SCOPING OPINION
Proposed Northern Hub:
Ordsall Chord
March 2012
independent impartial inclusive
CONTENTS
EXECUTIVE SUMMARY
1.0 INTRODUCTION...... 1
Background...... 1
The IPC’s consultation...... 2
Structure of the document...... 3
2.0 THE PROPOSED DEVELOPMENT ...... 4
Introduction...... 4
The Applicant’s information ...... 4
The IPC’s comments ...... 8
3.0 ES APPROACH AND TOPIC AREAS...... 11
Introduction...... 11
ES approach...... 11
Topic areas...... 13
4.0 OTHER INFORMATION ...... 25
Sites of Special Scientific Interest (SSSIs) ...... 25
European Protected Species (EPS) ...... 25
Health Impact Assessment...... 26
APPENDIX 1
APPENDIX 2
APPENDIX 3
Executive Summary
This is the Infrastructure Planning Commission’s (the IPC’s) Scoping Opinion (the Opinion) in respect of the content of the environmental statement (ES) prepared for the proposed Northern Hub: Ordsall Chord, Greater Manchester by Network Rail (the Applicant).
This document sets out the IPC’s opinion on the basis of the information provided in the Applicant’s report entitled ‘Northern Hub: Ordsall Chord Project Scoping Report – February 2012' (the Scoping Report). This Opinion is based upon the proposals as currently described by the Applicant.
The IPC has consulted on the Scoping Report and the responses received have been taken into account in adopting this Opinion. The IPC considers that the topics identified in the Scoping Report encompass those matters identified in Schedule 4, Part 1, paragraph 19 of The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009.
The IPC draws attention both to the general points and those made in respect of each of the specialist topics in this Opinion. For the purpose of the EIA, the key potential issues identified at this stage are:
• impacts on important cultural heritage assets • landscape and visual impacts • air-borne pollutants and fugitive dust emissions arising from construction traffic and during plant operation • impacts on the River Irwell • noise and vibration impacts • transport and other related impacts as a result of the increased rail movements
Matters are not scoped out unless specifically addressed and justified by the Applicant and confirmed as being scoped out by the IPC.
Scoping Opinion for the Proposed Northern Hub: Ordsall Chord
1.0 INTRODUCTION
Background
1.1 On 13 February 2012 the IPC received a Scoping Report submitted by the Applicant under Regulation 8 of The Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (SI 2263) (the EIA Regulations) in order to request a scoping opinion for the proposed Northern Hub: Ordsall Chord Project (the proposed development). This Scoping Opinion is made in response to this request and should be read in conjunction with the Applicant’s Scoping Report.
1.2 Regulation 8 enables an applicant before making an application for an order granting development consent to ‘ask the Commission to state in writing its opinion (a scoping opinion) as to the information to be provided in the environmental statement’.
1.3 The Applicant notified the IPC under Regulation 6(1)(b) of the EIA Regulations that it proposes to provide an ES in respect of the proposed development on 30 September 2011. Therefore, in accordance with Regulation 4(2)(a) the proposed development is determined to be EIA development.
1.4 Before adopting a scoping opinion the IPC (or the relevant authority) must take into account:
(a) ‘the specific characteristics of the particular development; (b) the specific characteristics of the development of the type concerned; (c) the environmental features likely to be affected by the development;’. EIA Regulations 8(9)
1.5 This Opinion sets out what information the IPC considers should be included in the ES for the proposed development. The Opinion has taken account of:
i the EIA Regulations; ii the nature and scale of the proposed development; iii the nature of the receiving environments; and iv current best practice in the preparation of environmental statements.
1.6 The IPC has also taken account of the responses received from the statutory consultees (see Appendix 2 of this Opinion). It has carefully
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considered the matters addressed by the Applicant and has used professional judgement and experience in order to come to this Opinion. It should be noted that when considering the ES, the Examining Authority (ExA) will not be precluded from requiring additional information from the Applicant if it is considered to be relevant in connection with the ES submitted with an application for a development consent order (DCO).
1.7 This Opinion should not be construed as implying that the IPC agrees with the information or comments provided by the Applicant in the request for an Opinion from the IPC. In particular, comments from the IPC in this Opinion are without prejudice to any decision taken by the IPC on submission of the application that any development identified by the Applicant is necessarily to be treated as part of a nationally significant infrastructure project (NSIP) or where relevant associated development, or development that does not require development consent.
1.8 Regulation 8(3) of the EIA Regulations states that a request for a scoping opinion must include:
(a) ‘a plan sufficient to identify the land; (b) a brief description of the nature and purpose of the development and of its possible effects on the environment; and (c) such other information or representations as the person making the request may wish to provide or make.’
1.9 The IPC considers that this has been provided in the Applicant’s Scoping Report.
The IPC’s consultation
1.10 The IPC has a duty under Regulation 8(6) of the EIA Regulations to consult widely before adopting a scoping opinion. A full list of the consultation bodies is provided at Appendix 1. The IPC’s list has been compiled by the IPC in its duty to notify the consultees in accordance with Regulation 9(1)(a). The Applicant should note that whilst the IPC’s list can inform their consultation, it should not be relied upon for that purpose.
1.11 The list of respondents who replied within the statutory timeframe and whose comments have been taken into account in the preparation of this Opinion is provided at Appendix 2 along with copies of their comments, to which the Applicant should refer in undertaking the EIA.
1.12 The ES submitted by the Applicant should demonstrate consideration of the points raised by the consultation bodies. It is recommended that
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a table is provided in the ES summarising the scoping responses from the consultation bodies and how they are considered in the ES.
1.13 Any consultation responses received after the statutory deadline for receipt of comments have not been taken into account within this Opinion. Late responses will be forwarded to the Applicant and will be made available on the IPC’s website. The Applicant should also give due consideration to them in carrying out the EIA.
Structure of the document
1.14 This document is the Scoping Opinion and is structured as follows:
Section 1 Introduction
Section 2 The proposed development
Section 3 ES approach and topic areas
Section 4 Other information
Appendix 1 Consultation bodies
Appendix 2 Respondents to consultation and copies of replies
Appendix 3 Presentation of the ES
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2.0 THE PROPOSED DEVELOPMENT
Introduction
2.1 The following is a summary of the information on the proposed development and its site and surroundings, prepared by the Applicant and included in their Scoping Report. The IPC has not verified this information, and has assumed that the information provided reflects the existing knowledge of the proposed development and the potential receptors/resources.
2.2 The Applicant should be aware that this Opinion only reflects the proposed development as described in the Scoping Report, and is based on the boundary shown on the Red Line Plan contained in Appendix A of the Scoping Report. It should be noted that if the proposed development changes substantially during the EIA process, prior to application submission, the Applicant may wish to consider the need to request a new scoping opinion.
The Applicant’s information
Overview of the proposed development
2.3 The Applicant proposes to develop a new two-track chord line approximately 1.5km in length with associated overhead line equipment, plant, junction equipment and signalling. The chord would be elevated and supported on earthworks, modified existing structures, or new structures.
2.4 The chord would cross the River Irwell and the Manchester Inner Ring Road and would provide a direct rail connection between Manchester Victoria, Manchester Piccadilly and Manchester Oxford Road Stations.
Description of the site and surroundings
The application site
2.5 The application site is located within an urban area on the edge of Manchester City Centre. It crosses the River Irwell into the City of Salford and centres on Grid Reference SJ 382891 97950. The application site is identified on the Red Line Plan in Appendix A of the Scoping Report.
2.6 Present land use within the application site comprises primarily existing railway infrastructure (including Salford Central Station). The application site covers part of the Museum of Science and Industry (MOSI) and the railway sidings leading into MOSI off Liverpool Road.
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There is a block of flats within the application site at the junction of Liverpool Road and Water Street which extends outside of the application site.
2.7 Roads within the application site include Water Street, Trinity Way (A6042, part of the Manchester Inner Ring Road), Irwell Street, New Bailey Street, Chapel Street and Blackfriars Road. A number of car parks also exist within the application site.
2.8 The River Irwell flows through the application site and is crossed by the following bridges:
• 1845 Brick Bridge Over River Irwell (Grade II listed structure) which carries the Bolton Lines • Stephenson’s Sandstone Bridge (Grade I listed structure) • Girder Bridge attached to the north side of Grade I Sandstone Masonry Bridge over the River Irwell (Grade II listed structure), and • Prince’s Bridge which carries Cycle Route 6 and Hampson Street, however is closed to vehicular traffic. There is also a gas main attached to the outside of the bridge.
2.9 There are eight other listed structures are present within the application site (see paragraph 4.2.5 and on the Environmental Constraints Plan in Appendix B of the Scoping Report).
2.10 The application site is located within Castlefield Conservation Area and Cathedral Conservation Area.
2.11 No registered parks and gardens or scheduled monuments have been identified within the application site.
2.12 The Manchester, Bolton and Bury Canal is located to the east of Prince’s Bridge. It leads north from the River Irwell beneath the Manchester IRR and the Chat Moss Viaduct.
2.13 The Irwell City Park Riverside Walkway passes through the application site alongside the River Irwell.
2.14 The application site is located within Air Quality Management Areas (AQMAs), however the Scoping Report does not identify the names of the AQMAs.
2.15 There are no ecological statutory designated sites (Special Protection Areas (SPAs), Special Areas of Conservation (SACs), Ramsar sites, Sites of Special Scientific Interest (SSSIs), National Nature Reserves (NNRs), or Local Nature Reserves (LNRs)) within the application site.
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2.16 There are a variety of habitats within the application site that have the potential to support protected species.
2.17 Parts of the application site are located within Flood Zones 2 and 3, and the Conurbation Core Critical Drainage Area (areas where there is known to be either a high risk of localised flooding from ordinary watercourses, culverts, or other sources or where the sewer system is operating at, or near to, full capacity and is particularly sensitive to rainfall exceedence events and surface water runoff). Flood Zones 2 and 3 extend beyond the application site.
2.18 The application site is underlain by a Principal Aquifer, with superficial deposits identified as Secondary Aquifer A.
2.19 Parts of the application site are located within Groundwater Inner Protection Zones I and II.
2.20 Former mining works and existing coal seams are located within, and in proximity to, the proposed development.
2.21 The application site is located within parts of the Water Street, Greengate and Salford Central Regeneration Areas.
The surrounding area
2.22 The surrounding area is urbanised and comprises local hotels and offices and the Granada Studios. There are also a number of residential areas in proximity to the application site, as identified in the Environmental Constraints Plans in Appendix B of the Scoping Report.
2.23 There are four listed structures within 500m of the application site, which are elements of the MOSI. These are
• the former Liverpool Road Railway Station (Grade I) • the Power Hall (Grade II) • the Air and Space Museum (Grade II), and • the former Lower Byrom Street entrance building (Grade II).
2.24 The Liverpool Road area is on the tentative World Heritage Site list. No further details are provided in the Scoping Report.
2.25 Two Scheduled Monuments (1001953 and 1020983) have been identified within 500m of the application site, although further details, including their locations, are not provided in the Scoping Report.
2.26 The following Conservation Areas have been identified in proximity to the application site on the Environmental Constraints Plans in Appendix B of the Scoping Report:
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• Adelphi Conservation Area, • Flat Iron Conservation Area, and • Shudehill Conservation Area.
2.27 The closest ecological statutory designated site is The Cliff/Kersal Dale LNR, located approximately 2.7km north-west of Victoria Station. The non statutory designated Ashton Canal (West) Site of Biological Importance (SBI) and Rochdale Canal (Stott’s Lane - Ducie Street Basin) SBI are located approximately 1.5km from the application site with no direct connectivity to the application site. The River Irwell is a SBI approximately 1.9km upstream of Victoria Station.
2.28 Downstream of the application site the River Irwell becomes the Manchester Ship Canal (the distance from the application site is not identified in the Scoping Report).
2.29 The Scoping Report states that the area on the right bank of the River Irwell is a Nitrate Vulnerable Zone (NVZ); it does not specify whether this is the east or west bank, or the precise location of the NVZ.
2.30 Twenty five licensed surface water discharge consent points and nine active Groundwater Abstraction Points are located within 500m of the application site, the locations of which have not been identified in the Scoping Report.
Description of the proposed development
2.31 The proposed development would comprise a new two-track chord line approximately 1.5km in length with associated overhead line equipment, plant, junction equipment and signalling.
2.32 Three new bridge structures are proposed to cross Water Street, the River Irwell and the Manchester IRR. These would comprise either decked pre-cast concrete or single/two span steel structures supported on columns or piers. The bridge over the River Irwell would require a new pier to be constructed in the river bed.
2.33 The existing Castlefield and Chat Moss viaducts would be widened at the point the Chord joins these structures, to accommodate the new tracks and associated equipment and maintenance walkways. Modifications would be made to the existing overhead line structures on these viaducts.
2.34 The maximum width of the track is expected to be 12m and the maximum height of the proposed structure above ground level is expected to be 11m (with the exception of the River Irwell).
2.35 Other works would include:
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• alterations to the position of existing signalling structures • removal/realignment of existing tracks on the Chat Moss and Castlefield viaducts • addition of new track switches/crossings at the Water Street and Irwell Street Junctions • remodelling of the track and overhead line equipment at Deal Street Junction, and • alterations to the existing platforms/track alignment within Salford Central Station to accommodate the new line and to provide space for new platforms to be provided within the station, if required, in future.
Proposed access
2.36 The access route to the proposed development is not specified in the Scoping Report.
Construction, operation, maintenance
2.37 If the proposed development is consented, the Applicant intends to commence construction in 2014. The development would be operational in late 2016/early 2017.
2.38 The track infrastructure has a finite operational design life of 125 years and would be replaced as required, as determined by routine track maintenance and asset survey findings. No details of the likely maintenance requirements have been provided in the Scoping Report.
Decommissioning
2.39 It is not anticipated that the proposed development would be decommissioned.
The IPC’s comments
2.40 The IPC notes that the Scoping Report’s description of the chord length differs: 1.5km (paragraph 1.1.2) and 300m (paragraph 2.2.1). The project description should be consistent throughout the ES. For scoping purposes the IPC has based this Opinion on the red line boundary provided in Appendix A of the Scoping Report.
2.41 The Scoping Report makes numerous references to the different railways lines within and in proximity to the application site. The IPC considers that a figure clearly identifying individual elements of the existing railway infrastructure would aid in understanding the project.
2.42 The IPC welcomes the use of environmental constraints plans to aid the reader to orientate the proposed development in its surrounding
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area. However, the naming of listed structures in the Scoping Report, the references in the text and the labels used on the figures are inconsistent, and are confusing to readers, eg paragraph 2.2.4 of the Scoping Report refers to the ‘Grade II Listed Castlefield viaduct’, however it is not identified on the Environmental Constraints Plan in Appendix B. The Applicant should ensure consistency between text and figures in the ES.
