oak Quercus spp, sycamore Acer pseudoplatanus, alder Alnus glutinosa, ash Fraxinus excelsior and pine Pinus spp. The boundary between the large golf course and former railway siding supports a strip of broadleaved plantation woodland, coniferous plantation woodland, and scrub.

10.3.5 At the time of the survey, the small golf course in the central eastern part of the Site supported lines of scattered trees, which included planted specimens of willow, eucalyptus Eucalyptus

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spp, Lombardy poplar Populus nigra ‘Italica’, pine, ash, oak, ornamental maple Acer spp, horse chestnut Aesculus hippocastanum, beech Fagus sylvatica and sycamore. These trees have become established on a pulverised fuel-ash (PFA) mound which will be extracted as part of the Proposed Development and will therefore be assessed as part of the ES.

10.3.6 Lombardy poplar trees feature along the power station access road north of the ash lagoons and also west of the recreation field where a former miniature railway has been routed through an area of woodland. To the south of this area, the perimeter of the recreational fishing pond supports scattered trees and scrub with species including birch, willow, hawthorn Crateagus monogyna, alder and sycamore.

10.3.7 In the eastern end of the Site, the Borrow Pit Lake is bordered by broadleaved plantation woodland to the east and south. This woodland supports semi-mature trees and shrubs with species such as horse chestnut, willow, apple Malus spp, alder, elder Sambucus nigra, lime Tilia x europaea, sweet chestnut, sycamore, oak, silver birch Betula pendula, wild service tree Sorbus torminalis and field maple Acer campestre. The understorey in this area is dominated by bramble Rubus fruticosus agg and buddleja in the more open areas, whilst the closed canopy areas were dominated by nettle, with wood avens Geum urbanum and fern Dropteris spp also present. Small areas of wetter vegetation were also noted, indicated by the presence of sedges.

Dense and Scattered Scrub

10.3.8 Whilst scrub was often present as part of the woodlands described above, it was noted as a distinct habitat in parts of the ash lagoons which were variably vegetated at the time of survey due to the cyclical working in the area. The central ash lagoon supported dense scrub dominated by young birch trees and bramble in the north, whilst scattered scrub was noted across the ash lagoon area. As there is an existing permission to excavate these lagoons for PFA, this will be undertaken prior to the commencement of the Proposed Development and a level platform created. Thus the ash lagoons will support bare ground/ephemeral short perennial in the baseline for the EIA and further re-profiling will be undertaken as part of the Proposed Development to create a suitable development platform.

Poor Semi-improved Grassland

10.3.9 The large disused golf course is currently unmanaged, supporting a sward of rank grasses that include species such as bent Agrostis spp, Yorkshire fog Holcus lanatus, cock’s-foot Dactylus glomerata, perennial rye-grass Lolium perenne, meadow foxtail Alopecurus pratensis and other tall ruderal vegetation such as creeping thistle Cirsium vulgare, and stands of ragwort Senecio jacobaea and dock Rumex spp.

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10.3.10 The small golf course, which is not physically connected to the larger golf course, was also unmanaged at the time of survey with a similar rank grassland vegetation.

Standing Water

10.3.11 Several standing waterbodies were present throughout the Site, both semi-natural and man- made in nature, with the latter related to the operation of the former power station.

10.3.12 Some of the waterbodies in the former large golf course were semi-natural in nature. Here, there were eight ponds (numbers 1-4, 7-8, 13 and 23) which varied in size and contained species such a bulrush Typha latifolia, sedge Carex spp, yellow flag iris Isis pseudacorus and branched bur-reed Sparganium erectum, with the larger waterbodies supporting submerged willow and alder saplings. The white water-lily Nymphaea alba was also noted growing in some of the water-filled ditches and ponds. A mat of the invasive non-native New Zealand pygmyweed Crassula helmsii was recorded on a pond in the east of the golf course, labelled as pond 13 in Figure 10.2 and described in Appendix 10.2.

10.3.13 Artificial waterbodies related to water intake and output from the power station, can be found across the Site. In the former large golf course, ditch numbers 9, 10, 11 and 12 were present as shown in Figure 2 and described in Appendix 10.2. These were still or very slow flowing with marginal aquatic vegetation including bulrush and floating sweet-grass Glyceria fluitans and a dense cover of duckweed Lemna spp. Ditch number 6 was dry at the time of survey. In the main power station site, man-made standing water was present in an ‘S-shape’ associated with a pumping station (pond numbers 14 and 15) and in the west near the former coal stockyard (numbers 20 and 21). These had steep concrete-lined sides with a lack of aquatic vegetation other than duckweed. Variably wet areas were present as shallow pools within the ash lagoons (pond 18) at the time of survey, although as noted previously these will not be present for the EIA baseline due to the extraction of PFA from the ash lagoons.

10.3.14 Other artificial waterbodies were present and had a past recreational use. A recreational fishing pond (formerly part of an ash lagoon) is located south of the playing fields (pond 16). This was initially dry at the end of the summer 2018 and had been pumped out to facilitate a fish rescue to the Borrow Pit Lake. As the weather became wetter later into 2018, this waterbody was observed to begin to refill. The Borrow Pit Lake (pond 19) is a large deep waterbody located in the east of the site, having been created in a pit left over from materials extraction for the power station construction. It is an established waterbody with marginal vegetation including bulrush, willowherb, water mint Mentha aquatic, purple loosestrife Lythrum salicaria and hemp agrimony

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Eupatorium cannabinum but with limited submerged vegetation and is thought to be stocked with fish including carp.

Watercourses

10.3.15 The River Trent runs directly along the northern boundary of the golf course, which is the northern boundary of the Site. The river flows from west to east with a wide channel and deep water. It supports a marginal vegetation of bulrush, common reed Phragmites australis and Himalayan balsam Impatiens glandulifera, with other species that are frequent along the banks including nettle and willowherb.

10.3.16 The Brereton Brook flows in a northerly direction towards the River Trent and bisects the ash lagoons and small golf course in a deep channel vegetated with dense bramble scrub. As previously described, the PFA in these two adjacent areas will be extracted. The watercourse will remain for the baseline of the EIA but its banks will be lowered and it will be surrounded by predominantly bare ground.

10.3.17 The former large golf course supports a number of drainage ditches, of which more information can be found in Appendix 10.2. Many of the smaller ditches were dry at the time of the survey but still supported plant species that are typical of wet conditions, such as bulrush and soft rush Juncus effusus, along with other species such as meadowsweet Filipendula ulmaria, gypsywort Lycopus europaeus, nettle and willowherb.

Spoil and Ephemeral/short Perennial Vegetation

10.3.18 A large area of spoil, which has variably been colonised by a mosaic of scrub, tall ruderal and ephemeral/short perennial species, lies behind the current Engie office and substation towards the centre of the Site. These spoil heaps are comprised of compacted rubble derived from the demolished Rugeley A power station and are accessible via a single lane track which winds through the lower lying areas of spoil. Where vegetation was present, buddleia was dominant, with birch and willow saplings also present. There was very little vegetation at ground level, with the plant species providing individual stands rather than dense cover. This is likely to be due to the compacted, dry and impoverished nature of the substrate. A mosaic of tall ruderal and ephemeral species was recorded, dominated in places by Canadian fleabane Erigeron Canadensis, a species naturalised in the UK which colonises bare waste ground. Other species included teasel Dispascus fullonum, St. Johns wort Hypericum spp, rosebay willowherb Chamaenerion angustifolium and bramble.

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10.3.19 A disused coal stockyard lies in the west of the site and supports a sparse short ephemeral/perennial vegetation community.

10.3.20 At the time of survey, three distinct ash lagoons were towards the eastern side of the site, each supporting different habitats due to the cyclical nature of their working. The western-most ash lagoon been recently worked for PFA extraction and was predominantly bare spoil, with little vegetation present. The eastern-most lagoon supported short impoverished vegetation including colonisers such as Canadian fleabane and yellow-wort Blackstonia perfoliata with some areas of shallow standing water dominated by golden dock Rumex maritimus around the margins. The central lagoon was vegetated with scrub, as described earlier.

10.3.21 For the baseline of the EIA, the whole ash lagoon area will be excavated for the PFA and a level platform created. As a result, it will be considered to support bare ground for the EIA baseline.

Amenity Grassland

10.3.22 Mown grassland continued to be present in parts of the Site, particularly in the centre. The former recreational fields supported short grassland as well as grassland to the west of the recreational fishing pond and roadside verges.

Hardstanding and Buildings

10.3.23 A large number of buildings and associated hardstanding were present. These included the former power station complex itself, substation and office buildings, social club, storage buildings, pumping station and environmental education building. With the exception of the substation and office buildings in the centre of the Site and the environmental education building in the east of the Site,which are to remain, all other structures are scheduled for demolition which is ongoing at the time of writing. Thus the baseline for the EIA will be for these buildings to have been removed and the ground levelled.

Vascular Plants

10.3.24 There were no plant species of conservation interest recorded on the Site during the Phase 1 habitat survey. However, due to the presence of bare ground and disturbed areas, it is possible that annual plant species of interest may colonise certain parts of the Site, and their potential future presence cannot be ruled out.

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10.3.25 The desk study revealed a number of vascular plant records from within 2km of the Site, with bluebell Hyacinthoides non-scripta being the only plant species protected under Schedule 8 (Wildlife and Countryside Act, 1981, as amended), the closest being off-site within Cawarden Springs Wood LWS.

10.3.26 There were no protected plant species recorded during the previous 2010 and 2015 habitat surveys of the Site. However, these surveys identified stands of cotoneaster and Himalayan balsam on the Site. These species are both invasive non-native species that are listed on Schedule 9 of the Wildlife and Countryside Act, 1981 as amended.

Species

Invertebrates

10.3.27 The only protected invertebrate species identified during the data search was the freshwater white-clawed crayfish, which is also listed as a priority species under the Staffordshire LBAP. Four records of this species were provided within 2km of the Site. All of these records were from within the Rising Brook watercourse in Rugeley, with the most recent record dating from 2016. The Rising Brook rises in Hednesford before flowing through Cannock Chase and into Rugeley. The brook is then culverted in Rugeley before entering the River Trent to the east of the town centre. There is potential for crayfish to be present in the River Trent alongside the Site as it is downstream of the Rising Brook.

10.3.28 The habitat assessment for white-clawed crayfish surveyed three waterbodies/watercourses within the Site – River Trent, Brereton Brook and Borrow Pit Lake. The findings are summarised in Table 10.7 below. Both the River Trent and Borrow Pit Lake were deemed potentially suitable for white-clawed crayfish with possible linkages to the known population in Rising Brook. Brereton Brook was considered unsuitable due to a lack of cobble substrate and poor water quality. The other watercourses/waterbodies on Site were not surveyed as they were deemed unsuitable.

10.3.29 For the purposes of this Scoping Report and prior to more detailed survey in April 2019, on a precautionary basis white-clawed crayfish are considered to be present within the River Trent and Borrow Pit Lake.

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Table 10.7: Habitat Assessment Results for White-clawed Crayfish

Habitat Dimensions Water pH Marginal Banks Substrate Flow Assess- Vegetation ment River 15m – 20m No Rush and Soft Some Moder Suitable for Trent in width. reading common earth, stones ate white- Water depth taken due reed suitable visible on from clawed >1m but to for river bed west to crayfish shallower difficulty burrowing east and linked margins accessing crayfish to known along some water populations stretches Brereton 2m in width pH 9.1, Heavily Some No Variabl Deemed Brook and 0.5m in suitable shaded in concrete evidence of e from unsuitable depth. for some areas stones or south for white- Appeared crayfish and cobbles on to clawed concrete but silty densely the bed north crayfish lined in some and poor vegetated places water in others quality Borrow >1m depth, pH 8.8, Bulrush Soft Some None Suitable for Pit Lake large lake. suitable earth, cobbles white- Too deep for for suitable and large clawed manual crayfish for stones crayfish. search burrowing visible Possible crayfish beneath the connectivity water to river via around the drain lake edge

10.3.30 In terms of other invertebrates, no further records were returned during the desk study. The Site does provide a variety of habitat types, which in turn are likely to attract a range of terrestrial and aquatic invertebrate species, however it is not considered likely that any other protected invertebrate species are present due to the habitats on Site being relatively common and widespread in the local area.

Amphibians

10.3.31 The desk study returned eleven great crested newt records from within 2km of the Site. The closest of these, dating from 2016, was 0.9km from the approximate centre of the Site and appeared to be from a pond on the opposite side of the River Trent. The River Trent lies between the majority of the other great crested newt records and the Site (and presents an effective barrier to movement), however there is one record from the same side of the river as the Site. This record dates from 2007 and is located approximately 2.8 km from the centre of the Site.

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10.3.32 In 2013, partial great crested newt surveys were undertaken on five waterbodies, and returned a negative result. A population of smooth newts Lissotriton vulgaris was recorded within a pond in the golf course in the north of the Site.

10.3.33 A Habitat Suitability Index (HSI) assessment has been undertaken on all the waterbodies within the Site and is presented in Appendix 10.2. In summary, the ponds and slow flowing ditches in the former large golf course were considered suitable for great crested newt, offering excellent or good habitat, due to their size, surrounding habitat and presence of aquatic vegetation. The recreational fishing pond (poor) and Borrow Pit Lake (below average) were considered to have less potential due to the presence of fish and waterfowl which can negatively affect the likelihood of great crested newt.

10.3.34 Whilst some of the waterbodies within the Site provided potentially suitable habitat for great crested newt, the current lack of records means for the purposes of the EIA baseline, this species is considered absent from the Site. Should any positive records be returned from the eDNA in April 2019, the assessment and consequent mitigation as part of the scheme will be altered accordingly.

10.3.35 Other more common amphibians have been confirmed present on the Site. During the 2018 reptile surveys, adult and juvenile frogs Rana temporaria and toads Bufo bufo were recorded under refugia near the Borrow Pit Lake, ash lagoons, road verges, rubble of power station A and small golf course. A juvenile smooth newt was also recorded under refuges in the ash lagoons on two of the seven survey visits and one was recorded under a refuge in the small golf course near Brereton Brook.

Reptiles

10.3.36 The desk study returned a single record of an adder Vipera berus dating from 1995 and approximately 2.5km from the approximate centre of the Site. A previous reptile survey in 2010 covered only the central part of the Site and recorded no reptile species.

10.3.37 The 2018 reptile surveys recorded no reptiles on the main power station site. However, the area of the former large golf course was not surveyed due to limited development proposals and therefore on a precautionary basis they are considered to potentially be present in this area due to the suitable habitats present.

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Birds

10.3.38 A number of bird records were provided by SER from within 2km of the Site and included goshawk Accipiter gentilis, kingfisher Alcedo atthis, short-eared owl Asio flammeus, nightjar Caprimulgus europaeus, Cetti’s warbler Cettia cetti, little ringed plover Charadrius dubius, marsh harrier Circus aeruginosus, hen harrier Circus cyaneus, merlin Falco columbarius, peregrine , hobby Falco subbuteo, crossbill Loxia curvirostra, wood lark Liullula arborea, red kite Milvus milvus, osprey Pandion haliaetus, black redstart Phoenicurus ochruros, golden plover Pluvialis apricaria, common tern Sterna hirundo, green sandpiper Tringa ochropus, and barn owl Tyto alba, along with a number of protected waterfowl species.

10.3.39 The more notable of these records was a barn owl flying directly outside of the western Site boundary, which dated from 2002, and a kingfisher record (both Schedule 1 species) from within the River Trent and located just outside of the western site boundary, which dated from 2003. Many of the bird records provided had a six-figure grid reference and so could not be attributed to a specific location.

10.3.40 The breeding bird surveys of the Site recorded 53 species of bird breeding on the Site with a minimum population of 282 pairs. Five of these species were listed as Schedule 1 (*) and another four were Red listed (**) of conservation importance, as summarised in Table 10.8 below. Peregrine is also listed on Annex 1 of the Birds Directive. A full list of the breeding birds present is provided in Appendix 10.3.

Table 10.8: Schedule 1 and Red Listed Birds Recorded Breeding within the Site

Species No. of Pairs Location on Site hobby * 1 Nest location withheld as sensitive information Peregrine * 1 Nest location withheld as sensitive information Little ringed plover * tbc Ash lagoons kingfisher * tbc Along River Trent on northern edge of the Site Black redstart * tbc Power station buildings lapwing ** tbc Ash lagoons Song thrush ** tbc Woodland/scrub wedges especially large golf course Spotted flycatcher ** 1-2 Mixture of trees and open areas for feeding linnet ** 3 Brownfield sites, hedgerows, margins and scrubland

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10.3.41 Of the birds recorded present on the Site, some are dependent on the particular habitats created on the Site due to its industrial heritage. These include black redstart, between 13 and 50 pairs of sand martin Riparia riparia within a bank in the ash lagoons, little ringed plover and lapwing nesting on the bare ground of the ash lagoons and hobby along the River Trent relying on sand martins as a food source.

10.3.42 The baseline for the EIA will be when the PFA extraction in the ash lagoons has taken place. As such, the habitats will differ from those currently present and will consequently support a differing assemblage of breeding birds. As mitigation and compensation will be included in the PFA extraction works to ensure legislative compliance, it is envisaged that alternative suitable habitats will be provided for the affected bird species such that as far as possible, they are able to continue to breed on or in close proximity to the Site, although the number of territories the area will support may vary. The baseline for the EIA will therefore be based on the breeding bird information presented here but there is the assumption that species which rely on the ash lagoons will be accommodated elsewhere.

10.3.43 Furthermore, as the baseline for the EIA is the demolition of the majority of the buildings on Site, species dependent on these habitats (such as peregrine and black redstart) will also have been provided alternative breeding habitat.

10.3.44 During the 2018 surveys, a number of incidental bird records were made. These included the Schedule 1 species barn owl roosting within a hawthorn tree alongside the River Trent (SK 06273 17781), which appeared to be a well-used day roost due to the number of droppings and pellets on the ground. Kingfishers (also Schedule 1) were observed flying along the River Trent and also along the ‘S-shaped’ drain near the pumping station. Sand martin nesting colonies (TN5) were observed in the banks of the ash lagoons and sand martins were seen flying over this area. A tawny owl Strix aluco roost was suspected within Leyland cypress Leylandii x cupressius along the eastern boundary in the large golf course (SK 06593 17507) with droppings and pellets observed.

10.3.45 Waterfowl were observed on or near the Borrow Pit Lake and recreational fishing pond, including heron Ardea cinerea, great crested grebe Podiceps cristatus, mallard Anas platyrhynchos, tufted duck Aythya fuligula, little egret Egretta garzetta, teal Anas crecca, Canada goose Branta canadensis, coot Fulica atra, cormorant Phalacrocorax carbo and moorhen Gallinula chloropus. Snipe Gallinago gallinago was also flushed from the undergrowth.

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Bats

10.3.46 There were records of eight bat species identified during the data search, along with further records of the genus Myotis and Pipistrellus that were not identified down to species level and records of bats for which no further identification was provided. Details of these records can be found below in Table 10.9.

Table 10.9: Bat Species Records Provided by SER within 2km of the Site

Species No. of Most Recent Distance from Roost Records Records Record Centre of Site (km) Myotis brandtii/ 2 2010 1.8 Unknown mystacinus Whiskered/ Brandts Myotis daubentonii 21 2010 3.1 Unknown Daubentons Myotis mystacinus 2 2008 0.5 Unknown Whiskered Myotis nattereri 1 2009 2.1 Unknown Natterers Myotis spp 13 2009 2.1 Unknown Nyctalus noctua Noctule 18 2016 2.2 Unknown Pipistrellus pipistrellus 39 2016 2.0 Yes Common pipistrelle Pipistrellus pygmaeus 28 2016 2.0 Unknown Soprano pipistrelle Pipistrellus spp 32 2018 3.1 Yes Pipistrelle Plecotus auritus Brown 2.3 2011 1.0 Yes long-eared Unidentified bat 10 2010 1.0 Yes

10.3.47 A number of the above bat records are from within the Site itself. These include soprano pipistrelle, common pipistrelle, brown-long eared, noctule, daubentons, whiskered, and Myotis spp. These records appear to be of bats foraging or commuting over the Site rather than roost records.

10.3.48 Targeted bat activity surveys were undertaken on part of the Site (central section to the south of the River Trent) in 2010. Five bat species (common and soprano pipistrelles, Daubenton’s, noctule and serotine) were recorded as well as bats of the Myotis genus. Bat activity was recorded to be highest (in the context of the Site) around the fishing pond near the recreation club in the centre of the Site.

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10.3.49 Bat roost assessments of trees were undertaken in 2015. Six trees were assessed as having low bat roost potential and one with high bat roost potential. These were in the large golf course and one (low potential) around the recreational fishing pond.

10.3.50 The 2017 activity survey recorded a very low level of bat activity. As shown in Figure 10.4, the northern transect picked up some pipistrelle foraging activity at and around the pump houses and along the northern access road. The central transect only recorded a single noctule pass at 2230. The southern transect recorded some limited common pipistrelle activity.

10.3.51 The 2018 bat surveys incorporated a driven transect, walked transect and static detectors, as shown in Figure 10.4. A bat roost assessment was also undertaken of the trees on Site.

Transects

10.3.52 The transect surveys predominantly recorded soprano pipistrelle Pipistrellus pygmaeus and common pipistrelle P. pipistrellus, with some Nyctalus species and Myotis species.

10.3.53 On the driven transect the bat passes recorded were almost all recorded on the road running alongside the Borrow Pit Lake in the eastern area of the Site.

10.3.54 At the listening points bats were recorded at LP2 (alongside Borrow Pit Lake near education centre) and LP5 (in the middle of the small golf course). Two bats were recorded at LP2 and one bat was recorded at LP5. On average there were 0.5 bat passes per listening point.

10.3.55 The bat passes recorded on the walked transect were relatively spread out over the transect route but concentrated more in the easternmost field of the large golf course.

10.3.56 The listening points where bat passes were recorded were LP2 (alongside one of the large linear ditches), LP3 (alongside the River Trent) and LP4 (alongside one of the smaller meandering ditches). There were two bats recorded at LP2 and LP3 and one bat at LP4. On average there were 1.25 bat passes per listening point during this transect.

10.3.57 Relatively similar numbers of bat passes recorded during each transect (12 during driven and 13 during walked). However, when looking at the average number of bat passes during each five minute listening point it seems that the large golf course had a higher level of activity than the rest of the Site, as expected given the habitats present there and connectivity to wider suitable habitats. The area of the next highest activity was the Borrow Pit Lake. The rest of the Site was relatively low in activity with very few bats recorded.

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Static Detectors

10.3.58 The static detectors showed higher levels of activity in the small golf course than the area with the rubble of power station A. This is thought likely to be because the golf course provides more mature vegetation and linear features for bats to commute and forage along. Again, the static detectors recorded soprano pipistrelle, common pipistrelle, Nyctalus species and Myotis species.

Bat Roost Assessment

10.3.59 The bat roost assessment of the trees on Site largely grouped the trees as low bat potential due to their relatively young age and straight habit due to close planting. However, the following trees were noted to exhibit features which could potentially support bats. These were around the Borrow Pit Lake, in the large golf course and on the northern facing embankment of the railway siding. Dependent on the layout of the Proposed Development and subsequent potential for effects, further surveys will be carried out in 2019 as necessary.

 A sycamore with medium bat potential within woodland around the Borrow Pit Lake (SK 07035 16514)  Medium potential alder to east of large golf course (SK 06426 17511)  High potential mature ash tree (SK 06211 17595)  Medium potential willow (SK 0606317705)  Medium potential willow (SK 06021 17738)  Medium potential ash tree (SK 05852 18022)  There was also a wooden shed with low potential towards the centre of the golf course (SK 05531 18107) 10.3.60 The bat roost assessment of the Environmental Education Centre considered it to provide low potential for roosting bats. No bats were observed to emerge from the building during the roost survey.

10.3.61 A further bat roost assessment of the Engie Office will be undertaken in early 2019 and included in the ES.

Badger

10.3.62 There were 47 badger Meles meles records provided by SER within 2km of the Site, the closest of these being located 0.6 km from the centre of the Site.

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Otter

10.3.63 There were eight otter Lutra lutra records from within a 2km radius around the Site. The majority of these were located north of the Site, with the most recent records dating from 2013 and the closest record being located 2.4km from the centre of the Site.

10.3.64 A previous survey for otter was undertaken in 2015. It found a suspected otter spraint under a footbridge over a drainage ditch flowing into the River Trent through the golf course.

