Thurrock Flexible Generation Plant Deadline 2 – Applicant’s Response to the ExA’s First Written Questions rpsgroup.com APPLICANT’S RESPONSE TO THE EXA’S FIRST WRITTEN QUESTIONS Contents 1. AIR QUALITY .............................................................................................................................. 3 2. CLIMATE CHANGE ................................................................................................................... 10 3. COMPULSORY ACQUISITION ................................................................................................. 15 4. CULTURAL HERITAGE ............................................................................................................ 24 5. CUMULATIVE IMPACTS........................................................................................................... 29 6. DESIGN AND LAYOUT ............................................................................................................. 33 7. DRAFT DEVELOPMENT CONSENT ORDER .......................................................................... 34 8. ENVIRONMENTAL IMPACT ASSESSMENT AND ENVIRONMENTAL STATEMENT .......... 43 9. GREEN BELT AND LOCAL PLANNING POLICY ................................................................... 47 10. GENERAL QUESTIONS............................................................................................................ 50 11. HABITATS AND ONSHORE ECOLOGY .................................................................................. 55 12. LANDSCAPE AND VISUAL ...................................................................................................... 62 13. LAND USE, AGRICULTURE AND SOCIOECONOMICS ......................................................... 64 14. MARINE ENVIRONMENT ......................................................................................................... 65 15. NOISE AND VIBRATION .......................................................................................................... 67 16. ONSHORE WATER ENVIRONMENT ....................................................................................... 69 17. TRANSPORT AND TRAFFIC .................................................................................................... 80 18. WASTE AND MINERALS .......................................................................................................... 82 19. SHIPPING AND NAVIGATION .................................................................................................. 83 New Documents Enclosed Reference Question(s) Title AQ-1 1.1.1 Air Quality Baseline AQ-2 1.1.10 Ecological Receptors AQ-3 1.10.15 Nitrogen Dioxide Contours CC-1 1.2.1 Hydrogen Combustion in Reciprocating Engines CA-1 1.3.9 Compulsory Acquisition Schedule CA-2 1.3.11 West Tilbury Common Byelaws HER-1 1.4.9 Minutes of Meeting with HE and ECC 10 February 2021 HER-2 1.4.1, 1.4.9 and 1.4.10 Historic Environment Information EIA-1 1.8.2 Comparison of Tilbury and Warley Sites GEN-1 1.10.12 NGET Letter 23 February 2021 ECO-1 1.11.16 Biodiversity Net Gain Spreadsheet N&V-1 1.14.2 Baseline Ambient Noise Levels FR-1 1.16.7 Surface Water Map FR-2 1.16.14 Environment Agency Letter 15 February 2021 TR-1 1.17.4 Lower Thames Crossing Comparison rpsgroup.com Page 1 APPLICANT’S RESPONSE TO THE EXA’S FIRST WRITTEN QUESTIONS Existing Documents Updated Question(s) Title 1.1.18, 1.8.3 and 1.16.16 Code of Construction Practice 1.1.18, 1.5.6, 1.8.5, 1.10.11, 1.15.6, Appendix 2.1: Mitigation, Enhancement and Monitoring Commitments 1.16.15, 1.16.16 and 1.16.17 Outline Written Scheme of Investigation (note – now split into two parts for 1.4.4 and 1.4.5 onshore and marine environment archaeological investigation) 1.5.5 Chapter 32: Summary of Cumulative Effects 1.5.10 Chapter 29: Geology, Hydrogeology and Ground Conditions 1.10.1 Other Consents and Licenses Statement 1.10.14 DCO Plans Restrictions on Public Access to the Causeway (note – this has now been 1.11.7 appended to the Design Principles Statement, so is no longer a standalone document) 1.11.15 Habitats Regulations Assessment Report 1.16.10 Chapter 31: Summary of Inter-Related Effects 1.17.6 Construction Traffic Management Plan Various Draft Development Consent Order rpsgroup.com Page 2 APPLICANT’S RESPONSE TO THE EXA’S FIRST WRITTEN QUESTIONS 1. AIR QUALITY ExQ. Question Response 1.1.1 The baseline concentrations for the applicable receptors (receptors 14 to 40, named R1 to R27) were taken from Table 18.44 of the Tilbury2 Volume 6 Part B ES Appendices 18.A – 18.E. This was for the 2020 Do Please explain how the baseline NO2 concentrations from the Tilbury 2 Air Quality Something scenario and therefore includes the predicted Tilbury2 Process Contribution (PC). Assessment