2.43 Figure 2 of the Scoping Report identifies the Manchester, Bolton and Bury Canal. It is not possible to discern from the figure and the text in paragraph 2.3.7 the route which the canal takes. The IPC considers that it would be useful to identify the route of the canal on a figure in the ES.
2.44 Paragraph 2.6.1 of the Scoping Report details alternative options for the proposed development which have been considered. The ES should provide further information on these alternatives, and consider alternative routing options. Appendix 3 of this Scoping Opinion provides further information on the consideration of alternatives.
2.45 The IPC recommends that the ES should include a clear description of all aspects of the proposed development including preparation, construction and operational stages. Although not exhaustive, the following list provides an indication of the aspects of the proposed development which are expected to be clearly set out in the ES:
• land use requirements for development and any associated auxiliary facilities, landscaping areas and potential off site mitigation or compensation schemes • characteristics of the land required during the construction and operational phases • a description and relevant plans for the land corridor, horizontal and vertical alignments (embankments, cuttings, false cuttings etc), structures such as bridges, crossings and tunnels, junctions, lighting, drainage outfalls, large signs and gantries, and side roads • construction processes and methods, including site preparation • locations, and restoration or reinstatement, of any construction compounds and lay down areas for major components and parking areas • the types and quantities of materials used, as well as waste arisings and plans for disposal • a description of the reinstatement and after-use of landtake following construction • any potential risk of accidents, having regard in particular to substances or technologies used • emissions (water, air and soil pollution, noise, vibration, etc); and
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• details of any measures required to mitigate impacts that form part of the scheme design, and • any other information requested by statutory consultees.
Construction, operation and maintenance
2.46 The ES should provide details of the construction programme to inform the assessment of potential impacts. This should include a breakdown of construction phases and the duration of each phase, the type of plant and equipment to be used, and key activities. Where certain construction activities are to be undertaken or restricted to a particular time of year, then this should be identified in the ES.
2.47 The Scoping Report states that an Environmental Management Plan (EMP) would be developed to minimise the effects of the proposed development on the surrounding environment (paragraph 11.5.5). The IPC welcomes this and recommends that a draft EMP is included in the ES. As a matter of good practice the EMP should include mitigation, enhancement and compensation measures required to avoid or reduce adverse impacts that are likely to arise during the pre-construction, construction, operation and decommissioning (where relevant) phases.
2.48 The Scoping Report states that routine track maintenance would occur during the operational period (paragraph 3.5.3), however does not provide any specific details. The ES should identify the likely maintenance requirements of the proposed development and any works that would potentially be required over its operational lifetime.
Decommissioning
2.49 Paragraph 3.5.3 of the Scoping Report states that the track infrastructure, including bridges, has a design life of 125 years and would be replaced as required and that the proposed development would not be decommissioned. Paragraph 3.5.4 states that if the Ordsall Chord should become out of use in the future, it is not the intention of Network Rail to remove the viaduct. The IPC acknowledges these comments but considers that the assessment should consider the potential impacts associated with decommissioning. In particular the focus of the assessment should be on the design and use of materials such that, if required, structures can be taken down with the minimum of disruption. Consideration should be given to elements of the project other than the viaduct which may be removed.
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3.0 ES APPROACH AND TOPIC AREAS
Introduction
3.1 This section contains the IPC’s specific comments on the ES approach and Topic Areas as set out in the Scoping Report. General advice on the presentation of an ES is provided at Appendix 3 of this Scoping Opinion and should be read in conjunction with this section.
3.2 Applicants are advised that the scope of the DCO application should be clearly addressed and assessed consistently within the ES.
ES approach
3.3 The IPC welcomes that an overall approach to EIA methodology is provided in Section 3 of the Scoping Report.
3.4 It is important to ensure that an up-to-date baseline is established for each environmental topic. The ES should clearly identify the dates of baseline surveys and/or the date of publication of information gathered through a desk based study. The methodology, including temporal and spatial scopes, should be agreed with the relevant consultees. Any consultation undertaken to inform assessment methodology should be reported on within the ES and where possible, evidence provided.
3.5 All assumptions used to inform the assessment, including the baseline and assessment years, should be fully set out and justified within the ES. The worst case scenario should be assessed in all cases and take into account type of plant used and the method of construction.
3.6 The Scoping Report provides descriptions for different levels of environmental receptor sensitivity and magnitude of impact in Tables 3.2 and 3.3; it is unclear whether these definitions are derived from guidance documents or industry standards, this should be clarified and the ES should clearly reference any guidance documents used.
3.7 Table 3.3 of the Scoping Report describes the magnitude of impacts. The IPC recommends that, where possible, quantitative measures of change are used, and that care is taken when using qualitative terms to ensure consistency.
3.8 Table 3.4 of the Scoping Report provides a matrix to determine the significance of effects as a function of environmental sensitivity and the magnitude of impact. It is not clear why, for 12 of the 25 cells in the table, two levels of significance are provided (e.g. Minor/Medium Significance within one cell) and the procedure to be followed to
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conclude on the level of significance in these cases. This should be rectified within the ES.
3.9 A number of sections of the Scoping Report *e.g. Ecology & Nature Conservation and Waste) contain a matrix to determine significance that differs from that proposed in the general methodology (Section 3 of the Scoping Report). It is recommended that a consistent approach to significance is used in the ES. Any departure should be clearly explained and justified. It is not clear how significance would be established where more than one definition is identified within each cell in the matrix.
3.10 The IPC welcomes the intention to determine the duration of effect within the ES, however does not agree that ‘very short term’ could be used to describe impacts that could occur for up to 2 years. The IPC recommends reconsideration of this aspect.
3.11 Paragraph 3.5.12 of the Scoping Report identifies ‘additional impacts arising from interrelationships within the scheme’ as an aspect of cumulative effects to be assessed within the ES. There should be a clear distinction between inter-relationships and cumulative effects, see Appendix 3 of this Opinion for further details.
3.12 Paragraph 3.5.13 of the Scoping Report details how other developments considered relevant to a cumulative assessment will be identified. The IPC directs the Applicant to Appendix 3 of this Opinion which provides further details with regards to identifying other major development which should be considered in the cumulative assessment.
3.13 The IPC notes that the ES will include details of mitigation measures for significant adverse effects. The ES should provide details of alternative mitigation measures considered, and situations where mitigation is not possible. The IPC recommends that an integrated approach to the design of mitigation measures is adopted. When considering mitigation measures for one topic, consideration should also be given to how the proposed measures may impact on or provide mitigation for other topics.
3.14 There is little reference in the Scoping Report to the monitoring of mitigation measures once the proposed development is operational. It would be helpful if information on monitoring plans could be included in the ES, particularly where mitigation relates to significant impacts. These mitigation measures should be included in the Environmental Management Plan (EMP) where appropriate.
3.15 In preparing the ES, the Applicant should also consider the responses provided by the consultation bodies (Appendix 2).
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Topic areas
General comments
3.16 Section 15 of the Scoping Report sets out the anticipated structure of the ES as follows:
• Volume 1: Non-Technical Summary • Volume 2: Main Statement • Volume 3: Technical Appendices and Supporting Information, and • Volume 4: Figures, Photographs and Plans.
3.17 The Scoping Report does not propose a chapter structure for the main report. However, the following topic areas have been considered in the Scoping Report:
• Section 4 – Archaeology and Cultural Heritage • Section 5 – Air Quality • Section 6 – Noise and Vibration • Section 7 – Ecology and Nature Conservation • Section 8 – Townscape and Visual Amenity • Section 9 – Water Quality, Hydrology and Hydrogeology • Section 10 – Geology, Soils and Land Contamination • Section 11 – Waste • Section 12 – Traffic and Transport • Section 13 – Socio-economics
Matters proposed to be scoped out
3.18 The Applicant has identified, in Table 17.1, the following topics to be scoped out from the EIA:
• operational air quality • operational water quality • operational geology, soils and land contamination • operational waste, and • operational traffic and transport.
The IPC agrees that operational traffic and transport can be scoped out. However, the IPC cannot agree at this stage to scope out the remaining topics from the ES as insufficient information has been provided by the Applicant to justify such an approach. Further advice is provided below.
3.19 The Scoping Report proposes to scope out operational air quality impacts from the EIA as they are ‘likely to be insignificant’ (paragraph 5.1.2). The IPC does not agree to this for the following reasons:
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• the Scoping Report states that ‘the majority of trains on the new chord will be electric passenger trains and no significant air quality impacts are anticipated with the operation of the proposed scheme’ (paragraph 5.6.2). However, the Scoping Report does not justify this conclusion and provides no information on the number of non- electrified trains using the chord, • the IPC does not consider that enough information has been provided within the Scoping Report with regards to the number of anticipated maintenance vehicle movements during the operational phase; all anticipated maintenance activities should be identified within the ES, and included in the operational air quality assessment, where relevant, • the new chord has the potential to influence driving patterns by changing individuals’ travelling patterns, which may impact on air quality, • it is unclear whether any roads will be permanently closed as a result of the proposed development, which may impact upon traffic flows and air quality, and • there are residential properties within 5m of the existing viaducts (paragraph 6.2.2 of the Scoping Report) and an AQMA (designated due to high volumes of local road traffic and their associated exhaust emissions, paragraph 5.2.1 of the Scoping Report) which could be affected by the factors identified above.
3.20 The Scoping Report proposes to scope out operational water quality from the EIA and states that the ‘potential for pollution of a controlled watercourse during the operational phase is considered negligible’ (paragraph 9.6.6). It is noted that the chord would be electrified, however there is no information in the Scoping Report with regards to whether non-electric trains (e.g. freight trains) will also utilise the tracks. Given that the proposed development crosses the River Irwell, the IPC cannot agree to scope out operational water quality on the basis of the information provided.
3.21 The Scoping Report states that operational effects in relation to Geology, Soils and Land Contamination are considered to be negligible (paragraph 10.5.7), however provides no information to support this conclusion. As a result, the IPC cannot agree to scoping this out.
3.22 The IPC does not consider that there is sufficient justification provided within the Scoping Report to agree to scoping out waste materials during operation. The ES should provide details of the anticipated volumes of operational waste, e.g. arising from maintenance.
3.23 The IPC considers that if the matters identified above in paragraphs 3.19-3.22 are covered sufficiently in the ES, the ES will broadly encompass those matters identified in Schedule 4 Part 1 paragraph 19 of the EIA Regulations.
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3.24 The IPC agrees that traffic and transport during the operational phase can be scoped out of the EIA and that no further detailed studies will be required. Nevertheless, the ES should not simply omit this topic but should include the justification for scoping out this topic and so demonstrate that the topic has not simply been overlooked.
3.25 If any other topics are subsequently scoped out by the Applicant from further assessment, the ES should explain the reasoning and justify the approach taken, to demonstrate that topics have not simply been overlooked.
Topic Areas
3.26 Each of the topic areas covered in the Scoping Report are considered in turn below. It should be noted that the general points made above and elsewhere in this Opinion are not repeated under each of the specialist topics. However, the Applicant should ensure that such issues are addressed fully before the ES is submitted to the IPC.
Archaeology and Cultural Heritage (Section 4 of the Scoping Report)
3.27 Data sources and study areas should be clearly defined and based on professional guidelines and practices. The IPC notes the intention to follow the Design Manual for Roads and Bridges guidance. Assessment methodology and proposed mitigation measures should be agreed with relevant consultees including the Local Authority and English Heritage (EH).
3.28 The description of the study area for Archaeology and Cultural Heritage is confusing. Paragraph 4.2.1 states that the ‘spatial scope of works will be delimited as being up to 500 metres from the permanent works’; paragraph 4.2.4 identifies designated monuments ‘within 500 metres of the scheme footprint’; paragraph 4.2.6 identifies structures ‘within 500m of the proposed new Chord’; and paragraph 4.4.1 states direct effects ‘within and adjacent to the scheme footprint’ will be addressed. Consistent terminology should be applied throughout this section (and the remainder of the ES) (see comments of Salford City Council in Appendix 2). The Applicant’s attention is drawn to the comments of EH (see Appendix 2) with regards to defining the study area.
3.29 The ES should detail the names, locations and characteristics of important heritage assets that could potentially be affected by the proposed development. Attention is drawn to the comments of EH (see Appendix 2) with regards to identifying potential receptors. Any cultural heritage/archaeological features that are likely to be affected directly or indirectly should be clearly identified in the plans in the ES. This should include assets considered to be of international, national, regional and local importance.
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3.30 The IPC notes and welcomes the approach to consider the setting of historic assets within the Cultural Heritage and Townscape and Visual Amenity Chapters in the ES (see paragraph 4.1.4 of the Scoping Report). The inter-relationship between aspects of the environment likely to be significantly affected is a requirement of the EIA Regulations (see Schedule 4, Part 1 of the EIA Regulations). More information on this aspect is provided in Appendix 3 of this Opinion.
3.31 The Scoping Report does not clearly identify the potential effects on archaeological and cultural heritage assets that may occur as a result of the proposed development. These should be clearly identified and assessed in the ES. In particular, the potential visual impacts of the removal or alteration of assets, and the effects of noise, vibration and dust on these assets should be considered.
3.32 The Scoping Report identifies the Liverpool Road area to be on the tentative World Heritage Site list. The ES should provide further details on this designation and assess the potential impacts on the area as a result of the proposed development.
3.33 The Applicant’s attention is drawn to the comments of EH (see Appendix 2) regarding the need to assess historic assets as a cluster, as assessing importance and impact on an asset-by-asset basis may result in an under-appreciation of significance.
3.34 Consideration should be given to designing the proposed new line in such a way to mitigate any visual impacts on historic assets (see comments of EH in Appendix 2).
3.35 In addition to the specific references above to comments made by EH, the IPC recommends that the Applicant addresses in the ES all the points made by EH in relation to this topic, including the approach taken to the option selection process which resulted in the choice of the proposed development as the preferred option.
Air Quality (Section 5 of the Scoping Report)
3.36 It is noted that the Applicant intends to use air quality monitoring data from Manchester City Council and Salford City Council to establish the baseline air quality conditions. The locations of the monitoring points and their distances from the application site are not identifiable from the information provided in the Scoping Report. These should be provided in the ES.
3.37 All assumptions and limitations to assessment should be clearly specified in all relevant sections of the ES. Assessment methodology, including the location of sensitive receptors and the need to obtain
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further baseline data, should be agreed with the relevant Local Authorities. Predicted pollutant concentrations should be assessed against the applicable standard or guideline value for the affected medium, e.g. relevant European air quality limit values and National Air Quality Objectives. The potential need for a quantitative assessment of dust impacts and any requirements for post construction monitoring should also be agreed with the relevant Local Authorities.