10.3.65 The 2018 otter survey recorded positive evidence of the species on the Site. A boulder on the edge of the Borrow Pit Lake was a well-used sprainting site. This waterbody was linked to the River Trent via a small drainage ditch, providing connectivity to the river itself which also offered suitable habitat. No signs were recorded due to the lack of suitable sprainting sites for survey (e.g. no exposed rocks), dense bankside vegetation and higher water level. An artificial holt was also found present on the Site at the eastern end on the river bank, although no otter signs were noted around it. Due to the suitability of the River Trent and Borrow Pit Lake for the species, offering cover, connectivity and food sources, it is considered that otter are present in these areas and could potentially range across the Site.

Water Vole

10.3.66 There were five records of water vole Arvicola terrestris from within the search area with the closest of these being a record from 0.7km from the centre of the Site, which dates from 1997. The most recent record of water vole within the area is from 2009. A survey undertaken in 2015 found no evidence of the species within the Site.

10.3.67 The 2018 water vole survey recorded potentially suitable habitat for the species in the water bodies and watercourses across the Site, in particular in the former large golf course. No signs of water vole were observed during the survey, but it was noted that the high levels of vegetation, especially after several years of no management, meant it was difficult to closely see the banks to search for signs. Due to the suitability of the aquatic habitats on the Site it is considered that water vole could potentially be present.

Other mammals

10.3.68 There were seven records of polecat Mustela putorius and 50 records of European hedgehog Erinaceus europaeus identified within 2km during the data search. Sightings during the surveys on Site included rabbit Oryctolagus cuniculus and field vole Microtus agrestis beneath reptile refuges.

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10.4 POTENTIAL ENVIRONMENTAL IMPACTS & EFFECTS

10.4.1 It is proposed that the impact assessment presented in the EIA for the Proposed Development will focus on sites, habitats and species which have been confirmed (or are likely to be) present on the Site, based on the surveys and desk study. These are termed ecological receptors. The sensitivity of these ecological receptors to effects arising as a result of the Proposed Development is briefly considered here, with the aim of identifying those which are potentially significant. In line with guidance provided in the Lichfield District Biodiversity and Development SPD, these will be reviewed alongside the selection criteria for local wildlife sites in Staffordshire in the ES.

10.4.2 Table 10.10 below sets out the ecological receptors proposed for assessment in the EIA along with an indication of the likely impacts and effects. These are split into those impacts which are likely occur at the site clearance/construction stage and those which occur post-construction during the occupation of the Site. In some cases effects, may be likely at both or just one stage.

10.4.3 At this scoping stage, effects on species groups such as bats are considered collectively. However these may be considered in more detail (for example individually or grouped based on behavioural characteristics) for the EIA.

10.4.4 For the purposes of this initial assessment, it is assumed that the Proposed Development will take place concurrently across the Site, whereas in reality it will be phased. Details of this phasing are not confirmed at the scoping stage but will be fully considered in the EIA.

Table 10.10: Potentially Significant Impacts on Ecological Receptors

Receptor Location (on/off Site) Potential Impacts: Site Potential Impacts: and Impact Pathway Clearance/ Post Construction Construction Stage Occupation Stage Cannock Chase Off Site 3.6km west. None anticipated Increase in SAC Increase in recreational use – recreational pressure trampling of habitats, on Annex I habitats nutrient enrichment, introduction of invasive species. Cannock Chase Off Site 3.6km west. None anticipated As above but also SSSI Recreational and disturbance effects on disturbance effects on species due to habitats and species increased footfall and dog walking Trent and Mersey Off Site 600m south Potential for run off and None anticipated Canal, Armitage east. Potential linkage pollution from works Chirch to with east of Site, around Borrow Pit Lake

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Tuppenhurst Road where canal is and in second access LWS upstream of LWS road construction

Coniferous and On Site. Direct loss. Direct loss of trees in Minimal. Possible root broadleaved areas of proposed compaction around plantation woodland development retained trees in areas and scattered trees of high footfall

Poor semi-improved On Site. Direct loss. Direct loss in areas of None anticipated. grassland proposed development, Habitat not sensitive to change in management pressure from for recreational facilities recreational use e.g. and mowing for paths trampling Standing water On Site. Damage, Direct loss of northern Pollution and disturbance, pollution end of recreational sedimentation via run- and sedimentation. fishing pond for road, off from access routes loss of ‘S-shaped’ ditches. Pollution and sedimentation. Watercourses: Potential habitat loss if Pollution and River Trent Off-site adjacent outfall required into river sedimentation of all watercourses Brereton Brook On Site Retained. Pollution and sedimentation Drainage ditches On Site Direct loss in areas for development or for re- routing

Flora of Potentially present on Potential loss of floral None anticipated conservation Site. Direct loss. species if present in interest areas for development

White-clawed Potentially present on Direct effects if works Recreational use of crayfish Site (in Borrow Pit take place in Borrow Pit Borrow Pit Lake Lake) and River Trent Lake or a new outfall in River Trent. Increase in sedimentation

Common On Site Habitat loss Incidental loss due to amphibians kerb and drain design, road casualties Reptiles Potentially present on Direct effects if works Longer term habitat Site (large golf course) destroy suitable habitat. change

Kingfisher On Site. Habitat loss, Direct effects if new Disturbance from disturbance outfall on River Trent is recreational pressure near suitable nest along River Trent habitat. banks

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Barn owl On Site. Habitat loss, No breeding site known Disturbance from disturbance on Site. Large golf increased public course will remain presence suitable foraging habitat. Loss of foraging habitat on main site

Little ringed plover On Site. Habitat loss, Direct loss of breeding Disturbance from disturbance habitat increased public presence

Peregrine Potential for Disturbance if works Potential for disturbance near nest site in disturbance from breeding season increased public presence Hobby On Site. Habitat loss, Not anticipated. Disturbance from disturbance Baseline for EIA is that increased public sand martins (prey) will presence near nest be mitigated for with site new nest site outside ash lagoons. No loss of food resource. Sand martin On Site. Habitat loss, Disturbance if works Disturbance from disturbance near nest site in increased public breeding season presence near nest site

Other breeding On Site. Habitat loss, Direct loss of nest sites, Disturbance from birds disturbance habitat loss increased public presence near nest sites Waterfowl On Site. Habitat loss, Direct loss of nest sites, Disturbance from disturbance habitat loss increased public presence near nest sites

Foraging and On Site. Habitat loss, Habitat loss reduces Lighting effects commuting bats disturbance flightlines and connectivity. Also foraging habitat loss

Roosting bats Potentially present on Direct roost loss if roost Lighting and Site in trees and destroyed or indirect disturbance effects buildings effects if work take place from development (Environmental nearby close to a roost Education Centre and Engie Offices)

Badger On Site. Effects on Sett collapse if works in Fragmentation of setts, habitat loss close proximity. foraging habitat. Risk Trapping of animals in of road casualties. Disturbance from

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excavations. Reduction increased public and in foraging areas dog presence. Possible increase in persecution

Otter On Site. Disturbance No holts found on Site. Disturbance from Disturbance resulting in increased public reduction of foraging presence including resource if works take dogs place on Borrow Pit Lake or River Trent

Water vole Potentially present on Direct loss if works take Disturbance from Site place in aquatic habitats increased public where water vole presence potentially present

10.4.5 It is considered that effects on some ecological features are not likely to be significant and are thus proposed to be scoped out of the EIA. These are set out in Table 10.11 below along with an explanation of the reasoning behind their exclusion.

Table 10.11: Sites, Habitats and Species Proposed to be scoped out of EIA

Feature to be Location (on/off Site) and Justification scoped out Impact Pathway Stafford Brook SSSI Off Site 3km north west Upstream of Site and no ecological connectivity. Air quality EIA chapter will be reviewed to confirm no potential occupation effects from increased air pollution on woodland bryophytes and lichens Blithfield Reservoir Off Site 4.2km north Designated for population of wintering SSSI goosander. There is no evidence that breeding goosander on Site form part of this population. Distance between the SSSI and the Site would rule out other direct effects. No effects anticipated during construction or operational phase Gentleshaw Off Site 4.7km south Designated for lowland heathland. No Common SSSI ecological connectivity. Air quality EIA chapter will be reviewed to confirm no potential occupation effects from increased air pollution on heathland bryophytes Brereton Works (S) Off Site 15m north of River Not ecologically linked to Site (opposite LWS Trent but further from side of river) proposed works

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Cawarden Springs Off Site 230m north of River Not ecologically linked to Site (opposite Wood LWS Trent but further from side of river) proposed works Lawnmeadow Off Site 500m north east of Not ecologically linked to Site (opposite Covert and River Trent but further from side of river) Ridgeware Hall proposed works LWS St John the Baptist Off Site 550m south east on No ecological connectivity as separated churchyard, opposite side of canal by the canal Armitage retained BAS Gorsy Bank LWS Off Site 675m south No ecological connectivity Trent and Mersey Off Site 800m north west No ecological connectivity (upstream of Canal Rugeley the Site) Retained BAS; Off Site 1km north Slitting Mill Brook Retained BAS Bardy Lane Hedge Off Site varying distances No ecological connectivity (H1) LWS Hood Lane Hedgerows LWS Horsey Lane (Hedge 16) BAS Chetwynds Coppice Off Site 1.4km south west No ecological connectivity Retained BAS Bailey Bridge Off Site 1.8km north on No ecological connectivity wetland and Sitch opposite side of River Trent Covert Brereton Hayes (N) Off Site 2km south west No ecological connectivity LWS Rugeley Fen LWS Off Site 2km north west No ecological connectivity as is upstream from the Site. Air quality EIA chapter will be reviewed to confirm no potential occupation effects from increased air pollution Dense and On Site Not a habitat of intrinsic interest but will be scattered scrub assessed in relation to species it supports (e.g. birds) Spoil and On Site (ash lagoons, rubble As above ephemeral/ short of power station A, coal perennial stockyard) Amenity grassland On Site As above Hardstanding and No buildings to remain on Hardstanding is not of ecological interest buildings Site for EIA baseline. Invasive species On Site Himalayan balsam and other potentially present invasives not of intrinsic interest but measures will be included to ensure legislative compliance

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Other invertebrates Potentially present on Site Common invertebrates present and good practice construction measures combined with habitat enhancement will provide continued habitat Great crested newt Absent Not considered present on Site at scoping stage. eDNA will provide confirmation and approach will be amended if necessary Other mammals On Site Common mammals present and good practice construction measures combined with habitat enhancement will provide continued habitat

10.5 MITIGATION ENVISAGED

10.5.1 The Proposed Development of the Rugeley Site will be carried out in an ecologically sensitive manner with the following broad principles:

 Embedded mitigation in masterplan through incorporation of ecologically sensitive design;  Maximising wildlife corridors and semi-natural habitats within the masterplan to ensure no net loss of biodiversity and an overall net gain;  Retention of large golf course near River Trent as a Country Park with minimal development effects;  Habitat enhancements in the large golf course, around the margins of the retained and newly created waterbodies and in all remaining habitats;  Reasonable avoidance measures - timing of works and use of sensitive clearance methodology to minimise effects on species present/potentially present;  Use of species development licenses if necessary and effects cannot be avoided;  Ecological supervision (via Ecological Clerk of Works ECoW);  Mitigation through employment of good practice construction measures (including a Construction Environmental Management Plan (CEMP); and  Phased construction of the Site

10.5.2 The exact mitigation, compensation and enhancement measures will be devised based on the final masterplan design and the significance of predicted impacts.

10.5.3 The aim will be for no net loss of biodiversity once the Proposed Development is completed, and a net biodiversity gain.

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CHAPTER 11: WATER ENVIRONMENT (INCLUDING FLOOD RISK)

11.1 INTRODUCTION

11.1.1 This chapter of the ES Scoping Report has been produced by AECOM.

11.1.2 The Water Environment topic presents an overview of the water environment baseline and proposed scope of works for assessing the potential effects of the Proposed Development on the water environment. The water environment includes surface and ground water quality, the hydromorphology of water bodies, flood risk and drainage. Where potential significant effects are identified mitigation is proposed.

11.1.3 General and topic-specific guidance presented within Volume 11 of the Design Manuel for Roads and Bridges1 have been used in preparation of this section.

11.1.4 The water environment topic (including water quality assessment, preliminary WFD assessment, water resources flood risk and drainage) is proposed to be scoped in to the EIA. Any aspects of the topic that are considered to be scoped out are discussed later in this chapter.

11.2 ASSESSMENT CRITERIA & METHODOLOGY

Previous Assessment

11.2.1 There is a volume of historical hydrological information including a Hydrological Constraints Report2 and subsequent surface water management strategy3 undertaken by Ramboll Environ and reported in April 2017.

1 Highways Agency (August 2008), DMRB Volume 11, Section 2, Part 4 Scoping of Environmental Impact Assessments; Highways Agency (June 1993), Design Manual for Roads and Bridges (DMRB) Volume 11, Section 3, Part 11 Geology and Soils; Highways Agency (June 1993), Design Manual for Roads and Bridges (DMRB) Volume 11, Section 3, Part 6 Land Use (incorporating Amendment No 1 dated August 2001).

2 Ramboll Environ (2017) Rugeley Power Station Hydrological Constraints Appraisal (Re- development). April 2017.

3 Ramboll Environ (2017) Rugeley Power Station Preliminary Earthworksand Surface Water Management Strategy (Re-development). April 2017

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Legislative Context

11.2.3 The following legislation, national policy and guidance documents are relevant to the assessment of impacts of the Proposed Development on the water environment:

 Water Framework Directive 2000/60/EC4;

 Priority Substances Directive 2008/105/EC5;

 Groundwater Directives 2008/105/EC and 2006/118/EC6;

 Floods Directives 2007/60/EC7;

 The Environmental Liability Directive 2004/35/EC8;

 The Freshwater Fish Directive 2006/44/EC9;

 The Water Act 201410;

 The Floods and Water Management Act 201011;

 The Land Drainage Act 1991 (as amended)12;

 The Water Resources Act 1991 (as amended)13;

 The Salmon and Freshwater Fisheries Act 1975 (as amended)14;

4 The European Union (2000) Water Framework Directive, Directive 2000/60/EC;

5 The European Union (2008) Priority Substances Directive, Directive 2008/105/EC

6 The European Union Directive (2006) Groundwater Daughter Directive, Directive 2006/118/EC

7 The European Union Directive (2007) The EU Floods Directive, Directive 2007/60/EC

8 The European Union (2004) The Environmental Liability Directive, Directive 2004/35/EC

9 The European Union (2006) Freshwater Fish Directive, Directive 2006/44/EC

10 Water Act 2014 London, Her Majesty’s Stationery Office

11 The Floods and Water Management Act 2010 London, Her Majesty’s Stationery Office

12 The Land Drainage Act 1991 London, Her Majesty’s Stationery Office

13 The Water Resources Act 1991

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 The Reservoirs Act 1975 (as amended)15;

 The Water Environment (Water Framework Directive) (England and Wales) Regulations 201716;

 The Environmental Permitting (England and Wales) Regulations 201617 [Ref 11.14];

 The Environmental Damage (Prevention and Remediation) Regulations 201518;

 The Water Framework Directive (Standards and Classification) Directions (England and Wales) 201519;

 The Flood Risk Regulations 200920;

 The Eels (England and Wales) Regulation 200921;

 The Groundwater (England and Wales) Regulations 200922;

 The Control of Substances Hazardous to Health Regulations 2002 (as amended)23;

 The Control of Pollution (Oil Storage) (England) Regulations 200124;

14 The Salmon and Freshwater Fisheries Act 1975 as amended, London, Her Majesty’s Stationery Office

15 The Reservoirs Act 1975 London, Her Majesty’s Stationery Office

16 The Water Environment (Water Framework Directive) (England Wales) Regulations 2003 London, Her Majesty’s Stationery Office

17 The Environmental Permitting (England and Wales) Regulations 2016 London, Her Majesty’s Stationery Office

18 The Environmental Damage (Prevention and Remediation) Regulations (2015) London, Her Majesty’s Stationery Office

19 The Water Framework Directive (Standards and Classification) Directions (England and Wales) 2015 London, Her Majesty’s Stationery Office

20 The Flood Risk Regulations 2009 London, Her Majesty’s Stationery Office

21 The Eels (England and Wales) Regulation 2009 London, Her Majesty’s Stationery Office

22 The Groundwater (England and Wales) Regulations (2009) London, Her Majesty’s Stationery Office

23 The Control of Substances Hazardous to Health Regulations 2002 as amended, London, Her Majesty’s Stationery Office

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 The UK Governments Water Strategy, Future Water25;

 Non-statutory technical standards for SuDS (Defra, 2015)26; and

 HM Government (2015), Building Regulations 2010, Drainage and Waste Disposal Approved Document H27.

11.2.4 Under the Environmental Permitting (England and Wales) Regulations 201615 an Environmental Permit is required from the Environment Agency for certain works within 8 m of the top of the bank surrounding Main Rivers. A permit may also be required for the discharge to surface waters or ground of any unclean construction site runoff.

11.2.5 Similarly, consent for certain works that may affect the flow in Ordinary Watercourses (i.e. all other watercourses that are not Main Rivers) under The Floods and Water Management Act 20109 and The Land Drainage Act 1991 (as amended)10 is required from the Lead Local Flood Authority (LLFA), which in this case is Staffordshire County Council (SCC). The distance from the watercourse that this applies to will be confirmed with SCC in due course.

Planning Policy and Guidance

11.2.6 A summary of the national and local policy documents relevant to the assessment of effects of the Proposed Development on the water environment is presented in the section below.

National Planning Policy

11.2.7 The Flood Risk and Coastal Change section of the Planning Policy Guidance28 (PPG) provides guidance for local planning authorities on assessing the significance of water environment effects of proposed developments. The guidance highlights that adequate water and wastewater infrastructure is needed to support sustainable development.

24 The Control of Pollution (Oil Storage) (England) Regulations 2001 London, Her Majesty’s Stationery Office

25 DEFRA (2011) Future Water, the Government’s water strategy for England, London, Her Majesty’s Stationery Office

26 DEFRA (2011) Non-statutory technical standards for SuDS

27 HM Government (2015), Building Regulations 2010, Drainage and Waste Disposal Approved Document H

28 Department for Communities and Local Government (2012) National Planning Policy Guidance, London, Her Majesty’s Stationery Office

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EIA Scoping Report Chapter 11: Hydrology (Including Flood Risk) Rugeley B Power Station, Rugeley

11.2.8 The National Planning Policy Framework29 (NPPF) and the Flood Risk and Coastal Change PPG26 recommends that Local Plans should be supported by a Strategic Flood Risk Assessment (SFRA) and should develop policies to manage flood risk from all sources taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as LLFAs and Internal Drainage Boards. Local Plans should apply a sequential, risk-based approach to the location of development to avoid, where possible, flood risk to public and property and manage any residual risk, taking account of the impacts of climate change, by:

 Applying the Sequential Test;

 Applying the Exception Test if necessary;

 Safeguarding land from development that is required for current and future flood management;

 Using opportunities offered by new development to reduce the causes and impacts of flooding; and

 Seeking opportunities to facilitate the relocation of development, including housing, to more sustainable locations where climate change is expected to increase flood risk so that some existing development may not be sustainable in the long-term.

11.2.9 An update to the Level 1 Strategic Flood Risk Assessment30 (SFRA) was undertaken in 2014 for Cannock Chase, Lichfield, South Staffordshire and Stafford Borough Councils. The objective of these assessments was to inform the plan-making process for each of the Council’s Local Plans. The aim of the Level 1 SFRA is to present sufficient information to enable the Local Planning Authority to apply the Sequential Test to site allocations, and forms part of the evidence base for the Core Strategy Development Plan Document.

11.2.10 Planning policy also encourages developers to include SuDS in their proposals where practicable. SuDS provide a way to attenuate runoff from a site to the rate agreed with the Lead Local Flood Authority to avoid increasing flood risk, but they are also important in reducing the quantities and concentration of diffuse urban pollutants found in the runoff.

29 Department for Communities and Local Government (2018) National Planning Policy Framework, London, Her Majesty’s Stationery Office

30 South Staffordshire County Council (2012) South Staffordshire Core Strategy; Cannock Chase Council, Lichfield District Council, South Staffordshire Council, Stafford Borough Council (2014) South Staffordshire District Council Level 1 Strategic Flood Risk Assessment

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11.2.11 In 2015 Defra published guidance on the use, design and construction of SuDS (Non-statutory technical standards for SuDS24. The type of SuDS proposed depends on local circumstances (e.g. ground conditions) and in the following order of preference as set out in the Building Regulations 2010 Approved Document H25 as follows:

 Soakaway or some other adequate infiltration system when that is not practical;

 To a watercourse. When that is not practical; and if the above are not possible; and

 To a surface water sewer.

Local Planning Policy

11.2.12 The Site lies within the administrative boundaries of Cannock Chase District Council (CCDC) and Lichfield District Council (LDC). Local planning policy for each Local Planning Authority is outlined below.

Current Planning Policy

11.2.13 The Cannock Chase Local Plan31 was adopted by Cannock Chase Council in 2014. The Local Plan helps to shape the way in which the physical economic, social and environmental characteristics of Cannock Chase District will change between 2006 and 2028.

11.2.14 Policy CP16 – Climate Change and Sustainable Resource Use - is of particular relevance to the Proposed Development. This policy includes for paying due regard to water quality issues, including for the River Trent, in order that it meets Water Framework Directive targets. The Humber River Basin Management Plan32 will be supported by not permitting developments that have a negative impact on water quality, either directly through pollution of surface or ground water or indirectly through overloading of Wastewater Treatment Works. The policy highlights the need to take account of both current and future levels of flood risk, and requires that all new residential developments should achieve water efficiency standards of 105 litres/person/day or less. It also seeks to protect the water environment through implementation of SuDS where viable; deculverting watercourses; attenuating surface water discharges to combined foul/surface water systems and reducing overflows. Developments must check for adequate on and off-site drainage infrastructure in order to serve their needs without posing a risk to the environment.

31 Cannock Chase District Council (2014) The Cannock Chase Local Plan

32 DEFRA (2018) Humber river basin district river basin management plan

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EIA Scoping Report Chapter 11: Hydrology (Including Flood Risk) Rugeley B Power Station, Rugeley

11.2.15 The Lichfield Local Plan Strategy 2008-202933 was adopted by Lichfield District Council in 2015. The strategy helps to shape the way in which the physical, economic, social and environmental characteristics of Lichfield District will change between 2008 and 2029.

11.2.16 The following policies are of relevance to the Proposed Development:

 Core Policy 1 – The Spatial Strategy – This policy aims to contribute to sustainable development to deliver 10,020 dwellings between 2008 and 2029. Proposals are to promote sustainability, including minimising and/or mitigating pressure on areas at risk of flooding, while also mitigating and adapting to climate change;

 Core Policy 2 – Delivering Sustainable Development – This policy includes for guiding development away from known areas of flood risk as identified in the Strategic Flood Risk Assessment (Level 1)28 and Surface Water Management Plan34. If development is proposed in flood risk areas a site-specific flood risk assessment is to be undertaken in line with the National Planning Policy Framework27; and

 Policy NR9 – Water Quality – “Development will be permitted where proposals do not have a negative impact on water quality, either directly through pollution of surface or ground water or indirectly through the treatment of waste water by whatever means”. It is also noted that developments with the River Trent catchment may be impacted by water abstraction and wastewater treatment limitation. The policy also specifically refers to the Water Framework Directive, stating that, “development must not result in any waterbody failing to meet the status class declared in the final River Severn35 and Humber30 River Basin Management Plans”.

Emerging Planning Policy

11.2.17 CCDC are starting the production of a new Local Plan which will utilise the work to be carried out to date on Local Plan Parts 1 and 2 and incorporate any areas which need reviewing and updating. Until the Local Plan is replaced, the adopted Local Plan Part 1 will still continue to set planning policy for the District.

33 Lichfield District Council (1998) Local Plan Strategy 2008-2029

34 Royal Haskoning (2012) South Staffordshire Surface Water Management Plan; Cannock Chase Council, Lichfield District Council, South Staffordshire Council, Stafford Borough Council

35 DEFRA (2018) Severn river basin district river basin management plan

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EIA Scoping Report Chapter 11: Hydrology (Including Flood Risk) Rugeley B Power Station, Rugeley

11.2.18 LDC are reviewing their local plan and once adopted it will replace the current local plan strategy (adopted in 2015) and the local plan allocations document (expected to be adopted in the first quarter of 2019). Until the time the new local plan is adopted LDC will continue to use the existing local plan when making planning decisions.

Guidance/ Best Practice

11.2.19 Current best practice guidance on the planning for and design of SuDS treatment is provided by C753 The SuDS Manual36, The Design Manual for Roads and Bridges (DMRB) HA 103/06 Vegetative Treatment Systems for Highway Runoff37, and the DMRB HD 33/06 Surface and Subsurface Drainage Systems for Highways38. In the context of the Proposed Development, the assessment guidance described in the C753 The SuDS Manual34 is the most appropriate method of assessment to determine the risk to the water environment and the need for treatment measures, and this is described in more detail later in this chapter.