were determined and for which year Supporting document AQ-1 provides a comparison of recent monitoring data and the concentrations taken they are for? Please also explain what from the Tilbury2 Air Quality Assessment. comparison has been undertaken between recent Applicant monitoring data and the concentrations taken In the AQ-1 document, a further sensitivity analysis has been undertaken to confirm that a conservative from the Tilbury 2 Air Quality Assessment. Do approach has been taken. Both the assessment in the ES and the sensitivity test incorporate several they confirm that a conservative approach is conservative assumptions, whether that is in the baseline concentration used or the significance criteria used. being undertaken? Both assessments have concluded that the resulting air quality effect of the proposed Thurrock Flexible Generation Plant is ‘not significant’ overall and both approaches are conservative. 1.1.2 Paragraph 4.1.16 of ES Chapter 12 states that receptors have been included at distances within Figure 4.1 shows the study area used for the assessment of potential effects from dust during construction. 20m, 50m, 100m, 200m and 350m of the site Paragraph 4.1.16 should have also mentioned that earthworks and construction activities are not expected at boundary (excluding Zone E). However, Figure Zone H (existing private road for access). Similarly for Zone F (area for habitat creation) the works would be 4.1 shows that other Zones have been excluded. limited to topsoil strip and some pond/hummock digging within agricultural land. These areas were therefore Applicant Please confirm the study area used and provide excluded from the assessment of dust during the construction phase. The buffers shown in Figure 4.1 are justification for any other development zones correct. excluded. 1.1.3 The receptors that were modelled are representative of either residential properties or schools. At residential properties and schools, both the annual mean NO2 objective and the short-term (1 hour) NO2 objective apply. Receptors at which only the short-term objective applies are locations where the public might reasonably be expected to spend 1-hour or longer; few such receptors were present at locations where concentrations could As described in Table 2.3 of ES Chapter 12 the reasonably be expected to be higher than for residences and schools. hourly-mean NO2 objective applies at any outdoor locations to which the public might reasonably be The only areas nearby where the short-term objective only could apply, that are nearer to the stacks than the expected to spend 1- hour or longer. However, receptors which have been modelled, are Parsonage Common to the north, Tilbury Fort and the footpath to the descriptions in Table 2.4 of ES Chapter 12 of the south (see figure below showing footpath). Figure AQ-2 (see response to Q1.1.15) shows the hourly mean the ES do not adequately describe the receptors NO2 process contributions (PCs) from the proposed development. Figure AQ-2 shows that the PCs at Applicant -3 or enable the identification of any short-term Parsonage Common, Tilbury Fort and the footpath are below 120 μg.m . If the PC is conservatively assumed receptors that have been modelled. Please to be 120 μg.m-3 at the nearest areas where the public might reasonably be expected to spend 1 hour or confirm how receptors relevant to short term longer, as long as the ambient concentration (AC) is less than 80 μg.m-3 the Air Quality Assessment Level exposures have been considered. (AQAL) of 200 μg.m-3 will be met. This can be checked from of the results of the RPS Project Specific Monitoring survey in Appendix 12.2 (APP-102): the nearest locations where NO2 was monitored were Location 1, 2 and 4. Table 1.3 of Appendix 12.2: Baseline Air Quality Conditions (APP-102) shows that NO2 concentrations of 21.2, 19.5 and 18.3 μg.m-3 were measured. A factor of 2 is used to estimate the short-term (e.g. hourly) baseline concentration from the longer-term period mean baseline concentration: when the maximum PC of 120 μg.m-3 is added to 2 x the annual-mean baseline of 21.2 μg.m-3, the resulting predicted rpsgroup.com Page 3 APPLICANT’S RESPONSE TO THE EXA’S FIRST WRITTEN QUESTIONS ExQ. Question Response -3 environmental concentration (PEC) is 162.4 μg.m . This is below (81%) of the hourly-mean NO2 AQAL of 200 μg.m-3 and the impacts are considered to be not significant. 1.1.4 Unless there are very few receptor locations in an assessment study area, it is not usual or realistic to assess every discrete receptor location that could potentially be affected; it is therefore usual to choose a limited number of receptor locations that are broadly representative of the general characteristics of particular areas, in locations where people