3.38 The IPC welcomes that Air Quality Management Areas (AQMAs) will be considered in the assessment. The ES should identify the names and locations of the AQMAs in relation to the application site. The reasons for declaration of the AQMA, specifying the air quality objectives that have been exceeded, should be identified.
3.39 The Scoping Report does not specifically identify potential sensitive receptors. The IPC considers that potential receptors should include those along affected access roads, local footpaths and public rights of way (PRoW), and should be agreed with the relevant statutory consultation bodies. Receptors should not be limited to those within the human environment, e.g. the applicant should consider the potential impacts of construction dust on ecological receptors and the River Irwell (given its Wildlife Corridor status and designation as an SBI).
3.40 The IPC notes that there are a number of proposed regeneration areas within and adjacent to the application site (paragraph 6.2.3 of the Scoping Report). Air quality impacts on these should be considered in the assessment.
3.41 Two different buffer zones for assessing air quality impacts have been identified in the Scoping Report (350m around the application site and 200m along haulage routes in paragraphs 5.5.11 and 5.5.12 respectively). This approach should be justified within the ES.
3.42 It is unclear why the finalised construction traffic flows will not be available for the EIA (paragraph 5.7.2). Any limitations associated with data used in the ES should be explained.
3.43 The IPC welcomes the development of a Nuisance Management Plan and Traffic Management Plan. These will need to be provided within the ES if relied upon to provide mitigation. Consideration should be given to mitigation measures appropriate to the size and scale of predicted impacts, including the monitoring of dust and odour complaints.
Noise and Vibration (Section 6 of the Scoping Report)
3.44 The Scoping Report provides limited information on how the baseline noise and vibration conditions will be determined; however it does state
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that ‘an ambient noise survey will be undertaken within and adjacent to the scheme footprint’ (paragraph 6.2.1). The IPC welcomes that the methodology will be discussed and agreed with the Environmental Health Officers at both Salford City Council and Manchester City Council; this should include the spatial and temporal scope for the baseline monitoring.
3.45 Care should be taken in identifying potential receptors. The IPC recommends that the Applicant agrees receptors to be assessed with the relevant Local Authorities. Attention is drawn to the comments of Salford City Council (see Appendix 2) regarding residential receptors.
3.46 The IPC notes that the baseline noise climate will be characterised at ‘sensitive times of the day’ (paragraph 6.7.1). These should be discussed and agreed with the relevant Local Authorities.
3.47 All design parameters and assumptions used in the noise and vibration prediction and assessment should be clearly stated in the ES. This should include information on the construction methods, the type of plant and machinery to be employed as well as phasing, and the duration and hours of construction. It is noted that the proposed development would include bridges. This may affect the noise profile; which should be taken into account in the assessment.
3.48 The proposed development may affect the volume, speed, frequency and type of train movements in Manchester. The ES should consider the full geographical extent of noise and vibration impacts and, where necessary, assess the likely significant effects.
3.49 Anticipated maintenance activities should be considered in the assessment.
3.50 No reference has been made to monitoring the effectiveness of mitigation measures implemented during the operational phase, and any potential residual impacts. Consideration should be given to putting in place a monitoring scheme for the lifetime of the development, which includes the monitoring of complaints during construction and operation.
3.51 Cross reference should be made to other sections of the ES where appropriate such as, for example, Traffic and Transport, and Townscape and Visual Amenity (in relation to any possible noise attenuation mitigation measures) in order to ensure that there is a consistent, integrated and comprehensive approach to assessment and mitigation.
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Ecology & Nature Conservation (Section 7 of the Scoping Report)
3.52 The Scoping Report identifies that the application site and surrounding area has the potential to support a number of protected species, such as bats, badgers, otters, water vole, birds, reptiles and amphibians (including great crested newts) (paragraph 7.2.8). The IPC is pleased to note that the Applicant intends to undertake relevant ecological surveys to ascertain the presence of such species, and expects the findings to be clearly set out in the ES.
3.53 The IPC welcomes the consultation undertaken to date with Natural England (NE) and recommends that this is ongoing. The study area, types of survey and methods of assessment should be agreed with NE and the relevant Local Authorities. This should include the timing and number of field surveys for habitats and protected species. Any limitations with the data should be clearly set out in the ES.
3.54 The Applicant’s attention is drawn to the comments of NE (see Appendix 2) with regards to the need for a habitat survey.
3.55 Consideration should be given to assessing the impacts on aquatic ecology as well as terrestrial ecology (see comments of the Environment Agency in Appendix 2).
3.56 It is noted that valued ecological receptors (VER) will be considered in the assessment if they are, at a minimum, of local importance (paragraph 7.5.4 of the Scoping Report). The methodology used to determine importance should be clearly defined within the ES.
3.57 The significance of impacts on VER is proposed to be assessed as ‘Negative, Positive or Not Significant’ (paragraph 7.5.14 of the Scoping Report). This departs from the methodology of assessing significance as proposed in section 3 of the Scoping Report. It is recommended that a consistent approach is used throughout the ES. any departure should be clearly explained and justified, and references made to any guidance used, where appropriate.
3.58 The ES should set out in full the potential risk to any European Protected Species (EPS) and confirm if any EPS licences will be required (see advice in Section 4 of this Opinion).
3.59 Attention is drawn to NE’s consultation response (see Appendix 2) which identifies the potential for contributing to the provision of strategic green infrastructure opportunity areas, and to the EA’s response (see Appendix 2) regarding increasing the extent and quality of greenspace.
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Townscape and Visual Amenity (Section 8 of the Scoping Report)
3.60 The approach to the Landscape and Visual Impacts Assessment (LVIA) and viewpoints assessment should accord with best practice as set out in the Landscape Institute’s ‘Guidelines for Landscape and Visual Impact Assessment’, and agreed with the relevant Local Authorities. See the comments of EH (Appendix 2) for further advice on relevant guidance documents.
3.61 The Applicant’s attention is drawn to the ‘Greater Manchester Urban Historic Landscape Characterisation’, compiled by the Greater Manchester Archaeological Unit, to provide a basis for more detailed characterisation of the study area (see comments of EH Appendix 2).
3.62 The Applicant should clearly indicate in the ES the size, dimensions and siting of the structures which would form part of the proposed development, as well as colours and choices of material to be used. Any structures or features that will be retained or removed should also be clearly identified in the ES.
3.63 It is noted that the spatial scope has been set for 1km around the application site (paragraph 8.5.6 of the Scoping Report) due to the location of the proposed development ‘within a highly developed urban area with limited views’. The IPC appreciates the urban setting of the proposed development, however given the elevated nature of the proposals considers that the Zone of Theoretical Visibility (ZTV) should be established and the study area agreed with the relevant Local Authorities. A Zone of Visual Influence (ZVI) would then be a useful aid to identify visual receptors affected by any cuttings, embankments, overhead lines, site access roads, road diversions and bridges proposed.
3.64 The IPC considers that photographs will help illustrate the views prior to development and use should be made of photomontages, upon completion and at an agreed future date where mitigation measures are fully established. Any photomontages should be presented in a clear and accessible format that includes clear points of reference to allow the reader to identify and fully understand the potential effects of the proposed development, including in relation to the historic landscape. The locations of viewpoints should be agreed with the relevant statutory consultees and should enable an assessment of the worst case scenario.
3.65 Consideration should be given to both day and night time views, including the impact of lighting. Care should be taken to ensure that photomontages are representative of the views in the area.
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Water Quality, Hydrology and Hydrogeology (Section 9 of the Scoping Report)
3.66 The study areas, assessment methodology and proposed mitigation measures for the water quality, hydrology and hydrogeology assessment should be agreed with the relevant regulatory bodies (i.e. the EA and the Local Authority).
3.67 The ES should identify and clearly map any surface water resources (including springs and private water supplies both internal and external to the site boundary) that could potentially affect or be affected by the proposal. Potential sources of pollution and pathways to hydrological and surface water receptors should be identified.
3.68 The Scoping Report identifies 25 licensed surface water discharge consent points, a Nitrate Vulnerable Zone (NVZ), groundwater abstraction points and a Groundwater Inner Protection Zone (Zone I) and Groundwater Outer Protection Zone (Zone II) within proximity of the application state. No information has been provided within the Scoping Report as to their locations and the potential impacts of the proposed development on these features, and if so, how these will be assessed. The IPC expects this to be covered in the ES, along with details on any proposed mitigation measures if required.
3.69 The Scoping Report states that a Flood Risk Assessment (FRA) may be undertaken (paragraph 9.6.1). Given the location of the proposed development within the Conurbation Core Critical Drainage Area and Flood Risk Zones 2 and 3, and as works will be undertaken within the River Irwell (paragraph 9.4.1 of the Scoping Report), the IPC recommends that an FRA should be developed in consultation with the relevant consultation bodies, including the EA and the relevant Local Authorities. The FRA should cover the risk of ground and surface water contamination in a flood event. The potential for the development itself to increase flood risk within the application site and elsewhere should also be considered in the ES. It should be clear whether any flood protection currently exists around the application site and, if so, identify the body/organisation that is responsible for maintaining it. The FRA should comply with national planning policy set out in Planning Policy Statement 25 (PPS25). The assessment should also take into account the latest climate change projections for the UK as detailed in the UK Climate Projections (UKCP09) at http://ukclimateprojections- ui.defra.gov.uk.
3.70 The Applicant’s attention is drawn to the comments of the EA with regards to considering the effects of scour on the river bed and the potential mobilisation of contaminated sediments should any structures be located in the river.
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3.71 The IPC recommends that a surface water management plan should be prepared, which may include a review of existing drainage facilities, and the provision of additional interceptors on site. The plan should aim to control the direction and speed of surface water run-off and reduce the risks of ground and surface water contamination in case of accidental spillage of fuel and other chemicals.
Geology, Soils and Land Contamination (Section 10 of the Scoping Report)
3.72 Table 10.3 of the Scoping Report is a matrix to determine the level of risk. It is not clear whether the level of risk will be used to identify the significance of effects as set out in the general EIA methodology proposed in Section 3. This should be clearly explained within the ES.
3.73 The Scoping Report indicates the likely presence of contaminated material within the application site (paragraph 10.2.5). The EIA should consider the potential for contaminated material being excavated during the construction stage, and should identify the characteristics and variability of the material. Proposed mitigation measures to deal with any contaminated/hazardous material found on site should be detailed in the ES and should not be limited to disposal; consideration should be given to the waste hierarchy, in particular remediation and re-use on-site. Any information obtained during site investigation should be used to inform the ‘Waste’ section of the ES.
3.74 The IPC expects appropriate remediation and mitigation measures to be identified in the ES to address all aspects of contamination, and to be incorporated in the EMP where appropriate.
3.75 This section of the ES should be cross referenced to the Water Quality, Hydrology and Hydrogeology section.
Waste (Section 11 of the Scoping Report)
3.76 The IPC welcomes the consideration of waste within the ES. The Applicant should ensure that the methodology used for the assessment is detailed in the ES and that any uncertainties are acknowledged.
3.77 The ES should contain details of the types and quantities of waste that require disposal, the disposal methods, and the likely number of vehicle movements required as a result. The IPC recommends that a draft of the Site Waste Management Plan is provided within the ES.
3.78 As with section 7:Ecology and Nature Conservation, this section provides a matrix to determine significance (Table 11.1 of the Scoping Report) that differs from that proposed in the general methodology (Section 3 of the Scoping Report). It is recommended that a consistent
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approach to significance is used in the ES. Any departure should be clearly explained and justified. It is not clear how significance would be established where more than one definition is identified within each cell in the matrix.
Traffic & Transport (Section 12 of the Scoping Report)
3.79 The ES should detail the transport routes to be utilised during construction both within the application site, and along the road network. Given the nature and location of the proposed development, consideration should be given to delivering materials and staff to site by rail.
3.80 Table 12.4 of the Scoping Report identifies a number of roads which are expected to be impacted upon by the proposed development. The Applicant should ensure that the spatial scope of the assessment is sufficiently wide and encompasses roads which may be used as alternatives to closed or diverted routes. A number of additional roads are identified in paragraph 2.5.5 of the Scoping Report as being contained within the application site. The ES should justify why particular roads are considered in the assessment. See the comments of Transport for Greater Manchester in Appendix 2.
3.81 The Scoping Report states that the information used in the assessment ‘may not include all information that is required’ (paragraph 12.7.1). The IPC acknowledges that in some cases it may not be possible to obtain certain information to inform an assessment. The ES should clearly explain the information which cannot be obtained and the reasons why, together with the implications of this on the assessment. The Applicant should agree the assessment methodology with the relevant Highways Authorities and ensure that they are satisfied with the level of information provided.
3.82 The Applicant’s attention is drawn to the comments of Salford City Council (see Appendix 2) regarding the need to consider movement along the riverside and onward journeys (e.g. through a relocated bridge).
3.83 The assessment should reflect the position during the full peak period in the regional centre (see comments of Transport for Greater Manchester in Appendix 2).
3.84 The IPC recommends that a draft Traffic Management Plan (TMP) is provided within the ES.
3.85 Paragraph 12.3.4 of the Scoping Report identifies the potential for Highways Agency construction works to take place within or adjacent to the proposed development. The potential for cumulative effects with
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these works in terms of construction traffic should be considered within the ES (see the response of the Highways Agency, Appendix 2).
Socio-Economics (Section 13 of the Scoping Report)
3.86 The IPC recommends that the assessment criteria for this topic should be locationally specific, and consider the potential significance of the impacts of the proposed development within the local and regional context.
3.87 The Scoping Report highlights that the proposed development will create new jobs during construction and operation (paragraph 13.4.2). The baseline employment conditions in the area should be established and the types of jobs generated should be considered in the context of the available workforce.
3.88 The assessment should consider the potential impacts of the proposed development on recreation, e.g. for users of the River Irwell, the canal system, hotels and tourist attractions which are identified in paragraph 13.2.1 of the Scoping Report.
3.89 The Scoping Report states that recognised methodologies for calculating socio-economic effects will be used in the assessment (paragraph 13.1.2). These methodologies should be clearly explained, and any guidance used should be referenced within the ES.
3.90 The Applicant’s attention is drawn to the comments of Salford City Council (see Appendix 2) regarding assessing the impacts of the proposed development on application sites in the vicinity that have planning permission.
Cumulative Effects (Section 14 of the Scoping Report)
3.91 The IPC welcomes the proposed assessment of cumulative effects and directs the Applicant to Appendix 3 of this Opinion for further information.
Other Matters
3.92 The Scoping Report states that new overhead lines will form part of the proposed development. As such, the IPC considers that the potential impacts of electromagnetic effects should be identified and, where necessary, assessed within the ES.