11.2.20 As of the 17th December 2015 all Pollution Prevention Guidance (PPG) documents published by the UK Environment Agencies were withdrawn. However, a new series of Guidance for Pollution Prevention (GPP) is in development, which provides updated good practice guidance to the UK. While this is not regulatory guidance (the UK government website sets out regulatory requirements) it remains a useful resource for best practice. Additional good practice guidance for mitigation to protect the water environment can be found in the following key Construction Industry Research and Information Association (CIRIA) documents:

 C741 Environmental Good Practice on Site Guide39;

 C648 Control of Water Pollution from Linear Construction Projects – Technical Guidance40;

 C609 Sustainable Drainage Systems, Hydraulic, Structural and Water Quality Advice41;

36 CIRIA (2015) The SuDS Manual (C753)

37 Highways Agency (2006), Design Manual for Roads and Bridges HD103/06, Vegetated Drainage Systems for Highway Runoff

38 Highways Agency, Design Manual for Roads and Bridges HD 33/06 Surface and Subsurface Drainage Systems for Highways

39 CIRIA (2015, 4th Edition) C741 Environmental Good Practice on Site Guide

40 CIRIA (2006) C648 Control of Water Pollution from Linear Construction Projects – Technical Guidance

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 C624 Development and Flood Risk – Guidance for the Construction Industry42; and

 C532 Control of Water Pollution from Construction Sites – Guidance for Consultants and Contractors43.

Baseline Data Collection

11.2.21 The data sources that will be used to inform the assessment of the Proposed Development on the water environment include:

 Existing scheme information (masterplan and parameter plans), topographical data, site reports and consultations;

 Online Ordnance Survey (OS) and aerial maps;

 Online historic maps;

 Various websites for data on water quality, water resources, hydrology, flood risk, climate, geology, soils;

 Water company asset plans;

 Any / current River Basin Management Plan, Catchment Abstraction Management Strategy, and Strategic Flood Risk Assessment covering the site;

11.2.22 A data request was submitted to the Environment Agency in December 2018 for further information on flood risk, water quality, resources and biological data for waterbodies in the study area. A response had not yet been received at the time of scoping, but this data will be used to augment the baseline water environment described at the impact assessment stage.

11.2.23 A data request was submitted to SCC (Lead Local Flood Authority), LDC and CCDC (Local Planning Authorities) for further information on local flood risk issues, surface water management requirements and the presence of private water abstractions (surface and ground). A response had not yet been received at the time of scoping, but any data received

41 CIRIA (2004) C609 Sustainable Drainage Systems, Hydraulic, Structural and Water Quality Advice

42 CIRIA (2004) C624 Development and Flood Risk – Guidance for the Construction Industry

43 CIRIA (2001) C532 Control of Water Pollution from Construction Sites – Guidance for Consultants and Contractors

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will be used to augment the baseline water environment described at the impact assessment stage.

11.2.24 A site visit will be undertaken in advance of the preparation of the impact assessment by a surface water specialist to observe surface waterbodies in the study area, observing their current condition and character, the presence of existing risks and any potential pathways for construction and operation impacts from the Proposed Development.

Proposed Assessment Methodology

11.2.25 The water environment assessment will be undertaken with regard to advice and methodologies set out in Department of Transport TAG Unit A3, Environmental Impact Appraisal. Chapter 10 presents ‘Impacts on the Water Environment’44, and DMRB Volume 11, Section 3, Part 10: Water Quality and Drainage (HD 45/09)45. Whilst this guidance was produced to facilitate the comparison of transport schemes, the definitions provided take into account the sensitivity and vulnerability of the water resource and are therefore applicable to the activities associated with the Proposed Development.

11.2.26 The assessment will consider potential impacts on surface water, flood risk, drainage and groundwater resources during construction and operation of the Proposed Development.

11.2.27 Following DMRB HD45/0943, the importance of the receptor (Table 11.1) and the magnitude of effect (Table 11.2) are determined independently from each other and are then used to determine the overall significance of effects (see Table 11.3). Where significant adverse effects are predicted, options for mitigation will be considered and secured where possible. The residual effects of the Proposed Development with identified mitigation in place will also be assessed, where required.

11.2.28 Any effects identified through the FRA, during either the construction or operation phases, will be evaluated and a significance value attributed to each effect in accordance with the methodology outlined in this chapter.

11.2.29 Whilst other disciplines may consider ‘receptor sensitivity’, ‘receptor importance’ is considered here. This is because when considering the water environment, the availability of dilution means that there can be a difference in the sensitivity and importance of a water body. For

44 Department for Transport (2014) TAG UNIT A3 Environmental Impact Appraisal. May 2014 Transport Analysis Guidance (TAG)

45 DMRB, (2009); Volume 11, Section 3, Part 10, HD45/09 Road Drainage and the Water Environment

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example, a small drainage ditch of low conservation value and biodiversity with limited other socio-economic attributes, is very sensitive to impacts, whereas an important regional scale watercourse, that may have conservation interest of international and national significance and support a wider range of important socio-economic uses, is less sensitive by virtue of its ability to assimilate discharges and physical effects. Irrespective of importance, all controlled waters in England are protected by law from being polluted.

11.2.30 Table 11.1 outlines the mechanism by which importance is determined.

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Table 11.1: Criteria to determine receptor importance

Type of Receptor Value(1) Groundwater Surface Water Morphology(2) Flood Risk

Very High Principal aquifer providing a EC Designated Salmonid/Cyprinid Unmodified, near to or pristine Floodplain or defence protecting more regionally important resource fishery conditions, with well-developed and than 100 residential properties from or supporting site protected diverse geomorphic forms and flooding under EC and UK habitat WFD Class ‘High’ site processes characteristic of river type. legislation protected/designated under EC or UK habitat legislation (SAC, SPA, SSSI, SPZ1 WPZ, Ramsar site, salmonid water)/Species protected by EC legislation High Principal aquifer providing WFD Class ‘Good’ Conforms closely to natural, unaltered Floodplain or defence protecting locally important resource or state and would often exhibit well- between 1 and 100 residential supporting river ecosystem Major Cyprinid Fishery developed and diverse geomorphic properties or industrial premises from forms and processes characteristic of flooding SPZ2 Species protected under EC or UK habitat legislation river type, with abundant bank side vegetation. Deviates from natural conditions due to direct and/or indirect channel, floodplain, and/or catchment development pressures. Medium Aquifer providing water for WFD Class ‘Moderate’ Shows signs of previous alteration and / Floodplain or defence protecting 10 or agricultural or industrial use or minor flow regulation but still retains fewer industrial properties from flooding with limited connection to some natural features, or may be surface water recovering towards conditions indicative of the higher category. SPZ3 Low Unproductive strata WFD Class ‘Poor’ Substantially modified by past land use, Floodplain with limited constraints and previous engineering works or flow low probability of flooding of residential regulation and likely to possess an and industrial properties artificial cross-section (for example trapezoidal) and would probably be deficient in bedforms and bankside

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Type of Receptor Value(1) Groundwater Surface Water Morphology(2) Flood Risk

vegetation. Could be realigned or channelised with hard bank protection, or culverted and enclosed. May be significantly impounded or abstracted for water resources use. Could be impacted by navigation, with associated high degree of flow regulation and bank protection, and probable strategic need for maintenance dredging. Artificial and minor drains and ditches would fall into this category.

(1): Professional judgement is applied when assigning an importance category to all water features. The WFD status of a watercourse is not an overriding factor and in many instances it may be appropriate to upgrade a watercourse which is currently at poor or moderate status to a category of higher importance to reflect its overall value in terms of other attributes and WFD targets for the watercourse. Likewise, a watercourse may be below Good Ecological Status, this does not mean that a poorer quality discharge can be emitted. All controlled waters are protected from pollution under the Environmental Permitting (England and Wales) Regulations 2016 and the Water Resources Act 1991 (as amended), and future WFD targets also need to be considered. (2): Based on the water body ‘Reach Conservation Status’ presently being adopted for HS2 (and developed originally by Atkins) and developed from Environment Agency conservation status guidance46/47 as HD45/0943 does not provide any criteria for morphology.

46 Environment Agency (1998) River Geomorphology: a practical guide

47 Environment Agency (1998) Geomorphological approaches to river management. Project record W5A/i661/1, prepared by Thorne, C., Downs, P.W., Newson, M.D., Clarke, M.J., and Sear, D.A., Environment Agency, Bristol.

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EIA Scoping Report Chapter 11: Hydrology (Including Flood Risk) Rugeley B Power Station, Rugeley

11.2.31 The magnitude of effect has been determined based on the criteria in Table 11.2 taking into account the likelihood of the effect occurring. The likelihood of an effect occurring is based on a scale of certain, likely or unlikely. Likelihood has been considered in the case of water resources only, as likelihood is inherently included within the flood risk assessment.

11.2.32 The identification of impacts will take into account all embedded and standard mitigation measures.

Table 11.2: Criteria to determine magnitude of impact (Potential or Residual)

Magnitude of Impact Description and Examples

Major Results in a loss of attribute and/or quality and integrity of the attribute: Adverse Surface water:  Loss of EC designated salmonid / cyprinid fishery;  Loss or extensive change to a designated Nature Conservation Site;  Pollution of portable source of abstraction;  Deterioration of a water body leading to a failure to meet Good Ecological Status / Potential (GES / GEP) and reduction in Class; Groundwater:  Loss of, or extensive change to, an aquifer;  Loss of, or extensive change to, groundwater supported designated wetlands; Flood Risk:  Increase in peak flood level (1% annual probability) >100 mm. Moderate Results in impact on integrity of attribute, or loss of part of attribute: Adverse Surface Water:  Partial loss in productivity of a fishery;  Contribution of a significant proportion in the effluent in the receiving river but insufficient to change its water quality status;  Deterioration of a water body leading to failure to meet GES / GEP; Groundwater:  Partial loss or change to an aquifer;  Partial loss of the integrity of groundwater supported designated wetlands; Flood Risk:  Increase in peak flood level (1% annual probability) >50mm. Minor Results in some measurable change in attribute’s quality or vulnerability: Adverse Surface Water:  Effect on water body which may prevent achievement of GES / GEP or other WFD target; Groundwater:  Effect on water body which may prevent achievement of GES / GEP or other WFD target; Flood Risk:  Increase in peak flood level (1% annual probability) >10mm.

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EIA Scoping Report Chapter 11: Hydrology (Including Flood Risk) Rugeley B Power Station, Rugeley

Magnitude of Impact Description and Examples

Negligible Results in impact on attribute, but of insufficient magnitude to affect the use or integrity: The Scheme is unlikely to affect the integrity of the water environment. Surface Water:  Discharges to watercourse but no significant loss in quality, fishery productivity or biodiversity; Groundwater:  No effect on WFD classification; Flood Risk:  Negligible change in peak flood level (1% annual probability) <+/- 10mm. Minor Results in some beneficial impact on attribute or a reduced risk of negative impact occurring: Beneficial Surface Water:  Enhancement of the water environment on a local scale;  Positive effect on WFD parameters, although insufficient to result in the improvement of class; Groundwater:  Positive effect on WFD parameters, although insufficient to result in the improvement of class; Flood Risk:  Reduction in peak flood level (1% annual probability) >10mm. Moderate Results in moderate improvement of attribute quality: beneficial Surface Water:  Enhancement of the water environment on a site wide scale;  Improvement in the class of specific WFD parameters of a water body, but not necessarily an improvement in overall water body status. Groundwater:  Improvement in the class of specific parameters of a WFD water body, but not necessarily an improvement in overall water body status. Flood Risk:  Reduction in peak flood level (1% annual probability) >50mm. Major Results in major improvement of attribute quality: beneficial Surface Water:  Removal of existing polluting discharge, or removing the likelihood of polluting discharges occurring to a watercourse;  Enhancement of the water environment on a regional scale beyond site boundaries;  Improvement of a water body to meet Good Ecological Status / Potential (GES / GEP). Groundwater:  Removal of existing polluting discharge to an aquifer or removing the likelihood of polluting discharges occurring, Recharge of an aquifer;  Improvement of a water body to meet Good Ecological Status / Potential (GES / GEP). Flood Risk:  Reduction in peak flood level (1% annual probability) >100mm. Source: HD45/0943

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EIA Scoping Report Chapter 11: Hydrology (Including Flood Risk) Rugeley B Power Station, Rugeley

11.2.33 The significance of effects has been determined using the matrix presented in Table 11.3. Effects classed as moderate or greater are considered significant in EIA terms (i.e. shaded cells).

11.2.34 Where the significance of an effect is represented by two descriptors, for example large/very large within the matrix, professional judgement has been used to determine which of the significance descriptors applies to the effect being assessed.

Table 11.3: Matrix to determine significance of effect

Importance Magnitude

Major Moderate Minor Negligible

Very High Very large Large / very large Moderate / large Neutral

High Large / very large Moderate / large Slight / moderate Neutral

Medium Large Moderate Slight Neutral

Low Slight / moderate Slight Neutral Neutral

Source: HD45/0943

Water Quality Assessment

11.2.35 A qualitative assessment of potential effects on surface water and ground water quality from the construction and occupation phases of the Proposed Development will be undertaken based on site surveys and desk study. This will consider the risk to surface water and groundwater bodies resulting from construction works or future occupation of the Site using a source-pathway-receptor approach. Surface water runoff from the new development will be assessed following the Simple Index Approach outlined in CIRIA C753 - The SuDS Manual34. Where there is a risk of pollution from construction or operation phases, mitigation measures will be described with reference to best practice guidance. The significance of effects will be determined with reference to the criteria set out within the Design Manual for Roads and Bridges HD45/0943. Please note that the assessment of risk from any contaminated land is described in Chapter 13: Ground Conditions.

11.2.36 Due to the potential impacts upon numerous WFD designated water bodies a Preliminary WFD Compliance Assessment will be undertaken. The aim of this assessment will be to determine the potential for any non-compliance of the Proposed Development with WFD

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objectives for affected water bodies using readily available information and site observations. This will include an examination of the potential construction and operation phase effects of the Proposed Development on relevant WFD hydromorphological, biological and physio- chemical parameters. Depending on the outcomes of the preliminary assessment further more detailed investigations may be required, in consultation with the Environment Agency.

Flood Risk Assessment

11.2.37 In line with the NPPF27, a FRA will be required to support the planning application as the footprint of the Site is larger than 1 ha and is partially located in Flood Zone 3. The scope of the FRA will identify and assess all forms of flooding to and from Proposed Development and demonstrate how these flood risks will be managed, taking into account the vulnerability of the proposed scheme and the potential impact of climate change. The overall objective of the FRA will be to comply with the requirements of NPPF, PPG and SCC/ LPA flood risk policies and include provisions with respect to surface water runoff management which meet the specific needs of the EA, SCC and Severn Trent Water.

11.2.38 A conceptual surface water drainage strategy will be required for the Proposed Development due to the change in land use type from predominantly previously developed land with areas of rural greenfield land to residential and commercial led urban development. The proposals will commit to meeting the requirements of NPPF, SCC and Severn Trent Water and will provide detail on how surface water runoff on site will be collected, managed and controlled prior to discharge, so as to minimise the potential risk of flooding. The Drainage Strategy will include a review of appropriate SuDS and will identify the residual risks that remain after implementation of the recommended mitigation measures.

Geographical Scope

11.2.39 As part of the water environment assessment process an approximate 1 km study area has been defined around the Proposed Development. Within this area, the known surface water features and their attributes have been identified, the extent of known flood risk has been determined, and the current ground water conditions described.

11.2.40 The study area will also consider any surface water or groundwater bodies or water dependent ecological sites outside this study area up to 2 km from the Proposed Development boundary if it is considered they are hydraulically linked and impact on determination of waterbody importance.

11.2.41 The flood risk study area will comprise Environment Agency Flood Zones (as defined in the PPG26) along the watercourses that may be affected by the Proposed Development. The

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Environment Agency designates flood risk zones on the basis of the annual probability of a flood event to occur as follows:

 Zone 1 is less than 0.1% annual probability of flood risk (i.e. a very low risk of flooding);

 Zone 2 between 0.1-1% annual probability of flood risk (i.e. a low risk of flooding); and

 Zone 3 is more than 1% annual probability of flood risk (i.e. a medium risk of flooding).

Temporal Scope

11.2.42 The temporal scope will cover the construction and occupation phases of the development.

11.2.43 The FRA and Drainage Strategy will include an assessment of the impact of climate change on all sources of flood risk, including surface water. The Proposed Development comprises mixed uses, including residential, commercial etc. therefore the assessment of flood risk will be undertaken for the lifetime of the development (assumed to be 100 years based on residential use, as outlined in the PPG).

11.3 BASELINE ENVIRONMENT

11.3.1 The relevant physical characteristics of the study area and the water features present are described in this section.

11.3.2 The following will form part of the baseline environment for the EIA (on the basis that they will be completed in advance of the commencement of development) and therefore will not form part of the assessed project:

 Demolition Consented under Prior Approvals 18/01098/FULM and CH/18/268; and

 Extraction of Pulverised Fuel Ash (PFA) from the eastern lagoons followed by the creation of a level platform.

Land Use, Topography and Rainfall

11.3.3 The Site borders the River Trent along its northeast boundary, is bounded by agricultural fields to the east, and the A51 to the south and west. Beyond the A51 to the south and west lies the Trent and Mersey Canal, and the residential and industrial outskirts of the town of Rugeley. Beyond the River Trent to the north is a railway line oriented approximately southeast to northwest, with mainly agricultural land beyond this within the study area.

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EIA Scoping Report Chapter 11: Hydrology (Including Flood Risk) Rugeley B Power Station, Rugeley

11.3.4 Topographic data for the study area has been obtained from online Ordnance Survey maps48. Ground levels across the Site itself are very level, being between 65 and 70m above ordnance datum (AOD). The section of the Site to the north of the railway line is generally lower than the actual power station Site. The railway line is raised above the majority of the Site.

11.3.5 To the north of the River Trent the land rises gradually across agricultural fields, to a peak of 100m AOD to the west of Stonyford Lane. To the south east the land rises more steeply through Hawkesyard Priory and St Thomas Priory Golf Club to reach 120m AOD at Brereton Cross. To the southwest of the Site the land remains initially flat across Mossley, the Way for the Millennium Path and the Trent and Mersey Canal, before rising more steeply through Brereton towards Chetwynd’s Coppice. Land to the west of the Site rises gradually towards Hagley Park, and to the north towards Rugeley Junction (railway junction).

11.3.6 As part of the development proposals ground levels will change across the Site, where required, including:

 Further re-profiling of the eastern lagoons (beyond that associated with the surrender of the Environmental Permit) to create a suitable development platform; and

 PFA extraction and re-profiling of the Golf Course and Leisure Area.

11.3.7 Proposed finished Site levels will be approximately 1m above the 1 in 100 year with climate change allowance flood level, which will be derived once hydraulic modelling information is received from the Environment Agency (requested in December 2018).

11.3.8 Using the Met Office website49, the nearest weather station is Penkridge, which is located approximately 14 km west-south-west of the Site. Based on the available data from this weather station it is estimated that the study area is likely to receive an average of more than 680 mm of rainfall per year, with it raining (greater than or equal to 1 mm of rain) on approximately 125 days per year. Graph 11.1 illustrates this data to show how the average rainfall varies throughout the year (data for the period 1981-2010).

48 Ordnance Survey online mapping, available online at www.bing.co.uk/maps, accessed December 2018

49 Met Office website, available online at http://www.metoffice.gov.uk/public/weather/forecast, accessed December 2018

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Graph 11.1 Penkridge Weather Station, Rainfall and Days of Rainfall 80 20 70 18 16 60 14 50 12 40 10 30 8

Rainfall Rainfall (mm) 6 20 4 10 2

0 0 Days Days ofRainfall 1mm >= Days Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Months Rainfall (mm) Days of Rainfall >= 1mm (days)

11.3.9 Graph 11.1 shows that the highest rainfall volumes are expected during the late summer through to mid-winter, with it being driest between February and March.

11.3.10 The same Met Office weather station at Penkridge reports that the study area generally gets around 47 days of frost (air) each year distributed evenly across December, January and February, with occasional days of frost in March, April, October and November.

Geology, Groundwater and Soils

11.3.11 According to the British Geological Society website50, the bedrock underlying the Site consists predominantly of Helsby Sandstone Formation – Sandstone, Pebbly (gravelly). The northwest corner of the Site is underlain by Tarporley Siltstone Formation – mudstone. To the north of this there are widespread deposits of Sidmouth Mudstone Formation. To the south and east of the Site, but within the study area, there are deposits of Mercia Mudstone Group and Chester Formation – Sandstone and Conglomerate, Interbedded.

11.3.12 The superficial deposits underlying the majority of the Site are River Terrace Deposits, 1 – Sand and Gravel. Around the River Trent is a band of Alluvium. There is a patch of Till, Mid Pleistocene – Diamicton in the south of the study area around Brereton.

50 British Geological Survey, Geology of Britain Viewer website, available at http://mapapps.bgs.ac.uk/geologyofbritain/home.html, accessed December 2018

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11.3.13 According to Defra’s Multi-agency geographical information for the countryside (MAGIC) map website51 the bedrock beneath the Site and within the study area to the south and east is Principal Aquifer. The Environment Agency describes this as “layers of rock or drift deposits that have high intergranular and/or fracture permeability - meaning they usually provide a high level of water storage. They may support water supply and/or river base flow on a strategic scale. In most cases, principal aquifers are aquifers previously designated as major aquifer”. The eastern extent of the study area is designated as Secondary B aquifer. The Environment Agency define this as, “predominantly lower permeability strata which may in part have the ability to store and yield limited amounts of groundwater by virtue of localised features such as fissures, thin permeable horizons and weathering”.

11.3.14 The superficial aquifer underlying the Site is designated as Secondary A aquifer. This is described by the Environment Agency as, “permeable strata capable of supporting water supplies at a local rather than strategic scale and in some cases forming an important source of base flow to rivers”. There are small patches of Secondary undifferentiated strata to the north and south of the study area. This is assigned in cases where it has not been possible to attribute either category A or B to a rock type. In most cases, this means that the layer in question has previously been designated as both minor and non-aquifer in different locations due to the variable characteristics of the rock type.

11.3.15 According to the Cranfield Soil and Agrifood Institute Soilscapes website52 the soils surrounding the River Trent within the study area are floodplain soils, although the majority of the Site is underlain by freely draining slightly acid loamy soils. The southern extent of the study area is underlain by freely draining, slightly acid sandy soils.

11.3.16 According to Defra’s Magic map49 there are no Source Protection Zones (SPZ) beneath the Site itself, but approximately 1 km west of the western boundary of the Site (i.e. at the border of the study area) there is source protection Zone 3 – Total Catchment (immediately west of Rugeley Town train station). This zone is defined as total area needed to support the abstraction of discharge from a potential groundwater source. Inner Protection Zones (Zone 1) are located over 1.7 km west of the Proposed Development adjacent to Rising Brook (centred approximately on NGR SK 03898 17610) and approximately 2 km northwest of the Proposed Development adjacent to the River Trent (centred approximately on NGR SK 03874 19480).

51 Multi-agency Geographical Information for the Countryside (MAGIC) website, available at http://www.natureonthemap.naturalengland.org.uk/; accessed December 2018

52 Cranfield University, Soilscapes website, available at http://www.landis.org.uk/soilscapes, accessed December 2018

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These Inner Protection Zones are defined as the zone with a travel time of 50-days or less from any point within the zone at, or below, the water table. The zone has a minimum 50- metre radius. It is based principally on biological decay criteria and is designed to protect against the transmission of toxic chemicals or water-borne diseases. Each patch of Zone 1 is surrounded by a band of Zone 2 – (Outer Protection). These are defined by the 400 day travel time from a point below the water table.

11.3.17 The Environment Agency’s Catchment Data Explorer website53 indicates that the study area is within the Staffordshire Trent Valley – Permo Triassic Sandstone WFD groundwater body (GB40401G300500). This has a surface area of 311.3 km2 and has an overall waterbody classification for 2016 of Poor. The quantitative and chemical classifications are both also Poor.

11.3.18 Data has been requested from the Environment Agency for details on groundwater abstractions in the study area. Details of Private Water Supplies in the study area have been requested from LDC and CCDC and the data will be used to inform the impact assessment.

11.3.19 Defra’s Magic map49 indicates that the Site is not located in a Drinking Water Safeguard Zone for groundwater.

Surface Waterbodies

11.3.20 The following surface waterbodies are present in the study area (WFD information is derived from the Environment Agency’s Catchment Data Explorer website51):

 River Trent (Main River and WFD designated as Trent from Moreton Brook to River Tame, GB104028047290) – flows adjacent to the east Site boundary. An additional upstream WFD reach falls within the study area (WFD designated as Trent from River Sow to Moreton Brook, GB104028047300), but this WFD reach is scoped out due to being upstream of the Proposed Development, and so will not be impacted. The Trent from Moreton Brook to River Tame WFD waterbody is not designated artificial or heavily modified. The reach is designated from its confluence with Moreton Brook (SK 04941 18699) to the River Tame (SK 19173 14873). It has a catchment area of 36.6 km2 and a length of 22.7 km. It is at Poor Ecological Status (2016 Cycle 2 classification) and Good Chemical Status. Fish and phosphate are at Poor Status, with invertebrates and

53 Environment Agency Catchment Data Explorer website (http://environment.data.gov.uk/catchment- planning/)

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‘macrophytes and phytobenthos combined’ at Moderate Status. The WFD waterbody objective is Good overall status by 2027;

 Moreton Brook (Main River and WFD designated as Moreton Brook from Source to River Trent, GB104028047380). This is a tributary of the River Trent, which flows southeast from its source close to Stowe-by-Chartley to meet the Trent at NGR SK 04941 18699. The confluence of this watercourse with the River Trent is 400 m west of the northwest corner of the Site. However, as it is upstream it will not be impacted by the Proposed Development and is scoped out of the assessment;

 Rising Brook (Main River and WFD designated, GB104028047280) – this is a tributary of the River Trent, it flows northeast from its source in Cannock Chase to its confluence with the Trent, which is approximately 150 m west of the northwest corner of the Site (SK 05096 18465). However, as it is upstream it will not be impacted by the Proposed Development and is scoped out of the assessment;

 Brereton Brook (ordinary watercourse) – flows south to north through the Site. OS mapping suggests that this watercourse rises from a spring at SK 04414 14581, and flows northeast towards Brereton where it then flows underground beneath the residential area and the Trent and Mersey Canal. It emerges approximately 100 m southwest of the Site boundary at SK 06192 16877, from where it continues northeast in a straightened channel through the Site. At the northern Site boundary the watercourse then flows east and meets the River Trent at SK 07181 17067;

 Trent and Mersey Canal (WFD designated as Trent and Mersey Canal, summit to Alrewas, GB70410142) – located south of the Site, and adjacent to the Site boundary at its southeastern extent. The waterbody is at Good Ecological and Good Chemical Status (under 2016 Cycle 2 classification), and so its objective is to maintain Good Status. Any works that affect the Trent and Mersey Canal may need permission from the Canal and Rivers Trust;

 Rugeley Town Main Water Drain – located to the west of the site. It is within an underground pipe where it passes through the previously operational part of the Site before becoming an open channel within the area in the undeveloped area of the Site between the power station (due to be demolished) and the River Trent;

 Northern Drain (ordinary watercourse) – located to the north of the railway embankment and aligned southeast to northwest through the northern extent of the site. Towards the

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centre of the Site, the drain passes across the Site boundary and flows to the north of the Site, parallel to the River Trent;

 Numerous other drains and ditches (ordinary watercourses), in particular there are several across the previous power station area and in the undeveloped area between the power station and River Trent;

 Borrow Pit Lake at the eastern extent of the Site. This appears to receive drainage from numerous ditches and the adjacent residential development (via an attenuation pond) and also overflows via a ditch to the River Trent. It has a surface area of approximately 67,000 m2;

 Ash lagoons are situated in the central south eastern part of the site and will be lost as part of the permit surrender activities for the Site (see Chapter 2);

 An attenuation pond immediately west of the southeastern boundary of the Site, which appears to serve Priory Avenue and The Cloisters and the adjacent housing development (NGR SK 06607 16511), prior to outfalling to the Borrow Pit Lake;

 Numerous ponds within the Site boundary (including the 15,900 m2 pond at the recreation ground) and in the wider study area. Those ponds outside of the Site boundary, with the exception of the aforementioned attenuation pond, are all scoped out of the assessment due to being isolated from the Proposed Development by major roads, railway lines and watercourses (River Trent and the Trent and Mersey Canal), as well as being upslope from the Site. Therefore, they do not have hydrological connectivity to the Proposed Development.

11.3.21 All of the watercourses described above are located within the Trent – Source to Sow Canals WFD Operational Catchment, which is located within the Humber AWB Management Catchment, which is located within the Humber River Basin District.

11.3.22 The proposed development must not cause deterioration of any relevant WFD parameter for these waterbodies (i.e. the reduction in class of any parameter), or prevent the improvement to meet future WFD objectives. In addition, WFD requirements apply to all inland waters and not just classified reaches. Where a new physical modification might result in non-compliance with the main objectives of the WFD, development might still be feasible if it meets the requirements of WFD Article 4.7 which includes stringent tests in terms of need, alternative options, and costs to be considered.

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11.3.23 According to Defra’s MAGIC map website49 the Site is not in a Drinking Water Safeguard Zone for surface water. The entire area is a Nitrate Vulnerable Zone (NVZ) for surface water (under the 2017 designations). Surface water NVZs are areas that drain into freshwater bodies that could have a nitrate concentration of >50 mg/l if action is not taken.

11.3.24 Data on water quality of surface waterbodies in the study area, active discharge consents to surface waterbodies, pollution incidents and abstractions from surface waterbodies have been requested by the Environment Agency, but have not been received at the time of writing (December 2018).

Flood Risk

11.3.25 The current Environment Agency online Flood Map for Planning54 indicates the Site is located predominantly within Flood Zone 1. Flood Zone 1 is defined by the EA as land that has a low probability of flooding, less than a 1 in 1000 year annual probability of river or sea flooding (< 0.1% Annual Exceedance Probability (AEP)). Land to the north and north east of the Site between the River Trent and the mineral railway is located in Flood Zone 2 and Flood Zone 3. Land located in Flood Zone 2 is classed as medium probability of flooding, between a 1 in 100 and 1 in 1000 annual probability of river flooding (1% - 0.1% AEP). Land located in Flood Zone 3 is classed as high probability of flooding, greater than 1 in 100 annual probability of flooding (> 1% AEP).

11.3.26 An area of Flood Zone 2 extends into the central area of the Site in the vicinity of the Ash Lagoons and to the north west of the Borrow Pit.

11.3.27 Pluvial flood risk has been identified in the SFRA28 as the most significant risk of flooding to the Cannock Chase area, which occurs due to the exceedance of the drainage capacity in urban areas. The Surface Water Management Plan55 indicated that there is risk of significant pluvial flood events within Cannock and Rugeley Town Areas.

11.3.28 The Environment Agency online Risk of Flooding from Surface Water map52 indicates that the majority of the Site is at very low risk of flooding from surface water. However, there are some ‘low’ to ‘high’ risk areas of surface water flooding associated with dry valleys, areas where surface water would naturally flow as a result of topography, the Ordinary Watercourses located within the Site boundary and the River Trent, located adjacent to, but outside of, the

54 Environment Agency (20180) Flood Map for Planning available at https://flood-map-for- planning.service.gov.uk/. Accessed December 2018.

55 Royal Haskoning (2010) Southern Staffordshire Surface Water Management Plan

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Site boundary. There are also some areas of surface water ponding associated with low topographical points across the Site.

11.3.29 General trends from the groundwater data show a pattern of flow from south west to north east, towards the River Trent, across the Site. Central areas of the Site conform to this pattern. Western parts of this area have a maximum groundwater level of 66.216 m AOD and the lowest level of 63.638 m AOD is found in the east.

11.3.30 According to the Environment Agency Long Term Risk of Flooding maps56 the majority of the Site area is not located in an area at residual risk of failure or breach of a reservoir. Land located between the mineral railway and the River Trent however would be at risk of flooding should a reservoir breach occur.

11.3.31 The Trent and Mersey canal is located to the south and west of the Site. The SFRA states “there were no records of canal breaches; therefore currently it is considered that the risk of flooding from canals is extremely low”.

11.3.32 There is likely to be limited existing sewer and surface water infrastructure present associated with existing infrastructure within the Site or within close proximity to the Site, including residential areas and the highway network.

Designated Sites of Ecological Importance

11.3.33 Using the MAGIC online map49 no statutory designated sites (including: SSSIs, SACs, SPAs, Ramsar and/ or NNRs) have been identified within the study area. The closest such site is Stafford Brook SSSI which is 3 km northwest of the Scheme boundary. This SSSI would not be impacted as it is upstream from the Site.

11.3.34 The presence of aquatic protected species or UK Biodiversity Action Plan habitats in watercourses will be determined at the next assessment stage. Furthermore, WFD monitoring data on biological quality elements (e.g. fish, macroinvertebrates, macrophytes and phytobenthos) has been requested from the Environment Agency for the River Trent and Trent and Mersey Canal.

56 Environment Agency, Long Term Risk of Flooding. Available at: https://flood-warning- information.service.gov.uk/long-term-flood-risk

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11.4 POTENTIAL ENVIRONMENTAL IMPACTS & EFFECTS

11.4.1 The Proposed Development has the potential to cause adverse effects to the water environment during construction and operation.

Construction Impacts and Effects

11.4.2 During construction the following adverse impacts may occur and so will be considered by the impact assessment:

 Impacts on water quality, both surface and groundwater, due to deposition or spillage of soils, sediments, oils, fuels, or other construction chemicals, or through uncontrolled site run-off (including from the site compound);

 Interception of groundwater through excavations and earthworks, which may temporarily change the hydraulic gradient in the area of excavation; and

 Potential increase in volume and rate of surface water runoff from new hardstanding leading to an impact on flood risk. This will be considered in the FRA.

11.4.5 Impacts on groundwater following disturbance of contaminated ground or groundwater are presented within Chapter 13 Ground Conditions.

Occupation Impacts and Effects

11.4.6 During operation the following adverse impacts may occur:

 Impacts on water quality in rivers and other surface waterbodies which may receive run- off from the proposed development (including run-off from new access roads, parking bays, residential dwellings, and other proposed facilities) either through the continual release of contaminants or as a result of accidental spillage (e.g. vehicle fuel spillage on parking bays);

 Physical damage to the morphology of water bodies (e.g. Brereton Brook within the Site) that could have both temporary and long term impacts on the hydromorphological conditions of the water bodies.

 Impacts on hydrogeology could occur from contaminant release during accidental spillages;

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 Changes in the natural form (e.g. where road cuttings are required) which may have a subsequent effect on surface and groundwater drainage patterns.

 Potential increase in volume and rate of surface water runoff from new impervious areas leading to an impact on flood risk.

 Impacts on hydraulic processes and sediment dynamics in watercourses and their floodplains due to potential watercourse crossings and road outfalls;

 Increased local demand on the capacity of public sewers and waste water treatment provision; and

 Increased local demand for potable water supply.

11.4.7 The proposed development may give rise to some beneficial impacts over existing conditions, such as through the employment of sustainable drainage solutions where they are currently limited on the Site.

11.5 MITIGATION ENVISAGED

Construction Phase Mitigation Measures

11.5.1 It is envisaged that a Construction Environmental Management Plan (CEMP) will be prepared prior to the commencement of development and then implemented during the construction phase. The CEMP would include a range of measures associated to mitigate potential impacts as associated with water resources. Such measures would accord with legal compliance and best practice guidance when working with or around sensitive water resources.

11.5.2 These measures will broadly focus on:

 managing the risk of pollution to surface waters and the groundwater environment;

 measures to control the storage, handling and disposal of substances during construction;

 the management of activities within floodplains (i.e. kept to a minimum) with temporary land take required for construction to be located out of the floodplain as far as reasonably practicable or allowances made for floodplain control measures and contingency actions; and

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 managing the risk from groundwater flooding through appropriate working practices (during earth cutting activities) and with adequate plans and equipment in place for de- watering to ensure safe dry working environments.

11.5.3 A Water Management Plan would also be produced to provide site specific information of how the risks to the water environment from potential pollution and the risk of physical damage would be managed.

11.5.4 During the construction phase, any discharges to surface water of ‘unclean’ runoff would require discharge consent. Works undertaken above or within 8 m of a watercourse would also require appropriate permissions from the Environment Agency or LLFA (i.e. Staffordshire County Council).

11.5.5 It is anticipated that monitoring of watercourses at risk of pollution during the construction phase would be required.

11.5.6 During construction there would be a requirement to protect construction plant, materials and construction workers from impacts due to flooding. Such measures would include, for example, locating construction compounds and material / plant storage areas outside of areas susceptible to flooding and having in place emergency flood response procedures. The management and subsequent implementation of such measures would also seek to avoid any potential pollution of local watercourses by construction materials in the event of flooding. These would be managed during the construction phase through the CEMP.

Operation Phase Mitigation Measures

11.5.7 The proposed drainage strategy will be developed in consultation with the Environment Agency, Staffordshire County Council (as LLFA), Seven Trent Water and potentially other statutory agencies, taking into account the findings of the FRA and water quality assessment prepared for the Proposed Development.

11.5.8 Sustainable Drainage Systems (SuDS) will be incorporated into the design of the Drainage Strategy to limit the impact on flood risk by reducing the rate at which runoff from new hard areas discharges into receiving watercourses. Attenuation of the discharge, as far as practicable, will be to equivalent Greenfield runoff rates as calculated in accordance with best practice for SUDS will be provided. Storage for additional flows up to the 1 in 100 year return period including a 40% climate change allowance will be provided in SUDS features. The suitability of the proposed SuDS treatment train for providing water quality treatment will be determined using the Simple Index Approach outlined in CIRIA C753 The SuDS Manual34.

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11.5.9 Should any watercourse crossings be designed into the scheme, then the channel designs for these crossings will be developed and informed by hydromorphological, flood risk and ecological assessment, and would aim to ensure that existing flow conditions within the channels are maintained and not significantly impacted by constrictions such that there would be no significant adverse impacts on channel flooding characteristics. The morphological and ecological function of these channels will also be taken into account during the design of new or modified structures and where possible opportunities for enhancement will be explored.

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CHAPTER 12: NOISE AND VIBRATION

12.1 INTRODUCTION

12.1.1 This chapter of the EIA Scoping Report has been produced by Air & Acoustic Consultants Limited (AAC) and outlines the proposed approach for assessing potential noise & vibration impacts as a result of the Proposed Development which is scoped in to the proposed EIA.

12.1.2 Noise & vibration changes could occur during construction phase as a result of the construction activities, traffic movements, highway interventions and mobile or stationary plant. During occupation the main changes in noise would arise as a result of changes to road layouts, traffic flows and the introduction of any new stationary plant. Vibration impacts resulting from rail activity could also give rise to impacts upon the operational use of the development

12.1.3 This chapter also includes a summary of the likely noise and vibration effects to be considered further in the ES.

12.1.4 Where appropriate the assessment will identify proposed mitigation measures to prevent, minimise or control likely negative effects arising from the Proposed Development.

12.2 ASSESSMENT CRITERIA & METHODOLOGY

Previous Assessment

12.2.1 A review of the local planning applications for the former land owned by Rugeley Power Station (Planning refs: 10/00420/REMM / 03/00628/FUL for an approved industrial / residential scheme) indicates that a lot of detailed noise assessment and modelling works have been undertaken as part of these applications due to the operation of the power plant at the time.

12.2.2 In 2010 a Noise Compliance Monitoring Report was produced by Jacobs to ascertain if the noise limit values associated the operation of Rugeley Power Station, including a new Flue-Gas Desulphurisation plant, are compliant with the limits set out within Condition no28. of an approved Section 36 planning application at both on-site and off-site locations. A review of this document indicates the Site was compliant.

Legislative Context

12.2.3 The ‘Control of Pollution Act 1974 gives local authorities powers in relation to noise and vibration from construction sites including to serve a notice, (under Section 60 of the act) specifying exactly how works should be carried out.

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12.2.4 An application for prior consent for the work can be completed under Section 61 of the Act providing a collaborative approach to the development.

12.2.5 Under Section 79 of the ‘Environmental Protection Act 1990 (as amended)’ local authorities are under a statutory general duty under the Environmental Protection Act 1990 to inspect their areas from time to time, to detect any statutory nuisances, including noise and vibration from construction sites.

12.2.6 Local authorities have a specific duty to serve an abatement notice under the EPA where a statutory nuisance exists or is likely to occur. An abatement notice will specify any works required to restrict the statutory nuisance and the time for compliance.

Planning Policy and Guidance

12.2.7 A summary of the national, regional and local planning policy relevant to the Proposed Development and assessment of noise & vibration impacts is provided below.

National Planning Policy Framework 2

12.2.8 The National Planning Policy Framework 2 was published in July 2018. It sets out the governments planning policies for England and how these are expected to be applied. The NPPF should be considered in the preparation of local and neighbourhood plans. No specific values or noise criteria are included in this document. However, noise is mentioned a number of paragraphs throughout the framework which have relevance to the Proposed Development.

12.2.9 Paragraph 170 states:

“Planning policies and decisions should contribute to and enhance the natural and local environment by:

[..]

e) preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help to improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans;

[..]”

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12.2.10 Paragraph 180 states:

“Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development. In doing so they should:

a) mitigate and reduce to a minimum potential adverse impacts resulting from noise from new development – and avoid noise giving rise to significant adverse impacts on health and the quality of life;

b) identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason;

[..]”

Noise Policy Statement for England (NPSE)

12.2.11 The Noise Policy Statement for England (NPSE) published in March 2010 by the Department for Environment Food and Rural Affairs (DEFRA) and is the overarching statement of noise policy for England.

12.2.12 The Noise Policy Vision is to:

“Promote good health and a good quality of life through the effective management of noise within the context of Government policy on sustainable development.”

12.2.13 The vision is supported by the following aims

“Through the effective management and control of environmental, neighbour and neighbourhood noise within the context of Government policy on sustainable development:

 avoid significant adverse impacts on health and quality of life;

 mitigate and minimise adverse impacts on health and quality of life; and

 where possible, contribute to the improvement of health and quality of life.”

12.2.14 The Explanatory Note to the NPSE introduces three concepts to the assessment of noise in the UK:

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 NOEL – No Observed Effect Level – This is the level below which no effect can be detected and below which there is no detectable effect on health and quality of life due to noise;

 LOAEL – Lowest Observable Adverse Effect Level – This is the level above which adverse effects on health and quality of life can be detected; and

 SOAEL – Significant Observed Adverse Effect Level – This is the level above which significant adverse effects on health and quality of life occur.

12.2.15 To note, none of these three levels are defined numerically in the NPSE and for SOAEL it states:

“It is not possible to have a single objective noise-based measure that defines SOAEL that is applicable to all sources of noise in all situations. Consequently, the SOAEL is likely to be different for different noise sources, for different receptors and at different times. It is acknowledged that further research is required to increase our understanding of what may constitute a significant adverse impact on health and quality of life from noise. However, not having specific SOAEL values in the NPSE provides the necessary policy flexibility until further evidence and suitable guidance is available.”

National Planning Policy Guidance

12.2.16 The National Planning Policy Guidance was published in March 2014. The web-based planning guidance summarises the noise exposure hierarchy and offers examples of outcomes relevant to the No Observed Effect Level (NOEL), Lowest Observed Adverse Effect Level (LOAEL) and Significant Observed Adverse Effect Level (SOAEL) effect levels described in the NPSE. The effect levels, NOEL, LOAEL and SOAEL. However, along with the NPSE it does not provide any numerical of definition of the NOEL, LOAEL and SOAEL.

Local Planning Policy

Cannock Chase Current Planning Policy

12.2.17 The Cannock Chase Local Plan was adopted in June 2014. No specific policies are in place which relate to noise and vibration.

Lichfield Current Planning Policy

12.2.18 The Lichfield Local Plan Strategy was adopted in February 2015. . Core Policy 3: Delivering Sustainable Development states:

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“The Council will require development to contribute to the creation and maintenance of sustainable communities, mitigate and adapt to the adverse effects of climate change, make prudent use of natural resources, reduce carbon emissions, enable opportunities for renewable energy and help minimise any environmental impacts. To achieve this, development should address the following key issues:

[..]

 minimise levels of pollution or contamination to air, land, soil or water, including noise and light pollution and avoid unacceptable uses within source protection zone 1 areas to safeguard water resources and ensure water quality;

[..]”

12.2.19 Policy BE10: High Quality Development states:

“All development proposals should ensure that a high quality sustainable built environment can be achieved. Development will be permitted where it can be clearly and convincingly demonstrated that it will have a positive impact on:

[..]

 Amenity, by avoiding development which causes disturbance through unreasonable traffic generation, noise, light, dust, fumes or other disturbance;

[..]”

Emerging Planning Policy

12.2.20 Due to changes to the national planning system (including the requirement for councils to review their plans every five years to see which policies may need updating), some parts of Cannock Chase Local Plan (Part 1) 2014, will soon be out of date. The production of a new Local Plan is being started which will utilise the work to be carried out to date on Local Plan Parts 1 and 2 and incorporate any areas which need reviewing/updating. Until it is replaced, the adopted Local Plan Part 1 will continue to set planning policy for the District.

12.2.21 LDC are reviewing their local plan and once adopted it will replace the current local plan strategy (adopted in 2015) and the local plan allocations document (on-going, expected to be adopted in 2018). Until the time the new local plan is adopted LDC will continue to use the existing local plan when making planning decisions.

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Guidance/ Best Practice

12.2.22 The assessment will take into account the following guidance:

 BS 5228-1:2009 + A1:2014 ‘Code of practice for noise and vibration control on construction and open sites – Part 1: Noise.

 BS 5228-1:2009 + A1:2014 ‘Code of practice for noise and vibration control on construction and open sites – Part 2: Vibration.

 BS 7445-1 & ISO 1996-1 Guidance on Sound measurement & Attenuation of sound during propagation outdoors;

 BS 8233:2014 Guidance on Sound Insulation and Noise Reduction for Buildings

 BS4142:2014 Methods for Rating and Assessing Industrial and Commercial Sound;

 The Department for Transport’s ‘Calculation of Road Traffic Noise’ (1988) (CRTN);

 BS 5228:2009 Code of Practice for Noise and Vibration Control on Construction and Open Sites;

 The ‘Professional Planning Guidance: Planning & Noise – New Residential Development’ (2017);

 BS 6472-1:2008 Guide to Evaluation of Human Exposure to Vibration in Buildings; and

 World Health Organisation Environmental Noise Guidelines (ENG) for the European Region: 2018.

Baseline Data Collection

12.2.23 The baseline noise and vibration environment will be established by a combination of noise and vibration monitoring. The baseline noise monitoring data collection has been undertaken over a 7-day period for the following locations, and illustrated on Figure 12.1:

 L1 West of the Site: Long term road traffic noise monitoring to determine road traffic noise levels, in accordance with CRTN, for baseline noise modelling. This monitoring location was utilised to for capture any industrial noise from the Amazon distribution centre;

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 L2: South-East of the Site: Long term road traffic noise monitoring to determine existing road traffic noise levels, in accordance with CRTN, for baseline noise modelling;

 L3 Centre of the site - Long term noise monitoring to determine ambient noise levels associated with the 400kV substation to be retained;

 L4 North-East area of Site: Long term noise monitoring to determine the existing noise levels associated with the West Coast main line; and

 L5: North area of Site: Long term noise and vibration monitoring to determine ambient noise levels and any vibration associated with the West Coast main line and the local Rugeley Trent Valley to Lea Hall line.

Figure 12.1: Monitoring Locations

12.2.24 The fully baseline noise monitoring was undertaken, following the BS 7445-1, ISO 1996-1:2016 Description, measurement and assessment of environmental noise - Part 1: Basic quantities and assessment procedures. All noise monitoring will be completed using Class 1 Sound Level Meters (SLMs), housed in environmental protection apparatus and having been laboratory calibrated within 24 months of use. Each of the SLMs were also field calibrated before and after the monitoring programme using a Class 1 Handheld Sound Level Calibrator.

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12.2.25 It is not expected that there will be significant baseline vibration levels due to distance between the site boundary to railway lines. However, monitoring has been undertaken on the boundary of the site at Monitoring location M5, to confirm this.

Proposed Assessment Methodology

12.2.26 The assessment will consider the following potential effects:

 A qualitative assessment for noise and vibration arising from works and activities associated with the construction phase;

 Quantitative assessment of noise arising as a result of an increase in traffic flow on the local road network and from any fixed plant items associated with the proposed development;

 Quantitative assessment of noise from existing and proposed stationary plant sources affecting future occupants of the Proposed Development and existing nearby residential receptors;

 The suitability of a proposed land use at the location proposed; and

 Consideration of any committed developments within the area.

12.2.27 To assess the impacts during the construction phase a qualitative assessment will be undertaken based upon the guidance contained within British Standard 5228-1:2009+A1:2014 ‘Noise and vibration control on construction and open sites – Part 1: Noise’ and BS 5228- 2:2009+A1:2014 ‘Noise and vibration control on construction and open sites – Part 2: Vibration’, and the national Planning Policy on Noise.