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4.0 OTHER INFORMATION
4.1 This section does not form part of the IPC’s opinion with regards to the information to be provided in the ES. However, it does respond to other issues that the IPC has identified which may help to inform the preparation of the application for the DCO.
Sites of Special Scientific Interest (SSSIs)
4.7 Where there may be potential impacts on the SSSIs, the Examining authority has duties under sections 28(G) and 28(I) of the Wildlife and Countryside Act 1981 (as amended) (the W&C Act). These are set out below for information.
4.8 Under s28(G), the decision maker has a general duty ‘… to take reasonable steps, consistent with the proper exercise of the authority’s functions, to further the conservation and enhancement of the flora, fauna or geological or physiographical features by reason of which the site is of special scientific interest’.
4.9 Under s28(I), the IPC/SoS must notify the relevant nature conservation body (NCB), NE in this case, before authorising the carrying out of operations likely to damage the special interest features of a SSSI. Under these circumstances 28 days must elapse before deciding whether to grant consent, and the IPC/SoS must take account of any advice received from the NCB, including advice on attaching conditions to the consent. The NCB will be notified during the examination period.
4.10 If applicants consider it likely that notification may be necessary under s28(I), they are advised to resolve any issues with the NCB before the DCO application is submitted to the IPC. If, following assessment by applicants, it is considered that operations affecting the SSSI will not lead to damage of the special interest features, applicants should make this clear in the ES. The application documents submitted in accordance with Regulation 5(2)(l) could also provide this information. Applicants should seek to agree with NE the DCO requirements which will provide protection for the SSSI before the DCO application is submitted.
European Protected Species (EPS)
4.11 The Applicant should also be aware that the decision maker under the Planning Act 2008 (PA 2008) has, as the competent authority (CA), a duty to engage with the Habitats Directive.
4.12 The IPC notes that there is potential for the presence of EPS within the study area for the proposed development. Where a potential risk to an
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EPS is identified and before making a decision to grant development consent the CA must, amongst other things, address the derogation tests in Regulation 53 of the Habitats Regulations. Therefore the Applicant may wish to provide information which will assist the decision maker to meet this duty. Where required the Applicant should, in consultation with NE, agree appropriate requirements to secure necessary mitigation.
4.13 If the Applicant has concluded (in consultation with NE) that an EPS licence is required the ExA will need to understand whether there is any impediment to the licence being granted. It would assist the examination if the Applicant could provide with the application confirmation from NE whether they intend to issue the licence in due course.
Health Impact Assessment
4.14 The IPC considers that it is a matter for the Applicant to decide whether or not to submit a stand-alone Health Impact Assessment (HIA) and that the Applicant should have particular regard to the responses received from the relevant consultees regarding health. The methodology for the HIA, if prepared, should be agreed with the relevant statutory consultees and take into account mitigation measures for acute risks.
4.15 The Applicant’s attention is drawn to the comments of the Health Protection Agency in Appendix 2 for further information on assessing the potential impact of the proposed development on public health.
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APPENDIX 1
CONSULTATION BODIES
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APPENDIX 1: CONSULTATION BODIES
The table below includes all the consultation bodies formally consulted by the IPC under Regulation 9(1)(a) of the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009.
SCHEDULE 1 DESCRIPTION ORGANISATION The Health and Safety Executive Health and Safety Executive The Relevant Strategic Health NHS North Of England Authority Natural England Natural England The Historic Buildings and English Heritage Monuments Commission for England The Relevant Fire and Rescue Greater Manchester Fire and Rescue Authority Service The Relevant Police Authority Greater Manchester Police Authority The Relevant Parish Council(s) or Ringway Parish Council Relevant Community Council Rixton-with-Glazebrook Parish Council Culcheth and Glazebury Parish Council The Environment Agency The Environment Agency The Commission for Architecture and CABE at Design Council The Built Environment The Relevant Regional Development North West Regional Development Agency Agency The Equality and Human Rights Equality and Human Rights Commission Commission The Commission for Sustainable Sustainable Development Commission Development The Homes and Communities Homes and Communities Agency Agency The Highways Agency The Highways Agency Integrated Transport Authorities Greater Manchester Combined Authority (ITAs) and Passenger Transport Transport for Greater Manchester Executives (PTEs) The Relevant Highways Authority Manchester City Council Salford City Council The Passengers Council Passenger Focus The Disabled Persons Transport Disabled Persons Transport Advisory Advisory Committee Committee The Coal Authority The Coal Authority The Office Of Rail Regulation Office of Rail Regulation (Customer Correspondence Team Manager) Approved Operator Network Rail Infrastructure Ltd Network Rail (CTRL) Ltd The Gas and Electricity Markets OFGEM Authority The Water Services Regulation OFWAT Authority
A1-1 120323_TR040008_1051473
The Relevant Waste Regulation The Environment Agency - Regional Authority contact The British Waterways Board The British Waterways Board The Health Protection Agency Health Protection Agency The Relevant Local Resilience forum Greater Manchester LRF The Crown Estate Commissioners The Crown Estate RELEVANT STATUTORY UNDERTAKERS Strategic Health Authority NHS North Of England NHS Foundation Trust University Hospital Of South Manchester NHS Foundation Trust Trafford Healthcare NHS Trust The Christie NHS Foundation Trust Central Manchester University Hospitals NHS Foundation Trust Salford Royal NHS Foundation Trust Pennine Acute Hospitals NHS Trust Greater Manchester West Mental Health NHS Foundation Trust Stockport NHS Foundation Trust Pennine Care NHS Foundation Trust Special Health Authority National Institute for Health and Clinical Excellence Primary Care Trust NHS Manchester NHS Stockport NHS Heywood, Middleton and Rochdale Salford Primary Care Trust NHS Bolton NHS Oldham NHS Bury NHS Trafford Ambulance Trust North West Ambulance Service NHS Trust Railway Network Rail Infrastructure Ltd BRB Residuary Limited Network Rail (CTRL) Ltd Light Railway Transport for Greater Manchester Water Transport The British Waterways Board Navigation Authorities Manchester Ship Canal Company Limited Manchester Ship Canal Company Limited C/O The Bridgewater Canal Company Dock Manchester Ship Canal Company Limited Universal Service Provider Royal Mail Group Water and Sewage Undertakers United Utilities Relevant Homes and Communities Homes and Communities Agency Agency Relevant Regional Development North West Regional Development Agency Agency Relevant Environment Agency The Environment Agency - Regional contact
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Public Gas Transporter British Gas Pipelines Limited Energetics Gas Limited ES Pipelines Ltd ESP Connections Ltd ESP Networks Ltd ESP Pipelines Ltd Fulcrum Pipelines Limited GTC Pipelines Limited Independent Pipelines Limited LNG Portable Pipeline Services Limited National Grid Gas Plc National Grid Gas Plc Quadrant Pipelines Limited Scotland Gas Networks Plc Southern Gas Networks Plc SSE Pipelines Ltd The Gas Transportation Company Limited Utility Grid Installations Limited Wales and West Utilities Ltd Electricity Distributors With CPO Electricity North West Limited Powers Energetics Electricity Limited ESP Electricity Limited Independent Power Networks Limited The Electricity Network Company Limited Electricity Transmitters With CPO National Grid Powers SECTION 43 CONSULTEES Local Authority Bolton Metropolitan Borough Council Bury Metropolitan Borough Council Manchester City Council Oldham Metropolitan Borough Council Rochdale Borough Council Salford City Council Stockport Council Tameside Metropolitan Borough Council Trafford Council Wigan Council Cheshire East Council Warrington Borough Council
Note: the Prescribed Consultees have been consulted in accordance with the IPC’s Advice Note 3 ‘Meeting the Commission’s Obligations’ (July 2011)
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APPENDIX 2
RESPONDENTS TO CONSULTATION AND COPIES OF REPLIES
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APPENDIX 2: RESPONDENTS TO CONSULTATION AND COPIES OF REPLIES
Consultation bodies who replied by the statutory deadline are shown in the table below with copies of their replies below.
Central Manchester University Hospitals NHS Coal Authority Culcheth and Glazebury PC English Heritage Environment Agency E S Pipelines Ltd, ESP Networks Ltd, ESP Pipelines Ltd, ESP Electricity Ltd and ESP Connections Ltd Greater Manchester Combined Authority Health and Safety Executive Health Protection Agency Highways Agency National Grid Natural England Pennine Acute Hospital NHS Trust Salford City Council SSE Pipelines Transport for Greater Manchester Wigan Council
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UNCLASSIFIED
200 Lichfield Lane Berry Hill Mansfield Nottinghamshire NG18 4RG
Tel: 01623 637 119 (Planning Enquiries)
Email: [email protected]
Web: www.coal.gov.uk/services/planning
FAO: Hannah Pratt – EIA and Land Rights Advisor on behalf of the IPC Infrastructure Planning Commission
[By Email: [email protected]]
05 March 2012
Dear Ms Pratt
Proposed Ordsall Chord
Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 SI 2263
Thank you for your consultation letter of 14 February 2012 seeking the views of The Coal Authority on the EIA Scoping Opinion for the above proposal.
I have reviewed the document provided by the developer and can confirm that The Coal Authority is satisfied that due consideration is being afforded to the issue of coal mining legacy, given that the site falls within the defined coalfield, with reference set out in paragraphs 10.2.9, 10.3.2 and 10.4.4 of the document.
The proposed Ordsall Chord falls within the defined coalfield, and therefore the Environmental Statement should afford some consideration to the legacy of past coal mining activity; although The Coal Authority records indicate there are no recorded surface hazards within the site.
Please do not hesitate to contact me if you would like to discuss this matter further.
Yours sincerely
Mark Harrison
Mark E. N. Harrison B.A.(Hons), DipTP, MRTPI Planning Liaison Manager
1
Protecting the public and the environment in coal mining areas
General Information for the Applicant
The Environmental Statement should include a risk assessment of the coal mining legacy, which should interpret the coal mining risks and be based on, and add to, up-to-date information of past coal mining activities in relation to the application site. Coal Mining Reports are available from www.groundstability.com or by telephoning 0845 762 6848.
This coal mining information should then be used to assess whether or not past mining activity poses any risk to the development proposal and, where necessary, propose mitigation measures to address any issues of land instability.
Disclaimer
The above consultation response is provided by The Coal Authority as a Statutory Consultee and is based upon the latest available data and records held by The Coal Authority on the date of the response. The comments made are also based upon only the information provided to The Coal Authority by the Local Planning Authority and/or has been published on the Council's website for consultation purposes in relation to this specific planning application. The views and conclusions contained in this response may be subject to review and amendment by The Coal Authority if additional or new data/information (such as a revised Coal Mining Risk Assessment) is provided by the Local Planning Authority or the Applicant for consultation purposes.
2
Protecting the public and the environment in coal mining areas
From: Mike Durrington To: IPC Scoping Opinion; Subject: Proposed Ordsall Chord - 120214_TR040008_1051212 Date: 07 March 2012 15:33:50
Dear Hannah, The Parish Council confirm that they have no comment to make on the proposal at this stage. Regards, Mike Mike Durrington Clerk, Culcheth & Glazebury Parish Council
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Hannah Pratt, Direct dial 0161-242-1412 Infrastructure Planning Commission, Temple Quay House, Your ref: 120214_TR040008 Temple Quay, _1051212 Bristol, BS1 6PN. Our ref: 839 9 March, 2012
Dear Ms Pratt,
PROPOSED ORDSALL CHORD (the project) PROPOSAL BY NETWORK RAIL (the developer) INFRASTRUCTURE PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) REGULATIONS 2009 SI 2263 (the EIA Regulations)
I refer to your letter of 14 February 2012, seeking the views of English Heritage on the information which should be provided in an environmental statement relating to the proposed Ordsall Chord.
English Heritage is the Government’s statutory advisor on the historic environment. A specific concern, therefore, is the impact of proposed developments on listed buildings, scheduled ancient monuments, conservation area, and other nationally important elements of the historic environment, whether designated or undesignated.
Before commenting in detail on the Scoping Report, I must make it clear that English Heritage believes that the initial option selection process which resulted in the selection of the Ordsall Chord as the preferred option for creating a new link between Manchester Piccadilly and Manchester Victoria was fundamentally flawed. By adopting only engineering and financial criteria in that option selection process, Network Rail has created a situation where the construction of their preferred option will almost inevitably result in substantial harm being caused to heritage assets of the highest importance. Given the importance of Manchester’s historic environment, and particularly the importance of its early railway heritage, we believe that considerations of potential impacts on the historic environment should have been factored into the initial option selection process.
Manchester’s Liverpool Road Station, now part of the Museum of Science and Industry [MOSI], is the earliest surviving passenger railway terminus in the world. The complex includes highly graded buildings and structures constructed for the opening of the world’s first inter-city railway, the Liverpool and Manchester, in 1830. It is a complex of the highest importance in heritage terms. Were the Ordsall Chord to be constructed, it would inevitably impact upon the setting of MOSI and the buildings of the former Liverpool Road Station, and would have a physical impact on the grade I listed Stephenson’s Bridge, which carries the original line of the Liverpool and Manchester Railway westwards across the River Irwell.
Government guidance, set out in PPS5, Planning for the Historic Environment, makes it clear that there should be a presumption in favour of the conservation of designated heritage assets, and that substantial harm to or loss of designated heritage assets of the highest significance, including grade I and II* listed buildings, “should be wholly exceptional” (Policy HE9.1). HE9.2 states that where an application will lead to substantial harm to or total loss of significance, consent should be refused unless it can be demonstrated that “the substantial harm to or loss of significance is necessary in order to deliver substantial public benefits that out weigh that harm or loss”. In our view, it will be hard to argue that substantial harm to the Stephenson Bridge and to the setting of MOSI is necessary to deliver substantial public benefits if alternatives to the Ordsall Chord are available but have simply been ruled out at the outset on the grounds of engineering complexity or cost.
Subject to these significant reservations, we have the following comments on the Scoping Report, and particularly on those sections relating to Archaeology & Cultural Heritage, and Townscape and Visual Amenity. We note that it is proposed to exclude a number of disciplines from consideration in the EIA, on the grounds that effects are considered to be negligible. Whilst we have no concerns about the majority of the disciplines to be scoped out, we consider that Transport might merit some consideration, because of the potential impact of the Ordsall Chord on rail links to MOSI, and therefore on the future operation of the museum.
Archaeology & Cultural Heritage
Whilst there is a separate chapter on Townscape and Visual Amenity, the historic townscape should be considered as part of the cultural heritage, and therefore be included among the receptors listed at para 4.1.3. The Environmental Constraints Plans in Appendix B illustrate only listed buildings/structures and conservation areas. The Plans really need to illustrate all heritage assets, whether designated or identified as locally important, including below-ground archaeology.