12.2.28 To predict the “with development”, noise levels across the site and at existing and future sensitive receivers, a 3D noise model will be created using the CadnaA noise propagations software, in-line with ISO 9613-2:1996 Attenuation of sound during propagation outdoors and ISO 17534-1:2015 - for the calculation of sound outdoors.

12.2.29 The modelling will include a verification process using the baseline monitoring data and baseline traffic data, to provide greater confidence in the modelling predictions. The noise model will utilise the traffic data provided within the Transport Assessment.

12.2.30 A quantitative assessment of the noise impacts as a result of changes in traffic flows on the local highway network will be undertaken, based upon CTRN (DoT, 1988) guidance.

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Selection of Sensitive Receptors

12.2.31 Sensitive receivers are places where a human receptor may be exposed to adverse noise or vibration impacts as a result of the Proposed Development. These impacts could be during the construction and operational phases. The ‘sensitivity’ of the receptor varies depending upon the type of receptor. For this assessment it has been assumed that any residential receptor has a high sensitivity. The exact choice of receptor locations will be defined by the geographical extend of traffic data provided for the operational phase and the level of information available for the phasing of the construction stage of the Proposed Development.

Geographical Scope

12.2.32 The geographical scope of the construction phase of assessment will be determined by the location of any ‘noisy’ construction activities relative to the location of any sensitive receptors and the extent of the local highway network being considered as part of the assessment of transportation effects of any construction vehicles (see Chapter 15). However, the DMRB guidance details that an assessment should be undertaken for receptors up to 600m of the Application Site.

12.2.33 The geographical scope of the operational phase of assessment will be determined by the extent of the local highway network being considered as part of the assessment of transportation effects (see Chapter 15), and the location of any new ‘noisy’ on-site stationary operational plant to any sensitive receptors on or off-site.

Temporal Scope

12.2.34 The assessment will consider the potential effects of the Proposed Development for the full duration of its construction phase, up to the full occupation of the Proposed Development. The assessment will consider all development phasing during this period, and how this programme might affect the potential effects of the Proposed Development throughout the construction and operational phases.

Significance Criteria

12.2.35 Based upon the assessment methodology set out above and the generic EIA significance criteria set out in Table 12.1 the following impact magnitude criteria will be utilised.

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Table 12.1: Impact Magnitude Criteria Potential Impact Source Neg VL L M H VH Construction Phase Construction Noise BS 5228-1 <-10dB <-5dB <0dB <+5dB <+10dB >+10dB Construction BS 5228-2 <0.3 <1.0 <10.0 >10.0 Vibration (mm/s) Construction Traffic Short - CTRN +/-0dB >+/-1dB >+/-3dB >+/-5dB Operational Phase Commercial / BS4142 <-10dB <-5dB <0dB <+5dB <+10dB >+10dB industrial Noise Operational Traffic Long - CTRN +/-0dB >+/-3dB >+/-5dB >+/-10dB

12.2.36 For the land use suitability element of the assessment this will be determined upon achieving acceptable internal noise levels within habitual rooms and external noise levels within amenity areas in line BS 8233:2014.

12.3 BASELINE ENVIRONMENT

12.3.1 The existing baseline noise and vibration levels across the Site have been established. During the site visits to undertake this monitoring the local ambient noise levels were noted to be principally influenced by the local highway network and high-speed trains travelling on the West Coast Main Line, and the local Rugeley Trent Valley to Lea Hall line. Odd bangs and other noises associated with the demolition works were also noted but these did not stand out as significant.

12.3.2 A summary of the noise monitoring results are provided in Table(s) 12.2 to 12.6. The daytime data is based upon 15-minute averages and presented as the range of levels recorded during the period. The night time levels are also provided as a range of monitored levels but based upon a 5-minute averaging period.

Table 12.2: Monitoring Results Location No.1 (dB(A))

Date LAeq LAeq (Range) LAMAX (Range) L90 (Range) Daytime (07:00 – 23:00) 03/12/2018 45.13 38 – 53 49 - 68 32 - 49 04/12/2018 46.64 38 – 54 48 - 71 32 - 46 05/12/2018 44.05 38 – 51 48 - 77 29 - 44 06/12/2018 46.58 39 – 54 48 - 71 33 - 47 07/12/2018 52.87 47 – 55 57 - 72 42 - 51 08/12/2018 47.78 44 – 50 55 - 75 39 - 46 Night-time (23:00 – 07:00) 03/12/2018 46.30 43 – 56 51 - 76 38 - 50

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04/12/2018 49.12 40 – 55 48 - 74 33 - 50 05/12/2018 50.79 44 – 55 52 - 77 39 - 49 06/12/2018 50.59 41 – 54 50 - 75 35 - 49 07/12/2018 53.04 47 – 59 54 - 77 44 - 54 08/12/2018 51.96 48 – 57 54 - 72 43 - 54

Table 12.3: Monitoring Results Location No.2 (dB(A))

Date LAeq LAeq (Range) LAMAX (Range) L90 (Range) Daytime (07:00 – 23:00) 03/12/2018 47.34 36 – 54 46 – 69 30 – 51 04/12/2018 46.81 41 - 52 53 - 72 32 - 47 05/12/2018 54.93 37 – 63 52 – 84 28 – 48 06/12/2018 50.10 41 - 58 52 - 80 31 - 51 07/12/2018 60.44 49 - 74 61 – 93 44 – 53 08/12/2018 67.81 48 - 74 66 - 96 39 - 51 09/12/2018 50.92 39 – 57 50 – 79 30 – 51 10/12/2018 48.82 37 - 60 51 - 82 27 - 44 Night-time (23:00 – 07:00) 03/12/2018 48.74 44 - 57 56 – 82 41 – 52 04/12/2018 51.15 45 – 57 52 - 75 36 - 53 05/12/2018 52.70 47 - 58 57 – 80 41 – 52 06/12/2018 57.44 45 – 71 55 - 96 37 - 57 07/12/2018 54.29 52 - 58 59 – 74 47 – 55 08/12/2018 68.96 57 – 75 73 - 95 48 - 55 09/12/2018 55.24 47 - 64 64 – 89 40 – 53 10/12/2018 52.41 45 – 59 55 - 82 39 - 53 11/12/2018 45.17 48 - 58 60 - 89 44 - 48

Table 12.4: Monitoring Results Location No.3 (dB(A))

Date LAeq LAeq (Range) LAMAX (Range) L90 (Range) Daytime (07:00 – 23:00) 03/12/2018 47.18 45 - 49 48 - 73 44 - 47 04/12/2018 46.52 44 - 50 48 - 73 43 - 46 05/12/2018 48.86 45 - 61 48 - 80 43 - 46 06/12/2018 47.80 44 - 51 51 - 75 43 - 49 07/12/2018 52.74 48 - 56 54 - 75 46 - 52 08/12/2018 48.62 47 – 50 49 - 65 45 - 48 09/12/2018 46.46 45 - 49 47 - 73 44 - 48 Night-time (23:00 – 07:00) 03/12/2018 47.91 46 - 62 52 - 82 44 - 47 04/12/2018 51.48 44 - 61 53 - 93 42 - 49 05/12/2018 50.66 46 - 57 54 - 81 44 - 49 06/12/2018 56.49 45 - 66 52 - 103 43 - 52

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07/12/2018 54.85 48 - 67 55 - 105 47 - 52 08/12/2018 50.56 48 - 55 55 - 74 46 - 52 09/12/2018 49.15 47 - 54 53 - 72 45 - 49

Table 12.5: Monitoring Results Location No.4 (dB(A))

Date LAeq LAeq (Range) LAMAX (Range) L90 (Range) Daytime (07:00 – 23:00) 03/12/2018 45.56 39 - 53 46 - 77 37 - 45 04/12/2018 44.78 35 - 54 48 - 81 32 - 40 05/12/2018 41.29 32 - 46 46 - 65 28 - 41 06/12/2018 43.44 37 - 47 43 - 66 32 - 44 07/12/2018 52.47 45 - 57 53 - 70 41 - 50 08/12/2018 45.85 37 - 50 43 - 71 35 - 46 Night-time (23:00 – 07:00) 03/12/2018 46.09 43 - 54 55 - 85 40 - 44 04/12/2018 48.91 37 - 55 52 - 79 34 - 48 05/12/2018 49.30 42 - 58 53 - 80 37 - 46 06/12/2018 51.08 39 - 66 49 - 91 34 - 47 07/12/2018 50.55 43 - 63 51 - 101 41 - 49 08/12/2018 47.75 44 - 54 51 - 72 41 - 49

Table 12.6: Monitoring Results Location No.5 (dB(A))

Date LAeq LAeq (Range) LAMAX (Range) L90 (Range) Daytime (07:00 – 23:00) 03/12/2018 47.87 40 - 54 50 - 71 38 - 50 04/12/2018 44.86 37 - 50 44 - 68 35 - 41 05/12/2018 44.89 38 - 48 45 - 65 36 - 45 06/12/2018 54.94 44 - 59 51 - 84 36 - 56 07/12/2018 60.56 53 - 64 60 - 78 48 - 59 Night-time (23:00 – 07:00) 03/12/2018 49.01 45 - 57 56 - 75 42 - 52 04/12/2018 52.73 41 - 60 53 - 83 37 - 54 05/12/2018 52.05 46 - 56 59 - 82 41 - 51 06/12/2018 54.60 45 - 60 58 - 95 38 - 54 07/12/2018 59.21 48 - 65 59 - 84 46 - 61

12.3.3 From the baseline monitoring data it can be seen that with the acceptation of a few individual periods the existing baseline noise levels are under the BS:8233 criterial for external amenity noise level of 55dB.

12.4 POTENTIAL ENVIRONMENTAL IMPACTS & EFFECTS

Construction Impacts and Effects

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12.4.1 The Proposed Development will involve a lengthy intensive construction programme over many years. The following likely significant effects associated with construction that will be considered further within the ES:

 Noise and vibration from fixed and mobile plant on-site during the Site preparation and construction activities. This has the potential to impact both existing and future occupiers of the Proposed Development, depending upon the phasing;

 Noise generated by construction traffic, on the existing local highway. This has the potential to impact both existing and future occupiers of the Proposed Development, depending upon the phasing;

Occupation Impacts and Effects

12.4.2 The Proposed Development will include a number of potential adverse impacts and effects upon both existing, sensitive receptors and future occupants of the Proposed Development. The following likely significant effects for the operational phase will therefore be considered further in the ES:

 Noise generated by the operational traffic, on the existing local highway. This has the potential to impact both existing and future occupiers of the Proposed Development, depending upon the phasing;

 Noise generated by any new operational fixed plant at any proposed commercial / industrial units upon existing and future occupiers of the Proposed Development; and

 The potential adverse impacts and effects of the suitability of the Site for any noise and vibration sensitive land uses.

12.5 MITIGATION ENVISAGED

Construction Phase

12.5.1 At this stage it is anticipated that through the development of a detailed Construction Environmental Management Plan (CEMP), that the impacts associated with the construction phase will be of a temporary nature and not significant. It is anticipated that the CEMP will include predictions of the likely noise and vibration impacts and a range of Best Practice methods to minimise and reduce these impacts. Examples of mitigation include:

 Construction activities should be confined to times of the day when they are least likely to be disturbing;

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 Careful selection of plant, construction methods and programming. Only plant conforming with relevant national or international standards, directives and recommendations on noise and vibration emissions should be used;

 Personnel should be instructed on best practice to reduce noise and vibration as part of their induction training and as required prior to specific work activities;

 The erection of site boundary hoardings (where required);

 The monitoring of noise and vibration at the nearest residential dwellings and a complaints procedure for local residential receptors;

 Undertaking ‘noisy’ activities over short periods to avoid adversely impacting local residents for long periods of time;

 The development of a Construction Logistics Plan to aid in routing construction vehicles away from quiet residential areas; and

 Given the potential phasing of construction, certain areas of the Proposed Development will be occupied while construction is still underway in adjacent areas. Where possible, the occupancy of completed phases of construction, including any potentially sensitive land uses, should be planned in such a way that there is a buffer between occupied areas and areas where construction is being carried out.

Operational Phase

12.5.2 Based upon professional experience it is anticipated that through careful and sustainable layout designs acceptable noises levels can be achieved both internally and externally. Examples of mitigation include:

 Through the deriving of noise limits, based upon the prevailing background noise environment and the criteria set out in BS 4142:2014) any new stationary plant would be mitigated to ensure the stationary does not adversely impact existing and future occupants of the Proposed Development;

 As the design changes during the outline planning and reserved matters applications, through following the mitigation principals set out in WHO guidance and BS 8233:2014 it is anticipated compliance can be achieved. Examples of mitigation include:

o Placing amenity away from noise sources (i.e. road traffic noise) where possible; and

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o Design facades and any ventilation systems so they achieve suitable internal noise levels within habitual rooms and avoid the potential of internal overheating.

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CHAPTER 13: GROUND CONDITIONS

13.1 INTRODUCTION

13.1.1 This chapter of the ES Scoping Report has been produced by AECOM.

13.1.2 The ground conditions topic assesses the potential impact from land contamination both to the Proposed Development and also to surrounding receptors. Where potential significant effects are identified likely mitigation has been suggested. The topic also considers the superficial (drift) and bedrock geology and the potential presence of geological Sites of Special Scientific Interest (SSSI), Local Geological Sites (LGS) and agricultural land that may be impacted upon by the Proposed Development.

13.1.3 General and topic-specific guidance presented within Volume 11 of the Design Manual for Roads and Bridges1 have been used in preparation of this Chapter.

13.1.4 The ground conditions topic is proposed to be scoped in to the EIA. Any aspects of the topic that are considered to be scoped out are discussed later in this chapter.

13.2 ASSESSMENT CRITERIA & METHODOLOGY

Previous Assessment

13.2.1 There is a volume of historical ground investigation information including a Phase I Environmental Assessment (Desk Study) from December 2016 and subsequent Phase II environmental ground investigations undertaken by Ramboll Environ reported in 2017.

Legislative Context

13.2.2 The following key legislation (UK Acts/Regulations) is of direct relevance to the assessment of effects of the Proposed Development on ground conditions.

1 Highways Agency (August 2008), DMRB Volume 11, Section 2, Part 4 Scoping of Environmental Impact Assessments; Highways Agency (June 1993), Design Manual for Roads and Bridges (DMRB) Volume 11, Section 3, Part 11 Geology and Soils; Highways Agency (June 1993), Design Manual for Roads and Bridges (DMRB) Volume 11, Section 3, Part 6 Land Use (incorporating Amendment No 1 dated August 2001).

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The Environmental Protection Act 1990 and Part 2A (the Contaminated Land Regime)2

13.2.3 Current legislation relating to contaminated land in the UK is contained within Part 2A of The Environmental Protection Act (EPA), which was inserted by s57 of the Environment Act 1995 and by s86 of the Water Act 2003, and elaborated upon within the Contaminated Land (England) Regulations 2006 [S.I. 2006/1380] (amended 2012 [S.I. 2012/263]). Under Part 2A, sites are identified as 'contaminated land' if they are: causing harm, if there is a significant possibility of significant harm, or if the site is causing, or could cause, pollution of controlled waters (i.e. both surface and groundwater).

The Water Act 20033

13.2.4 The Water Act 2003 introduced a revision to the wording of the EPA, which requires that if a site is causing or could cause significant pollution of controlled waters, it may be determined as contaminated land. Once a site is determined to be contaminated land then remediation is required to render significant pollutant linkages insignificant (i.e. the source-pathway-receptor relationships that are associated with significant harm to human health and/or significant pollution of controlled waters), subject to a test of reasonableness.

The Water Resources Act 19914

13.2.5 The Water Resources Act 1991 provides statutory protection for controlled waters (i.e. streams, rivers, canals, marine environment and groundwater) and makes it an offence to discharge to controlled waters without the permission or consent of the regulators of these areas.

The Building Act 1984 and the Building Regulations & c (Amendment) Regulations 20165

13.2.6 The Building Act 1984 and in particular the associated Building Regulations & c (Amendment) Regulations 2016 are key when considering structural and design aspects of a development in terms of the geotechnical properties of the ground. The Building Act 1984 requires that

2 Her Majesty's Stationery Office (HMSO) (1990), Part 2A of the Environment Protection Act 1990 Contaminated Land Statutory Guidance (April, 2012).

3 HMSO (2003), The Water Act 2003.

4 HMSO (2009), The Water Resources Act 1991.

5 HMSO (1984), The Building Act 1984; HMSO (2016), The Building Regulations & c (Amendment) Regulations 2016

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buildings are constructed so that ground movement caused by swelling, shrinkage, freezing, landslip or subsidence of the sub-soils will not impair the stability of any part of the building. Notably, the Building Regulations & c (Amendment) Regulations 2016 also control ground gas mitigation which is a particularly pertinent consideration when considering land contamination.

Other relevant legislation

13.2.7 Other legislation (EU Directives, followed by UK Acts then Regulations) of reference to this topic, and not already outlined above, includes:

a) The Water Framework Directive (2000/60/EC)6;

b) The Groundwater Directive (2006/118/EC)7;

c) The Environmental Quality Standards (EQS) Directive (2008/105/EC)8;

d) The Environmental Liability Directive (2004/35/EC)9;

e) The Environment Act 199510;

f) The Town and Country Planning Act 199011;

g) Environmental Permitting (England and Wales) Regulations 201612;

h) Hazardous Waste (England and Wales) (Amendment) Regulations 201613;

i) Contaminated Land (England) (Amendment) Regulations 201214;

6 EU (2000), The Water Framework Directive (2000/60/EC).

7 EU (2006), The Groundwater Directive (2006/118/EC).

8 EU (2008), The Environmental Quality Standards (EQS) Directive (2008/105/EC).

9 EU (2004), The Environmental Liability Directive (2004/35/EC);

10 HMSO (1995), The Environment Act 1995;

11 HMSO (1990), Town and Country Planning Act 1990

12 HMSO (2016), The Environmental Permitting (England and Wales) Regulations 2016.

13 HMSO (2016), The Hazardous Waste (England and Wales) (Amendment) Regulations 2016.

14 HMSO (2012), Contaminated Land (England) (Amendment) Regulations, 2012.

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j) Environmental Damage (Prevention and Remediation) Regulations 200915; and

k) Anti-Pollution Works Regulations 199916.

Planning Policy and Guidance

13.2.8 The following planning policy and guidance documents are of direct relevance to the assessment of effects of the Proposed Development on ground conditions.

National Planning Policy

13.2.9 National planning policy is established within the recently revised National Planning Policy Framework (NPPF)17. Relevant policy references/summaries are presented in Table 13.1.

Table 13.1: Revised National Planning Policy Framework (Department for Communities and Local Government (DCLG), 2018)

Policy Reference Summary Paragraph 117 Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously-developed or 'brownfield' land. Paragraph 118 c) Planning policies and decisions should give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs, and support appropriate opportunities to remediate despoiled, degraded, derelict, contaminated or unstable land. Paragraph 170 a) Planning policies and decisions should contribute to and enhance the natural and local environment by: …. protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan). Paragraph 170 b) Recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland. Paragraph 170 e) Preventing new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by, unacceptable levels of soil, air, water or noise pollution or land instability. Development should, wherever possible, help improve local environmental conditions such as air and water quality, taking into account relevant information such as river basin management plans.

15 HMSO (2009), Environmental Damage (Prevention and Remediation) Regulations 2009.

16 HMSO (1999), Anti-Pollution Works Regulations 1999.

17 Department for Communities and Local Government (2018), National Planning Policy Framework.

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Policy Reference Summary Paragraph 170 f) …by:…remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate. Paragraph 171 Plans should: distinguish between the hierarchy of international, national and locally designated sites; allocate land with the least environmental or amenity value, where consistent with other policies in this Framework…... Paragraph 178 a) Planning policies and decisions should ensure that: …a site is suitable for its proposed use taking account of ground conditions and any risks arising from land instability and contamination. This includes risks arising from natural hazards or former activities such as mining, and any proposals for mitigation including land remediation (as well as potential impacts on the natural environment arising from that remediation) Paragraph 178 b) Planning policies and decisions should also ensure that:… after remediation, as a minimum, land should not be capable of being determined as contaminated land under Part IIA of the Environmental Protection Act 1990 Paragraph 178 c) Planning policies and decisions should also ensure that:… adequate site investigation information, prepared by a competent person, is presented. Paragraph 179 Where a site is affected by contamination or land stability issues, responsibility for securing a safe development rests with the developer and/or landowner. Paragraph 180 Planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment, as well as the potential sensitivity of the site or the wider area to impacts that could arise from the development. Paragraph 183 The focus of planning policies and decisions should be on whether proposed development is an acceptable use of land, rather than the control of processes or emissions (where these are subject to separate pollution control regimes). Planning decisions should assume that these regimes will operate effectively. Equally, where a planning decision has been made on a particular development, the planning issues should not be revisited through the permitting regimes operated by pollution control authorities.

13.2.10 The NPPF Planning Practice Guidance sections on “land affected by contamination” and “land instability” have also been taken into account and provide further detail regarding the approach to assessing and managing land contamination and instability.

13.2.11 Other relevant policy/guidance includes the Department of the Environment, Transport and the Regions guidance ‘Soil Strategy for England’18. This sets out national objectives for the sustainable management of soil. The four key objectives detailed in that strategy, which will be taken into account in this assessment are:

18 Department of the Environment, Transport and the Regions (2009), Soil Strategy for England, 2009.

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a) agricultural soils will be better managed and threats to them will be addressed;

b) soils will play a greater role in the fight against climate change and in helping us manage our impacts;

c) soils in urban areas will be valued during development and construction practices will ensure vital soil functions can be maintained; and

d) pollution of our soils is prevented, and our historic legacy of contaminated land is being dealt with.

Local Planning Policy

Current Planning Policy

13.2.12 The Cannock Chase Local Plan (Part 1) 2014 is the statutory development plan for Cannock Chase District Council (CCDC); it forms the principal basis for which development is promoted and controlled. The plan was adopted on Wednesday 11th June 2014. The Cannock and Rugeley Town Centre Area Action Plans provide further policy context in relation to the largest town centres in the District. The Hednesford Neighbourhood Plan also forms part of the development plan and was adopted on 28th November 2018. Initial work on Local Plan (Part 2) included consideration of possible Site Allocations and Planning Standards; this work will now be carried forward as part of the Local Plan Review. Policy CP12 ‘Biodiversity and Geodiversity’ and Policy CP16 ‘Climate Change and Sustainable Resource Use’ are considered of particular relevance to the ground conditions topic.

13.2.13 For Lichfield District Council (LDC), the local plan is made up of a number of documents. The adopted local plan strategy and the local plan allocations will replace the 1998 Lichfield District local plan; it is supported by a number of supplementary planning documents. Local communities may also progress their own neighbourhood plans. The Lichfield District Council local plan strategy 2008-2029 was adopted by full council on 17th February 2015 and forms the first part of the new local plan for Lichfield District. The local plan strategy replaces the saved policies of the 1998 Lichfield District local plan (as outlined in Appendix J of the local plan strategy). The local plan allocations document forms the second part of the local plan for Lichfield District. The local plan allocations document is on-going and will be progressed to consider various issues and add further detail to the strategic policy within the adopted plan. Core Policy 2 ‘Presumption in Favour of Sustainable Development’, Core Policy 3 ‘Delivering Sustainable Development’ and Core Policy 13 ‘Our Natural Resources’ are considered of particular relevance to the ground conditions topic.

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Emerging Planning Policy

13.2.14 Due to changes to the national planning system (including the requirement for councils to review their plans every five years to see which policies may need updating), some parts of Cannock Chase Local Plan (Part 1) 2014 will soon be out of date. The production of a new Local Plan is being started which will utilise the work to be carried out to date on Local Plan Parts 1 and 2 and incorporate any areas which need reviewing/updating. Until it is replaced, the adopted Local Plan Part 1 will still continue to set planning policy for the District.

13.2.15 LDC are reviewing their local plan and once adopted it will replace the current local plan strategy (adopted in 2015) and the local plan allocations document (on-going, expected to be adopted in 2018). Until the time the new local plan is adopted LDC will continue to use the existing local plan when making planning decisions.

Guidance/Best Practice

13.2.16 The following includes a non-exhaustive list of additional guidance considered pertinent and applicable to the ground conditions topic:

a) Contaminated Land Report (CLR11) Model Procedures for the Management of Land Contamination, 200419;

b) CIRIA C665, Assessing risks posed by hazardous ground gases to buildings, 200720;

c) BS 10175 (2011 +A2 2017), Investigation of Potentially Contaminated Sites - Code of Practice21;

d) BS 8576 (2013), Guidance on investigations for ground gas. Permanent gases and Volatile Organic Compounds (VOCs)22;

19 Environment Agency (EA) (2004), Contaminated Land Report (CLR11) Model Procedures for the Management of Land Contamination, 2004

20 CIRIA C665 (2007), Assessing risks posed by hazardous ground gases to buildings, 2007.

21 British Standard BS 10175 (2011 +A1 2013), Investigation of Potentially Contaminated Sites - Code of Practice.

22 British Standard BS 8576 (2013), Guidance on investigations for ground gas. Permanent gases and Volatile Organic Compounds (VOCs).

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e) BS 8485 (2015), Code of practice for the design of protective measures for methane and carbon dioxide ground gases for new buildings23; and

f) Guidance for the Safe Development of Housing on Land Affected by Contamination, R&D Publication 6624.

Baseline Data Collection

13.2.17 Establishment of the baseline environment will involve reference to existing data sources, consultation with statutory bodies and other organisations, and fieldwork surveys.

13.2.18 Information will be obtained from the following sources:

a) British Geological Survey (BGS);

b) Department for Environment, Food and Rural Affairs (DEFRA);

c) Environment Agency (EA);

d) Landmark ‘Envirocheck’ Report or similar;

e) Natural England;

f) Cannock Chase District Council;

g) Lichfield District Council;

h) Local Geological Groups; and

i) Historical site investigation information pertinent to the ground conditions topic including any relevant information recorded from the previous site walkover (undertaken by AECOM on 26th and 27th September 2018).

23 British Standard BS 8485 (2015), Code of practice for the design of protective measures for methane and carbon dioxide ground gases for new buildings.

24 National House Building Council (NHBC), Environment Agency (EA) and Chartered Institute of Environmental Health (CIEH) (2008), Guidance for the Safe Development of Housing on Land Affected by Contamination, R&D Publication 66.

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13.2.19 A Landmark Envirocheck Report (or similar) will be obtained for the Site to provide environmental data covering potential sources of contamination, previous industrial land use and sensitive land uses.

13.2.20 Historical factual and interpretative geotechnical and geo-environmental reports relating to site investigations will be reviewed and reported as applicable in the assessment.

13.2.21 A Remediation and Reclamation Strategy is currently being developed by AECOM and will separately discuss the pertinent previous investigation/assessment undertaken for the Site, whilst an additional intrusive ground investigation scope is also being developed in support of this. The intrusive ground investigation is due to be undertaken in early 2019 and will be used to further detail prevailing ground conditions and to inform any assessments made in relation to the potential constraints associated with the ground conditions topic. The Remediation and Reclamation Strategy is a working document and will be informed by the assessment and conclusions of the proposed EIA and would be implemented prior to the commencement of the Proposed Development.

Proposed Assessment Methodology

General

13.2.22 The ground conditions topic will be assessed using published information, existing information from historical investigation/assessments and available data from any additional ground investigations due to be undertaken during the impact assessment period. This section outlines the proposed assessment methodology.

Land Contamination

13.2.23 Areas of potential contamination will be identified within the study area (defined later under the heading ‘Geographical Scope’ in Paragraph 13.2.30) related to the Proposed Development. In line with the EA Contaminated Land Report CLR11, the assessment of land contamination will take the form of a tiered, risk-based approach, as summarised below:

a) Tier 1: qualitative risk assessment based on a desk top study of available information to identify potential sources of contamination, receptors to contamination and potential pathways between them. The identified sources, pathways and receptors are presented in the form of a Conceptual Site Model (CSM) showing the potential contaminant linkages (PCL);

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b) Tier 2: If PCLs are identified, this means there is a theoretical risk to receptors from contamination and intrusive investigation should be used to provide data to inform a generic quantitative risk assessment (GQRA). The GQRA involves comparison of site-specific, laboratory analytical data against appropriate generic assessment criteria (GAC) for human health and/or controlled waters which represent minimal or tolerable risk; and

c) Tier 3: detailed quantitative risk assessment to identify whether contamination identified above minimal or tolerable risk levels represents an unacceptable risk and therefore requires remediation.

Screening assessment

13.2.24 A qualitative assessment of the risks posed by land contamination within the ground conditions study area will be undertaken by first assigning a ‘site rating’ to each identified historical or current area of potential land contamination identified in the baseline review. The site rating is based partly on the relationship between the identified area of potential land contamination and its proximity to the Site together with the extent of any proposed cut/fill earthworks to be undertaken to facilitate the Proposed Development. The site rating also considers the nature of the current and/or historical land use, as certain land uses typically result in a greater potential for contamination of the ground to have occurred. The lower the site rating then the lower the risk. Professional judgement will be applied in reviewing the generated site ratings. Generally, site ratings of two or less are considered not to pose a significant risk and will not be considered for further assessment. Site ratings of three or more will be considered further. The next step for screening is a review of sensitive receptors and their proximity to the potential contaminated site; a combination of this review and the site rating defines whether a site advances to the detailed assessment stage for further risk and impact assessment as described below.

Risk and impact assessment

13.2.25 The approach to assessing the potential impacts of the Proposed Development will be undertaken by comparing the risk levels at baseline with the CSM and the risk levels for the construction and post-construction stages respectively, to determine any change in risk at each stage.

13.2.26 Potential risks are determined and assessed based on the likelihood (or probability) and consequence using the principles given in the NHBC, EA and CIEH report R&D66. This provides guidance on development and application of the consequence and probability matrix

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to risk assessment and broad definitions of consequence. The risk matrix is presented in Table 13.2.

Table 13.2: Estimation level of risk

Consequence Probability Severe Medium Mild Minor High Very high risk High risk Moderate risk Low risk likelihood

Likely High risk Moderate risk Moderate/low risk Low risk

Low Moderate risk Moderate/low risk Low risk Very low risk likelihood

Unlikely Moderate/low risk Low risk Very low risk Very low risk

13.2.27 The significance of the effects of land contamination will be assessed by comparing the difference in risk for each contaminant linkage at baseline to those at construction and at post construction stages. Where there is shown to be a decrease in contamination risk the Proposed Development is assessed as having a beneficial effect on the environment in the long term.

13.2.28 The definitions of the significance criteria to be used are presented in Table 13.3. This provides details of how increases and decreases in the contamination risks identified are related to the significance criteria adopted. Potential effects that are determined as being moderate or major are classed as ‘significant’ effects. Where an effect is anticipated to be neutral or minor, these effects are classed as ‘not significant’.

Table 13.3: Significance criteria

Significance Criteria Definition Major adverse effect An increase in contamination risk of 4 or 5 risk levels in the risk matrix, e.g. from land that has a very low contamination risk in the baseline becomes a high or very high risk Moderate adverse effect An increase in contamination risk of 2 or 3 risk levels in the risk matrix, e.g. land that has a low contamination risk in the baseline becomes a moderate or high risk Minor adverse effect An increase in contamination risk of 1 risk level in the risk matrix, e.g. land that has a low contamination risk in the baseline becomes a moderate/low risk Neutral effect No change in contaminated land risks Minor beneficial effect A reduction in contamination risk of 1 risk level in the risk matrix, e.g. land that has a moderate/low contamination risk in the baseline becomes a low risk

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Significance Criteria Definition Moderate beneficial effect A reduction in contamination risk of 2 or 3 risk levels in the risk matrix, e.g. land that has a high contamination risk in the baseline becomes a moderate/low or low risk Major beneficial effect A reduction in contamination risk of 4 or 5 risk levels in the risk matrix, e.g. land that has a very high contamination risk in the baseline becomes a low or very low risk

Land Stability

13.2.29 As set out above, a Remediation and Reclamation Strategy is being prepared and will be implemented prior to the commencement of the Proposed Development. Whilst some reference to land stability may be included within the baseline of the EIA, the Remediation and Reclamation Strategy will identify and mitigate any land stability issues associated with the Proposed Development.

Geographical Scope

13.2.30 The study area for the ground conditions assessment will comprise the Site and an additional radial zone of 250 metres (m). A radial zone of 1 kilometre (km) will be considered for groundwater and potable water abstraction within the context of identifying potential receptors to any soil and/or groundwater contamination. This is considered appropriate for the consideration of historical and current potentially contaminative land uses which may have resulted in contamination within the study area.

Temporal Scope

13.2.31 The temporal scope will cover the construction and occupation phases of the Proposed Development.

Stakeholder Engagement

13.2.32 Initial contact has been made with CCDC, LDC and the EA and a date agreed (14th January 2019) to meet at LDC’s offices. The meeting will be used to discuss the proposed methodology and also provide the stakeholders with the opportunity to provide any local knowledge that may be applicable to the areas under assessment.

13.2.33 The meeting will also be used as a forum to discuss related but separate issues including the Remediation and Reclamation Strategy, the proposed ground investigation scope and drainage/water strategies for the Site.

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13.3 BASELINE ENVIRONMENT

Ground Conditions

Published Geology

13.3.1 The published 1:50,000 scale geological map (Sheet 140, “Burton upon Trent”, 1982) and the online Geology of Britain Viewer (BGS) indicate the Site is underlain by the following geological succession:

a) Alluvium – clays, silt sand and gravel deposits located along the northern boundary of the Site with a tract of alluvium extending across the northern corner of the Site and adjoining buildings to the east.

b) River Terrace Deposits – stratified sand and gravel deposits with thin clay seams and gravels across the entirety of the Site except the northern corner of the Site which is occupied by the coal store fields and adjoining buildings.

c) The Bromsgrove Sandstone Formation underlies the river terrace and alluvial deposits. The Sandstone overlies the Cannock Chase Sandstone Formation both belonging to the Triassic Sherwood Sandstone Group. The upper sequence of the Bromsgrove Sandstone Formation is typically thinly interbedded, pink and red, commonly micaceous, sandstone and red and green mudstone while the basal section is described as fine to coarse grained sandstone with occasional mudstone and conglomerate layers. The Cannock Chase Formation is generally described as coarse grained, current-bedded, red-brown sandstone with conglomerate lenses and layers. Thinly bedded, dark red, fine-grained, micaceous sandstone also occur in the sequence with frequent, irregular, erosional upper surfaces. The conglomerate horizons are abundant in the Cannock Chase area where they readily weather to masses of loose, well rounded gravels of quartzite, Carboniferous Limestone, chert and igneous rocks.

Coal Mining

13.3.2 The Site is not considered a high risk for development in relation to coal mining. A legacy of coal mining does exist to the south off-site approximately 300 m to 400 m away, as part of the former Lea Hall Colliery with deep shafts encountering coal seams at depths of 179 m to 194 m. Deep boreholes carried out on site encountered the coal measures beneath the Triassic strata at depths greater than 200 m. It is understood that the inception of the Rugeley Plant would have been related to the founding of the colliery and as such, shallow coal workings

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and shafts are unlikely to be present within the footprint of the Site. Thus, it is unlikely that the material above the coal would have been substantially worked to create a risk from shallow mining. Deep mining of coal has taken place beneath the footprint of the Site during operation of the Lea Hall Colliery. It is understood that settlement, following deep coal mining, has taken place in the eastern area of the Site.

Historical Ground Investigation

General

13.3.3 The historical ground investigation undertaken at the Site may be split into three defined areas as shown on Figure 13.1: Former Coal Storage Area (Northern Area); Cooling Towers and Ancillary Infrastructure (Central Area); Former Golf Course (i.e. in the central part of the Site), PFA Lagoons and Borrow Pit Lake (Southern Area). A summary is provided below.

Geology and Groundwater

13.3.4 In the Northern Area, the stratigraphy typically comprised Made Ground (up to 13 m in thickness) over River Terrace Deposits (ranging in thickness from 0.10 m to 13.5 m) and underlain by Bedrock (Bromsgrove Sandstone Formation) encountered at depths ranging from 5.6 m below ground level (bgl) to 14.8 m bgl. During drilling, groundwater strikes were encountered in the Northern Area from 1.20 m bgl to 4.60 m bgl. Groundwater monitoring levels varied from 65.28 m Above Ordnance Datum (AOD) to 66.61 m AOD during the period 5th November 2012 to 29th November 2012.

13.3.5 In the Central Area, the stratigraphy typically comprised Made Ground (up to 3.65 m in thickness) over River Terrace Deposits (ranging in thickness from 1.0 m to 14.8 m) and underlain by Bedrock (Bromsgrove Sandstone Formation) encountered at depths ranging from 3.35 m bgl to 15.1 m bgl. During drilling, groundwater strikes were encountered in the Central Area from 0.35 m bgl to 4.60 m bgl. Groundwater monitoring levels varied from 65.28 m AOD to 66.32 m AOD the period 5th November 2012 to 29th November 2012.

13.3.6 In the Southern Area, the stratigraphy typically comprised Made Ground (up to 10.5 m in thickness) over River Terrace Deposits (ranging in thickness from 0.4 m to 13.55 m) and underlain by Bedrock (Bromsgrove Sandstone Formation) encountered at depths ranging from 4.0 m bgl to 16.05 m bgl. During drilling, groundwater strikes were encountered in the Southern Area from 0.70 m bgl to 10.0 m bgl. Groundwater monitoring levels varied from 63.23 m AOD to 65.41 m AOD during the period May 2006 to October 2006.

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13.3.7 General trends from the groundwater data show a pattern of flow from South West to North East, towards the River Trent, across the Site. Central areas of the Site conform to this pattern. Western parts of this area have a maximum groundwater level of 66.216 m AOD and the lowest level of 63.638 m AOD is found in the East. The values from this area give an approximate groundwater level gradient of -25mm/m from South West to North East. Results from the Coal Stores show a possible similar trend to this, however there is insufficient data to validate this observation.

13.3.8 The PFA Lagoons appear to show no trend in direction or gradient of groundwater flow. The area has greater range of groundwater levels when compared to the rest of the Site, ranging from 70.290 m AOD to 61.257 m AOD and there are no clear spatial trends. However, it is noted that groundwater strikes are predominantly found along the interface between Made Ground and River Terrace Deposits suggesting that the Made Ground determines the groundwater flow of this area.

Identified Soil Contamination

13.3.9 A human health risk assessment has been carried out using the chemical test results undertaken on the soil samples from the Site during the Ramboll 2016 and 2017 ground investigations. A total of 87 samples (62 samples from Made Ground and 25 from the natural superficial deposits) were tested for a variable range of substances including metals and inorganics, polycyclic aromatic hydrocarbons (PAH), total petroleum hydrocarbons (TPH), polychlorinated biphenyls (PCBs), volatile organic compounds (VOCs) and semi-volatile organic compounds (SVOCs). The chemical test results were compared with generic assessment criteria (GAC) for residential (with plant uptake) end-use.

13.3.10 Contaminants with elevated concentrations, when compared with their corresponding GACs, were detected in Made Ground across the Site, predominantly in northern and central areas of the Site. Limited analyses were conducted on samples from the Lagoon area.

13.3.11 Three of the twenty-five samples from the superficial deposits analysed exhibited elevated concentrations of some contaminants in comparison to the corresponding GACs. These samples are from WS10 (benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, beryllium, lead) located in the GT4 and A.B.F oil tank area in the north of the Site; WS04 (beryllium and lead) located in the diesel tanks area in the northwest of the Site; and WS19 (TPH) in the central area of the Site.

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13.3.12 A total of forty-seven soil samples from the Site were sent for asbestos identification analyses. Loose fibres of chrysotile were detected in WS610, BH512, WS13a and TP02, while loose amosite fibres were detected in WS601, BH306 and TP03.

13.3.13 Asbestos has been identified in an area of the Site (confidential due to the presence of protected species) at the surface due to disturbance of buried materials by animals (See Chapter 10 – Ecology).

Land Contamination and Sensitive Sites/Receptors

13.3.14 The Site has been subject to potential sources of contamination historically including a former sewage works and activities associated with the inactive power station. Other off-site current/historical features also represent potentially contaminative sources including railway land and various commercial/industrial land use within the immediate vicinity (250 m) of the Site.

13.3.15 The Site is situated in an area that AECOM considers has moderate controlled waters sensitivity to any potential land contamination. The underlying aquifers are classified as Secondary A (superficial deposits of Alluvium and River Terrace Deposits) and Principal (the solid geology of Bromsgrove Sandstone Formation and Kidderminster Formation). The Bereton Brook is present on site and flows to the River Trent which is located 50 m from the Site, at its closest point. There are groundwater abstractions in the surrounding area, one of which is understood to be potable, although this is approximately 1.8 km from the Site and therefore outside of the study area. There are three Environmental Permits at the Site associated with power generation and disposal of PFA material. There are also sensitive residential receptors within 50 m of the Site.

13.3.16 There are no Sites of Special Scientific Interest (SSSI) within 1 km of the Site, according to information held on Defra’s MAGIC website25, and so these can be scoped out of the assessment.

13.3.17 The extent of any Local Geological Sites (LGS) is currently not fully determined and as such these cannot be scoped out of the assessment. Consultation with local groups will be required.

25 Department for Environment, Food & Rural Affairs (DEFRA) MAGIC website, https://magic.defra.gov.uk/MagicMap.aspx, accessed 14th December 2018.

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13.3.18 The Site does not include land which is in agricultural use and as such impact on agricultural land can be scoped out of the assessment.

13.4 POTENTIAL ENVIRONMENTAL IMPACTS & EFFECTS

Construction Impacts and Effects

13.4.1 In the locations of potentially contaminative land uses, there is the potential for construction to affect human and controlled waters receptors and for the ground conditions to impact on the design of the Proposed Development.

13.4.2 Potential impacts include but are not limited to:

a) mobilising existing contamination in soil and groundwater as a result of ground disturbance and de-watering during construction;

b) increasing the potential for contaminants in unsaturated soils to leach to groundwater in open excavations during construction;

c) increasing the potential for contaminated surface run-off to migrate to surface water and groundwater receptors as a result of leaching from uncovered stockpiles;

d) discharge of water from de-watering to surface watercourses;

e) introducing new sources of contamination, such as fuels and oils used in construction plant;

f) creating preferential pathways for the migration of contamination and gases, for example along new below ground service routes, service ducts and as a result of de- watering; and

g) introducing new human health receptors such as site staff during construction.

Occupation Impacts and Effects

13.4.3 By the occupation phase of the Proposed Development conditions may have altered from the baseline as a result of, but not limited to:

a) introducing site users, site maintenance staff and the site buildings/infrastructure as new receptors; and

b) contamination which has been encountered having been removed or remediated.

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13.4.4 No significant impacts and effects are anticipated during the occupation phase of the Proposed Development. However, there would be potential for environmental risks as associated with spillages due to road accidents or faulty vehicles.

13.5 MITIGATION ENVISAGED

Construction Phase Mitigation Measures

13.5.1 A Remediation and Reclamation Strategy will be designed and implemented to minimise potential soil contamination and land stability issues at the Site before the Proposed Development proceeds.

13.5.2 A Construction Environmental Management Plan (CEMP) would be prepared and implemented by the construction contractor which would include a range of measures associated with mitigating potential impacts as associated with land contamination. Such measures would accord with legal compliance and best practice guidance when working with or around contaminated materials. Potential impacts on off-site receptors would be addressed through the adoption of the following measures:

a) Dampening of ground with water to minimise dust;

b) Sheeting of lorries transporting spoil off site and the use of dust suppression equipment on plant;

c) Groundwater level controls (as required);

d) Adequate fuel/chemical storage facilities e.g. bunded tanks, hard standing and associated emergency response/spillage control procedures;

e) Well maintained plant and associated emergency response/spillage control procedures; and

f) Any temporary onsite storage of contaminated material would be stored on sheeting and covered to minimise the potential for leachate and run off from the stockpile being generated.

13.5.3 The prevention of pollution of controlled waters would be achieved via the mitigation measures as detailed in Chapter 11: Water Environment. Mitigation measures to protect controlled waters would take into account the results of any ground investigation undertaken and would account for any necessary strategy to remediate areas posing risks to controlled waters. The mitigation measures would also aim to ensure that the surface water run-off from

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the construction site (site preparation, earthworks and construction activities) do not have a detrimental effect on any receiving watercourses in the area. Construction involving piling and/or penetrative ground improvement would require a location-specific risk assessment to establish the means of mitigating the risks of causing new pollutant linkages and/or worsening existing ones with respect to risks to controlled waters at the construction stage.

Occupation Phase Mitigation Measures

13.5.4 The Proposed Development occupation phase would not include any activities that are likely to generate contaminants that could pose significant risk to sensitive receptors. However, there would be potential for environmental risks as associated with spillages due to road accidents or faulty vehicles. To mitigate the impacts on controlled waters during the Proposed Development occupation stage, the highway drainage system (refer to Chapter 11: Water Environment) will incorporate appropriate measures to minimise impacts associated with accidents and spillages. In addition, any spillages following road accidents would be routinely managed by Highways England who is responsible for the maintenance of Highways England assets in the West Midlands Region.

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EIA Scoping Report Chapter 14: Landscape and Visual Rugeley B Power Station, Rugeley

CHAPTER 14: LANDSCAPE AND VISUAL

14.1 INTRODUCTION

14.1.1 This chapter of the ES Scoping Report has been produced by Bradley Murphy Design (BMD) and will identify and describe the potential for landscape and visual effects as a result of the Proposed Development. Landscape and visual effects are scoped in to the proposed EIA.

14.1.2 The chapter outlines the methods for the Landscape & Visual Impact Assessment (LVIA), followed by a description of the relevant baseline conditions of the Site and surrounding area. Potential mitigation measures have also been identified that aim to avoid, reduce or offset any adverse effects.

14.2 ASSESSMENT CRITERIA & METHODOLOGY

Previous Assessment

14.2.1 Cannock Chase District Council and Lichfield District Council have produced a joint Supplementary Planning Document (SPD) which aims to assist with the delivery of LDC Local Plan Strategy Core Policy 1, particularly delivery of 10,030 dwellings over the plan period to 2029, alongside CCDC Local Plan Part 1, particularly Core policies 1 (Strategy) and 3 (Design).

14.2.2 The SPD contains, within chapter 2, a Site Analysis that provides background context, identifying existing landscape and community features within the Site. The SPD provides a summary of the key constraints and opportunities for the redevelopment of the Site. Chapter 4 sets out a number of Development Principles that seek to respond to the relevant planning policies, site analysis and principle development opportunities and constraint which aim to guide future planning applications for the redevelopment of Rugeley Power Station.

Legislative Context

14.2.3 The Guidelines for Landscape and Visual Impact Assessment, Third Edition (GLVIA3) states in reference to the European Union Directive 2011/92/EU:

“The Directive is clear that the emphasis is on the identification of likely significant environmental effects. This should embrace all types of effect and includes, for example, those that are positive/ beneficial and negative/ adverse, direct and indirect, and long and short term, as well as cumulative effects. Identifying significant effects stresses the need for an approach that is in proportion to the scale of the project that is being assessed and the nature of its likely effects. Judgement needs to be exercised at all stages in terms of the scale of investigation that is

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appropriate and proportional. This does not mean that effects should be ignored or their importance minimised but that the assessment should be tailored to the particular circumstances in each case.”

14.2.4 The LVIA will include a detailed review of all policy and guidance – of relevance to landscape and visual effects – at a national, regional and local level. Those of greatest relevance to the proposed assessment of landscape and visual effects are set out below.

National Planning Policy

The National Planning Policy Framework (2018);

14.2.5 The National Planning Policy Framework (NPPF) – revised 24 July 2018, sets out the Government’s planning policies for England and provides a framework within which the appropriate local authority can produce local and neighbourhood plans; the NPPF is material consideration in making planning decisions.

14.2.6 The NPPF sets out three overarching objectives in achieving sustainable development, these are interdependent and need to be considered in mutually supportive ways. Economic, social and environmental objectives should be delivered through the preparation and implementation of plans and application of the policies within the NPPF. The NPPF also notes the importance that planning policies and decisions should play active role in guiding development towards sustainable solutions, which should also respond to local circumstances, reflect the local character and the needs and opportunities of each area.

 Chapter 8 Promoting healthy and safe communities

 Chapter 12 Achieving well-designed places

 Chapter 15 Conserving and enhancing the natural environment

Local Planning Policy

Lichfield District Council

Lichfield District Council Local Plan Strategy (2015)

14.2.7 Current strategic planning policy for Lichfield District Council (LDC) is the Local Plan Strategy 2009-2029 and the saved policies of the 1998 Lichfield District Local Plan. The Local Plan Strategy 2008-2029 was adopted by full council on Tuesday 17 February 2015. The Local Plan Strategy is Part 1 of a new Local Plan for Lichfield District, Part 2 - Local Plan Allocations will

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follow. The Local Plan Strategy replaces the saved policies of the 1998 Lichfield District local plan. Policies within the Local Plan Strategy that are relevant to the Landscape and Visual Assessment are: -

 Core Policy 13: Our Natural Resources

 Policy NR4: Trees, Woodland & Hedgerows

 Policy NR5: Natural & Historic Landscapes

 Policy NR7: Cannock Chase Special Area of Conservation

Neighbourhood Development Plans

 Armitage with Handsacre Neighbourhood Plan – 2017-2029,

 Longdon Parish Neighbourhood Plan – 2017-2029, Made 08 October 2018

Cannock Chase District Council

Cannock Chase District Council Local Plan Part 1 (2014)

14.2.8 Local Plan Part 1 is a combination of the former emerging Core Strategy and Rugeley Town Centre Area Action Plan.

14.2.9 Work had begun on Part 2 of the Local Plan, however, this has been replaced by Local Plan review. The production of a new Local Plan is starting which will utilise the work carried out to date on Parts 1 and 2. Until this new Local Plan is adopted the planning policy within Local Plan Part 1 will continue to used.