The spatial scope of the assessment (para 4.2.1 may need to be extended in certain areas, particularly where setting is being considered. There could potentially be an impact on the settings of listed buildings further east along Liverpool Road than the boundary shown on the Red Line Plan, for example.
It is important that the historic assets within the study area, and particularly the group of transport-related assets at its core, are dealt with as a cluster. Assessing importance and impact on an asset-by-asset basis may result in an under- appreciation of significance and an under-recording of the cumulative impact upon the historic environment. The assessment method therefore needs to address what might be described as the ‘cumulative sensitivity’ of the cluster of historic assets within the study area, and not just that of each individual receptor/resource (para 4.5.2) and the ‘cumulative impact’ on the cluster, and not just that on an individual receptor/resource (para 4.53).
Townscape & Visual Impact
The assessment of the sensitivity, quality and character of existing townscape and landscape features should be based upon existing historic characterisation. The Greater Manchester Urban Historic Landscape Characterisation, compiled by the Greater Manchester Archaeological Unit, will provide a basis for more detailed characterisation of the study area (para 8.2.3).
In addition to the quoted sources of guidance, the assessment method should be based on the guidance on historic characterisation issued by English Heritage, such as Understanding Place: Historic Area Assessments – Principles and Practice (English Heritage 2010), and Understanding Place: Character and context in local planning (English Heritage 2011).
Mitigation of Significant Adverse Effects
We note that options to reduce or remove significant adverse effects will be explored during the detailed design process (para 4.6.1), and welcome the fact that a Heritage Architect has been appointed to inform the developing design in terms of heritage impacts and mitigation of significant adverse effects (para 4.6.2). However, we can find no suggestion in the Scoping Report that any consideration is being given to creating landmark new bridge structures of exceptional design quality to carry the proposed new line over the River Irwell and the Inner Ring Road. This might, it could be argued, provide some mitigation for the significant harm which will be caused to historic assets and to their settings by the construction of the Ordsall Chord. The description of the proposed new bridges at para 2.2.5 suggests that the opportunity to create landmark new structures has not been grasped.
Yours sincerely,
Andrew Davison Inspector of Ancient Monuments/Team Leader e-mail: [email protected]
Our ref: SO/2012/110245/01-L01 Infrastructure Planning Commission Your ref: Temple Quay House (2 The Square) 120214_TR040008_1051212 Temple Quay Bristol Date: 13 March 2012 Avon BS1 6PN
FAO Hannah Pratt
Dear Madam
PROPOSED ORDSALL RAIL CHORD - SCOPING CONSULTATION PROPOSAL BY NETWORK RAIL
Thank you for consulting this Agency on the above scoping opinion.
We have no objection in principle to the proposed scheme and would make the following comments on the Scoping Report (127523-A-ENV-REP-PBL-0004 Revision P02):-
We would prefer to see any new bridge design for crossing the river to be of free span design and avoiding new piers within the main channel. The existing channel width should also be retained in order to maintain flood flow capacity of the river.
If it is proposed to locate a pier in the river, the EIA should consider the effects of scour on the river bed and the potential mobilisation of contaminated sediments.
We would agree with the proposal to include a flood risk assessment in the EIA. The Scoping Report has identified the main issues to consider in relation to content of a FRA. We would be pleased to comment on any draft FRA in due course.
We welcome Network Rail's commitment to undertake a full ecological assessment as part of the proposed Ordsall Chord development area as part of overall EIA process, and deliver a high quality landscape design, that encourages greater biodiversity interest, particularly with this sited along the key ecological network and wildlife corridor of the River Irwell.
We note that water quality has been scoped out for the operational phase but it is important that the water quality is fully considered during the construction phase, particularly if a new pier is to be located within the river channel.
Environment Agency Richard Fairclough House Knutsford Road, Warrington, WA4 1HT. Customer services line: 03708 506 506 www.environment-agency.gov.uk Cont/d..
We would highly recommend that any extended Phase One survey is conducted at an appropriate time of year, to ensure the majority of ecological constraints be identified, and the need for any further protected species are fully identified. Based on current scheme proposals indicating works in the river channel may be required, through new bridge works or demolitions, aquatic as well as terrestrial ecology must also be considered as part of any EIA.
We would welcome as part of any options appraisal, any opportunity to potentially open up this heavily traversed and highly shaded section of the River Irwell, and to increase the extent and quality of greenspace and riverine recreational routeway along this portion of the Irwell River Park.
If you or the developer require any further information or have any queries, please do not hesitate to contact me.
Yours faithfully
Mr CHRIS WARING Planning Technical Specialist
Direct dial 01925 542497 Direct fax 01925 415961 Direct e-mail [email protected]
End 2
From: Alan Slee To: IPC Scoping Opinion; Subject: RE: PROPOSED ORDSALL RAIL CHORD - SCOPING CONSULTATION Date: 20 February 2012 11:31:10
Dear Alison,
PROPOSED ORDSALL CHORD (the project) PROPOSAL BY NETWORK RAIL (the developer) 120214_TR040008_1051212 Post Codes M3 5EN, M3 4PU Grids 382964, 398276 : 382890,397846
Further to your letter communication to E S Pipelines Ltd, ESP Networks Ltd, ESP Pipelines Ltd, ESP Electricity Ltd and ESP Connections Ltd dated 14 February 2012 confirm that our businesses have no comments at this stage.
Regards,
Alan Slee Operations Manager
DD 01372 227567 Mobile 07766 802070 Fax 01372 386203 www.espipelines.com
From: IPC Scoping Opinion [mailto:[email protected]. uk] Sent: 14 February 2012 15:28 To: Alan Slee Subject: FW: PROPOSED ORDSALL RAIL CHORD - SCOPING CONSULTATION
Dear Sir/Madam
Please find attached a letter about a scoping consultation for the above proposal.
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Alison L Down EIA and Land Rights Advisor Infrastructure Planning Commission (IPC) Temple Quay House Temple Quay Bristol BS1 6PN
Direct Line: 030 3444 5039 Helpline: 0303 444 5000 Email: [email protected] Web: www.independent.gov.uk/infrastructure
The IPC gives advice about applying for an order granting development consent or making representations about an application (or a proposed application). The IPC takes care to ensure that the advice we provide is accurate. This communication does not however constitute legal advice upon which you can rely and you should note that IPC lawyers are not covered by the compulsory professional indemnity insurance scheme. You should obtain your own legal advice and professional advice as required.
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From: [email protected] To: IPC Scoping Opinion; Subject: Infrastructure Planning Commission - GMCA - Ordsall Chord project Date: 13 March 2012 17:41:26
Dear Hannah,
Thank you for consulting the Greater Manchester Combined Authority with regard to the environmental statement to be prepared by Network Rail with regard to the Ordsall Chord scheme.
The GMCA, and its constituent bodies, are very supportive of the Ordsall Chord scheme and are pleased that good progress in now being made in bringing the scheme forward.
In terms of information and issues we would ask the IPC to consider, firstly we are keen that the IPC has full regard to the comments that will be submitted by Transport for Greater Manchester, Manchester City Council and Salford City Council.
Secondly, we would ask that the Developer is reminded of the need to be very sensitive to the heritage impacts of this scheme, which is situated in an area of enormous historical significance. Further, it will be incumbent on the Developer to consider fully all the long term impacts of the Scheme on the local highway network, including any negative impacts on cycling and walking routes, and work to reduce these to an absolute minimum.
Finally, we are also keen that the Developer in setting out any construction project plan, is sufficiently aware of any negative impacts that may arise on the local highway and railway networks during the construction phase, and that it commits to working closely and consulting with the local highway authorities and TfGM at all times in order to mitigate these.
Yours sincerely,
Roderick Fawcett Principal Policy Officer
Greater Manchester Integrated Support Team Telephone: (0161) 234 3023 Mobile: 07946 330576 www.agma.gov.uk ********************
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Centre for Radiation, Chemical and Environmental Hazards
Health Protection Agency FAO Hannah Pratt Centre for Radiation, Infrastructure Planning Commission Chemical and Environmental Hazards [email protected]
Chilton, Didcot Oxfordshire OX11 0RQ
8 th March 2012 Tel +44 (0) 1235 822849 Fax: +44 (0) 1235 833891 www.hpa.org.uk/IPC
Your Ref: 120214_TR040008_1051212
Our Ref: TR_RA_RA_120214_131
Dear Hannah
Proposed Ordsall Chord Development
Network Rail has asked the Infrastructure Planning Commission (IPC) for its opinion (“scoping opinion”) on the information to be provided in an Environmental Statement (ES) relating to a proposal for a 1.5 km chord line linking Manchester Piccadilly Station and Manchester Victoria Station, via Oxford Road Station and Deal Street Junction. The request for a scoping opinion is a precursor to an intensive and detailed independent assessment of the environmental impact of the proposed development.
The HPA is a statutory consultee at the pre-application and application stages for nationally significant infrastructure projects (NSIPs) “which are likely to involve chemicals, poisons or radiation which could potentially cause harm to people.”1 For those NSIP applications subject to Environmental Impact Assessment (EIA) the HPA is a consultation body under the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009.
The IPC must therefore consult the HPA on the information that the HPA considers should be provided in the ES (or confirm that the HPA has no comments) before the IPC adopts its scoping opinion.
The HPA’s enclosed response focuses on health protection issues relating to chemicals and radiation. The advice offered by the HPA is impartial and independent. The scope of the HPA’s response does not extend to wider health matters; these fall under the remit of other stakeholders.
The Appendix outlines generic considerations that the HPA advises are addressed by all promoters when they are preparing ESs for NSIPs. In terms of the level of detail to be included in ESs, the HPA recognises that the differing nature of projects is such that their impacts will vary. The HPA’s view is that the assessments undertaken to inform the ES should be proportionate to the potential impacts of the proposal. Where a promoter determines that it is not necessary to undertake detailed
1 Cited in the Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009
assessment(s) (e.g. undertakes qualitative rather than quantitative assessments), if the rationale for this is fully explained and justified within the application documents, then the HPA considers this to be an acceptable approach.
Yours sincerely
Head of Department Environmental Hazards & Emergencies Department
[email protected] Please mark any correspondence for the attention of Ms Clare Gruar.
Page 2 of 9
Appendix: HPA recommendations regarding the scoping document
General approach The EIA should give consideration to best practice guidance such as the Government’s Good Practice Guide for EIA2. It is important that the EIA identifies and assesses the potential public health impacts of the activities at, and emissions from, the installation. Assessment should consider the development, operational, and decommissioning phases.
The EIA Directive3 requires that ESs include a description of the aspects of the environment likely to be significantly affected by the development, including “population”. The EIA should provide sufficient information for the HPA to fully assess the potential impact of the development on public health. The HPA will only consider information contained or referenced in a separate section of the ES summarising the impact of the proposed development on public health: summarising risk assessments, proposed mitigation measures, and residual impacts. This section should summarise key information and conclusions relating to human health impacts contained in other sections of the application (e.g. in the separate sections dealing with: air quality, emissions to water, waste, contaminated land etc) without undue duplication. Compliance with the requirements of National Policy Statements and relevant guidance and standards should be highlighted.
It is not the HPA’s role to undertake these assessments on behalf of promoters as this would conflict with the HPA’s role as an impartial and independent body.
Consideration of alternatives (including alternative sites, choice of process, and the phasing of construction) is widely regarded as good practice. Ideally, EIA should start at the stage of site and process selection, so that the environmental merits of practicable alternatives can be properly considered. Where this is undertaken, the main alternatives considered should be outlined in the ES4.
The following text covers a range of issues that the HPA would expect to be addressed by the promoter. However this list is not exhaustive and the onus is on the promoter to ensure that the relevant public health issues are identified and addressed. The HPA’s advice and recommendations carry no statutory weight and constitute non-binding guidance.
Receptors The ES should clearly identify the development’s location and the location and distance from the development of off-site human receptors that may be affected by emissions from, or activities at, the development. Off-site human receptors may include people living in residential premises; people working in commercial, and industrial premises and people using transport infrastructure (such as roads and railways), recreational areas, and publicly-accessible land. Consideration should also be given to environmental receptors such as the surrounding land, watercourses, surface and groundwater, and drinking water supplies such as wells, boreholes and water abstraction points.
Impacts arising from construction and decommissioning Any assessment of impacts arising from emissions due to construction and decommissioning should consider potential impacts on all receptors and describe monitoring and mitigation during these phases. Construction and decommissioning will be associated with vehicle movements and cumulative impacts should be accounted for.
2 Environmental Impact Assessment: A guide to good practice and procedures - A consultation paper; 2006; Department for Communities and Local Government. Available from: http://www.communities.gov.uk/archived/publications/planningandbuilding/environmentalimpactassessment 3 Directive 85/337/EEC (as amended) on the assessment of the effects of certain public and private projects on the environment. Available from: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:1985L0337:20090625:EN:PDF 4 DCLG guidance, 1999 http://www.communities.gov.uk/documents/planningandbuilding/pdf/155958.pdf Page 3 of 9
We would expect the promoter to follow best practice guidance during all phases from construction to decommissioning to ensure appropriate measures are in place to mitigate any potential impact on health from emissions (point source, fugitive and traffic-related). An effective Construction Environmental Management Plan (CEMP) (and Decommissioning Environmental Management Plan (DEMP)) will help provide reassurance that activities are well managed. The promoter should ensure that there are robust mechanisms in place to respond to any complaints of traffic-related pollution, during construction, operation, and decommissioning of the facility.
Emissions to air and water Significant impacts are unlikely to arise from installations which employ Best Available Techniques (BAT) and which meet regulatory requirements concerning emission limits and design parameters. However, the HPA has a number of comments regarding emissions in order that the EIA provides a comprehensive assessment of potential impacts.
When considering a baseline (of existing environmental quality) and in the assessment and future monitoring of impacts these: • should include appropriate screening assessments and detailed dispersion modelling where this is screened as necessary • should encompass all pollutants which may be emitted by the installation in combination with all pollutants arising from associated development and transport, ideally these should be considered in a single holistic assessment • should consider the construction, operational, and decommissioning phases • should consider the typical operational emissions and emissions from start-up, shut-down, abnormal operation and accidents when assessing potential impacts and include an assessment of worst-case impacts • should fully account for fugitive emissions • should include appropriate estimates of background levels • should identify cumulative and incremental impacts (i.e. assess cumulative impacts from multiple sources), including those arising from associated development, other existing and proposed development in the local area, and new vehicle movements associated with the proposed development; associated transport emissions should include consideration of non-road impacts (i.e. rail, sea, and air) • should include consideration of local authority, Environment Agency, Defra national network, and any other local site-specific sources of monitoring data • should compare predicted environmental concentrations to the applicable standard or guideline value for the affected medium (such as UK Air Quality Standards and Objectives and Environmental Assessment Levels) If no standard or guideline value exists, the predicted exposure to humans should be estimated and compared to an appropriate health-based value (a Tolerable Daily Intake or equivalent). Further guidance is provided in Annex 1 This should consider all applicable routes of exposure e.g. include consideration of aspects such as the deposition of chemicals emitted to air and their uptake via ingestion • should identify and consider impacts on residential areas and sensitive receptors (such as schools, nursing homes and healthcare facilities) in the area(s) which may be affected by emissions, this should include consideration of any new receptors arising from future development
Whilst screening of impacts using qualitative methodologies is common practice (e.g. for impacts arising from fugitive emissions such as dust), where it is possible to undertake a quantitative assessment of impacts then this should be undertaken.