14.2.10 Policies within the Local Plan Strategy that are relevant to the Landscape and Visual Assessment are: -

 CP13: Cannock Chase Special Area of Conservation (SAC)

 CP 14: Landscape Character and Cannock Chase AONB

 CP 15: Historic Environment

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Emerging Planning Policy

Lichfield District Council

 Lichfield District Council Local Plan Allocations 2008-2029 (Emerging)

Guidance/ Best Practice

Technical Guidance

14.2.11 The LVIA will be in accordance with the principles of good practice set out in the following published guidance produced by the relevant professional organisations concerned with landscape and visual assessment:

 Guidelines for Landscape and Visual Impact Assessment Third Edition (2013) (GLVIA3), published by the Landscape Institute and the Institute of Environmental Management & Assessment;

 GLVIA3 Statement of Clarification 1/13 (2013), published by the Landscape Institute; and

 Landscape Institute Advice Note 01/11, Photography and Photomontage in Landscape and Visual Impact Assessment (2011), published by the Landscape Institute.

Supplementary Planning Documents

14.2.12 Local Plans are supported by a number of Supplementary Planning Documents (SPD). An SPD is a planning policy document that supports policy within an adopted Local Plan. There are two types of SPD: the first being policy supporting a District-wide objective, with the second supporting a policy for a specific site or areas.

Rugeley Power Station SPD – adopted 20 February 2018

14.2.13 This SPD aims to assist with the delivery of LDC Local Plan Strategy Core Policy 1, particularly delivery of 10,030 dwellings over the plan period to 2029, alongside CCDC Local Plan Part 1, particularly Core policies 1 (Strategy) and 3 (Design).

14.2.14 The SPD is set out as a Development Brief to provide guidance to landowners, developers and the local community with regards to layout, form and quality of development on the site. As such, this document will form a material consideration, which will be taken into consideration by

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LDC and CCDC when determining any future planning application for the site to facilitate a high quality, sustainable development appropriate to its locality.

Biodiversity and Development SPD – adopted 17 May 2016

14.2.15 This SPD highlights the requirement for applicants to protect and enhance existing nature conversation features within proposed developments, following best practice guidance and the mitigation hierarchy. On occasions where it is not possible, the SPD details what LDC requires a developer to consider when incorporating ecological compensation (including Biodiversity Offsets) as part of the development.

Tree, Landscape and Development SPD – adopted 17 May 2016

14.2.16 This SPD covers trees, woodlands, hedgerows and other landscape features or habitats where trees and shrubs play an important part - such as orchards, parks and gardens, amenity spaces and green infrastructure. The SPD sets out the retention, protection and incorporation of trees, hedgerows and woodlands as part of a sustainable development, along with the provision of new trees, hedgerows, woodlands and shrub planting as part of the design of a development and its landscaping scheme.

Sustainable Design SPD – adopted December 2015

14.2.17 This SPD seeks to give guidance on how sustainable development can be achieved through connectivity and integration, in terms of how places are sustainably connected by transport linkages and patterns of development. It then considers how the layout and density can assist in creating sustainable development, through green infrastructure, standards for parking and spaces around dwellings, utilising sustainable drainage systems, creating walkable communities and energy efficient layouts.

Staffordshire Residential Design Guide – Staffordshire County Council - adopted December 2015

14.2.18 The design guide provides information and advice to guide the design of new residential developments in Staffordshire to create visually attractive, safe, convenient, secure and economical settlements.

Trent and Mersey Conservation Area Appraisal – DRAFT 2018

14.2.19 An Appraisal of the Trent and Mersey Canal Conservation Area through Cannock Chase District was first carried out in 2012. The document has been updated to reflect subsequent design changes, updates to the planning policy context following national and local policy changes,

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and references reflecting recent development and changes of use in and adjacent to the Conservation Area. The Appraisal is intended as a guide upon which to base the form and style of future development in the area. It is supported by adopted policy in the Cannock Chase Local Plan (Part 1) 2014 CP15 seeking to protect and enhance the historic environment, policies CP12 and CP14 aiming to conserve biodiversity and landscape character and Policy CP3 seeking high standards of design.

Baseline Data Collection

14.2.20 In order to understand the baseline position for landscape and visual receptors, a preliminary desk study was undertaken which identified potentially sensitive / designated landscape resources by reference to national Geographic Information System (GIS) databases, Ordinance Survey (OS) maps and existing published landscape character studies, relevant planning policy guidance and / or designated or protected views.

14.2.21 The desk study has included a review of the following sources of information:

 Natural England NCA Profile 69: Trent Valley Washlands & Profile 67 Cannock Chase and Cank Wood (2014);

 Staffordshire County Council - Planning for Landscape Change: Supplementary Planning Guidance to the Staffordshire and Stoke on Trent Structure Plan 1996 – 2011

 Review of Landscape Character Assessment for Cannock Chase District (Nov 2016)

 Cannock Chase AONB Landscape Character Assessment (2017);

 Ordnance Survey Mapping at 1:25,000 scale;

 Aerial photography of the site and wider area (Google Earth, www.maps.google.co.uk and www.bing.com/maps);

 Multi Agency Geographic Information for the Countryside (MAGIC) interactive mapping (www.magic.gov.uk);

 National Heritage List for England Map Search, English Heritage (http://www.english- heritage.org.uk/);

 National Cycle Network mapping (www.sustrans.org.uk);

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 British Geological Survey, Geology of Britain Viewer (https://www.bgs.ac.uk/).

14.2.22 The LVIA will include a field survey to confirm the features or elements that contribute to the character of the landscape (as described by published documents) and to determine the potential visibility of the proposed development. A series of representative photographs will be taken with a digital camera with a 50mm lens (equivalent focal length) at approximately 1.6m in height, presented as a series of panoramic photographs, included to illustrate landscape character in the area and also as specific viewpoints representative of nearby visual receptors. These will be used to inform the assessment of both landscape and visual impacts. Proposed viewpoint locations are provided in Figure 14.1.

Proposed Assessment Methodology

Scope of Assessment

14.2.23 An LVIA comprises two interrelated parts:

 a landscape impact assessment, which considers the effects of the proposed development on the physical landscape and the potential for changes in its character; and

 a visual impact assessment, which considers the potential changes to the visual context arising from the proposed development including general setting and views for local residents, walkers, horse riders, visitors and vehicular traffic, collectively these are described as ‘receptors’.

14.2.24 Whilst the methodology used throughout the EIA will be adhered to for consistency, it will be tailored in the LVIA to ensure the assessment accords with the principles of best practice set out in the following published guidance:

 Guidelines for Landscape and Visual Impact Assessment Third Edition (2013) (GLVIA3), published by the Landscape Institute and the Institute of Environmental Management & Assessment;

 GLVIA3 Statement of Clarification 1/13 (2013), published by the Landscape Institute; and

 Landscape Institute Advice Note 01/11, Photography and Photomontage in Landscape and Visual Impact Assessment (2011), published by the Landscape Institute.

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14.2.25 Whilst linked, the assessment of landscape and visual effects are treated separately in LVIA. Full details of the methodology are included at Appendix 14.1. In summary, the approach used to identify and assess landscape and visual effects is summarised as follows:

 Determine the scope of the assessment;

 Collate baseline information for landscape and visual receptors, including completing desk study research and undertaking field survey work;

 Review the type of development proposed and determine the susceptibility of the landscape and visual receptors to the type of change proposed;

 Combine value with susceptibility to determine the sensitivity of landscape and visual receptors to the nature of the development proposed;

 Describe the nature and magnitude of change (impact) likely to be experienced by landscape and visual receptors as a result of the proposed development;

 Assess the level (and significance) of effects for landscape and visual receptors in relation to the proposed development, through a clear description of judgements on sensitivity and magnitude of impact; and

 Describe any measures (mitigation) to avoid or reduce the magnitude of any adverse impact;

 Describe any residual effects, and their significance, following mitigation; and

 Identify those effects that are considered important to decision making.

 The contribution designated features make to the value / sensitivity of visual receptors will also be considered as part of the visual impact assessment.

Uncertainties and limitations

14.2.26 The LVIA will consider the contribution heritage and ecological features make to the character and value of the landscape and visual receptors, along with an assessment of the likely effect of the Proposed Development on the landscape character and views associated with heritage features. It must be noted that this assessment has been carried out in landscape and visual terms only, as an assessment of impact on heritage assets and their wider cultural setting (e.g. impacts on cultural and historic associations) are considered to be beyond the remit of this LVIA

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and are covered by Archaeology and Built Heritage Chapters, to ensure continuity and consistency the LVIA will, where appropriate, reference these assessments. However, the LVIA does not assess direct or any other indirect effects on heritage or ecological resources.

14.2.27 No limitations have been identified that would affect the conclusion of this assessment for Environmental Impact Assessment (EIA) purposes.

Geographical Scope

14.2.28 A preliminary study area of 5km from the Application Site boundary was identified to conduct initial baseline studies, considering the nature and scale of the Proposed Development in relation to the existing physical characteristics of the landscape as well as existing landscape studies and assessments. This preliminary study area is considered to be sufficient to account for potential significant effects that may arise as a result of the Proposed Development.

14.2.29 Published National, County and District level landscape character assessments, provide detail on Landscape Character Types and Areas, these identify the key characteristics, condition and landscape guidelines for each of the differing landscapes and will be assessed as part of the LVIA, this will also include an assessment of any likely effects on existing landscape features within and in the immediate vicinity of the Site, including land use, ecology, landform / topography, hydrology, vegetation cover and public access.

14.2.30 As part of the preliminary study, the likely visual envelope of the development was considered, to define the scope of potential visual impact. The visual envelope considered the location of visual barriers (built form and large areas of vegetation) to identify those areas of the landscape that theoretically would be visually connected to the proposed development. To inform the LVIA in more detail, a Zone of Theoretical Visibility (ZTV) would be prepared, based on the emerging (as part of the iterative design process) and fixed parameters for the development.

14.2.31 Within the Study Area, there are a number of Conservation Areas and Cannock Chase Area Outstanding Natural Beauty. These features are illustrated on the Planning Policy and Environmental Designations Plan with Proposed Viewpoint Locations included in Figure 14.1.

Temporal Scope

14.2.32 An assessment is then presented of the potential effects of the Proposed Development during enabling / construction works and once the Proposed Development is completed (year 0) and operational (after 15 years).

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14.3 BASELINE ENVIRONMENT

14.3.1 As set out in Chapters 2 and 3, a number of works are being undertaken as part of the surrender process of the Environmental Permit for the Site and do not form part of the Proposed Development for which outline planning permission is sought. These works are therefore assumed to be in place and form part of the baseline. This ‘future baseline’ will therefore form the starting point for assessment of Landscape and visual impacts and effects.

14.3.2 The preliminary study (as noted under geographical scope above) included a review of the following existing landscape character assessments, which describe national, county and district landscape character within the study area:

 The Character of England: Landscape, Wildlife and Natural Features (2014), Natural England.

 Planning for Landscape Change: Supplementary Planning Guidance to the Staffordshire and Stoke on Trent Structure Plan, 1996 – 2011 - Adopted on 10 May 2001

 Cannock Chase Area of Outstanding Natural Beauty (AONB) Review of AONB Landscape Character Framework – August 2017.

 Review of Landscape Character Assessment for Cannock Chase District - 09 November 2016

14.3.3 The following character areas lie within the study area and have been considered as part of the initial desk study:

 National Character Areas : 69 Trent Valley Washlands & 67 Cannock Chase and Cank Wood

 Landscape Character Type : Riparian Alluvial Lowlands, River Meadowlands and Settled Farmlands

14.3.4 The published assessments provide a hierarchical appraisal of the character of the Site, its surroundings and the wider region through a recognised process of landscape characterisation. It should be noted that there are often subtle differences between and within individual landscape character areas that can give rise to variations in both actual and perceived quality, condition, value and susceptibility to change. Furthermore, boundaries between character areas do not always follow recognised features within the landscape such as rivers, settlement edges

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or field boundaries. In these cases, the boundaries between character areas should be treated as transitions where there is a gradual change in character as is often the case with landscapes at the national and regional level.

14.3.5 Features of note within 2km of the Site boundary include the following

 Spode House and attached Coachhouse, Hawkesyard Priory - Grade: II

 Roman of St Thomas, Hawkesyard Priory - Grade: II

 Trent and Mersey Conservation Area – Parts adjacent to Rugeley and Armitage and Handsacre.

14.3.6 Within 5km of the Site, there are also Conservation Areas at Colton and Mavesyn Ridware, along with Cannock Chase Area Outstanding Natural Beauty. It is currently considered that the landscape character and setting of these sites will not be impacted by the proposed development. However, where there is potential intervisibility this will be considered further in as part of the LVIA. These are illustrated on the Planning Policy and Environmental Designations Plan with Proposed Viewpoint Locations included in Figure 14.1.

14.3.7 Key visual receptors (places with potential views of the site) include the following:

 The settlement of Rugeley, to include Brereton and Ravenhill, located directly to the south and west;

 The settlement edge of Armitage, located approximately 500m to the south east;

 The villages of:

o Colton, located approximately 2.3km to the north;

o Mavesyn Ridware, located approximately 800m to the east;

o Hill Ridware, located 1.2km to the north east;

 A small number of individual farmsteads and residential properties scattered throughout the landscape surrounding the Site;

 The Way for the Millennium Long Distance Footpath, which runs from the east, taking in the Trent and Mersey Canal to the south of the Site and continuing out to the wider landscape to the north west;

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 A number of footpaths and bridleways running throughout the landscape surrounding the Site;

 Footpaths and Bridleways that run though Cannock Chase AONB, located 1.83km to the south west and the closest point;

 The A51 which runs adjacent to the south western site boundary.

 A number of roads associated with the surrounding settlements and rural lanes crossing the agricultural landscape.

14.4 POTENTIAL ENVIRONMENTAL IMPACTS & EFFECTS

Effects Scoped Out

14.4.1 Following a desk based study it is considered that the effects beyond 5km would be insignificant and so would not be included as part of the assessment.

14.4.2 The National Landscape Character Areas inform the context for County and Local level character assessments, they do not however provide a sufficient level of detail appropriate to the nature of effects likely to arise at a local level as a result of the Proposed Development. Given the relatively small part of the National Character Areas that would be impacted by the development, any effects are likely to be minor at most, which is insignificant in EIA terms, so these would note be assessed any further as part of the LVIA.

14.4.3 Colton and Mavesyn Ridware Conservation Areas, along with Cannock Chase Area of Outstanding Natural Beauty (AONB) lie within the Study Area. However, it is considered that due to the intervening landform, existing built development and vegetation the Proposed Development would not affect the landscape character and setting of these villages or the AONB. That said there is the potential for intervisibility, therefore any views would be considered further in as part of the LVIA. Potential views are illustrated on the Planning Policy and Environmental Designations Plan with Proposed Viewpoint Locations included in Figure 14.1.

Effects Scoped In

14.4.4 The LVIA will be based on views from publicly accessible locations, where an impact on residential and other private views (e.g. commercial properties) is noted, this will, necessarily be estimated (unless access is provided by landowner).

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14.4.5 The viewpoints identified in this scoping report (see Figure 14.1) are expected to illustrate the greatest potential impact from a representative range of receptors including residences, public rights of way, public open spaces, private open spaces, commercial operations, the road network etc. The LVIA will not necessarily identify all locations from where the Proposed Development would potentially be visible

14.4.6 Landscape Character Types and Areas described in the county and district level assessments are considered to provide a sufficient level of detail to assess the likely local effects of the Proposed Development, therefore these would be assessed as part of the LVIA, alongside any likely effects on existing landscape features within and in the immediate vicinity of the Site, including land use, ecology, landform / topography, hydrology, vegetation cover and public access.

14.4.7 The LVIA will determine the sensitivity of landscape and visual resources. Desk studies indicate that the sensitivity of the landscape is Low, with the sensitivity of visual receptors ranging from Low to High (with the greatest sensitivity associated with tourist destinations, residential receptors or designated locations such as Scheduled Monuments).

Construction Impacts and Effects

14.4.8 The construction phase is likely to comprise activities such as enabling works on site, the phased introduction of infrastructure, as well as ongoing construction activities necessary to implement the Proposed Development.

14.4.9 Depending on the nature of construction activities and the associated logistics for moving material and plant on and off Site, it is likely that construction features and activities would be visible from locations in close proximity to the Site (largely along existing adjacent roads and industrial development) and from a limited number of elevated locations in the surrounding landscape. Whilst not exhaustive, these features and activities are likely to include:

 The establishment of tree and hedgerow protection measures in accordance with BS5837/2012;

 Signage / Site hoarding / perimeter fencing;

 Temporary site infrastructure such as porta-cabins and plant storage;

 Stockpiling and open storage;

 Haulage and construction traffic with flashing hazard warning lights;

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 Plant and machinery including lifting equipment with flashing hazard warning lights; and

 The construction of the Proposed Development, to include on site highways infrastructure and servicing, including drainage and lighting; and

14.4.10 Initial strategic landscape mitigation measures, which includes ‘soft’ landscape works to the periphery of the Site (such as topsoiling, woodland planting and seeding), would be implemented at the earliest opportunity. Attenuation basins would be constructed alongside each relevant phase of the works. Significant construction effects are likely to be limited to the site itself and areas within the immediate landscape (including visual receptors). It is expected that all other effects beyond 1km of the site boundary would be insignificant but this would be assessed in detail as part of the LVIA.

Occupation Impacts and Effects

14.4.11 On completion, it is anticipated that the settlement edge would not extend beyond the boundaries of the original power station. Development parcels are anticipated to be split into distinct areas, set within a strategic framework of green infrastructure, comprising retained and new structural landscaping, likely to include a new country park proposed to the north eastern part of the Site. The existing trees, woodland and hedgerow vegetation within the development will be retained where possible, with all Site boundary vegetation remaining, this would provide an existing mature wooded setting to the Proposed Development at an early stage. The existing 400kv and 132kv substations within the centre of the Site will remain and continue to provide a notable feature within the wider landscape.

14.4.12 There would be a range of views of residential, commercial and employment development with associated infrastructure. There would also be views of extensive new woodland areas with enhanced ecological habitats, SuDS ponds and swales. However, the presence of existing woodland to the south would limit the influence of the extended development edge on the surrounding landscape to the south.

14.4.13 As with construction phases, significant effects on completion are likely to be limited to the site itself and areas within the immediately landscape (including visual receptors). It is expected that all other effects beyond 1km of the site boundary would be insignificant but this would be assessed in detail as part of the LVIA.

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14.5 MITIGATION ENVISAGED

14.5.1 Mitigation measures would include the save guarding of all existing trees and vegetation where possible in accordance with Trees in relation to design, demolition and construction - BS5837/2012 and the development of a comprehensive green infrastructure strategy to include provision for screening and softening of the Proposed Development where required to minimise adverse effects on landscape character and visual amenity, while providing suitable visual links between the Proposed Development and the surrounding landscape.

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CHAPTER 15: TRANSPORT AND ACCESS

15.1 INTRODUCTION

15.1.1 This chapter of the EIA Scoping Report has been prepared by mode transport planning (mode). Mode is a transport planning practice with significant experience in the promotion of and transport assessment of strategic development proposals.

15.1.2 The chapter describes the assessment methodology; the baseline conditions at the Site and surroundings; the potential significant environmental impacts; and the mitigation measures anticipated to prevent, reduce or offset significant adverse effects.

15.1.3 It is proposed that Transport and Access is scoped in to the EIA.

15.2 ASSESSMENT CRITERIA & METHODOLOGY

Planning Policy and Guidance

National Planning Policy

15.2.1 The NPPG was published in 2012 and revised in 2018. The updated guidance aims to facilitate the development of a robust and well thought out site, enabling an assessment of the transport impacts of both existing and proposed developments. The guidance can inform sustainable approaches to transport. A strong assessment will establish evidence that may be useful in:

 Improving the sustainability of transport provision;  Enhancing the levels of accessibility;  Creating a choice amongst different modes of transport;  Improving health and well-being;  Supporting economic vitality;  Improving public understanding of the transport implications of development;  Enabling other highway and transport authority’s/service providers to support and deliver the transport infrastructure that conforms to the Local Plan; and  Supporting local businesses and the regional economy.

15.2.2 The NPPF sets out the government’s planning policies for England, and how these are expected to be applied, stating that all developments generating significant amounts of movement should be supported by a Transport Assessment (TA) or Transport Statement

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(TS), alongside a Travel Plan (TP). Within the NPPF, it is suggested that an economic, social and environmental objective should be at the heart of the planning process.

15.2.3 Under the Promoting Sustainable Transport chapter it is stated that transport issues should be considered from the earliest stages of plan-making and development proposals. By doing this the potential impacts of development on transport networks can be addressed and the appropriate transport infrastructure can be implemented. By considering transport at the earliest stages, it allows the opportunity to promote walking, cycling and public transport, and mitigate any problems.

15.2.4 Significant developments should be focused on being sustainable, this can be done through limiting the need to travel and offering a genuine choice of transport modes.

15.2.5 Within this context, new developments should:

“…give priority first to pedestrian and cycle movements, both within the scheme and with neighbouring areas… facilitating access to high quality public transport, with layouts that maximise the catchment area for bus or other public transport services, and appropriate facilities that encourage public transport use”.

“…create places that are safe, secure and attractive – which minimise the scope for conflicts between pedestrians, cyclists and vehicles, avoid unnecessary street clutter, and respond to local character and design standards”.

15.2.6 Furthermore, the principles state that plans should

“…make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable”.

15.2.7 The NPPF promotes sustainable transport, stating that

“...the transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel. However, the Government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas.”

15.2.8 The NPPF requires all developments generating significant amount of movement to develop a TP.

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Local Planning Policy

Current Planning Policy

15.2.9 The Lichfield District Council Local Plan Strategy (LDLPS) was created to help shape the physical, economic, social and environmental characteristics of Lichfield District between 2008 and 2029.

15.2.10 Lichfield District Council (LDC) has consulted on its Local Plan Allocations Document which identifies Rugeley Power Station within Policy R1. Policy R1 sees East of Rugeley Housing Land as ‘an opportunity for a sustainable and well-designed mixed-use development which is integrated into the existing strategic development allocation.’

15.2.11 The Local Plan allocation is supported by a Concept Statement, this statement sets out key objectives for the Site including:

 To provide strong walking and cycling links through the development and between the new and existing residential developments; and,

 Enhancing the sustainable transport options available within the East of Rugeley area.

15.2.12 Within the LDLPS, it states that the provision and enhancement of public transport links and improvements to the highway network are essential to encourage sustainable travel patterns. These enhancements are in terms of both vehicular and pedestrian / cyclist provision, with safety at the forefront.

15.2.13 The plan continues, stating that all new developments should be within 350m of a bus stop, this will not only allow choice, but promote smarter travel choices.

15.2.14 Chapter 7 Public Transport considers reducing the need to travel. It details that by directing growth towards existing sustainable settlements; securing improvements to public transport, pedestrian and cycling infrastructure; and increasing access to sustainable forms of transport; this can be achieved.

15.2.15 The LDLPS examines creating sustainable transport in new developments, stating that it is fundamental to improve access to public transport. By not only improving access to public transport but giving the choice to be able walk and cycle, it will subsequently minimise the need to travel by car. Consequently, the reduction in car use will reduce congestion, mitigating the effects of climate change and creating better living environments for residents. The strategy states that an important aspect of this strategy is managing growth alongside

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reducing the need to travel by car. Integrating transport choices within developments will allow these strategies to be implemented.

15.2.16 Core Policy 5: Sustainable Transport, states that improved accessibility and transport choices will reduce the use of the private car and promote healthier lifestyles.

15.2.17 The chapter continues to state that development proposals, either individually or collectively, will have to make appropriate provisions for:

 Reducing the need to travel;  Widening travel choices;  Making sustainable travel more attractive than private car;  Improving road safety; and  Reducing the impact of travel upon the environment.