The HPA’s view is that the EIA should appraise and describe the measures that will be used to control both point source and fugitive emissions and demonstrate that standards, guideline values or health- based values will not be exceeded due to emissions from the installation, as described above. This should include consideration of any emitted pollutants for which there are no set emission limits. When assessing the potential impact of a proposed installation on environmental quality, predicted Page 4 of 9
environmental concentrations should be compared to the permitted concentrations in the affected media; this should include both standards for short and long-term exposure.
Additional points specific to emissions to air When considering a baseline (of existing air quality) and in the assessment and future monitoring of impacts these: • should include consideration of impacts on existing areas of poor air quality e.g. existing or proposed local authority Air Quality Management Areas (AQMAs) • should include modelling using appropriate meteorological data (i.e. come from the nearest suitable meteorological station and include a range of years and worst case conditions) • should include modelling taking into account local topography
Additional points specific to emissions to water When considering a baseline (of existing water quality) and in the assessment and future monitoring of impacts these: • should include assessment of potential impacts on human health and not focus solely on ecological impacts • should identify and consider all routes by which emissions may lead to population exposure (e.g. surface watercourses; recreational waters; sewers; geological routes etc.) • should assess the potential off-site effects of emissions to groundwater (e.g. on aquifers used for drinking water) and surface water (used for drinking water abstraction) in terms of the potential for population exposure • should include consideration of potential impacts on recreational users (e.g. from fishing, canoeing etc) alongside assessment of potential exposure via drinking water
Land quality We would expect the promoter to provide details of any hazardous contamination present on site (including ground gas) as part of the site condition report.
Emissions to and from the ground should be considered in terms of the previous history of the site and the potential of the site, once operational, to give rise to issues. Public health impacts associated with ground contamination and/or the migration of material off-site should be assessed5 and the potential impact on nearby receptors and control and mitigation measures should be outlined.
Relevant areas outlined in the Government’s Good Practice Guide for EIA include: • effects associated with ground contamination that may already exist • effects associated with the potential for polluting substances that are used (during construction / operation) to cause new ground contamination issues on a site, for example introducing / changing the source of contamination • impacts associated with re-use of soils and waste soils, for example, re-use of site-sourced materials on-site or offsite, disposal of site-sourced materials offsite, importation of materials to the site, etc.
Waste The EIA should demonstrate compliance with the waste hierarchy (e.g. with respect to re-use, recycling or recovery and disposal).
For wastes arising from the installation the EIA should consider: • the implications and wider environmental and public health impacts of different waste disposal options • disposal route(s) and transport method(s) and how potential impacts on public health will be mitigated
5 Following the approach outlined in the section above dealing with emissions to air and water i.e. comparing predicted environmental concentrations to the applicable standard or guideline value for the affected medium (such as Soil Guideline Values) Page 5 of 9
Other aspects Within the EIA the HPA would expect to see information about how the promoter would respond to accidents with potential off-site emissions e.g. flooding or fires, spills, leaks or releases off-site. Assessment of accidents should: identify all potential hazards in relation to construction, operation and decommissioning; include an assessment of the risks posed; and identify risk management measures and contingency actions that will be employed in the event of an accident in order to mitigate off-site effects.
The EIA should include consideration of the COMAH Regulations (Control of Major Accident Hazards) and the Major Accident Off-Site Emergency Plan (Management of Waste from Extractive Industries) (England and Wales) Regulations 2009: both in terms of their applicability to the installation itself, and the installation’s potential to impact on, or be impacted by, any nearby installations themselves subject to the these Regulations.
There is evidence that, in some cases, perception of risk may have a greater impact on health than the hazard itself. A 2009 report6, jointly published by Liverpool John Moores University and the HPA, examined health risk perception and environmental problems using a number of case studies. As a point to consider, the report suggested: “Estimation of community anxiety and stress should be included as part of every risk or impact assessment of proposed plans that involve a potential environmental hazard. This is true even when the physical health risks may be negligible.” The HPA supports the inclusion of this information within EIAs as good practice.
Electromagnetic fields (EMF) There is a potential health impact associated with the electric and magnetic fields around substations and the connecting cables or lines. The following information provides a framework for considering the potential health impact.
In March 2004, the National Radiological Protection Board, NRPB (now part of the HPA), published advice on limiting public exposure to electromagnetic fields. The advice was based on an extensive review of the science and a public consultation on its website, and recommended the adoption in the UK of the EMF exposure guidelines published by the International Commission on Non-ionizing Radiation Protection (ICNIRP):- http://www.hpa.org.uk/Publications/Radiation/NPRBArchive/DocumentsOfTheNRPB/Absd1502/
The ICNIRP guidelines are based on the avoidance of known adverse effects of exposure to electromagnetic fields (EMF) at frequencies up to 300 GHz (gigahertz), which includes static magnetic fields and 50 Hz electric and magnetic fields associated with electricity transmission.
HPA notes the current Government policy is that the ICNIRP guidelines are implemented in line with the terms of the EU Council Recommendation on limiting exposure of the general public (1999/519/EC): http://www.dh.gov.uk/en/Publichealth/Healthprotection/DH_4089500
For static magnetic fields, the latest ICNIRP guidelines (2009) recommend that acute exposure of the general public should not exceed 400 mT (millitesla), for any part of the body, although the previously recommended value of 40 mT is the value used in the Council Recommendation. However, because of potential indirect adverse effects, ICNIRP recognises that practical policies need to be implemented to prevent inadvertent harmful exposure of people with implanted electronic medical devices and
6 Available from: http://www.cph.org.uk/showPublication.aspx?pubid=538 Page 6 of 9
implants containing ferromagnetic materials, and injuries due to flying ferromagnetic objects, and these considerations can lead to much lower restrictions, such as 0.5 mT as advised by the International Electrotechnical Commission.
At 50 Hz, the known direct effects include those of induced currents in the body on the central nervous system (CNS) and indirect effects include the risk of painful spark discharge on contact with metal objects exposed to the field. The ICNIRP guidelines give reference levels for public exposure to 50 Hz electric and magnetic fields, and these are respectively 5 kV m−1 (kilovolts per metre) and 100 μT (microtesla). If people are not exposed to field strengths above these levels, direct effects on the CNS should be avoided and indirect effects such as the risk of painful spark discharge will be small. The reference levels are not in themselves limits but provide guidance for assessing compliance with the basic restrictions and reducing the risk of indirect effects. Further clarification on advice on exposure guidelines for 50 Hz electric and magnetic fields is provided in the following note on the HPA website: http://www.hpa.org.uk/webw/HPAweb&HPAwebStandard/HPAweb_C/1195733805036
The Department of Energy and Climate Change has also published voluntary code of practices which set out key principles for complying with the ICNIRP guidelines for the industry. http://www.decc.gov.uk/en/content/cms/what_we_do/uk_supply/consents_planning/codes/codes.aspx
There is concern about the possible effects of long-term exposure to electromagnetic fields, including possible carcinogenic effects at levels much lower than those given in the ICNIRP guidelines. In the NRPB advice issued in 2004, it was concluded that the studies that suggest health effects, including those concerning childhood leukaemia, could not be used to derive quantitative guidance on restricting exposure. However, the results of these studies represented uncertainty in the underlying evidence base, and taken together with people’s concerns, provided a basis for providing an additional recommendation for Government to consider the need for further precautionary measures, particularly with respect to the exposure of children to power frequency magnetic fields.
The Stakeholder Advisory Group on ELF EMFs (SAGE) was then set up to take this recommendation forward, explore the implications for a precautionary approach to extremely low frequency electric and magnetic fields (ELF EMFs), and to make practical recommendations to Government. In the First Interim Assessment of the Group, consideration was given to mitigation options such as the 'corridor option' near power lines, and optimal phasing to reduce electric and magnetic fields. A Second Interim Assessment addresses electricity distribution systems up to 66 kV. The SAGE reports can be found at the following link: http://sagedialogue.org.uk/ (go to “Document Index” and Scroll to SAGE/Formal reports with recommendations)
The Agency has given advice to Health Ministers on the First Interim Assessment of SAGE regarding precautionary approaches to ELF EMFs and specifically regarding power lines and property, wiring and electrical equipment in homes: http://www.hpa.org.uk/webw/HPAweb&HPAwebStandard/HPAweb_C/1204276682532?p=120789792 0036
The evidence to date suggests that in general there are no adverse effects on the health of the population of the UK caused by exposure to ELF EMFs below the guideline levels. The scientific evidence, as reviewed by HPA, supports the view that precautionary measures should address solely the possible association with childhood leukaemia and not other more speculative health effects. The measures should be proportionate in that overall benefits outweigh the fiscal and social costs, have a Page 7 of 9
convincing evidence base to show that they will be successful in reducing exposure, and be effective in providing reassurance to the public.
The Government response to the SAGE report is given in the written Ministerial Statement by Gillian Merron, then Minister of State, Department of Health, published on 16th October 2009: http://www.publications.parliament.uk/pa/cm200809/cmhansrd/cm091016/wmstext/91016m0001.htm http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/DH_1 07124
HPA and Government responses to the Second Interim Assessment of SAGE are available at the following links: http://www.hpa.org.uk/Publications/Radiation/HPAResponseStatementsOnRadiationTopics/rpdadvice _sage2 http://www.dh.gov.uk/en/Publicationsandstatistics/Publications/PublicationsPolicyAndGuidance/DH_1 30703
The above information provides a framework for considering the health impact associated with the proposed development, including the direct and indirect effects of the electric and magnetic fields as indicated above.
Liaison with other stakeholders, comments should be sought from: • the local authority for matters relating to noise, odour, vermin and dust nuisance • the local authority regarding any site investigation and subsequent construction (and remediation) proposals to ensure that the site could not be determined as ‘contaminated land’ under Part 2A of the Environmental Protection Act • the local authority regarding any impacts on existing or proposed Air Quality Management Areas • the Food Standards Agency for matters relating to the impact on human health of pollutants deposited on land used for growing food/ crops • the Environment Agency for matters relating to flood risk and releases with the potential to impact on surface and groundwaters • the Environment Agency for matters relating to waste characterisation and acceptance • the Primary Care Trusts and Strategic Health Authority for matters relating to wider public health
Page 8 of 9
Annex 1
Human health risk assessment (chemical pollutants) The points below are cross-cutting and should be considered when undertaking a human health risk assessment: • The promoter should consider including Chemical Abstract Service (CAS) numbers alongside chemical names, where referenced in the ES • Where available, the most recent United Kingdom standards for the appropriate media (e.g. air, water, and/or soil) and health-based guideline values should be used when quantifying the risk to human health from chemical pollutants. Where UK standards or guideline values are not available, those recommended by the European Union or World Health Organisation can be used • When assessing the human health risk of a chemical emitted from a facility or operation, the background exposure to the chemical from other sources should be taken into account • When quantitatively assessing the health risk of genotoxic and carcinogenic chemical pollutants the HPA does not favour the use of mathematical models to extrapolate from high dose levels used in animal carcinogenicity studies to well below the observed region of a dose-response relationship. When only animal data are available, we recommend that the ‘Margin of Exposure’ (MOE) approach7 is used
7 Benford D et al. 2010. Application of the margin of exposure approach to substances in food that are genotoxic and carcinogenic. Food Chem Toxicol 48 Suppl 1: S2-24 Page 9 of 9
From: Reynolds, Shaun To: IPC Scoping Opinion; cc: Wroe, Billy; Subject: Ordsall Chord - Scoping Report (HA Reference CRS - 670751) Date: 01 March 2012 09:48:37
The Highways Agency has the following comments regarding the Scoping Report of the February 2012:
-We are content that sufficient liaison opportunity has been included within this scoping report to cover issues that may arise as part of the construction period for the motorway network.
- In paragraph 12.3.4 we would like to ask for clarification on where this statement has come from. In our discussion with Network Rail we have made them aware of the possibility of us undertaking significant work on the Strategic Road Network at the same time (subject to funding decisions). In physical terms our schemes would not interact with the Ordsall Chord construction in itself but construction traffic utilising the motorway network may need to pass through parts of the SRN with significant traffic management being in place. Therefore we cannot see how the schemes would overlap to allow "construction works to be funded within or adjacent to the scheme footprint".
Regards
Shaun
Shaun Reynolds, Asset Manager Highways Agency | Piccadilly Gate | Store Street | Manchester | M1 2WD Tel: +44 (0) 161 9305824 Web: http://www.highways.gov.uk GTN: 4315 5824
Safe roads, reliable journeys, informed travellers Highways Agency, an executive agency of the Department for Transport.
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National Grid house Warwick Technology Park Gallows Hill, Warwick CV34 6DA
Land and Development Infrastructure Planning Commission Vicky Stirling Temple Quay House Policy Planner Temple Quay Lands & Development Bristol [email protected] BS1 6PN Direct tel: +44 (0)1926 653746 Mobile: +44 (0)7747 671508
www.nationalgrid.com SUBMITTED VIA EMAIL TO: [email protected]
07 March 2012 Our Ref: NW_TW_Z3_F_09726 Your Ref: TR040008
Dear Sir/Madam,
PROPOSED ORDSALL CHORD (the project) PROPOSAL BY NETWORK RAIL (the developer) INFRASTRUCTURE PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) REGULATIONS 2009 SI 2263 (the EIA Regulations)
I refer to your letter dated 14 th February concerning the above proposal and confirm that National Grid Transmission does not wish to make any representation with regard to the above scheme.
However, National Grid Gas Distribution owns and operates the local gas distribution network in the area of the proposed works. Gas distribution assets, including mains operating at a pressure above 7 bar are located within or in close proximity to the proposed site of the Project. National Grid Distribution apparatus directly crosses the development boundary: Medium or Low Pressure Gas Distribution Apparatus
Due to the presence of National Grid Gas Distribution apparatus within the development boundary, National Grid should be contacted before any physical works are carried out to ensure our apparatus is not affected by any of the proposed works and reference should be made to the HSE Guidance Note HSG47 - 'Avoiding Danger from Underground Services'.