15.2.18 Initiatives related to sustainable transport improvements within the District will be supported, these include proposals for:

 Railway facilities and access improvements;  Improved walking and cycling facilities within urban areas, securing connections within and to new developments;  The extension of bus services, and high-quality facilities, that promote public transport use; and  Reducing the isolation of rural communities through public transport improvements, improved walking and cycling links and the continued facilitation of community-based transport.

15.2.19 There are Strategic Objectives set out for the Site, those which are relevant are as follows:

 To integrate the development of up to 1130 homes and associated facilities within the landscape setting;  To provide convenient walking and cycling links between the new and existing developments;  Building on existing transport networks, and enhancing the sustainable transport options; and  Ensuring a good degree of physical and social integration with the existing settlement.

15.2.20 Within the strategy, there is a discussion into infrastructure. The strategy states that public transport must serve the Site, this can be achieved by local bus stops (350m) and the promotion of smarter travel choices. The infrastructure must also consider the provision of pedestrian and cycling routes throughout the Site, this can link the development to facilities beyond the Site. Within these pedestrians and cycling routes, there must also be safe crossing points, creating safe and attractive routes.

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Cannock Chase Local Plan

15.2.21 The Local Plan Part 1 brings together the former emerging Core Strategy and Rugeley Town Centre Action Plan into one document. The Local Plan plans to shape the way in which the physical, economic, social and environmental characteristics of Cannock Chase District will change between 2006 and 2028.

15.2.22 The Local Plan sets out transportation goals, one of which is an enhanced rail service between Rugeley and Birmingham, alongside Chase rail line improvements. Furthermore, the plan calls for considerations into bus service and station improvements, alongside better walking and cycling opportunities.

15.2.23 Policy CP10 discusses sustainable transport, stating that The Cannock Chase Council will work alongside bus and rail operators such as Staffordshire County Council; the West Midlands Integrated Transport Authority; and other local transport bodies to help develop and promote sustainable transport modes. The aim is to provide realistic alternatives to the car, which will help contribute to achieving national climate change targets and reduce air pollution. New developments will be expected to promote sustainable transport and where appropriate.

15.2.24 In the context of buses, Policy CP10 states that the retention and development of bus services is paramount. Strong bus services can assist people, including the disabled and those without access to a car, to gain access to work, health, leisure and education facilities. The service provision must rectify network gaps and respond to strategic growth.

15.2.25 Policy CP10 discusses the importance of rail improvements, these improvements include the upgrade of the Chase Line. The improvements of the line consist of increased line speed, re- signalling and electrification. The rail improvements go beyond the Chase Line, with improvements also being made to local rail services with advanced frequency, increased capacity and restoration of the trains themselves. The improvements to rail all extend to the scheduling and station infrastructure with plans to have more staffed offices and better accessibility for disabled passengers.

15.2.26 The improvement of the bus and rail will allow an improved and integrated bus/rail service, allowing for interchange facilities to be created. There is also conditional support for High Speed 2, subject to improvements to the Chase Line services and infrastructure to improve connectivity with Birmingham.

15.2.27 The improvement of walking and cycling is discussed, the measures must improve or provide facilities for pedestrians that are safe, secure, direct, convenient and attractive. This will be

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promoted through Public Rights of Way, a network of pedestrian routes linked to the Green Space Network, giving pedestrians priority, pedestrianisation and traffic-calming schemes.

15.2.28 Priority will be given to improve or provide pedestrian facilities that:

 Link town centres, rail and bus stations, residential and employment areas, and public open space;

 Access to recreational purposes in the countryside; and

 Meet the needs of people with impaired mobility.

15.2.29 When considering cycling, Cannock Chase District Council (CCDC) is working in conjunction with Sustrans, the Highway Authority and developers to add to the District's strategic cycle network on the Policies Map. The authorities plan to provide facilities and introduce measures to improve travel for cyclists, this includes:

 The provision of segregated cycling routes within new developments, both residential and commercial (in excess of 200 dwellings);

 The provision of cycle corridors and crossings in existing highways, new road schemes and traffic management and calming schemes;

 The provision of secure cycle parking facilities in town centres, railway stations and new retail development; and

 The provision of showers and lockers at all major employment sites (as part of a TP submitted under the requirements of a planning application).

15.2.30 The Staffordshire Local Transport Plan sets out proposals for transport provision in the county, including sustainable modes of transport, alongside this is car-based travel and maintenance of local footways.

15.2.31 The ambitious Staffordshire Local Transport Plan plans for local transport provision and maintenance, the plan intends to complete this through a number of strategies including:

 Enabling economic growth through transport without causing congestion;

 Creating opportunities for residents and visitors to access jobs and education;

 Maintaining the current highway;

 Improving travel safety;

 Responding to current and future climate issues;

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 Encouraging and providing active travel choices; and

 Minimising the negative impacts of transport on the environment.

15.2.32 Transport plays a vital role in helping to ensure that both areas, and residents, can reach their potential. Transport can stimulate areas of deprivation and support regeneration and tourist activity, reducing disparities between rural and urban areas.

15.2.33 The Local Plan states that local authorities have a clear mandate to manage expected growth through a mixture of hard and soft measures, integrating into existing transport networks.

15.2.34 Policy 1.1 states that:

 Ensuring that the local transport network should contribute to the vibrancy of towns;

 New developments should support good public transport links, or be well connected to existing links;

 Ensuring that new developments are well connected to walking and cycling networks/facilities;

 Place and movement should be considered together;

 Ensuring that transport investment opportunities are maximised;

 Provide tailored transport services and travel incentives for those with access barriers; and

 Maintaining and expanding the local public transport network.

15.2.35 Policy 3.1 details how design should be encouraged in new developments to create smarter travel choices, by using smart designs there will be a reduction in private motor vehicle use.

15.2.36 Policy 3.4 discusses how the council will seek to improve and integrate transport services by working with bus and rail operators to create a more integrated system. An integration between coaches and other methods of travel, for example timing; infrastructure; information and ticketing, will allow a more cohesive journey for passengers. The integration can also stem between linking public transport services and regional airports.

15.2.37 Policy 5.1 converses about putting pedestrian travel at the forefront of travel. This can be achieved through:

 Investing in improvements for pedestrians and cyclists;

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 Encouraging major employers to develop travel plans as a way of creating and managing sustainable travel;

 Promoting and running schemes that encourage smarter travel; and

 Traffic-regulation orders (such as low-emission zones, no stopping zones).

Emerging Planning Policy

Rugeley Power Station Development Brief – Consultation Document

15.2.38 The document states under road hierarchy, where possible, development proposals should utilise the existing road network to maintain easements and way-leaves. This will help establish a primary route through the Site.

15.2.39 In the context of pedestrian and cycle links, a key principle of the development is to be sustainable, reducing car dependency and utilising its connections to public transport.

15.2.40 The proposals should seek to integrate with the access points provided as part of the recent residential development to the south of the Site, and also provide designated safe crossing points to ensure safety and encourage usage of pedestrian and cycle links.

15.2.41 Safe and secure cycle parking should be provided on Site where appropriate, encouraging residents to travel via bicycle.

Guidance/ Best Practice

15.2.42 The assessment will be based on the following guidance:

 1993 Institute of Environmental Assessment (now the Institute of Environmental Management and Assessment - IEMA) publication Guidance Notes No. 1: Guidelines for the Environmental Assessment of Road Traffic, hereafter referred to as the IEMA guidelines; and,

 Design Manual for Roads and Bridges (DMRB) – Volume 11 (Environmental Assessment).

Baseline Data Collection

15.2.43 A detailed Site audit will be carried out via a combination of desktop study and Site visits, the purpose of which was to review the local road network in the vicinity of the Site and identify key pedestrian trip attractors, pedestrian and cycle crossing points and other areas of pedestrian activity. Other groups, locations and areas, which may be sensitive to changes in traffic conditions, were also considered. Additionally, the Site visit considered road links and junctions that may have queuing and capacity issues or the potential to be an accident

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hotspot. This analysis will identify those links within the study area that are considered to be more sensitive (Major classification) and will classify the sensitivity of each link in the study area.

15.2.44 Traffic survey data has been collected during November 2018 for the study area illustrated on Figure 15.1.

15.2.45 In addition, Personal Injury Accident data will be obtained from SCC for a study area consistent with that over which traffic survey data has been collected.

Proposed Assessment Methodology

15.2.46 There are a number of environmental effects that can be potentially significant when considering traffic changes in relation to a new development. These are summarised below and will be considered and analysed for the road links that exceed the IEMA significance criteria, for changes in traffic flow volume or composition:

 Severance;  Driver Delay;  Pedestrian Delay;  Pedestrian/Cycle Amenity;  Fear and Intimidation;  Accidents and Safety; and  Abnormal/Hazardous load.

15.2.47 The construction of the development proposals is anticipated to utilise standard techniques and accordingly is unlikely to attract abnormal or hazardous load movements and accordingly these are scoped out of any subsequent assessment.

15.2.48 Given the nature of the development proposals it is considered unlikely that abnormal or hazardous load movements will be required during the occupation phase and accordingly these are scoped out of any subsequent assessment.

15.2.49 The ES chapter will consider potential environmental effects on the following receptors:

 local roads and road users; and  land uses fronting local roads. 15.2.50 The classification of receptor sensitivity is summarised in Table 15.1.

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Table 15.1: Classification of Receptor Sensitivity Receptor / Sensitivity Receptor Type

Receptors of greatest sensitivity to traffic flow: schools, colleges, Major playgrounds, accident blackspots, retirement homes, urban/residential roads without footways that are used by pedestrians. (Paragraph 2.5 IEMA Guidelines, 1993) Traffic flow sensitive receptors including: congested junctions, Moderate doctors’ surgeries, hospitals, shopping areas with roadside frontage, roads with narrow footways, un-segregated cycleways, community centres, parks, recreation facilities. Receptors with some sensitivity to traffic flow: places of worship, Minor public open space, nature conservation areas, listed buildings, tourist attractions and residential areas with adequate footway provision.

Negligible Receptors with low sensitivity to traffic flows and those sufficiently distant from affected roads and junctions.

15.2.51 The assessment of the construction phase of the development will consider the impacts of construction traffic on the surrounding highway network. Construction traffic will be generated using first principles techniques and will be considered in relation to the anticipated phasing of the development so that a calculation of the forecast daily construction traffic flows can be carried out.

15.2.52 The assessment of the occupation phase of the development will comprise a comparison of changes in traffic flow between the agreed future year reference case and reference case + development scenarios. It is envisaged that the reference case will include traffic generated by identified committed developments as advised by the respective planning and highway authorities.

15.2.53 In order to ensure a relative assessment of any potential change in road traffic in environmental terms, the criteria outlined in Table 15.2 will be used.

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Table 15.2: Magnitude of Impact Criteria Change in Traffic Flow Magnitude of Impact

Change in total traffic or HGV flows Major over 90%

Change in total traffic or HGV flows Moderate of 60-90%

Change in total traffic or HGV flows Minor of 30-60%

Change in total traffic or HGV flows Negligible of less than 30%

15.2.54 The criteria included in Table 15.2 are in line with IEMA Rule 1 – Include roads where traffic flows are forecast to increase by more than 30% (or where the number of HGV’s is forecast to increase by more than 30%). Any links forecast to experience a change classified as major, moderate or minor will be assessed in greater detail in line with environmental impacts summarised in Section 15.4.

15.2.55 The level of total traffic flow or composition change will subsequently be considered in relation to the sensitivity of the receptor (Table 15.1) in line with the significance matrix summarised in Table 15.3.

Table 15.3: Significance of Effect Criteria

Magnitude of

Sensitivity of Impact Receptor Major Moderate Minor Negligible Major Major Major Moderate Minor Moderate Major Moderate Minor Negligible Minor Moderate Minor Negligible Negligible Negligible Minor Negligible Negligible Negligible

15.2.56 The significance matrix also captures IEMA rule 2 – Include any specifically sensitive areas where traffic flows are forecast to increase by 10% or more as highly sensitive. A logic check of the IEMA rule 2 criteria will be applied in this instance to those links of Major sensitivity forecast to experience changes of less than 10% discounted from further detailed analysis. Such links will then be included within the assessment.

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Geographical Scope

15.2.57 The geographical scope of the assessment will be consistent with the area of local highway network over which traffic data has been collected as summarised in Figure 15.1.

Temporal Scope

15.2.58 The assessment will cover the construction and occupation phases of the development. When considering the occupation phase of the development this will assume full delivery of the development.

15.3 BASELINE ENVIRONMENT

Local Highway Network

15.3.1 The area of local highway network relative to the Site is illustrated on Figure 15.1. The Site is abutted by the A51 which connects to other key roads including the A513, Brereton Road and the A460. The A51 provides direct access to Chester in a northern direction. The A51 is a two- way single carriageway road that links the Site directly to Lichfield to the south-east and to Stafford (via the A513) to the north-west. The A513 also provides access to the Armitage and Handsacre to the east of the Site.

15.3.2 The A51 links with the A5148 and A38 to the south-east of Lichfield from which it is possible to links with the A5 and M6 toll.

15.3.3 The A51 links with A460 via a roundabout junction the north-west of the Site. The A460 provides a linkage to the A5 and M6 Toll at Churchbridge.

Walking and Cycling

15.3.4 The north-west and south boundaries of the Site are linked to the A51. The A51 provides pedestrian footways and a shared footway/cycleway within the immediate vicinity of the Site.

15.3.5 The A51 comprised of a shared footway, providing direct access to Rugeley Trent Rail Station. At the western edge of the carriageway, the road benefits from a dedicated shared footway/cycleway which extends as far south as the A51/Power Station Road/Rugeley Power Station Site Access roundabout junction.

15.3.6 The eastern side of the A51 provides a paved footpath that routes southwards from opposite the JCB Cab Systems plant to a ‘Chase Line’ railway bridge that crosses the A51, c. 210m north of the Site access.

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15.3.7 From the A51/Wheelhouse Road roundabout, the A51 remains aligned by both a pedestrian footway and shared footway/cycleway until it links to the A513 Rugeley Road at the A51/A513 Rugeley Road/Armitage Road roundabout.

15.3.8 By using the pedestrian infrastructure that is connected to the Site it is possible to access properties and amenities that are located to the east of Rugeley, including Rugeley Trent Valley Railway Station and also, the village of Aldridge to the southeast.

15.3.9 In terms of cycling, the Site is positioned adjacent to an off-road shared footway/cycleway that routes along the A51, west and south of the Site. By travelling along the A51 route, cyclists can access an extensive cycle network that comprises of a number of on-carriageway, off- road, signed and advisory cycle links that are dispersed throughout the town of Rugeley; nearby rural areas and Cannock Chase (see Figures 15.2 and 15.3, ‘Cycling in Cannock Chase’ and ‘Cycling in Lichfield District’).

15.3.10 The topography of the local area suggests that within the vicinity of the Site, the gradient and surfacing would not be limiting factors in people choosing to cycle. Resultantly, it is concluded that there are good opportunities; with no real physical barriers, for cycle travel between the Site and surrounding area for recreational journeys and commuting.

Bus Services

15.3.11 A number of bus services operate within Rugeley; however, the current bus provisions are mainly focused within existing residential areas and not the more industrial Trent Valley area.

15.3.12 In terms of the existing local bus services that operate within the vicinity of the Site, the nearest bus stops to the Site in a northern direction is Rugeley Bus Station. The bus station is located 1.2km from the Site, approximately a 16-minute walk or a 5-minute cycle, the bus stops are marked by bus shelters.

15.3.13 The bus stops at the station are served by the 24, 825 and 829 bus services which provide access to a number of locations such as Lichfield, Stafford Hospital and Brereton. All stops along the route are signposted and provide timetabling information for users. The location and routes of the bus stops are illustrated on Figure 15.4.

15.3.14 The typical daytime frequency of the bus services is summarised in Table 15.1 below.

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Table 15.1 Frequency of Local Bus Services Service No. Route Peak Hour Freq Peak Hour Freq Days of Operation (Weekdays) (Weekends) 24 Rugeley – 2 per hour 2 per hour on 6 days a week Brereton Saturday and no Sunday service 825 Rugeley – 2 per hour 2 per hour on 6 days a week Stafford Hospital Saturday and no Sunday service 829 (School Rugeley – 2 per day No weekend 5 days a week service) Lichfield

15.3.15 In summary, the local area makes provision for at least 4 services per hour in each direction, (at least 8 services per hour in both directions) which provides access to Rugeley, Brereton, Stafford Hospital and Lichfield. These services provide future residents with accessible to everyday leisure, retail and employment destinations in the wider area.

15.3.16 Rugeley provides access to a historic market town, whilst access to Lichfield provides access to key leisure and employment destinations in the city, and to areas outside the city, such as Birmingham City Centre, Birmingham Airport, Solihull and major towns in Warwickshire via Coventry Railway Station.

Rail Services

15.3.17 The Site benefits from being within walking distance of many transport hubs, including 2 railway stations. Rugeley Town Railway Station and Rugeley Trent Valley Station. Both stations are located on the newly electrified ‘Chase Line’ and the West Coast Mainline Railway, these lines provide access to West Midlands Train Services that travel frequently to destinations including Birmingham New Street, Crewe, Stoke-on-Trent, Stone, Rugby and London Euston.

15.3.18 Rugeley Town Railway Station is located c. 1.5km west of the development, this can be accessed via a 25-minute walk or an 8-minute cycle. The station can also be accessed by the 825 within a 20-minute journey.

15.3.19 Rugeley Trent Valley Station is c. 2km to the northwest, the Site can be accessed within a 27- minute walk which may not be seen as an attractive walking distance from the Site, the station can be accessed using other sustainable modes such as a 9-minute cycle. The location of the railway stations is shown in Figure 15.5.

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15.3.20 The typical frequency of train services that serve the Rugeley Railway stations is summarised in Table 15.2 below:

Table 15.2 Frequency of Train Services Destination Fastest Journey Time Typical Frequency

Rugeley Town Railway Station Birmingham New Street 51 minutes Every 30 minutes

Rugeley Trent 3 minutes Every 30 minutes

Cannock 11 minutes Every 30 minutes

Walsall 28 minutes Every 30 minutes

Rugeley Trent Valley Railway Station London Euston 1 hour 35 minutes Every 60 minutes

Birmingham New Street 55 minutes Every 60 minutes

Crewe 59 minutes Every 60 minutes

Rugby 46 minutes Every 60 minutes

Stoke-on-Trent 37 minutes Every 60 minutes

Derby 56 minutes Everyone 60 minutes

Tamworth 14 minutes Every 60 minutes

15.3.21 Rugeley Town Railway Station is operated by West Midland Trains, providing frequent services to locations including Cannock, Walsall and Birmingham New Street. The station has facilities including being open 24/7 and having car parking for visitors.

15.3.22 Rugeley Trent Station is operated by West Midland Trains, providing very frequent services to key destinations including London Euston, Birmingham New Street, Liverpool Lime Street, Rugby and Northampton. The station’s facilities include bicycle parking with CCTV, a car park, being open 24/7 and having disabled parking spaces.

15.4 POTENTIAL ENVIRONMENTAL IMPACTS & EFFECTS

15.4.1 There are a number of environmental effects that can be potentially significant when considering traffic changes in relation to a new development. These effects are consistent whether assessed in relation to the construction or occupation phases. The assessments typically rely upon the relative change in traffic flow between the future year baseline and the

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development scenario in relation to effect specific criteria in order to gauge the requirement for mitigation or otherwise.

15.4.2 The specific environmental effects to be considered are summarised in Section 15.1.

Construction Impacts and Effects

Severance

15.4.3 Guidance on the assessment of severance is provided in the DMRB, Volume 11, Section 3, Part 8 entitled ‘Pedestrians and other community effects’ (Highways Agency, 1993) for new road schemes.

15.4.4 The assessment of the degree of severance is typically carried out in relation to 24-hour AADT flows. The AM and PM peak period traffic data collected to informed this analysis has been converted to 24-hour AADT flows using locally derived conversion factors for the purposes of the proposed assessment.

15.4.5 Therefore, in order to assess severance, the current severance caused by traffic and related factors along the roads surrounding the development will be estimated. The extent to which additional traffic may exacerbate this problem in accordance with the rules contained within the IEMA guidelines will be assessed.

Driver Delay

15.4.6 The TA will include analysis of driver delay through the analysis of individual junction locations in line with the study area summarised in Figure 15.1.

15.4.7 The IEMA guidelines state that delays are only likely to be significant when the traffic on the network surrounding the development is already at, or close to, the capacity of the system.

15.4.8 Therefore, the ES will consider the capacity operation of these junctions where links forecast to experience substantial, moderate or minor changes in traffic flow comprise one or more of the junction approaches. Relevant sections of the TA will be referenced/appended to the ES in order to provide a commentary on junction capacity.

Pedestrian Delay

15.4.9 Changes in the volume, composition or speed of traffic may affect the ability of people and cyclists to cross roads, and therefore, increases in traffic levels are likely to lead to greater

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increases in delay. Delays will also depend upon the general level of pedestrian and cycling activity, visibility and general physical conditions of local infrastructure.

15.4.10 Few quantitative methods of assessing pedestrian delay exist. The IEMA Guidelines suggest a range of pedestrian crossing times of 10 seconds (lower threshold) to 40 seconds (higher threshold) that equate to a link with no crossing facilities of a two-way flow of approximately 1,400 vehicles in the peak periods.

15.4.11 Given the range of local factors and conditions which can influence pedestrian and cycling delay, the IEMA guidelines do not recommend that thresholds be used as a means to establish the significance of pedestrian and cycling delay but recommend that reasoned judgements be made instead. However, the IEMA guidelines do note that, when existing traffic flows are low, increases in traffic of around 30% can significantly increase the delay experienced by pedestrians/cyclists attempting to cross a road.

Pedestrian and Cyclist Amenity

15.4.12 Pedestrian amenity is broadly defined as the relative pleasantness of a journey and is considered to be affected by traffic flow, traffic composition and pavement width/separation from traffic.

15.4.13 The IEMA guidelines suggest a tentative threshold for judging the significance of changes in pedestrian amenity would be where traffic flow (or its HGV component) is halved or doubled.

Fear and Intimidation

15.4.14 There is neither formal guidance nor a consensus of thresholds for the assessment of the level of fear and intimidation experienced by pedestrians. However, the degree of fear and intimidation experienced is generally dependent on traffic volumes, composition and the presence of protection such as wide footways or guardrails. The assessment will refer to the guidelines specified in the IEMA guidelines at section 4.41.

15.4.15 The IEMA guidelines also note that consideration should also be given to areas where there are likely to be particular problems, such as high-speed sections of road, locations of turning points and accesses. Consideration should also be given to areas frequented by school children, the elderly and other vulnerable groups.

Accidents and Safety

15.4.16 Where a proposed development is expected to produce a change in the character of the traffic on the local road network, as a result of increased HGV movements for example, the IEMA

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guidelines state the implications of local circumstances/factors which may elevate or lessen risks of accidents (e.g. junction conflicts), would require professional judgement in order to assess potential significance of accident/safety risk. Relevant sections of the TA will be referenced/appended to the ES in order to provide a commentary on road safety.

Occupation Impacts and Effects

15.4.17 The assessment of specific environmental effects in relation to changes in traffic flow as a result of the development proposals will be carried out in line with the same methodology as previously discussed in relation to construction impacts for each effect.

15.5 MITIGATION ENVISAGED

Construction Phase

15.5.1 A Construction Environmental Management Plan (CEMP) will be developed prior to construction commencement, setting out the full construction methodology including details of HGV routing and hours of operation, and will be submitted to LDC, CCDC and Staffordshire County Council (SCC) for their approval. It is envisaged that the CEMP will include the following items:

 Construction Travel Plan;  Agreed vehicle routing plan;  Agreed hours of operation;  Details of wheel washes; and,  Details of road cleaning.

15.5.2 In terms of the construction workforce accessing the Site, a Construction Travel Plan (CTP) will be developed minimising the impact of staff travel to the Site during construction. This CTP will be developed to include initiatives such as car sharing and sufficient parking/compound space in order to contain parking on Site.

Occupation Phase

15.5.3 It is envisaged that the following inherent mitigation measures will be designed into the development proposals:

 Pedestrian and cycle permeability with defined routes between the Site, Rugeley town centre, Rugeley town railway station, Rugeley Trent Valley railway station and surrounding residential areas;

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 Cycle parking to be provided in line with locally adopted standards;

 Network of pedestrian routes throughout the Site; and,

 The layout allows for bus penetration to enable easy access to public transport services. It is envisaged that this will be delivered by either diversion of existing bus routes or provision of new bus route to better link the Site with key destinations such as Rugeley town centre, Rugeley town railway station, Rugeley Trent Valley railway station.

15.5.4 There is also a potential requirement for off-site highway capacity mitigation to be required as a result of the Proposed Development. The requirement, location and form of this mitigation will be identified as part of the assessment.

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