It is essential that no mechanical excavations take place above or within 0.5 m of Low and Medium pressure systems. Safe digging practices, in accordance with Health and Safety Executive document HSG47, must be used to verify and establish the actual position of mains, pipes, cables, services and other apparatus on site before any mechanical plant is used. Further guidance and information can be found at: http://www.nationalgrid.com/uk/Gas/Safety/work/downloads/
Please find attached plans showing the location of the above mentioned assets for your reference.
We would request that the potential impact of the proposed development on our existing gas distribution assets is considered in any subsequent reports or as part of any subsequent application, including the Environmental Statement. National Grid is a trading name for: National Grid is a trading name for: National Grid Electricity Transmission plc National Grid Gas plc Registered Office: 1-3 Strand, London WC2N 5EH Registered Office: 1-3 Strand, London WC2N 5EH Registered in England and Wales, No 2366977 Registered in England and Wales, No 2006000 National Grid house Warwick Technology Park Gallows Hill, Warwick CV34 6DA
For specific advice relating to National Grid’s gas distribution network or to discuss the project with a National Grid gas engineer, please contact Plant Protection on 0800 688588 quoting Eagles reference: NW_TW_Z3_F_09726
Further Advice
If we can be of any assistance to you in providing informal comments please do not hesitate to contact us at the address below.
National Grid Land & Development Stakeholder and Policy Manager Land & Development Team National Grid House Warwick Technology Park Gallows Hill Warwick CV34 6DA
Yours sincerely,
Vicky Stirling
Vicky Stirling Land and Development (Submitted Electronically)
National Grid is a trading name for: National Grid is a trading name for: National Grid Electricity Transmission plc National Grid Gas plc Registered Office: 1-3 Strand, London WC2N 5EH Registered Office: 1-3 Strand, London WC2N 5EH Registered in England and Wales, No 2366977 Registered in England and Wales, No 2006000 SCALE: 1 : 2500 LP MAINS This plan shows those pipes owned by National Grid Gas plc in their role as a Desktop MAPS Version 5.1.2.0 MP MAINS Licensed Gas Transporters (GT). Gas pipes owned by other GTs, or otherwise privately owned, may be present in this area. USER ID: Nicola.clamp Information with regard to such pipes should be obtained from the relevant owners. The information shown on this plan IP MAINS is given without warranty, the accuracy thereof cannot be guaranteed. Service pipes, valves, syphons, stub connections, DATE: 17/02/2012 LHP MAINS etc. are not shown but their presence should be anticipated. No liability of any kind whatsoever is accepted by NHP MAINS National Grid Gas plc or their agents, servants or contractors for any error or NRSWA RESPONSE omission. Safe digging practices, in accordance with HS(G)47, must be used to verify and establish the actual position of mains, pipes, services and other apparatus on site before any mechanical plant is used. It is your responsibility to ensure MAP REF: SJ8398 0m 50m East Area Approximate scale 1 : 2500 printed that this information is provided to all persons (either direct labour or contractors) working for you on or near gas CENTRE: 383550, 398817 on A3 Colour Landscape apparatus. The information included on this plan should not be referred to beyond a period of 28 days from the date This plan is reproduced from or based on the of issue. OS map by National Grid Gas plc, with the sanction of the controller of HM Stationery Office. Crown Copyright Reserved. SCALE: 1 : 2500 LP MAINS This plan shows those pipes owned by National Grid Gas plc in their role as a Desktop MAPS Version 5.1.2.0 MP MAINS Licensed Gas Transporters (GT). Gas pipes owned by other GTs, or otherwise privately owned, may be present in this area. USER ID: Nicola.clamp Information with regard to such pipes should be obtained from the relevant owners. The information shown on this plan IP MAINS is given without warranty, the accuracy thereof cannot be guaranteed. Service pipes, valves, syphons, stub connections, DATE: 17/02/2012 LHP MAINS etc. are not shown but their presence should be anticipated. No liability of any kind whatsoever is accepted by NHP MAINS National Grid Gas plc or their agents, servants or contractors for any error or NRSWA RESPONSE omission. Safe digging practices, in accordance with HS(G)47, must be used to verify and establish the actual position of mains, pipes, services and other apparatus on site before any mechanical plant is used. It is your responsibility to ensure MAP REF: SJ8398 0m 50m East Area Approximate scale 1 : 2500 printed that this information is provided to all persons (either direct labour or contractors) working for you on or near gas CENTRE: 383550, 398817 on A3 Colour Landscape apparatus. The information included on this plan should not be referred to beyond a period of 28 days from the date This plan is reproduced from or based on the of issue. OS map by National Grid Gas plc, with the sanction of the controller of HM Stationery Office. Crown Copyright Reserved. WARNING! This area contains Gas Mains Operating at Intermediate Pressure between 2 and 7 bar. Before excavating in the area contact the Local Network Office.
SCALE: 1 : 2500 LP MAINS This plan shows those pipes owned by National Grid Gas plc in their role as a Desktop MAPS Version 5.1.2.0 MP MAINS Licensed Gas Transporters (GT). Gas pipes owned by other GTs, or otherwise privately owned, may be present in this area. USER ID: Nicola.clamp Information with regard to such pipes should be obtained from the relevant owners. The information shown on this plan IP MAINS is given without warranty, the accuracy thereof cannot be guaranteed. Service pipes, valves, syphons, stub connections, DATE: 17/02/2012 LHP MAINS etc. are not shown but their presence should be anticipated. No liability of any kind whatsoever is accepted by NHP MAINS National Grid Gas plc or their agents, servants or contractors for any error or NRSWA RESPONSE omission. Safe digging practices, in accordance with HS(G)47, must be used to verify and establish the actual position of mains, pipes, services and other apparatus on site before any mechanical plant is used. It is your responsibility to ensure MAP REF: SJ8397 0m 50m East Area Approximate scale 1 : 2500 printed that this information is provided to all persons (either direct labour or contractors) working for you on or near gas CENTRE: 383028, 397961 on A3 Colour Landscape apparatus. The information included on this plan should not be referred to beyond a period of 28 days from the date This plan is reproduced from or based on the of issue. OS map by National Grid Gas plc, with the sanction of the controller of HM Stationery Office. Crown Copyright Reserved.
Date: 12 March 2012 Our ref: 5408/45894 Your ref: 120214_TR040008_1051212
Ms Hannah Pratt Infrastructure Planning Commission Natural England Temple Quay House Consultation Service Temple Quay Hornbeam House BRISTOL Electra Way Crewe Business Park BS1 6PN CREWE CW1 6GJ
T: 0300 060 3900
BY EMAIL ONLY
Dear Ms Pratt
PROPOSED ORDSALL CHORD (the project) PROPOSAL BY NETWORK RAIL (the developer) INFRASTRUCTURE PLANNING (ENVIRONMENTAL IMPACT ASSESSMENT) REGULATIONS 2009 SI 2263 (the EIA Regulations)
Thank you for your consultation on the above dated 14 February 2012.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We have considered the scoping report against the full range of Natural England’s interests in the natural environment. Based on the information provided with, we ask that the following comments are taken into consideration.
Case law1 and guidance2 have stressed the need for a full set of environmental information to be available for consideration prior to a decision being taken on whether or not to grant planning permission.
Overall, we are satisfied that the topics listed in Section 3 of the scoping report are those that need to be addressed and reported upon, regarding potential impacts on the natural environment.
We consider the scoping report to be comprehensive and we are satisfied with the proposed methodologies for assessing the impacts on ecology and nature conservation (Section 7) and Townscape & Visual Amenity (Section 8).
We have checked our records and based on the information provided, we can confirm that there are no statutory designated sites within 2km of the application site; that is Sites of Special Scientific Interest (SSSIs) and sites of European or international importance (Special Areas of Conservation, Special Protection Areas and Ramsar sites).
1 Harrison, J in R. v. Cornwall County Council ex parte Hardy (2001) 2 Note on Environmental Impact Assessment Directive for Local Planning Authorities, Office of the Deputy Prime Minister (April 2004) 1 Protected species If any protected species are found the Environmental Statement should include details of: The species concerned; The population level at the site affected by the proposal; The direct and indirect effects of the development upon that species; Full details of any mitigation that might be required; Whether the impact is acceptable and/or licensable.
For European protected species it is illegal to intentionally kill, injure or otherwise disturb them. If any of these species are found to be present the developer should further consult Natural England about licensing implications before the application is submitted to IPC. This should be done in line with IPC Guidance Note 11 on working with other public bodies and WML-G36 (01/12) NSIP and EPS mitigation licensing.
Other features of nature conservation interest, e.g. habitats and species identified within the UK and Local Biodiversity Action Plans. Natural England advises that the habitat survey carried out on the site should identify any important habitats present. In addition species surveys should be carried out at appropriate times in the year, to establish whether any scarce or priority species are present. The Environmental Statement should include details of: Any historical data for the site affected by the proposal (e.g. from previous surveys); Additional surveys carried out as part of this proposal; The habitats and species present; The status of these habitats and species (e.g. whether BAP priority habitat); The direct and indirect effects of the development upon those habitats and species; Full details of any mitigation that might be required.
The development should avoid adverse impacts on the most important wildlife areas within the vicinity of the development, and should where possible provide opportunities for overall wildlife gain.
We note the location of the scheme falls within or adjacent to strategic green infrastructure opportunity areas identified within the strategic Green Infrastructure (GI) strategy for Greater Manchester. We would therefore encourage Network Rail to consider opportunities for contributing to the provision of wider strategic green infrastructure, in particular linked to the Irwell City Park, which is a key GI investment zone and part of the Core GI Network for the Greater Manchester area. This should be considered in addition to the acknowledged value of the River Irwell in Salford as a wildlife corridor (Section 7, paragraph 7.2.5 refers). This may also be linked to elements of landscape design mitigation in terms of public realm treatments and impacts on pedestrian and cycle links in the area.
I trust these comments are helpful. For any correspondence or queries relating to this consultation only, please contact David Carter at by telephone or email, as shown below. For all other correspondence, please contact the Consultation Service at Crewe (see above).
Yours sincerely
David Carter Lead Adviser Land Use Operations Team Direct dial: 01653 696082 Email: [email protected]
2
From: [email protected] To: IPC Scoping Opinion; Subject: Ref:120214_TR040008_1051212 - Ordsall Chord Date: 16 February 2012 15:10:59
FTAO Hannah Pratt
I am writing to confirm that SSE Pipelines Ltd do not have any comments to make regarding the above proposal.
Regards
Janice Grant Technical Support Officer
For and on behalf of Kevin Bennett SSE Pipelines General Manager
SSE | Robert Brown House, 5 Pipers Way, Thatcham, Berkshire. RG19 4AZ. UK
T: +44 (0)1635 272520 M: +44 (0)1635 272586 www.sse.com
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SSE plc Registered Office: Inveralmond House 200 Dunkeld Road Perth PH1 3AQ Registered in Scotland No. SC117119 www.sse.com
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Hannah Pratt EIA And Land Rights Our reference: Advisor Your reference: Temple Quay House Please ask for: Mrs E Breheny Direct line: 01942 489130 Temple Quay Date: 6th March 2012 Bristol BS1 6PN
Dear Ms Pratt
Town and Country Planning Act 1990 Town and Country Planning (Development Management Procedure) (England) Order 2010 Application Number: NLA/12/00068 Location: Proposed Ordsall Chord Proposal: Proposed Ordsall Chord - Proposal by Network Rail
I refer to your consultation fated 14th February 2012. I can confirm that Wigan Council has no representations to make on the proposal.
If you wish to discuss the matter please contact me on 01942 489130
Yours sincerely
E Breheny
Mrs E Breheny Planning Assistant
Please reply to: Mrs E Breheny Places Directorate: Economy Waste and Infrastructure, Development Implementation Wigan Council, PO Box 100, Wigan WN1 3DS Phone: 01942 489000 Fax: 01942 404222 E-mail: [email protected] www.wigan.gov.uk
APPENDIX 3
PRESENTATION OF THE ENVIRONMENTAL STATEMENT
120323_TR040008_1051473
APPENDIX 3 PRESENTATION OF THE ENVIRONMENTAL STATEMENT
The Infrastructure Planning (Applications: Prescribed Forms and Procedure) Regulations 2009 (SI 2264) (APFP) sets out the information which must be provided for an application for a development consent order (DCO) for nationally significant infrastructure under the Planning Act 2008 (PA 2008). Where required, this includes an environmental statement (ES) (APFP 5(2)(a)). Applicants may also provide any other environmental information considered necessary to support the application within the ES as set out in Regulations 5(2)(e), (l) and (m). Information which is not environmental information need not be replicated or included in the ES.
An ES is described under the Infrastructure Planning (Environmental Impact Assessment) Regulations 2009 (SI 2263) (the EIA Regulations) as a statement: a) ‘that includes such of the information referred to in Part 1 of Schedule 4 as is reasonably required to assess the environmental effects of the development and of any associated development and which the applicant can, having regard in particular to current knowledge and methods of assessment, reasonably be required to compile; but b) that includes at least the information required in Part 2 of Schedule 4’. (EIA Regulations Regulation 2)
The purpose of an ES is to ensure that the environmental effects of a proposed development are fully considered, together with the economic or social benefits of the development, before (under the PA 2008 regime) the development consent application is determined. It should be an aid to decision making.
The IPC advises that the ES should be laid out clearly with a minimum amount of technical terms and should provide a clear objective and realistic description of the likely significant impacts of the proposed development. The information should be presented so as to be comprehensible to the specialist and non-specialist alike. The IPC recommends that the ES be concise with technical information placed in appendices.
ES indicative contents The IPC emphasises that the ES should be a ‘stand alone’ document in line with best practice and case law. The EIA Regulations Schedule 4, Parts 1 and 2, set out the information for inclusion in ESs.
Schedule 4 Part 1 of the EIA Regulations states this information includes:
‘17. Description of the development, including in particular—
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(a) a description of the physical characteristics of the whole development and the land-use requirements during the construction and operational phases; (b) a description of the main characteristics of the production processes, for instance, nature and quantity of the materials used; (c) an estimate, by type and quantity, of expected residues and emissions (water, air and soil pollution, noise, vibration, light, heat, radiation, etc) resulting from the operation of the proposed development.
18. An outline of the main alternatives studied by the applicant and an indication of the main reasons for the applicant’s choice, taking into account the environmental effects.
19. A description of the aspects of the environment likely to be significantly affected by the development, including, in particular, population, fauna, flora, soil, water, air, climatic factors, material assets, including the architectural and archaeological heritage, landscape and the interrelationship between the above factors.
20. A description of the likely significant effects of the development on the environment, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long- term, permanent and temporary, positive and negative effects of the development, resulting from: (a) the existence of the development; (b) the use of natural resources; (c) the emission of pollutants, the creation of nuisances and the elimination of waste, and the description by the applicant of the forecasting methods used to assess the effects on the environment.
21. A description of the measures envisaged to prevent, reduce and where possible offset any significant adverse effects on the environment.
22. A non-technical summary of the information provided under paragraphs 1 to 5 of this Part.
23. An indication of any difficulties (technical deficiencies or lack of know-how) encountered by the applicant in compiling the required information’.
EIA Regulations Schedule 4 Part 1
The content of the ES must include as a minimum those matters set out in Schedule 4 Part 2 of the EIA Regulations. This includes the consideration of ‘the main alternatives studied by the applicant’ which the IPC recommends
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could be addressed as a separate chapter in the ES. Part 2 is included below for reference:
Schedule 4 Part 2
‘24. a description of the development comprising information on the site, design and size of the development;
25. a description of the measures envisaged in order to avoid, reduce and, if possible, remedy significant adverse effects;
26. the data required to identify and assess the main effects which the development is likely to have on the environment;
27. an outline of the main alternatives studies by the applicant and an indication of the main reasons for the applicant’s choice, taking into account the environmental effects;
28. a non-technical summary of the information provided [under the four paragraphs above]’.
‘Traffic and transport’ is not specified as a topic for assessment under Schedule 4; although in line with good practice the IPC considers it is an important consideration per se, as well as being the source of further impacts in terms of air quality and noise and vibration.
Balance The IPC recommends that the ES should be balanced, with matters which give rise to a greater number or more significant impacts being given greater prominence. Where few or no impacts are identified, the specialist section may be much shorter, with greater use of information in appendices as appropriate.
The IPC considers that the ES should not be a series of disparate specialist sections and stresses the importance of considering inter-relationships between factors and cumulative impacts.
Scheme proposals The scheme parameters will need to be clearly defined in the draft DCO and therefore in the accompanying ES which should support the application as described. The IPC is not able to entertain material changes to a project once an application is submitted. Applicant’s attention is drawn of the applicant to the DCLG and the IPC’s published guidance and advice on the preparation of a draft DCO and accompanying application documents.
Flexibility The IPC acknowledges that the EIA process is iterative, and therefore the proposals may change and evolve. For example, there may be changes to the scheme design in response to consultation or through identification of new constraints that restrict the scheme parameters. Such changes should be
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addressed in the ES. However, at the time of the application for a DCO, any proposed scheme parameters should not be so wide ranging as to represent effectively different schemes.
It is a matter for the applicant, in preparing an ES, to consider whether it is possible to assess robustly a range of impacts resulting from a large number of undecided parameters. The description of the proposal in the ES must not be so wide that it is insufficiently certain to comply with requirements of paragraph 17 of Schedule 4 Part 1 of the EIA Regulations.
The Rochdale Envelope principle (see R v Rochdale MBC ex parte Tew (1999) and R v Rochdale MBC ex parte Milne (2000)) is an accepted way of dealing with uncertainty in preparing development applications. Further information is provided in the IPC’s Advice Note 9 ‘Using the ‘Rochdale Envelope’ which is available on the IPC’s website.
Applicants should make every attempt to narrow the range of options and explain clearly in the ES which elements of the scheme have yet to be finalised and provide the reasons. Where some flexibility is sought and the precise details are not known, the maximum potential adverse impacts that the project could have should be assessed to ensure that the project as it may be constructed has been properly assessed.
Where flexibility is required careful consideration should be given to the way in which relevant mitigations and any associated requirements are reflected in the DCO application.
The ES should be able to confirm that any changes to the development within any proposed parameters would not result in significant impacts not previously identified and assessed. The maximum and other dimensions of the proposal should be clearly described in the ES, with appropriate justification. It will also be important to consider choice of materials, colour and the form of the structures and of any buildings. Lighting proposals should also be described.
Scope Physical scope
In general the IPC recommends that the physical scope for the EIA should be determined in the light of:
• the nature of the proposal being considered • the relevance in terms of the specialist topic • the breadth of the topic • the physical extent of any surveys or the study area, and • the potential significant impacts.
The IPC recommends that the physical scope of the study areas should be identified for each of the environmental topics and should be sufficiently robust in order to undertake the assessment. This should include at least the
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whole of the application site, and include all offsite works. For certain topics, such as landscape and transport, the study area will need to be wider. The extent of the study areas should be determined by establishing the physical extent of the likely impacts and on the basis of recognised professional guidance and best practice, whenever this is available.
The IPC considers that the study areas should also be agreed with the relevant consultees and local authorities and, where this is not possible, this should be stated clearly in the ES and a reasoned justification given.
Breadth of the topic area
The ES should explain the range of matters to be considered under each topic and may respond partly to the type of project being considered. If the range considered is drawn narrowly then a justification for the approach should be provided.
Temporal scope
The assessment should consider:
• environmental impacts during construction works • environmental impacts on completion/operation of the development • where appropriate, environmental impacts a suitable number of years after completion of the development (for example, in order to allow for traffic growth or maturing of any landscape proposals), and • during decommissioning. In terms of decommissioning, the IPC acknowledges that the further into the future any assessment is made, the less reliance may be placed on the outcome. However, the purpose of such a long term assessment, as well as to enable the decommissioning of the works to be taken into account, is to encourage early consideration as to how structures can be taken down. The purpose of this is to seek to minimise disruption, to re-use materials and to restore the site or put it to a suitable new use. The IPC encourages consideration of such matters in the ES.
The IPC recommends that these matters should be set out clearly in the ES and that the suitable time period for the assessment should be agreed with the relevant statutory consultees.
The IPC recommends that throughout the ES a standard terminology for time periods should be defined, such that for example, ‘short term’ always refers to the same period of time.
Baseline The IPC recommends that the baseline should describe the position from which the impacts of the proposal are measured. The baseline should be chosen carefully and, whenever possible, be consistent between topics. The identification of a single baseline is to be welcomed in terms of the approach
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to the assessment, although it is recognised that this may not always be possible.
The IPC recommends that the baseline environment should be clearly explained in the ES, including any dates of surveys. Care should be taken to ensure that all the baseline data remains relevant and up to date. The baseline and the proposed development should be described within the context of the site and any other proposals in the vicinity.
For each of the environmental topics, the data source(s) for the baseline should be set out together with any survey work undertaken with the dates. The timing and scope of all surveys should be agreed with the relevant statutory bodies and appropriate consultees, wherever possible.
Identification of impacts and method statement Legislation and guidelines
In terms of the EIA methodology, the IPC recommends that reference should be made to best practice and any standards, guidelines and legislation that have been used to inform the assessment. This should include guidelines prepared by relevant professional bodies.
In terms of other regulatory regimes, the IPC recommends that relevant legislation and all permit and licences required should be listed in the ES where relevant to each topic. This information should also be submitted with the application in accordance with the APFP Regulations.
In terms of assessing the impacts, the ES should approach all relevant planning and environmental policy – local, regional and national (and where appropriate international) – in a consistent manner.
Assessment of effects and impact significance
The EIA Regulations require the identification of the ‘likely significant effects of the development on the environment’ (Schedule 4 Part 1 paragraph 20).
As a matter of principle, the IPC applies the precautionary approach to follow the Court’s1 reasoning in judging ‘significant effects’. In other words ‘likely to affect’ will be taken as meaning that there is a probability or risk that the development will have an effect, and not that a development will definitely have an effect. The IPC considers it is imperative for the ES to define the meaning of ‘significant’ in the context of each of the specialist topics and for significant impacts to be clearly identified. The IPC recommends that the criteria should be set out fully and that the ES should set out clearly the interpretation of
1 See Landelijke Vereniging tot Behoud van de Waddenzee and Nederlandse Vereniging tot Bescherming van Vogels v Staatssecretris van Landbouw (Waddenzee Case No C 127/02/2004)
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‘significant’ in terms of each of the EIA topics. Quantitative criteria should be used where available. The IPC considers that this should also apply to the consideration of cumulative impacts and impact inter-relationships.
The IPC recognises that the way in which each element of the environment may be affected by the proposed development can be approached in a number of ways. However it considers that it would be helpful, in terms of ease of understanding and in terms of clarity of presentation, to consider the impact assessment in a similar manner for each of the specialist topic areas. The IPC recommends that a common format should be applied where possible.
Inter-relationships between environmental factors
The inter-relationship between aspects of the environment likely to be significantly affected is a requirement of the EIA Regulations (see Schedule 4, Part 1 of the EIA Regulations). These occur where an activity from the proposed development has a likely significant effect on more than one aspect of the environment, an example being foundation piling which could have a likely significant effect on the marine environment by virtue of changing the noise and water quality environment.
The IPC considers that the inter-relationships between factors must be assessed in order to address the environmental impacts of the proposal as a whole. This will help to ensure that the ES is not a series of separate reports collated into one document, but rather a comprehensive assessment drawing together the environmental impacts of the proposal. This is particularly important when considering its impacts in terms of any permutations or parameters. It also allows for the development of mitigation measures to serve more than one specialist topic.
Cumulative impacts
The potential cumulative impacts with other major developments will need to be identified, as required by the Directive. The significance of such impacts should be shown to have been assessed against the baseline position (which would include built and operational development). In assessing cumulative impacts, other major development should be identified through consultation with the local planning authorities and other relevant authorities on the basis of those that are:
• under construction • permitted application(s), but not yet implemented • submitted application(s) not yet determined • projects on the IPC’s programme of projects • identified in the relevant development plan (and emerging development plans - with appropriate weight being given as they move closer to adoption) recognising that much information on any relevant proposals will be limited, and
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• identified in other plans and programmes (as appropriate) which set the framework for future development consents/approvals, where such development is reasonably likely to come forward. Details should be provided in the ES, including the types of development, location and key aspects that may affect the EIA and how these have been taken into account as part of the assessment.
Where appropriate, the ES should take account of any offshore licensed and consented activities in the area, for the purposes of assessing cumulative effects, through consultation with the relevant licensing/consenting bodies.
For the purposes of identifying any cumulative effects with other developments in the area, applicants should, as necessary, also consult bodies in other EU States to assist in identifying those developments (see commentary on Transboundary Effects below).
Related development
The ES should give equal prominence to any development which is related with the proposed development to ensure that all the impacts of the proposal are assessed.
The IPC recommends that the applicant should distinguish between development for which development consent will be sought and any other development. This distinction should be made clear in the ES.
Alternatives
The ES must set out an outline of the main alternatives studied by the applicant (if any) and provide an indication of the main reasons for the choice, taking account of the environmental effect (Schedule 4 Part 1 paragraph 18).
Matters should be included, such as inter alia alternative design options and alternative mitigation measures. The justification for the final choice and evolution of the scheme development should be made clear. Where other sites have been considered, the reasons for the final choice should be addressed.
The IPC advises that the ES should give sufficient attention to the alternative forms and locations for the off-site proposals, where appropriate, and justify the needs and choices made in terms of the form of the development proposed and the sites chosen.
Mitigation measures
Mitigation measures may fall into certain categories namely: avoid; reduce; compensate or enhance (see Schedule 4 Part 1 paragraph 21); and should be identified as such in the specialist topics. Mitigation measures should not be developed in isolation as they may relate to more than one topic area. For each topic, the ES should set out any mitigation measures required to prevent, reduce and where possible offset any significant adverse effects, and
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to identify any residual effects with mitigation in place. Any proposed mitigation should be discussed and agreed with the relevant consultees.
The effectiveness of mitigation should be apparent. Only mitigation measures which are a firm commitment and can be shown to be deliverable should be taken into account as part of the assessment.
It would be helpful if the mitigation measures proposed could be cross referred to specific provisions and/or requirements proposed within the draft DCO. This could best be achieved by means of describing the mitigation measures proposed either under each of the specialist sections or collating these within a summary section on mitigation in the ES.
The IPC advises that it is considered best practice to outline in the ES, the structure of the environmental management and monitoring plan and safety procedures which will be adopted during construction and operation and may be adopted during decommissioning.
Cross references and interactions
The IPC recommends that all the specialist topics in the ES should cross reference their text to other relevant disciplines. Interactions between the specialist topics is essential to the production of a robust assessment, as the ES should not be a collection of separate specialist topics, but a comprehensive assessment of the environmental impacts of the proposal and how these impacts can be mitigated.
As set out in EIA Regulations Schedule 4 Part 1 paragraph 23, the ES should include an indication of any technical difficulties (technical deficiencies or lack of know-how) encountered by the applicant in compiling the required information.
Consultation
The IPC recommends that any changes to the scheme design in response to consultation should be addressed in the ES.
Transboundary effects The IPC recommends that consideration should be given in the ES to any likely significant effects on the environment of another Member State of the European Economic Area. In particular, the IPC recommends consideration should be given to discharges to the air and water and to potential impacts on migratory species and to impacts on shipping and fishing areas.
Further information on transboundary issues is provide in the IPC’s Advice Note 12 ‘Development with significant transboundary impacts consultation’ which is available on the IPC’s website.
Summary tables The IPC recommends that in order to assist the decision making process, the applicant may wish to consider the use of tables in the ES:
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Table [x] Residual impacts to identify and collate the residual impacts after mitigation on the basis of specialist topics, inter-relationships and cumulative impacts.
Table [xx] Taking account of the IPC scoping opinion to demonstrate how the assessment has taken account of the adopted Scoping Opinion and other responses to consultation.
Table [xxx] Reflecting mitigations within the DCO application to set out the mitigation measures proposed, as well as assisting the reader, the IPC considers that this would also enable applicants to cross refer mitigation to specific provisions proposed in the ES to be included within the draft DCO.
Table [xxxx] Cross reference to the HRA and any other relevant environmental information submitted separately to the ES to cross reference where details in the HRA (where one is provided) such as descriptions of sites and their locations, together with any mitigation or compensation measures, are to be found in the ES.
Terminology and glossary of technical terms The IPC recommends that a common terminology should be adopted. This will help to ensure consistency and ease of understanding for the decision making process. For example, ‘the site’ should be defined and used only in terms of this definition so as to avoid confusion with, for example, the wider site area or the surrounding site.
A glossary of technical terms should be included in the ES.
Presentation The ES should have all of its paragraphs numbered, as this makes referencing easier as well as accurate. This takes account of IPC Guidance Note 2 on the preparation of application documents states that 'in all cases the application documents must be paginated and paragraphs must be numbered'. Appendices must be clearly referenced, again with all paragraphs numbered.
All figures and drawings, photographs and photomontages should be clearly referenced. Figures should clearly show the application site application boundary.
Bibliography A bibliography should be included in the ES. The author, date and publication title should be included for all references. All publications referred to within the specialist sections should be included.
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Non-technical summary The EIA Regulations require a Non Technical Summary (EIA Regulations Schedule 4 Part 1 paragraph 22). This should be a summary of the assessment in simple language. It should be supported by appropriate figures, photographs and photomontages.
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